CWP- 34243- IN THE HIGH COURT OF PUNJAB AND HARYANA AT Hans Steel Rolling Mills State of Punjab CORAM : HON’BLE MR. JUSTICE HON’BLE MS. JUSTICE LAPITA BANERJI Present : Mr. for the petitioner. Ms. Shruti, AAG, Punjab. DEEPAK SIBAL It is not disputed that prior to passing of the impu adjudication order dated 74 of the Punjab Goods and Services Tax Act, 2017, perta financial year 2017 the petitioner, also contravenes Section 75(4) of the Central Goods and Services Tax Act 2017, which mandates the respondent hearing to the assessee before any adverse action against the assessee. 2. In covered in its favour by a recent judgment rendered by us on 24.03.2026 in CWP-33977-2025 others’. 3. Learned counsel for the respondent distinguish the applicability of (supra) to the petitioner’s case. -2025 Sr. No.136 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP- 34243 Date of Decision : Hans Steel Rolling Mills … Versus State of Punjab and others …Respondent HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Mukul Singla, Advocate for the petitioner. Ms. Shruti, AAG, Punjab. *** DEEPAK SIBAL, J. (Oral) It is not disputed that prior to passing of the impu adjudication order dated 17.05.2023 (Annexure P of the Punjab Goods and Services Tax Act, 2017, perta financial year 2017-18, no opportunity of personal hearing was afforded to the petitioner, which not only violates the principles of natural justice but also contravenes Section 75(4) of the Central Goods and Services Tax Act mandates the respondent-authorities to hearing to the assessee before any adverse action against the assessee. In the light of the above, the petitioner’s case would be covered in its favour by a recent judgment rendered by us on 24.03.2026 in 2025 ‘Kemexel Ecommerce Pvt. Ltd. Vs. State of Punjab and Learned counsel for the respondent distinguish the applicability of Kemexel Ecommerce Pvt. Ltd.’s (supra) to the petitioner’s case. IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 34243-2025 Date of Decision :18.05.2026 …Petitioner …Respondents DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI It is not disputed that prior to passing of the impugned (Annexure P-3) passed under Section of the Punjab Goods and Services Tax Act, 2017, pertaining to the , no opportunity of personal hearing was afforded to which not only violates the principles of natural justice but also contravenes Section 75(4) of the Central Goods and Services Tax Act, authorities to provide opportunity of hearing to the assessee before any adverse action against the assessee. above, the petitioner’s case would be covered in its favour by a recent judgment rendered by us on 24.03.2026 in Ecommerce Pvt. Ltd. Vs. State of Punjab and Learned counsel for the respondents has not been able to Kemexel Ecommerce Pvt. Ltd.’s case VANDANA 2026.05.19 17:24 I attest to the accuracy and integrity of this document CWP- 34243- 4. In 17.05.2023 (Annexure P (Annexure P-5) to proceed afresh 5. The petition is allowed in the above terms. 18.05.2026 vandana Whether speaking/reasoned : Whether reportable -2025 In view of the above, the impugn 17.05.2023 (Annexure P-3) and the appellate order dated 5) are set aside. However, liberty is granted to the respondent afresh against the petitioner, in accordance with law. The petition is allowed in the above terms. (DEEPAK SIBAL JUDGE (LAPITA BANERJI) JUDGE ther speaking/reasoned : Yes/No Whether reportable : Yes/No view of the above, the impugned adjudication order dated and the appellate order dated 07.07.2025 ty is granted to the respondents in accordance with law. The petition is allowed in the above terms. DEEPAK SIBAL) JUDGE (LAPITA BANERJI) JUDGE VANDANA 2026.05.19 17:24 I attest to the accuracy and integrity of this document