135 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-16234-2026 (O&M) Date of Decision: 7th July, 2026. M/S SAPRA BROTHERS .…...Petitioner(s) V/s UNION OF INDIA AND OTHERS ......Respondent(s) CORAM: HON'BLE THE ACTING CHIEF JUSTICE HON'BLE MR. JUSTICE ROHIT KAPOOR Present Mr. Kshitij Sharma, Advocate, for the petitioner. Mr. Rishabh Kapoor, Senior Standing Counsel for the respondent-CGST. **** ASHWANI KUMAR MISHRA, A.C.J. (Oral) 1. The present Writ Petition has been filed by the petitioner seeking quashing of show cause notice dated 28.06.2024 (Annexure P-1) issued under Section 122 of the CGST/SGST/IGST Act and Form DRC-01 dated 18.10.2024 (Annexure P-2) issued by respondent No.2, and order dated 06.03.2026 (Annexure P-4) passed by respondent No.3, allegedly being passed in violation of principles of natural justice as the same was passed without affording any opportunity of personal hearing to the petitioner. 2. Learned counsel for the petitioner contends that the show‑cause notice dated 28.06.2024 was never served upon the petitioner through any prescribed mode, thereby depriving the petitioner of an opportunity to submit a reply. Subsequently, respondent No.2 issued order dated 18.10.2024 (DRC‑01), proposing a demand of ₹10,75,94,211/‑ solely on the ground that no reply to the show‑cause notice had been filed by the SURESH KUMAR 2026.07.13 16:44 I attest to the accuracy and integrity of this document CWP-16234-2026 (O&M) petitioner. He, therefore, prays that show cause notice dated 28.06.2024 and the consequential proceedings be set aside, and matter be remanded to the competent authority to pass a fresh order after affording an opportunity of personal hearing to the petitioner. 3. Learned counsel for the respondents, who has appeared on advance notice, does not dispute the factual aspect that opportunity of personal hearing has not been afforded to the petitioner. Learned counsel for the respondents, therefore, states that the matter can be conveniently remitted back to the concerned authority, for affording an opportunity of personal hearing to the petitioner to proceed afresh, in accordance with law. 4. In view of the fair stand taken by the respondents, this matter is remitted back to the authority concerned, and the impugned show cause notice dated 28.06.2024 (Annexure P-1) and consequential proceedings are set aside for such reasons. The respondents shall afford an opportunity of personal hearing to the petitioner, and they shall be at liberty to proceed further in accordance with law. 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, shall stand disposed of. [ASHWANI KUMAR MISHRA] ACTING CHIEF JUSTICE [ROHIT KAPOOR] JUDGE July 7, 2026 Ess Kay Whether speaking / reasoned : Yes / No Whether Reportable : Yes / No SURESH KUMAR 2026.07.13 16:44 I attest to the accuracy and integrity of this document