HIGH COURT OF JUDICATURE AT ALLAHABAD LUCKNOW WRIT TAX No. - 1401 of 2025 Court No. - 3 HON'BLE SHEKHAR B. SARAF, J. HON'BLE MANJIVE SHUKLA, J. 1. Heard Shri Rajesh Chandra Mishra, learned counsel for the petitioners and Shri Sanjay Sarin, learned Standing Counsel for the State. 2. Challenge has been raised to the adjudication order dated 21.12.2023 passed under Section 73(9) of the U.P. G.S.T Act, 2017 for the tax period 2017-18 and the attachment order dated 10.11.2025. 3. It has been submitted, the essential requirements of rules of natural justice have been violated inasmuch as the petitioners were not given reasonable opportunity of personal hearing. The date fixed for personal hearing was the same as the date fixed for filing of reply. In that regard reliance has been placed on Writ Tax No.303 of 2024, Mahaveer Trading Company Vs. Deputy Commissioner State Tax and Another. 4. The above facts are not in dispute. Therefore, no useful purpose may be served either in keeping the present petition or calling for a counter affidavit or relegating the petitioners to the forum of appeal. The rules of natural justice are far too well established to allow any exception to be made in that regard. Unless, the petitioners had been put to notice with respect to the demand proposed to be created by the adjudication order and unless he had been given adequate opportunity to present his case, the order that may arise may remain procedurally defective. Versus Counsel for Petitioner(s) : Rajesh Chandra Mishra Counsel for Respondent(s) : C.S.C. M/S Jai Chandrikey Trading Trading Co.Thru. Proprietor Sunil Kumar Trivedi And Another .....Petitioner(s) State Of U.P. Thru. Commissioner State Tax Lko. And Another .....Respondent(s) 5. Accordingly, the writ petition stands disposed of with the following directions:- (i) The orders dated 21.12.2023 and 10.11.2025 are set aside. (ii) The petitioners may treat the impugned order as the final notice. (iii) It may submit its further reply thereto within a period of three weeks. In that regard, it may remain open to the petitioners to raise all jurisdictional and merit issues. Subject to such compliance made, the adjudicating authority may fix a date for personal hearing with at least 15 days notice to allow the petitioners to be prepared on all counts. The petitioners undertake to appear before the adjudicating authority on the dates that may be fixed. Accordingly, appropriate reasoned order may be passed thereafter. November 27, 2025 Satish WTAX No. 1401 of 2025 2 (Manjive Shukla,J.) (Shekhar B. Saraf,J.) Digitally signed by :- SATISH KUMAR BHARATI High Court of Judicature at Allahabad, Lucknow Bench