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[Cites 7, Cited by 0]

Andhra Pradesh High Court - Amravati

Shriji Associates vs Assistant Commissioner, on 18 September, 2020

Author: J. Uma Devi

Bench: J. Uma Devi

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IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI

(SPECIAL ORIGINAL JURISDICTION)

 

FRIDAY, THE EIGHTEENTH DAY OF SEPTEMBER TWO THOUSAND AND TWENTY

:PRESENT:

THE HONOURABLE SRI JUSTICE RAKESH KUMAR
AND
THE HONOURABLE MS JUSTICE J. UMA DEVI

WRIT PETITION NO: 8768 OF 2020

Between:
M/s. Shriji Associates, rep. by its Managing Partner, Mr. Sudhir Oza, 9-16-17, CBM
Compound, Visakhapatnam-530 003.
...Petitioner
AND
1. Assistant Commissioner, China Waltair Circle, Visakhapatnam.
2. Union of India, rep. by Secretary to Government, Finance Department, NewDelblhi.

...Respondents

Petition under Article 226 of the Constitution of India 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 declaring
that the proviso to Section 50 of the Central Goods and Services Tax Act, 2017 inserted
by Section 100 of Finance (No.2) Act, 2019 applies retrospectively from 01.07.2017 and
consequently set aside the demand notice dated 27.02.2019 (mistakenly mentioned as
2019) for the months from April, 2018 to March, 2019 issued by the 1% Respondent
demanding interest under the pre-amended Section 50 of the CGST Act declare that the
summary levy and demand of interest under Section 50 of the CGST Act which is not
preceded by an adjudication as per Section 73 of the CGST Act determining the
principal amount payable is illegal and co the scheme of the CGST Act, 2017 and
principles of natural justice and (c) alternatively, declare that Section 50(1) of the CGST
Act, in so far as it seeks to levy interest on the gross tax liability without duly reducing
the input tax credit available to the registered person under the CGST Act as being
illegal, confiscatory and contrary to the fundamentals of the levy of interest, a colourable
exercise to levy penalty in the guise of interest and strike down Section 50(1) to such
extent as being unconstitutional.

IA NO: 1 OF 2020

Petition under Section 151 CPC praying that in the circumstances stated in the
affidavit filed in support of the writ petition, the High Court may be pleased to grant stay
of all further proceedings, pursuant to the impugned notice dated 27.02.2019
(mistakenly mentioned as 2019) issued by the 1%* Respondent for the months from April,
2018 to March, 2019, pending disposal of WP 8768 of 2020, on the file of the High
Court.

The petition coming on for hearing, upon perusing the Petition and the affidavit
filed in support thereof and the order of the High Court dated 16-07-2020 & 13.08.2020
made herein and upon hearing the arguments of Sri S Dwarakanath Advocate for the
Petitioner and of, GP for Commercial Tax for the Respondent No.1, and the Court made
the following.
 

 

ORDER:

[Proceedings taken up through Video Conferencing] Sri Sekhar, learned Government Pleader for Commercial Taxes requests for granting two weeks time for filing counter. The prayer is allowed.

List this matter after three weeks so that if the counter affidavit is filed within two weeks, learned counsel for the petitioner may consume one week for examining the same and for filing reply, if any. List this matter on 09.10.2020 side by side of W.P.No.8734 of 2020. Interim order granted earlier shall stand extended till the next date. gg/- R. KARTHIKEYAN 'ASSISTANT REGISTRAR ITTRUE COPY!I/ _ . So For assistat ecrrar To,

1. One CC to Sri. S Dwarakanath Advocate [OPUC]

2. Two CCs to GP For Commercial Tax, High Court Of Andhra Pradesh. [OUT]

3. Two spare copy.

SRL HIGH COURT RKJ & JUDJ DATED:18-09-2020 NOTE: LIST THIS MATER ON 09.10.2020 SIDE BY SIDE OF W.P.NO.8734 OF 2020 ORDER WP.No.8768 of 2020 INTERIM ORDER EXTENDED