2026 (7) TMI 68

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.... nature of Writ of certiorari quashing the exparte impugned Orders both dated 21.05.2025 in Nos. ACCT(Audit)-2/HPT/GST-ADJN/Order-/2025-26/T and ACCT(Audit)-2/HPT/GST-ADJN/Order-/2025-26/T for the tax periods 2021-22 & 2022-23 passed by the 1st Respondent (Annexure-C & D) in the Petitioner's case. This Hon'ble' High Court may be pleased to issue a Writ of Certiorari or a direction in the nature of Writ of certiorari quashing the Show Cause Notices in Form GST DRC-01 both dated 08.04.2024 in Nos. CTO/ENF/HPT/U/S73/15/2024-25/7775 & CTO/ENF/HPT/U/S73/16/2024-25/7776 issued by the 2nd Respondent for the tax periods 2021-22 & 2022-23 (Annexure-A & A1) in the Petitioner's Case. This Hon'ble' High may be ....

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....ct to the tax that was leviable. In the said context, it is submitted that having regard to the notification dated 28.06.2017 (Annexure-S to the writ petition), which has been modified vide notification dated 31.12.2017 (Annexure-T to the writ petition), the tax leviable under the provisions of the Act were to be paid on reverse charge basis by the recipient of the service. That the business of the petitioner is covered under the notification dated 31.12.2018. The respondent No.1-Assistant Commissioner while noticing that the petitioner had provided security services, levied tax on the petitioner, who had provided the services and was not the recipient of the services. 5. Learned AGA submits that the orders dated 21.05.2025 passed under ....