V/. YiY9 lndia Private Limited v. ""' "'

't rhe Joint commissioner, S.ecundrabad GST commissionerate GST Bhavan. ^ L.BStadium Road Basheerbagh, utdeiabi,i-5oijdij;. - 2 The commissioner of centrariax,'centriiEri"Jl""o service Tax GST ,iisn3i"'#i'sfl H[,T,:1"',:;f *+*g*;j:la1-ilS,#J"; _ Department. secrelariat Buiidin6s. Hv;;;a',6;d- 4' central Board of rndirect raxes"ano 6riiori, o"partment of Revenue. _ Represented by Its Secretary to Governmenf'fie"ibelnl _1 10001 5. The Union.of tridia, nep. by il-$c;;i;;'Mi"i.ti! oirinrnce. Department of ...RESPONDENTS Petition unddr Articre 226 of rhe constitution of rndia praying that in the circumstances stated in the affidavit fired therewith, the High court may be pleased to issue any writ or order or Direction more particurarry one in the nature of writ of Mandamus dectaring the action of 1st Respondent in issuing the lmpugned ORDER rN .RTGTNAL No.233'2,24-25-SEC-ADJN-JC-(GST) dated 19-02-2025 for the years 2o2o-21, 2021-22 and 2022-23 issued by the .rst Respondent confirming the (i) Demand of Rs.3,09,36,523/-(rcsr) uNDER section 73(9) of CGST Act2017 read with section 20 of the |GST Act 2o1r (ii) rnterest under section 50(1) of GGST Act 2017 tead with section 20 of the |GST Act (iii) Penalty of Rs.30,93,657/-(tGST) on the tax demand u/s 73 (9) uls 122(2)(a) ot CGST Act r/w section 20 of |GST Act as the same is contrary to the principres of naturaljustice,issuanceofconsolidated/compositeSCNandOlOfor(3)yearsin contravention of the Provisions of CGST Act, which is Contrary to the Apex Court JudgmentfollowedbyvariousHighCourts,beyondtheJurisdiction,patentlyillegal andlacksStatutorybacking,withoutauthorityunderlaw,unreasonedorder, issued with pre-determined mind, arbitrary, with unsigned DRC-07' DRC-01' DRC- lAandviolativeofArticlelg(1Xg),265,300AoftheConstitutionoflndia'andto set aside the lmPugned order. IA NO: 1 OF 2025 PetitionunderSectionl5lCPCprayingthatinthecircumstancesstatedin the affidavit filed in support of the petition, the High Court may be pleased to grant stay of all further proceedings in pursuance the ORDER lN ORIGINAL No.233120241-25.5EC-ADJN-JC-(GST)dated19-02-2025fortheYears2020.21' 2021-22&2022-23issuedbythelstRespondentconfirmingthe(i)Demandof Rs.3,09,36.573/-(IGST) UNDER Section 73(9) of CGST Act 20'17 read with Section 20 of the IGST Act 2017 (ii) lnterest under Section 50(1) of CGST Act 2017 read with section 20 of the IGST Act (iii) Penalty of Rs.30,93,657/- (IGST) on the tax demand u/s 73 (9) uts 122(2)(a) of CGST Act r/w section 20 of IGST Act pending disposal of this writ Petition' Counsel for the Petitioner: SRl. T S MURTHY Cor"t"f for the Respondent Nos.1 TO 3: SRI SWAROOP OORILLA' Special Govt Pleader for State Tax CounselfortheRespondentNo.4:SRIVIJHAYK'PUNNA,SENIORSCFOR cBlc Counsel for the Respondent No.S: SRI GADI PRAVEEN KUMAR' Dy' SOLICITOR GENERAL OF INDIA W.P.NO: 19074OF 2o25 Between:

