Facts of the Case
- Assessee
Profile: The petitioner, M/s Skanda Marketers, is a
proprietary concern managed by Sri T.S. Srinivasulu, engaged in commercial
business activities in Tumkur, Karnataka.
- Issuance
of Impugned Orders: The petitioner was faced with two
separate adjudication orders passed under Section 73 of the CGST/KGST Act,
2017 for the identical tax period spanning from April 2019 to March 2020
(FY 2019-20).
- First
Order: Passed on August 6, 2024, by the Commercial
Tax Officer, SGSTO-172, Madhugiri.
- Second
Order: Passed shortly after on August 31, 2024, by
the Commercial Tax Officer (Audit), Madhugiri, accompanied by a demand
notice in Form GST DRC-07.
- Dual
Authority Inception: The core grievance arose because these
parallel proceedings were initiated, managed, and concluded by two
completely different tax officers attached to separate wings (regular
sub-office vs. audit wing) based on two separate notices.
- Amnesty
Claim: Following the first order, the petitioner
submitted an application for waiver of interest and penalty under Section
128A using Form GST SPL-02, seeking shelter under the state amnesty
framework.
Issues Involved
- Whether
the tax department can legally sustain two distinct and parallel
adjudication orders under Section 73 of the CGST/KGST Act for the exact
same tax period (FY 2019-20) executed by two different field officers.
- Whether
the impugned orders suffered from a severe breach of natural justice,
given the internal factual contradictions within the orders regarding
whether the taxpayer had filed a response or failed to show cause.
- Whether
the High Court should issue a Mandamus directing the tax department to
accept the petitioner’s Section 128A Amnesty application at this interim
stage.
Petitioner’s Arguments
- Multiplicity
of Proceedings: The petitioner's counsel vehemently argued
that having two separate authorities adjudicate turnovers and pass
distinct assessment orders under Section 73 for the same financial period
is highly irregular, jurisdictional overreach, and legally untenable.
- Contradictory
Record Keeping: It was highlighted that the second impugned
order dated August 31, 2024, was inherently flawed; it paradoxically
recorded in one section that the petitioner had filed a comprehensive
response on August 22, 2024, while noting in another section that the petitioner
failed to show cause.
- Amnesty
Protection: The petitioner asserted their right to have
their statutory waiver application under Section 128A considered, as they
intended to resolve the liabilities under the administrative scheme rather
than undergo dual taxation liabilities.
Respondent’s Arguments
- Failure
to Respond at Initial Stages: The learned Additional
Government Advocate (AGA) appearing for the State of Karnataka defended
the department’s actions by pointing out that the petitioner had
completely failed to file responses to the initial statutory intimations
issued in Form GST DRC-01A and the subsequent Show Cause Notices.
- Unreported
Turnover Adjustments: The state argued that the parallel
proceedings were triggered because certain taxable turnovers had been
excluded or omitted by the taxpayer, which caught the attention of both
the audit team and the regular jurisdictional office. Therefore, the
absence of active participation from the taxpayer led to the ex-parte
passing of both orders.
Court Order / Findings
- Quashing
of Parallel Orders: The High Court observed that the core
of the issue lay in procedural confusion—two separate officers handling
parallel files based on even-dated notices, combined with contradictory
statements inside the audit order regarding the receipt of the taxpayer’s
objections. Consequently, the Court held that both impugned orders (dated
06.08.2024 and 31.08.2024) must be "jettisoned".
- Remand
for Fresh Adjudication: The High Court formally
quashed both orders and restored the proceedings to the second respondent
(Commercial Tax Officer) for de novo consideration. The petitioner was
granted explicit liberty to file a detailed reply and present additional
supporting documentation on or before July 6, 2026.
- Decline
on Amnesty Direction: The Court noted that since the precise
structural details of the petitioner’s Section 128A waiver application
were not actively forms of the primary case records before it, no formal
direction could be given to the department to consider the amnesty scheme
at this juncture. The primary focus remained on resetting the structural
assessment itself.
Important Clarification
Key Legal Takeaway: A taxpayer cannot be subjected to double jeopardy or parallel adjudications by different wings of the GST Department (such as the jurisdictional circle office and the audit wing) for the same assessment year. Even if a taxpayer fails to respond to initial notices, the department must coordinate internally to ensure a singular, unified adjudication process rather than passing conflicting, multiple orders under Section 73.
Sections Involved
- Section
73 of the Central Goods and Services Tax Act, 2017 (CGST Act) / Karnataka
Goods and Services Tax Act, 2017 (KGST Act):
Determination of tax not paid or short paid or erroneously refunded or
input tax credit wrongly availed or utilized for any reason other than
fraud or any willful-misstatement or suppression of facts.
- Section
128A of the CGST/KGST Act, 2017: Statutory provisions
governing the waiver of interest or penalty, or both, under specific
Amnesty Schemes.
- Articles 226 and 227 of the Constitution of India: Constitutional writ jurisdiction of the High Court invoked to challenge arbitrary administrative action and seek a Writ of Certiorari.
Link to download the order - https://mytaxexpert.co.in/uploads/1783061793_335compressed.pdf
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