Facts of the Case
Supreme Food Products approached the High Court of
Kerala being aggrieved by two assessment orders passed under the provisions of
the GST laws for the assessment years 2017-18 (November to March) and 2018-19.
The record reflected that DRC-01A notice dated 20
February 2020 had been issued for FY 2017-18 and FY 2018-19. Thereafter, DRC-01
notices dated 1 September 2021 were issued separately for FY 2017-18 and FY
2018-19. The petitioner submitted replies dated 7 October 2021 against those
notices.
Subsequently, two assessment orders dated 15
November 2021 were passed against the petitioner. The assessment order relating
to FY 2017-18 raised a demand of Rs. 15,31,029, while the assessment order
relating to FY 2018-19 raised a demand of Rs. 29,75,338.
Aggrieved by these two assessment orders, the
petitioner instituted the writ petition before the High Court.
Issues
Involved
The principal issues arising for consideration
were:
- Whether the petitioner could be permitted to discontinue the writ
proceedings and avail the statutory appellate remedies against the two GST
assessment orders dated 15 November 2021.
- Whether the period during which the writ petition remained pending
before the High Court could be excluded while determining the limitation
period for filing the statutory appeals.
- Whether the petitioner could raise all available contentions
against the impugned assessment orders before the first appellate
authority in accordance with law.
Petitioner’s
Arguments
The petitioner submitted before the High Court that
it did not wish to pursue the writ petition further and sought permission to
avail the statutory remedies against Exts. P8 and P9, namely the two assessment
orders dated 15 November 2021.
The petitioner further requested that the period
during which the writ petition remained pending before the High Court be
excluded for the purpose of determining the limitation period within which the
statutory appeals were required to be filed.
Thus, the petitioner sought liberty to challenge
the assessment orders before the competent first appellate authority without
losing the statutory remedy merely because time had elapsed during the pendency
of the writ proceedings.
Respondent’s
Arguments
The learned Senior Government Pleader was heard by
the High Court.
The judgment does not record any detailed
independent objection, counter-argument, or substantive opposition advanced by
the respondent against the petitioner’s request to pursue the statutory
appellate remedy and seek exclusion of the writ-pendency period for limitation
purposes.
Accordingly, no additional respondent argument
should be attributed beyond what is expressly recorded in the judgment.
Court Order
/ Findings
Having regard to the facts and circumstances of the
case and considering the submissions made before it, the High Court closed the
writ petition.
The Court expressly clarified that the petitioner
would be at liberty to raise all contentions against Exts. P8 and P9 by filing
statutory appeals before the first appellate authority in accordance with law.
Significantly, the High Court directed that the
period from 18 February 2022 to 16 November 2022 be excluded for the
purpose of determining the period of limitation within which the statutory
appeals were required to be filed.
However, this exclusion was made subject to an
express condition: the petitioner was required to file the appeal within one
week from the date of receipt of a certified copy of the judgment.
Accordingly, the writ petition was disposed of with
liberty to pursue the statutory appellate remedies on the above terms.
Important
Clarification
The judgment is important for the following precise
clarification:
Where the petitioner chose not to continue with the
writ petition and instead sought to pursue the statutory appellate remedy
against GST assessment orders, the High Court permitted such a course and
excluded the period during which the writ petition remained pending for
determining limitation.
However, the benefit was expressly conditional. The
statutory appeal had to be filed within one week from the date of receipt of a
certified copy of the judgment.
The decision should not be read as laying down an
unrestricted proposition that the pendency period of every writ petition must
automatically be excluded in all GST appeals. The relief in this case was
granted having regard to the facts and circumstances before the Court and
subject to the specific filing condition imposed in the judgment.
Sections /
Provisions Involved
GST Laws: Assessment
proceedings and statutory appellate remedy against assessment orders.
Specific statutory section: The judgment itself does not expressly identify or mention any
particular section number of the CGST Act, SGST Act, or other GST enactment
governing the assessment orders or statutory appeals. Therefore, no specific
section number should be inserted into the case summary as though it were
expressly adjudicated in the judgment.
Procedural documents involved: DRC-01A and DRC-01 notices.
Core legal issue: Statutory appellate remedy against GST assessment orders and exclusion of the writ-pendency period while determining limitation for filing appeals.
Link to download the order -https://www.mytaxexpert.co.in/uploads/1783311946_988compressed.pdf
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