HIGH COURT OF JUDICATURE AT ALLAHABAD WRIT TAX No. - 4660 of 2025 Court No. - 3 HON'BLE SAUMITRA DAYAL SINGH, J. HON'BLE INDRAJEET SHUKLA, J. 1. Heard Sri Aditya Pandey, learned counsel for the petitioner and Sri Arvind Kumar Mishra, learned counsel for the revenue and perused the record. 2. The present writ petition has been filed challenging the Adjudication Order dated 30.07.2025 passed under Section 74 of the U.P.G.S.T. Act passed by respondent no. 2 creating a demand of tax of Rs. 67,70,012/- for the F.Y. 2018-19. 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. 4. In addition, it has been submitted that there is absolutely no jurisdiction with the respondent authority inasmuch no allegation of fraud or suppression of material fact has been made in the impugned show-cause notice. Therefore, proceedings were initiated outside the limitation. 5. Facts being similar, writ petition is allowed and the impugned order is set aside, subject to the petitioner depositing Rs. 6,78,000/- 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: Versus Counsel for Petitioner(s) : Aditya Pandey Counsel for Respondent(s) : C.S.C. M/S Om Prakash Chaubey .....Petitioner(s) State of U.P. and Another .....Respondent(s) (i) Petitioner shall file reply, if any, within a further period of four weeks therefrom. (ii) 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. (iii) Petitioner undertakes to cooperate and participate in the proceedings and not seek any undue or long adjournment. 6. 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. 7. The amount so deposited by the petitioner shall remain subject to the final outcome of the adjudication proceedings. October 15, 2025 Abhilash WTAX No. 4660 of 2025 2 (Indrajeet Shukla,J.) (Saumitra Dayal Singh,J.) Digitally signed by :- ABHILASH SINGH High Court of Judicature at Allahabad