HIGH COURT OF JUDICATURE AT ALLAHABAD WRIT TAX No. - 5249 of 2025 Court No. - 3 HON'BLE SAUMITRA DAYAL SINGH, J. HON'BLE INDRAJEET SHUKLA, J. 1. Heard Sri Shubham Agarwal, learned counsel for the petitioner and Sri Arvind Mishra and Shri Saumitra Singh, learned counsel for the respondents and perused the record. 2. The present writ petition has been filed challenging the Adjudication Orders dated 09.04.2024 passed by respondent No. 3 for financial year 2018- 2019, order dated 29.04.2024 passed by respondent No. 4 for financial year 2018-2019 and order dated 07.08.2024 passed by respondent No. 3 for financial year 2019-2020 passed under Section 73 of the U.P.G.S.T. Act passed by respondent creating demand of tax of Rs. 37,22,658/-, 35,55,600/- and Rs. 2,01,210/- in the respective order. 3. Submissions have been advanced as have already been considered in large number of similar petitions. Primarily, we have considered and dealt with the same in Writ Tax No. 3964 of 2025 (M/s Riya Construction vs State of U.P. & 3 Ors, Neutral Citation No. - 2025:AHC:179271-DB, dated 09.10.2025. Addition it has been submitted that in the present case another error or law exists, inasmuch as two adjudicating orders have been passed for the same tax period i.e FY 2018-2019 by order dated 09.04.2024 tax Rs 37,22,658 has been demanded whereas by other order dated 29.04.2024 tax Rs.35,55,600/- has been demanded for the same period. In view of settled position of law, it is impermissible to pass two adjudicating orders for the same tax period for the same infringement/ lapses. 5. Further additionally challenge has also been raised to the order dated Versus Counsel for Petitioner(s) : Shubham Agrawal Counsel for Respondent(s) : A.S.G.I., C.S.C., Saumitra Singh M/S Insolox Sports & Infratech Private Limited .....Petitioner(s) Union Of India And 3 Others .....Respondent(s) 07.08.2024 passed for the FY 2019-20 raising tax demand of Rs.2,01,210 . 4. Facts being similar, writ petition is allowed and the impugned orders dated 09.04.2024, 29.04.2024 and 07.08.2024 are set aside, subject to the petitioner depositing Rs. 3,75,000 for FY 2018-2019 and Rs 21,000/- for FY 2019-2020 towards the disputed amount (including the amount that may have already been deposited or recovered) within a period of one month from today, with the following directions: (i) Subject to the above deposit being made by the petitioner, the Adjudicating Authority shall make available to the petitioner copy of the show cause notice together with any additional/supplementary notice etc issued in these proceedings together with copies of Relied Upon Documents ('RUDs' in short) within a period of two weeks from the date of compliance shown by the petitioner. (ii) Petitioner shall file reply, if any, within a further period of four weeks therefrom. (iii) Thereupon the respondent No.2 shall fix appropriate date for hearing and communicate the same to the petitioner in the manner prescribed by law with at least two weeks' advance notice. (iv) Petitioner undertakes to cooperate and participate in the proceedings and not seek any undue or long adjournment. 5. It is expected that the proceedings thus remitted would be concluded within six months from the date the petitioner makes first compliance under this order and deposits the amount specified above. 6. The amount so deposited by the petitioner shall remain subject to the final outcome of the adjudication proceedings. October 14, 2025 Nadeem WTAX No. 5249 of 2025 2 (Indrajeet Shukla,J.) (Saumitra Dayal Singh,J.) Digitally signed by :- NADEEM AHMAD High Court of Judicature at Allahabad