1. M/s. V R Power Sotutions, Rep._gy its Managing partner, Mrs. p. Viii, 10_ 558/2, Nagaram Viilage, Keesaia tMandat, tvteoEnai Miiiiigiri,'tetr"g;#_SOo 083 AND 1. Assistant commissioner (State Taxes), Keesara-l circle, Malkajgiri Division, 2. 9tate of Telangan_a, R"p gy its. Secretary to Government (Revenue), State 3. Union of lndia, Rep. by its Secr6tary (Revenue), North Block, New Delhi Tax Department, Secretaridt. Hvderabad' Telangana ...PETITIONER ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit fired therewith, the High court may be pleased to issue a writ of Mandamus or any other appropriate writ or order or drrection by setting aside the impugned show cause notice dated 31 .s.2024 along with proceedings in Form GST DRC-01 vide Ref.No.ZD36os24og2143G dated 31 .5.2024 and order dated 28.8.2024 arong with proceedings in Form GST DRc- 07 vide Ref.No.ZD36082411g9os2 dated 28.8.2024 issued by the 1s1 Respondent for the tax period Aprir, 2019 to March, 2o2o without having any signatures as illegal and contrary to the provisions under the central Goods and Service Tax Act, 2017 and the Terangana Goods and services Tax Act, 2o1r and void in absence of non-compliance of Rule 142 (iA) of the central Goods and Service Tax Rules, 2017 and rerangana Goods and services Tax Rures, 2017. lA NO: 1 OF 2025 Petition under section i 51 cpc praying that in the circumstances stated in the affidavit filed in support of the petition, the High court may be pleased to grant stay of all further proceedings pursuant to the impugned order dated 28.g.2o24 along with proceedings in Form GST DRC-02 vide Ref.No.2D3608241.199052 dated 28.8.2024 issued by the 1st Respondent for the tax period April, 2019 to March, 2020 under the centrar Goods and service Tax Act, 2017 and the Telangana Goods and services Tax Act, 2017 pending disposar of the Writ Petition as otherwise the Petitioner will be put to severe loss and hardship. Counsel for the Petitioner: SRI K.p.AMARNATH REDDY counsel for the Respondent Nos.1 & 2: SRI SWAROOP OORILLA, special Counsel for the Respondent No.3: SRI GADI PRAVEEN KUMAR' Dy' Govt Pleader for State Tax SOLICITOR GENERAL OF INDIA W.P.NO:1909 1 0F 2025 Between: Hariom Communications LLP, Suit No'6, 4th floor, Plot No'47'48'49' 2nd A;d;", street no.1, sy.noZlb,Fitrika Nlagar' Madhapur' Seri Lingampally' 'ti;;;;;b;, i;rangi#- sooodi Rqpresentdt bv Authorised signatory.V Mr Ramesr'bhai Aged 4Tyears,rR/o.. Blavani ii]btbli6i,'"i namti6'Oani. kirp5, Arrrt FarK, Streei no.3, B/H Alap Green City Raiya Road' Rajkot' Gujarat-36ooo7 ...pETtnoNER -Slo-4. AND 1 2 TheAssistantCommissionerofstatetax,Madhapur-SCircle,,l2thfloor,.^^ Gi;;Vi;;;; briroi"s, oppo.ite Gandhi Bhavan' Nampallv, Hvderabad- 500 00'l 6iate of Telanqana, Through Principal Secretary to Gov Department t Ctmmercial Tax), Hyderabad, Telangana' emment, Revenue ...RESPONDENTS Petition under Article 226 of lhe constitution of lndia praying that in the circumstancesstatedintheaffidavitfiledtherewith,theHighCourtmaybe pleased to issue a writ, order, or direction or plea one in the nature of writ of mandamus declaring (a) That impugned order in FORM GST DRC-07 bearing Reference No. zD3608241399305dated3oto}t2o24issuedbytheRespondentNo.,l undertheprovisionsofCGsT/TGSTAct'20lTasbeingvoid,arbitrary' illegal, without jurisdiction, without authority of law apart from being violativeofArticlesl+,r9(1Xg)and265oftheConstitutionoflndia,andto consequentlY set aside the same. lA NO: 1 OF 2O2s Petition under section 151 CPC praying that in the circumstances stated in theaffidavitfiledinsupportofthepetition,theHighCourtmaybepleasedtostay operation of impugned order in FORM GST DRC-07 bearing Reference No. 2D36O8241399305 dated 3OlOBl2O24 issued bythe Respondent No 1' Counsel for the Petitioner: SRI P.VENKAT PRASAD 7 r counser for the Respondents: sRr swARoop ooRrLLA, Speciar Govt preader for State Tax W.P.NO:1 9099 oF 2025 Between: charter Grobar rechnorogies pvt. Ltd, Having its office at prot no 56/8.3rd ftoor power Mech tT park; Jubitee E"irr'r" rvrjotiip,ji, ivoli"i,jj,"rJiJi,i,r", - 500081 Represented by its Authorised Signato.y AND ...PET!T|oNER '1 . State Tax Officer. Hyderguda_Ashok Nagar, Abids Division, Hyderabad 2. State of Tetanoana ,gq gy its SeCreiJry ili'GJvernment (Revenue), State Tax Department, s"ecreiarlSi, HvJ"rro"j*'' * """ ...RESPONDENTS Petition under Article 226 0f the constitution of rndia praying that in the circumstances stated in the affidavit fired therewith, the High court may be pleased to issue a writ, order, or direction more particurarry one in the nature of writ of Mandamus decraring the impugned summary of the order in Form DRC-07 vide Ref No. 2D360225070614H dt. 24.o2.2o2s arong with Attachment to Demand order passed by the 1st Respondent and Summary of Show Cause Notice in Form DRC-01 vide Ref. No. 2D361 124032866D dt.27.11.2024 arong with attachment issued by the r st Respondent for the tax period Aprir, 2020 to March ' 2021 as iregar, arbitrary and non-est in raw and consequenfly set aside the impugned order and show cause notice. lA NO: 1 oF 2025 Petition under section 151 cpc praying that in the circumstances stated in the affidavit fired in support of the petition, the High court may be preased to stay all further proceedings pursuant to the order in Form DRC-07 vide Ref. No. 2D360225070614H dt. 24.02.2025 passed by the 1st Respondent for the tax period April, 2O2O lo March,2021 . Counsel for the Petitioner: SRI MOHD MUKHAIRUDDIN Counsel for the Respondents: SRI SWAROO' OORi.U, Spe"irl Govt pleader for State Tax W.P.NO: 19134OF 202s Between: M/s. Pariiatha Homes and Developers Pvt. Ltd.' No. 109,'1St Floor, G.B.S. Enclave, Motivalley, 500015 (Rep by its Chairman) Flat Tirumalgherry, Hyderabad- ...PETITIONER AND

