Facts of the Case
The petitioners approached the Delhi High Court in writ
proceedings arising from a Show Cause Notice dated 16 August 2022. The
controversy before the Court concerned the availability and supply of documents
connected with the Show Cause Notice, including seized documents treated as Relied
Upon Documents (RUDs), other documents stated to be in the custody of the
respondent/Revenue, and electronic devices requiring cloning before being
returned to the petitioners’ authorised representative.
Pursuant to an earlier order dated 12 October 2022,
counsel appearing for the respondent/Revenue returned with instructions and
informed the Court regarding the steps proposed for supplying documents and
dealing with seized electronic devices. The order records that the RUDs, namely
seized documents appended to the subject Show Cause Notice, had already been
furnished to the petitioners.
The Revenue further stated that where documents were not on
record but remained in its custody, photocopies would be furnished with an
endorsement clarifying that the photocopy of the relevant document was backed
by a seized document in the custody of the Revenue. The Court specifically
recorded that such endorsement should clearly reflect this position.
As regards electronic devices, the Revenue stated that they
would be cloned and thereafter returned to the authorised representative of the
petitioners. The date and time for carrying out this exercise were to be fixed
and communicated in writing by email. The entire exercise was directed to be
completed within four weeks.
Issues Involved
The principal issues arising in the proceedings were whether
the petitioners should receive complete access to the documentary material
relevant to the Show Cause Notice, including documents in the custody of the
Revenue; whether photocopies of such documents should carry a clear endorsement
linking them to seized originals in Revenue custody; whether seized electronic
devices should be cloned and returned to the petitioners’ authorised
representative; and what reasonable period should be granted for filing a reply
to the Show Cause Notice after completion of the document-supply and cloning
exercise.
The proceedings also involved the broader procedural question
of ensuring an effective opportunity to respond to the Show Cause Notice after
access to the relevant material and electronic devices had been facilitated.
Petitioners’ Arguments
The petitioners’ case, as reflected from the relief ultimately
addressed through the Revenue’s statements and the Court’s directions,
concerned access to documents and seized material necessary for responding
effectively to the Show Cause Notice dated 16 August 2022.
The petitioners required the relevant documents in Revenue
custody to be made available and sought appropriate handling of seized
electronic devices. Once the Court recorded the directions concerning supply of
documents, cloning and return of electronic devices, and the subsequent time
allowed for filing the reply to the Show Cause Notice, learned senior counsel
for the petitioners stated that the writ petitions could be closed.
It is important to clarify that the three-page order does not
record a detailed merits-based argument on the substantive tax allegations
contained in the Show Cause Notice. Therefore, no substantive tax defence
should be attributed to the petitioners beyond what is actually reflected in
the judicial order.
Respondent’s Arguments / Revenue’s Stand
The respondent/Revenue, through its counsel, made the
following statements before the Delhi High Court:
- The Relied
Upon Documents (RUDs), namely seized documents appended to the Show
Cause Notice, had already been furnished to the petitioners.
- Documents
not on record but in the custody of the Revenue would be supplied by way
of photocopies.
- Such
photocopies would carry an endorsement clarifying that the relevant
photocopy was backed by a seized document held in the custody of the
Revenue.
- The
endorsement on the document should clearly disclose this position.
- The
electronic devices would be cloned and thereafter returned to the
authorised representative of the petitioners.
- The
date and time for the cloning exercise would be fixed and communicated to
the petitioners in writing through email.
- The
Revenue’s statement was taken on record by the Court.
Court Order / Findings
The Delhi High Court disposed of the writ petitions by
recording and acting upon the statements made on behalf of the Revenue and
issued clear procedural directions.
The Court directed that the exercise concerning the relevant
documents and cloning/return of electronic devices be completed within four
weeks.
The Court further clarified that once the aforesaid exercise
was completed, the petitioners would file their reply to the Show Cause Notice
dated 16 August 2022 within six weeks thereafter.
In view of these directions, counsel for the petitioners
stated that the writ petitions could be closed, and the Court ordered
accordingly.
The Court additionally clarified that the petitioners would
bear the costs of photocopying as well as cloning.
Important Clarification
This order should be understood as a procedural direction
concerning access to documents, treatment of material in Revenue custody,
cloning and return of seized electronic devices, and the timeline for replying
to the Show Cause Notice.
The Delhi High Court did not adjudicate the substantive
merits of the tax allegations in the Show Cause Notice in this order. Nor
did the Court quash the Show Cause Notice. Instead, the proceedings were closed
after recording the Revenue’s statements and establishing a structured timeline
for completion of the document/electronic-device exercise and filing of the
petitioners’ reply.
A particularly significant clarification is that where a
document was not on record but remained in Revenue custody, the photocopy to be
supplied was required to carry an endorsement making clear that it was backed
by a seized document held by the Revenue. This ensured clarity regarding the
source and custody of the underlying seized material.
The Court also expressly placed the cost of photocopies and
cloning upon the petitioners.
Sections
Involved
The uploaded order does not expressly identify or
adjudicate any specific section of the CGST Act, 2017, Central Excise Act,
1944, or another taxing statute as the determinative statutory provision in
the operative directions. Accordingly, inserting a specific statutory section
as though expressly decided by the Court would alter the meaning and scope of
the order.
The legal subject matter, as actually reflected in the order,
concerns:
Article 226 of the Constitution of India – writ
jurisdiction of the High Court, reflected by the W.P.(C) proceedings.
Show Cause Notice proceedings –
procedural opportunity to respond after completion of supply/access to relevant
material.
Relied Upon Documents (RUDs) – seized
documents appended to the subject Show Cause Notice.
Documents in Revenue custody – supply
of photocopies with appropriate endorsement regarding the seized document
backing them.
Seized electronic devices –
cloning followed by return to the authorised representative of the petitioners.
Principles of natural justice and effective opportunity of response – relevant to the procedural context, although the order itself does not set out an elaborate doctrinal ruling under a specifically cited statutory section.
Link to download the order - https://mytaxexpert.co.in/uploads/1783155994_870compressed.pdf
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