[2026:RJ-JP:23636-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 8486/2026 GVK Jaipur Expressway Pvt. Ltd., Toll Plaza At 286, Village Thikariya, Ajmer Road (NH-8) Jaipur 303007 Rajasthan (GSTIN 08AABCG5541J1Zk) Through Its Chief Financial Officer Shri Ravi Kumar Dharba, Aged About 62 Years, S/o Shri Subramanyam Gopalaiah, R/o Sri Nilayam, Street No. 8, Opp. Lane To Park No. 2, Gandhi Nagar, Secunderabad- 500080. ----Petitioner Versus 1. Deputy Commissioner Of State Tax, Zone-III, Kar Bhawan, Jhalana Institutional Area Jaipur Rajasthan. 2. State Of Rajasthan, Through The Chief Commissioner Of State Tax, Kar Bhawan, Ambedkar Circle, Jaipur. 3. Union Of India Through The Chairman, Central Board Of Indirect Taxes And Customs, North Block, New Delhi. ----Respondents For Petitioner(s) : Mr. N.K. Jain with Mr. Rohan Chatter and Ms. Satvika Jha For Respondent(s) : Ms. Mahi Yadav, AAG with Mr. Rohan Mittal and Mr. Arun Kumar HON'BLE THE ACTING CHIEF JUSTICE MR. SANJEEV PRAKASH SHARMA HON'BLE MR. JUSTICE MANEESH SHARMA Order 29/06/2026 1. The issue raised in the present writ petition has already been examined by us relating to the same petitioner for the year 2018- 19, whereas, the present petition is with regard to the year 2019- 20, this Court earlier passed following order:- “1. The petitioner before us was issued GST DRC-07 order on 29.02.2024 and a demand was raised for Rs.3.39 crores. In the order it was specifically found that the taxpayer did not discharge due GST liability through DRC-13 for the year 2018- 19 and accordingly, the demand as well as interest and penalty was imposed. The order was not challenged by the petitioner in appeal, therefore, vide order dated 19.12.2025, [2026:RJ-JP:23636-DB] (2 of 2) [CW-8486/2026] against the total demand including the tax and interest of Rs.14,06,54,640/-, the account of the petitioner was attached. 2. Learned counsel for the petitioner submits that the petitioner did not come to know about the orders passed by the GST Authorities and has vaguely averred in his petition without any documentary proof that the show cause notice as well as DRC-07 orders were not properly communicated and placed on the GST Portal. It is stated that the same was communicated on the main dashboard of the Portal, although no documentary proof in this regard has been filed. 4. Learned counsel for the petitioner also relies on the judgment passed by this Court in D.B. Civil Writ Petition No.15466/2025 (Eagle Trans Shipping and Logistics India Private Ltd. Vs. Union of India & Ors.) dated 06.11.2025 wherein, this Court allowed the petitioner to file appeal holding that a person cannot be left remediless, if the time period of filing of appeal has expired and there are valid reasons for the delay in filing of appeal. 5. In the present case however, we find that the said judgment would have no application to the present case. In the facts of the present case, neither an appeal has been filed nor an attempt has been made to file an appeal. In fact, the petitioner has moved a rectification application only for seeking rectification of the order. Thus, we do not find that contentions of the petitioner having no knowledge of the order or the show cause notice are correct. It appears that there has been a deliberate ignorance shown towards the show cause notice and the order because it is not possible for a company not to have known about the order passed under Section 74 of the RGST/CGST Act, 2017 (for short 'the Act of 2017'), more so, as it continues to hold the GST number and would, therefore, be filing regular monthly returns. Annual returns. are also required to be filed as per the Act of 2017. In these circumstances, we are unable to accept the contentions of the petitioner that it had no knowledge of the orders being passed for show cause notice and it is only thereafter the bank account has been attached that the petitioner has approached this Court. Equity, therefore, does not lie in its favor. On facts, we find that that the petitioner does not deserve any indulgence. 6. The petition is, accordingly, dismissed. Pending application, if any, also stands dismissed.” 2. The present writ petition accordingly stands dismissed mutadis mutandis. 3. All pending applications also stand disposed of. (MANEESH SHARMA),J (SANJEEV PRAKASH SHARMA),ACTING CJ GAURAV/DIKSHA/12