118 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-16174-2026 (O&M) Date of Decision: 2nd July, 2026. M/S. SBP SHINESTAR PVT. LTD. .…...Petitioner(s) V/s THE EXCISE AND TAXATION OFFICER-CUM-STATE TAX OFFICER, MOHALI-WARD NO.2, EXCISE AND TAXATION BHAWAN, MOHALI ......Respondent(s) CORAM: HON'BLE THE ACTING CHIEF JUSTICE HON'BLE MR. JUSTICE ROHIT KAPOOR (Through Video Conference/Hybrid Mode) Present Mr. Vikrant Kackria, Advocate, for the appellants/petitioners. (appeared through VC) Ms. Samdisha Kaur, AAG, Punjab. **** ASHWANI KUMAR MISHRA, A.C.J. (Oral) 1. The present Writ Petition has been filed seeking quashing of order dated 05.06.2025 (Annexure P-1), issued by the respondent for recovery of tax demand amounting to `3,24,67,794/- from the petitioner for the financial year 2023-2024. 2. It is submitted that the impugned penalty has been imposed upon the petitioner without issuing any show cause notice or affording any opportunity of personal hearing, therefore, the impugned action of the respondent amounts to a violation of principles of natural justice. 3. Learned State counsel, who has appeared on advance notice SURESH KUMAR 2026.07.06 14:08 I attest to the accuracy and integrity of this document CWP-16174-2026 (O&M) does not dispute the factual aspects that neither any show cause notice was issued to the petitioner, nor any opportunity of personal hearing was afforded to the petitioner. Learned State counsel, therefore, states that the matter can be conveniently remitted back to the concerned authority, for conducting the proceedings afresh in accordance with law after affording an opportunity of personal hearing to the petitioner. 4. In view of the fair stand taken by the respondents, this matter is remitted back to the authority concerned, and the impugned order dated 05.06.2025 (Annexure P-1) is set aside. The respondents shall proceed afresh in accordance with law after affording an opportunity of personal hearing. It is further provided that no coercive action henceforth shall be taken in the matter and any recovery already made shall abide by the fresh orders to be passed in accordance with law. 5. Petition stands disposed of accordingly. 6. Pending applications, if any, in this case are disposed of accordingly. [ASHWANI KUMAR MISHRA] ACTING CHIEF JUSTICE [ROHIT KAPOOR] JUDGE July 2, 2026 Ess Kay Whether speaking / reasoned : Yes / No Whether Reportable : Yes / No SURESH KUMAR 2026.07.06 14:08 I attest to the accuracy and integrity of this document