HIGH COURT OF JUDICATURE AT ALLAHABAD LUCKNOW WRIT TAX No. - 1411 of 2025 Court No. - 2 HON'BLE MRS. SANGEETA CHANDRA, J. HON'BLE AMITABH KUMAR RAI, J. 1. Heard learned Counsel for the petitioner and learned Standing Counsel appearing on behalf of the State Respondents. 2. This petition has been filed with the following main prayer:- "Issue a writ, order or direction in the nature of certiorari quashing the impugned order dated 14/08/2024 (Annexure no.1) passed by the Opp. Party No.2. Issue a writ, order or direction in the nature of mandamus, directing the opposite parties to not to enforce/ proceed to recovery, the order U/s 73 dated 14/08/2024 against the petitioner firm passed by the Opposite Party No.2" 3. It has been submitted by the learned Counsel for the petitioner that the petitioner Firm is a sole proprietorship Firm and has been registered under the State G.S.T. Act with GSTIN No.09AVSPS7323M1ZL in the name of M/s Indra Bhan Singh. For the tax period of April, 2019 to March, 2020, the returns of the petitioner Firm were scrutinized by the Department and the respondent no.2 has issued a notice under Section 61 of the Act on 04.12.2021 on the tab relating to 'Additional Notices' and directed the Versus Counsel for Petitioner(s) : Satish Kumar Pandey Counsel for Respondent(s) : C.S.C. M/S Inder Bhan Singh Thru. Proprietor Indra Bhan Singh .....Petitioner(s) State Of U.P. Thru. Prin. Secy. Institutional Finance Lko. And And Another .....Respondent(s) petitioner Firm to submit its reply by 18.12.2021. Such notice could not be accessed by the petitioner. The respondent no.2 further issued a notice under Section 73(1) of the Act on 22.05.2024 again on the tab relating to the 'Additional Notices' and directed to file its reply by 16.01.2024. 4. The petitioner was issued show-cause notice on 22.06.2024 under Section 73(1) and date of submission of reply to the notice, date & time of personal hearing and venue of personal hearing, were fixed for the same day i.e. for 22.06.2024 itself. 5. A second notice was served to him on 02.07.2024 fixing date of 02.08.2024 for submission of reply and personal hearing was fixed for same day i.e. for 02.08.2024. Hence the petitioner was deprived of reasonable opportunity of hearing. 6. The respondent no.2 has adjudicated the case by an order dated 14.08.2024 under Section 73 of the Act imposing the tax liability along with interest and penalty amounting to Rs.20,17,724/-. 7. It has been submitted by learned counsel for the petitioner that the petitioner could not be said to have been given reasonable opportunity of hearing as on the date fixed for submission of reply, the date of personal hearing was also mentioned. 8. We are not convinced with such argument. 9. The petitioner has a statutory remedy of filing an Appeal. 10. This petition is disposed of with a direction to the petitioner to approach the Appellate Authority under Section 107 of the G.S.T. Act. December 8, 2025 Rahul WTAX No. 1411 of 2025 2 (Amitabh Kumar Rai,J.) (Mrs. Sangeeta Chandra,J.) Digitally signed by :- RAHUL TRIPATHI High Court of Judicature at Allahabad, Lucknow Bench