HIGH COURT OF JUDICATURE AT ALLAHABAD LUCKNOW WRIT TAX No. - 968 of 2025 Court No. - 6 HON'BLE PANKAJ BHATIA, J. 1. Heard Shri Pranjal Shukla, learned counsel for the petitioner and Shri Sanjay Sarin, learned Standing Counsel for the State. 2. Present petition has been filed challenging the order dated 28.03.2024 passed under Section 73 of the GST Act as well as the order dated 27.08.2025 whereby the appeal was dismissed as being beyond limitation. 3. Contention of learned counsel for the petitioner is that no opportunity of hearing was granted while passing the order under Section 73. He states that show cause notice was uploaded on the 'additional tab', as such, the same could not be noticed. 4. Learned Standing Counsel is not in a position to dispute the said fact. 5. It is argued that the said issue was dealt with by this Court vide judgment dated 22.07.2024 passed in Writ Tax No.855 of 2024 (Ola Fleet Technologies Private Limited v. State of UP and 2 Ors.). 6. On the said sole ground, following the judgment in the case of Ola Fleet Technologies Private Limited (supra), present petition is allowed. 7. Orders dated 28.03.2024 & 27.08.2025 are quashed. Versus Counsel for Petitioner(s) : Devanand Pandey Counsel for Respondent(s) : C.S.C. M/S Jain Agencies,Balrampur Thru. Authorized Signatory .....Petitioner(s) State Of U.P. Thru. Prin. Secy. Deptt. Of State Tax Lko. And 2 Others .....Respondent(s) 8. Matter is remanded to the assessing authority to pass fresh order after giving an opportunity of hearing to the petitioner. September 19, 2025 nishant WTAX No. 968 of 2025 2 (Pankaj Bhatia,J.) Digitally signed by :- NISHANT MOHAN High Court of Judicature at Allahabad, Lucknow Bench