HIGH COURT OF JUDICATURE AT ALLAHABAD WRIT TAX No. - 3850 of 2025 Court No. - 3 HON'BLE SHEKHAR B. SARAF, J. HON'BLE PRAVEEN KUMAR GIRI, J. 1. Heard learned counsel appearing on behalf of the petitioner and Sri Parv Agarwal, learned counsel appearing on behalf of the respondent No.1. 2. This is a writ petition under Article 226 of the Constitution of India wherein the writ petitioner is aggrieved by the impugned demand-cum- show cause notice dated June 28, 2025 issued by the Superintendent (A.E.) Commissionerate, Gautam Budh Nagar/respondent No.1. 3. Upon hearing counsel appearing on behalf of the parties we are of the view that the petitioner should file its reply before the authority concerned within a period of six weeks from date. Once the reply is received by the authority concerned, an opportunity of personal hearing should be granted to the petitioner before passing of the reasoned order by the authority concerned taking into the consideration the judgements that may be cited by the parties. We make it clear that the authority concerned should decide on the issue of jurisdiction first before proceeding on merit. 4. The writ petition is disposed of accordingly. September 11, 2025 Kuldeep Versus Counsel for Petitioner(s) : Suyash Agarwal Counsel for Respondent(s) : A.S.G.I., C.S.C., Parv Agarwal, Saumitra Singh (Praveen Kumar Giri,J.) (Shekhar B. Saraf,J.) M/S O.P. Packers .....Petitioner(s) Superitendent (A.E.) Cgst Commissionerate And 2 Others .....Respondent(s) Digitally signed by :- KULDEEP SINGH High Court of Judicature at Allahabad