1 2026:CGHC:19010 NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR WPT No. 161 of 2021  M/s Yash Construction And Supplier Near Deshbandhu Deshbandhu English School Building, Station Road, Raipur Chhattisgarh Through Proprietor Sh. Subhash Agrawal S/o Sh. Puran Lal Agrawal, Aged About 50 Years, R/o 17/115, Nehar Para, Near Deshbandhu English School Building, Station Road, Raipur Chhattisgarh ... Petitioner(s) versus 1. Designated Committee Central Goods And Service Tax, Central Excise Building Tikra Para, Dhamtari Road Raipur (Chhattisgarh) 2. Principal Commissioner Central Goods And Service Tax, Central Excise Building Tikra Para, Dhamtari Road Raipur (Chhattisgarh) 3. Joint Commissioner C G S T Central Excise Building, Tikra Para, Dhamtari Road, Raipur (Chhattisgarh) 4. Assistant Commissioner C G S T Central Revenue Building, Civil Lines, Raipur (Chhattisgarh) 5. Union Of India Through Secretary, Department Of Revenue, Ministry Of Finance Department Of Revenue Room No. 46, North Block New Delhi 110001 ... Respondent(s) For Petitioner : Mr. Hari Agrawal, Advocate For Respondent No. 1 to 4 : Mr. A.S. Kachhwaha, Advocate For UOI/ Respondent No. 5 : Mr. Abhishek Banjare, CGC Hon’ble Shri Justice Rakesh Mohan Pandey Order On Board Digitally signed by AJINKYA PANSARE Date: 2026.04.25 10:36:18 +0530 2 24.4.2026 1) By way of this petition, petitioner has sought following reliefs:- 10.1. The Hon'ble Court may kindly be pleased to call for entire records of the case; and 10.2. The Hon'ble Court may kindly be pleased to quash the impugned circular dated 25.09.2019, clause (iv) (Annexure P-16), and 10.3. The Hon'ble Court may kindly be pleased to hold SVLDRS Form -3 (Annexure P-12) as illegal and may be pleased to direct the respondent to issue SVLDRS-3 in accordance with Section 124(1)(c) in the same way as issued in cases falling under category of Litigation; and 10.4. The Hon'ble Court may kindly be pleased to quash the impugned notice dated 07.07.2021 (Annexure P-15). 10.5. Any other relief, which this Hon'ble Court deems fit and proper, may also be awarded to the Petitioner including the cost of the petition. 2) Mr. Hari Agrawal, learned counsel for the petitioner submits that petitioner who is a proprietorship firm engaged in construction and related activities was subjected to a show-cause notice on 29.3.2011 by respondent authorities alleging evasion of service tax and consequently, a demand notice of Rs. 7,97,773.20/- was issued under SVLDR Scheme. He further submits that this demand was increased to Rs. 15,49,005.60/- vide demand notice dated 18.5.2020 and same is under challenge in this petition. He contends that petitioner is ready to comply with the revised demand raised by the respondent authorities and direction may be issued to respondent authorities to accept the amount mentioned 3 in notice dated 18.5.2020. 3) Mr. A.S. Kachhwaha, learned counsel appearing for the respondent No. 1 to 4 submits that department has no objection to petitioner depositing the enhanced tax amount pursuant to demand notice dated 18.5.2020 and department would take appropriate decision in this regard. 4) Heard. 5) Taking into consideration the above-discussed facts, petitioner is permitted to deposit the revised tax amount mentioned in demand notice dated 18.5.2020. It is directed that if petitioner deposits the tax amount as per demand notice dated 18.5.2020, respondents No. 1 to 4 shall decide this issued in accordance with law. At the same time, petitioner would be at liberty to make a representation before respondent authorities, who in turn are directed to consider such representation, if so moved by petitioner and pass appropriate order(s) accordingly. 6) With the aforesaid observation(s) and direction(s), this petition stands disposed. It is made clear that this Court has not expressed any opinion on the merits of case. Sd/- (Rakesh Mohan Pandey) JUDGE A j i n k y a