2026:JHHC:16767-DB 1 IN THE HIGH COURT OF JHARKHAND AT RANCHI W.P.(T) No. 3840 of 2026 M/s. Kalsi Buildcon Private Limited, having its registered office at Springdales, Kilburn Colony, Hinoo, PO & PS-Doranda, District- Ranchi, represented through its Authorized Signatory Shri Sonu Kumar Dubey, S/o Shri Kush Dubey, R/o Village-Diharia, Kishunpur, PO-Kishunpur, PS-Patan, District-Palamau ... ... Petitioner Versus 1. The Principal Commissioner, Central Goods and Services Tax & Central Excise, Ranchi Commissionerate, having its office at Central Revenue Building, 5A, Main Road, Ranchi 2. The Additional Commissioner, Central Goods and Services Tax & Central Excise, Ranchi South Division, having its office at Central Revenue Building, 5A, Main Road, Ranchi 3. The Superintendent, Central Goods and Services Tax & Central Excise, Ranchi South Division, Range-VI, 2nd & 3rd Floor, Midtown Chamber, 1, Club Road, Ranchi ... … Respondents ----- CORAM: HON’BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE RAJESH SHANKAR For the Petitioner : Mr. N.K. Pasari, Advocate Mr. Shubham Choudhary, Advocate For the Respondents : Mr. Amit Kumar, Sr. SC, CGST Mr. Anurag Vijay, Jr. SC, CGST ----- Order No. 02 Dated: 11.06.2026 1. Heard learned counsel for the parties. With their consent and at their request, we finally dispose of this writ petition. 2. The petitioner seeks certain refunds based upon Final Order No. 77206 of 2024 dated 24.10.2024 in Service Tax Appeal No. 75934 of 2022 instituted by the petitioner before the Customs, Excise and Service Tax Appellate Tribunal, Eastern Zonal Bench, Kolkata. 3. The operative portion of the order dated 24.10.2024 is contained in paragraph nos. 7 and 7.1, which we transcribe below for the convenience of reference: 2026:JHHC:16767-DB 2 7. We further take note of the fact that in this case, there were confusions with regard to the service rendered to the Government and all the documents pertaining to the appellant’s activity were also in the public domain. In these circumstances, we hold that the extended period of limitation is not invokable. We note that in this case, for the period from 2014-15 up to June, 2017, the Show Cause Notice has been issued on 20th September, 2019. Consequently, the demand pertaining to the extended period of limitation is not sustainable and therefore, set aside. 7.1. We hold that any demand which is within the normal period of time, is liable to be paid by the appellant, along with interest.” 4. In terms of the above order, any demand made upon the petitioner pertaining to the extended period of limitation has been set aside. However, the Customs, Excise and Service Tax Appellate Tribunal has held that any demand within the normal period is liable to be paid by the petitioner to the respondents, together with interest. 5. The grievance now raised in the petition is that the respondents are not acting in accordance with the order dated 24.10.2024 passed by the Customs, Excise and Service Tax Appellate Tribunal. The petitioner has contended that, according to its calculations, a refund, along with interest, becomes payable. The learned counsel for the respondents does not agree with this position. 6. At this stage, it is not for us to determine whether any refund is due to the petitioner or whether the petitioner is 2026:JHHC:16767-DB 3 liable to pay any amounts to the respondents. That exercise will have to be undertaken by the respondents themselves. However, the respondents will have to undertake this exercise within a reasonable period. 7. Accordingly, we direct the concerned respondent i.e., the 3rd respondent, to act on the order dated 24.10.2024 passed by the Customs, Excise and Service Tax Appellate Tribunal, and determine whether any refund with interest is required to be made to the petitioner or whether the petitioner is required to pay any amounts to the revenue together with interest. This exercise must be completed within three months from today, if necessary, after hearing the petitioner. In fact, we think that it would be better if the petitioner were heard so that the matter can be sorted out at the earliest. The 3rd respondent must communicate its decision to the petitioner within three months. 8. If, in terms of the decision so taken, any refund with interest is found to be due to the petitioner, then the same must be paid to the petitioner within a month of such decision. Similarly, the learned counsel for the petitioner, on instructions, states that if any amount, together with interest, is found to be payable by the petitioner to the respondents, the same will be paid within a month from the date of such communication. The learned counsel, however, clarifies that this shall be subject to any further 2026:JHHC:16767-DB 4 legal proceedings that the petitioner may wish to initiate in this matter, and to any interim relief that may be granted restraining the enforcement of such demand in the meantime. 9. We clarify that we have not examined the rival contentions on merits and, therefore, all contentions of all parties are left open to be decided by the 3rd respondent in the first instance. 10. This writ petition is disposed of in the above terms without any order for costs. (M. S. Sonak, C.J.) (Rajesh Shankar, J.) June 11, 2026 Manish/Ritesh Uploaded on 12.06.2026