. HIGH COURT OF JUDICATURE AT ALLAHABAD WRIT TAX No. - 1715 of 2026 . Court No. - 3 HON'BLE SAUMITRA DAYAL SINGH, J. HON'BLE SWARUPAMA CHATURVEDI, J. 1. Heard Sri Bharat Bhushan along with Sri Ami Tandon, learned counsel for the petitioner and Sri Dhananjay Awasthi and Sri Sanjai Kumar Om, learned counsel for the revenue. 2. By a separate order passed in M/S Shankar Trading Company Vs. Union Of India And 3 Others, 2026:AHC:102564-DB, we have disposed of the writ petition filed by the co-noticees on the following terms:- "(i) The impugned order dated 22.12.2025 is set aside and the matter is remitted to the adjudicating authority to pass a fresh order. (ii) For that purpose, the Adjudicating Authority may issue to the petitioner, a fresh copy of the original Show-Cause notice together with copies of RUDs and a list of non-RUDs. That compliance may be made within a period of two weeks from today. (iii) Upon receipt of such communication, the petitioner may apply to the Adjudicating Authority to be supplied any other Versus Counsel for Petitioner(s) : Ami Tandon Counsel for Respondent(s) : A.S.G.I., Dhananjay Awasthi, Gaurav Bishan M/S. Divya Laxmi Trading And Co. .....Petitioner(s) Union Of India And 3 Others .....Respondent(s) document including copies of non-RUDs, within a further period of one week therefrom. (iv) Subject to such compliance, the application moved by the petitioner may be considered by the Adjudicating Authority within a further period of one week. Copies of all other documents to be supplied to the petitioner may be made available within that time. If copy of any document or non-RUD, is to be declined, adequate reasons may be communicated to the petitioner, within that time. (v) Thereafter, the Adjudicating Authority may fix appropriate date in the proceeding with at least 15 days advance notice. The petitioner undertakes to cooperate in the proceedings and not seek any undue or long adjournment. (vi) At that stage, if the revenue seeks to rely on statement of any person, recorded during investigation etc., the same would necessarily be made available to the petitioner on the date fixed in the proceedings. On that date itself, the petitioner may apply for opportunity to cross-examine any witness being relied by the revenue. (vii) Wherever the revenue seeks to rely on adverse statement made against the petitioner, normally opportunity of cross- examination, if prayed for, may be allowed to the petitioner. If such opportunity is to be declined, adequate reasons for the same may be communicated to the petitioner within a week of its application. (viii) Accordingly, the proceedings may continue such that the same may be concluded within a period of six months from today, after affording due opportunity of personal hearing to the petitioner." 3. Though, ground of arrest is not being pressed in the present case, insofar as denial of opportunity of hearing and recording of reasons are concerned, similar grounds have been pressed in the present case. Further, it has been WTAX No. 1715 of 2026 2 stressed that the RUDs were not made available to the petitioner before the adjudicating proceedings were concluded. Also other grounds have been pressed to doubt the credibility of the material relied by the revenue. 4. In view of the similar facts, present petition is also disposed of on the same terms. May 5, 2026 #Vikram/- WTAX No. 1715 of 2026 3 (Swarupama Chaturvedi,J.) (Saumitra Dayal Singh,J.) Digitally signed by :- VIKRAM GUPTA High Court of Judicature at Allahabad