1. Siate Tax Officer (ST), Begumpet ll Circle, Begumpet Divisior 6:-3-789, 6th Floor Pavani Presiige, Ameerpet, Hyderabad, Telangana 5!0016' ^ 2. State of Telangana]Rep. by iis Secietary to Government (Revenue), State Tax Department, Secretariat, Hyderabad ...RES'ONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a writ of Mandamus or any other appropriate writ or order or direction by setting aside the unsigned lmpugned Form GST DRC-o1A dt.21 .11.2024 vide Ref No. 2D3611240212532 along with Attachment to show Cause Notice in Form GST DRC-01 dl. 21 .11.2024, unsigned impugned Show Cause Notice in Form GST DRC-01 dt.O7.12.2024 vide Ref. No' 2D3612240O8640T and consequential impugned order dt.20.02.2025 along with Order in Form GST DRC-07 dt.2O.O2.2025 vide Ref No. 2D360225055106N issued by the 1St Respondent for the tax period April 2020 1o March 2021 without having any signature or authentication as illegal, arbitrary. lA NO: 1 OF 2025 Petition under Section 151 cPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High court may be pleased to grant stay of all furthdr proceedings pursuant to impugned Order dt.20.02.2025 along with Order in Form GST DRC-07 dt.2o.02.2025 vide Ref No. 2D360225055106N of the lst Respondent for the tax period April 2O2O to March 2021 pending disposal of the Writ Petition as otherwise the Petitioner will be put to severe loss and hardship." Counsel for the Petitioner: M/s. YAMMANURU SlRl REDDY Counsel for the Respondents: SRI SWAROOP OORILLA, Special Govt Pleader for State Tax The Court made the following: COMMON ORDER -r THE HON'BLE THE ACTING CHIEF JUSTTCE SUJOY PAUL AND THE HON'BLE SMT. JUSTTCE RENUKA YARA UIRIT PETITION Nos. 13618 , L9O74. r9O91, 19099 and 19134 of2o25 COMMON ORDER: (Per the Hon'ble the Acting Chief Justice Sujog paul) Learned counsel Sri T.Srinivasa Murthy, Sri K.p.Amarnath Redd"v, Sri P.Venkat Prasad, Sri Mohd. Mukhairuddin and Ms. Yammanuru Siri Reddy for the petitioners; Sri Vijhay K.Punna, iearneci Senior Standing Counsel for CBIC ald Sri Sr.r'aroop Oorilla, learned Special Government pleader for state Ta-x.

