$~93 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 8469/2024, CM APPL. 34906/2024 M/S. CREDULITY SOLUTIONS PRIVATE LIMITED .....Petitioner Through: Mr. Harish Malhotra, Sr. Adv. with Mr. Manish Khurana, Adv. versus COMMISSIONER OF DELHI GOODS AND SERVICES TAX & ANR. .....Respondents Through: Ms. Urvi Mohan and Mr. Sumit Kumar, Advs. CORAM: HON'BLE MR. JUSTICE ANIL KSHETARPAL HON'BLE MR. JUSTICE AMIT MAHAJAN O R D E R % 21.07.2026 1. Learned Senior Counsel representing the Petitioner submits that, in respect of Financial Year („FY‟) 2019-20, a similar assessment order had been passed against the Petitioner. The said order was challenged before this Court in W.P. (C) 14410/2024, which came to be disposed of vide order dated 15.10.2024. The relevant observations of this Court are extracted below: “W.P.(C) 14410/2024, CM APPL. 60404/2024 (Stay) 1. The writ petitioner is aggrieved by the final order dated 11 July 2024 passed under Section 73 of the Central Goods and Services Tax Act, 2017 [‘Act’]. W.P.(C) 14410/2024, CM APPL. 60404/2024 (Stay) 2. The said final order was preceded by a Show Cause Notice [‘SCN’] dated 13 May 2024. While responding to the same, the petitioner had furnished detailed replies dated 13 June 2024 and 26 June 2024 and which stand placed on our record as Annexure P-6. In terms of the aforesaid, it had been duly conveyed to the respondents that all tax liabilities had been duly discharged and that the action based solely on the fact This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 23/07/2026 at 12:11:30 that the registration of the supplier had been cancelled with retrospective effect would not sustain. 3. We however note that while passing the final order which stands impugned before us, none of the contentions which were taken by the writ petitioner have been either noticed or examined. 4. In view of the aforesaid and on our expressing a tentative opinion that the impugned order would be liable to be set aside on this short score alone, Mr. Singh, learned counsel appearing for the respondent submitted that the ends of justice may merit the matter being remitted to the competent authority for adjudication afresh. 5. Accordingly, and for reasons noted hereinabove, we allow the instant writ petition and quash the impugned order dated 11 July 2024. 6. We leave it open to the competent authority to proceed in the matter afresh, bearing in mind the reply which had been submitted by the writ petitioner and after affording it an opportunity of personal hearing. 7. All rights and contentions of respective parties on merits are kept open.” 2. Learned Senior Counsel further submits that, pursuant to the aforesaid remand order dated 15.10.2024, the assessing authority, by order dated 02.06.2026, has recalled the remand proceedings and closed the matter. 3. Learned Senior Counsel submits that the present Writ Petition pertains to FY 2018-19 and raises an identical issue. It is contended that the Impugned Order dated 30.04.2024 (hereinafter referred to as „Impugned Order‟) erroneously records that the tax has not been deposited, whereas the Petitioner had, in fact, duly discharged the tax liability. In support of the said submission, reliance is placed upon Form GSTR-3B. 4. Having regard to the fact that, in respect of the very same This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 23/07/2026 at 12:11:30 Petitioner and on an identical issue pertaining to FY 2019-20, the remand order was set aside by this Court and the matter was remitted for fresh adjudication, this Court is of the opinion that the present matter also deserves to be remitted to the competent authority. Accordingly, the Impugned Order is set aside. 5. It shall be open to the competent authority to pass a fresh order in accordance with law, after granting the Petitioner an opportunity of hearing and without being influenced by any observations made in the present order. ANIL KSHETARPAL, J. AMIT MAHAJAN, J. JULY 21, 2026/kp/shah This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 23/07/2026 at 12:11:30