2. Regard being had to the similitude of the questions involved, on the joint request of learned counsel for the parties, the matters are analogously heard and decided by this common order.

3. Learned counsel for the petitioners ald learned Special Government Pleader for State Tax submitted that since the impugned notice(s) and order(s) are unsigned, the same may be set aside in vieu, of the common order passed in W.p.No.21 101 of 2024 &, batch, dated 2a.O2.2025. I l

4. Accordingly, the impugned notice(s) and order(s) in these Writ Petitions are set aside. The consequential bank attachment(s), if any, shall also stand revoked. Liberty is reserved to the respondents to issue fresh show cause notice(s)/ order(s) in accordance with law and, for undertaking this exercise afresh, the limitation will not be a hurdle for the respondents.

5. The Writ Petitions are disposed of without expresslng any opinion on the merits of the case. No costs Interlocutory applications, if any pending, sha11 also stand closed. //TRUE COPY// Sd/. MOHD. ISMAIL DEPUTY REGISTRAR ( ir. SECTION OFFICER To 1 State Tax Officer (ST), Begumpet ll Circle, Begumpet Division 6-3-789' 6th Floor Pavani Presiige, Ameerpet, Hyderabad, Telangana 5000't 6' Stiie Tix Officer, H-yciergudalAsholi Nagar, Abids Division,. Hvderabad ine Assistant Comriissi5ner of State tai, Madhapur-S Circle' 12th floor, Cigrn Vitiirr building, Opposite Gandhi Bhavan, Nampally, Hyderabad- 500 001 . Assistant Commissioner (State Taxes), Keesara-l Circle, Malkajgiri Division, Telangana fnJStireta.V to Government (Revenue), State Tax Department, Secretariat, Hvderabad, State of Telangana. iilloi;tC"rmissioner. S-ecunderabad GST commissionerate GST Bhavan, L.B.Stadium Road Basheerbagh, Hyderabad-500004. ine C-ommissioner of Central iax, Central Exice and Service Tax GST Bhavan, L.BStadium Road Basheerbagh, Hyderabad-500004. ihe Principat Secretary to Revenue CT Department, Secretariat Buildings, Hyderabad, State ofTelangana. The Secretary to Government Central Board of lndirect Taxes and Uus\oms, Department of Revenue, New Delhi -1 10001 .^ t _ 2 3 4 5 6 7 B I 1 0. The Secretary Ministry of Finance, Union of lndia, Department of Revenue, New Delhi-'t 1001 'I'1 .One CC to SRI T.S.IMURTHY, Advocate [OPUC] 12.One CC to SRI K.P.AMARNATH REDDY, Advocate [OPUC] tS.One CC to SRI P.VENKAT PRASAD, Advocate [OPUC] r+.One CC to SRI MOHD MUKHAIRUDDIN, Advocate IOBVqI - rS.One CC to M/s. YAIVIMANURU SlRl REDDY, Advocate tqlqql i6.on; aa i; SRr GADI PRAVEEN KUMAR, DY. sollclroR GENERAL oF rz.onl cb to sit vtJHAY K. PUNNA, sENloR sc FoR cBlc [oPUC] - i 8. on; Cc io Snr SWAROOP OORILLA' Special Govt Pleader for State Tax rNDrA [OPUC] \ loPUCl

19.Two CD Copies PSK PVL HIGH COURT DATED:1410712025 COMMON ORDER ( \. \ WP.Nos.13618, 19074,19091, 19099 AND 19134 ot 2025 I I DISPOSING OF THE WRIT PETITIONS WITHOUT COSTS 1 \3 g