M/S. Magnum Estates Private Limited vs Additional Commissioner on 15 July, 2026

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    Orissa High Court

    M/S. Magnum Estates Private Limited vs Additional Commissioner on 15 July, 2026

                   ORISSA HIGH COURT : CUTTACK
    
                       W.P.(C) No.34660 of 2025
    
                  In the matter of an Application under
         Articles 226 and 227 of the Constitution of India, 1950
    
                                 ***
    

    M/s. Magnum Estates Private Limited
    (A company registered under
    the Companies Act)
    represented by its
    Executive Director
    Sri C.V. Padmarajan
    Aged about 80 years
    Son of Late C.V. Kelappan
    At: Sector-A, Zone-A, Plot No.132-A
    Mancheswar Industrial Estate
    Mancheswar, Bhubaneswar
    Odisha – 751 010. … Petitioner

    -VERSUS-

    SPONSORED

    1. Additional Commissioner, GST (Appeals)
    At: Central Excise & Customs
    Central Revenue Building, Rajaswa Vihar
    Bhubaneswar-7, Odisha.

    2. Superintendent
    CGST & Central Excise Balasore-1 Range
    At: White House Lane
    Balasore – 756 001.

    3. Superintendent
    Jajpur Audit Circle, GST &
    Central Excise Audit Commissionerate
    At: The Principal Commissioner (Audit)

    W.P.(C) No.34660 of 2025 Page 1 of 14
    Central GST & Cx, Central Revenue Building
    Rajaswa Vihar
    Bhubaneswar – 751 007
    Odisha. … Opposite parties.

    Counsel appeared for the parties:

    For the Petitioner : Ms. Kajal Sahoo,
    M/s. Ronit Ghosh, Subhajeet Sahu,
    Urmila Sahoo, Romeet Panigtrahi,
    Deepshikha Mallik, Advocates.

    For the Opposite parties : Avinash Kedia,
    Junior Standing Counsel
    (CGST, CEx & Customs)

    P R E S E N T:

    HONOURABLE CHIEF JUSTICE
    MR. HARISH TANDON

    AND

    HONOURABLE JUSTICE
    MR. MURAHARI SRI RAMAN

    Date of Hearing : 30.06.2026 :: Date of Order : 15.07.2026

    O RDER

    Questioning the legality, rationality and propriety of
    Order dated 29.09.2025 passed by the Additional
    Commissioner, GST (Appeal) under Section 107 of the
    Central Goods and Services Tax Act, 2017/the Odisha
    Goods and Services Tax Act, 2017
    (collectively be
    referred to as “GST Act”, for convenience) refusing to
    interfere in the challenge as to authority and rationality

    W.P.(C) No.34660 of 2025 Page 2 of 14
    in levying interest and imposition of penalty thereon
    while undertaking adjudication process under Section
    73 of the GST Act pertaining Financial Year 2017-18 by
    the Superintendent, CGST & Central Excise, Balasore-I
    Range, Balasore vide Order dated 15.12.2023, the
    petitioner has come up before this Court invoking
    extraordinary jurisdiction under Articles 226 and 227 of
    the Constitution of India for grant of following relief(s):

    “Under the aforesaid circumstances it is prayed that this
    Hon‟ble Court may be graciously pleased to:

    (a) Admit the writ application;

    (b) Issue rule nisi calling upon the 0pp. Party No. 1 as to
    why order dated 29.09.2025 purportedly passed
    under Section 107 of the OGST/CGST Act vide
    Annexure-4 contrary to provisions of the
    OGST/CGST Act shall not be quashed being illegal,
    arbitrary, without jurisdiction and in violation of
    natural justice and unsustainable in law;

    (c) To refund the pre-deposit of Rs.18,710/- paid during
    the filing of Appeal which is in contravention to the
    provisions of Section l07(6)(b) of the CGST/OGST
    Act, 2017 in the end of justice:

    (d) If the opposite party do not show cause or shows
    insufficient cause make the rule absolute;

    (e) To issue writ in the nature of mandamus or any
    other appropriate writ directing the opposite parties
    to quash Order dated 29.09.2025 passed by the
    opposite party No.1 vide Annexure-4 in the end of
    justice;

    W.P.(C) No.34660 of 2025 Page 3 of 14

    (f) To pass such order/orders, direction/directions,
    writ/writs as may be deemed fit and proper in the
    circumstances of the case;

    (g) To allow the writ petition;

    And for this act of kindness the petitioner shall as in duty
    bound and ever pray.”

    2. The petitioner, a company carrying on its business being
    assigned with registration under the GST Act, in an
    audit under Section 65 read with Rule 101 of the Central
    Goods and Services Tax Rules, 2017/the Odisha Goods
    and Services Tax Rules, 2017 (collectively, „GST Rules”)
    found to have availed input tax credit to the tune of
    Rs.6,08,455/- with respect to supply of exempted goods
    during the Financial Year 2017-18. The petitioner
    reversed an amount of Rs.1,77,136/- on 15.01.2020
    through DRC-03 and rest amount out of total sum of
    Rs.6,08,455/- was reversed in the return vide GSTR-3B
    filed in respect of tax period October, 2019.

    2.1. The audit pointed out that the petitioner is liable to pay
    an amount of Rs.1,87,093/- towards interest for delayed
    reversal of amount of input tax credit with penal
    consequences to be adjudicated upon under Section 73
    of the GST Act. Accordingly a show cause notice being
    issued on 28.04.2023, the petitioner participating before
    the authority concerned explained that the objection
    raised in the audit is untenable and is liable to be
    dropped. Notwithstanding such explanation of the
    W.P.(C) No.34660 of 2025 Page 4 of 14
    petitioner, the Adjudicating Authority proceeded to raise
    demand towards penalty of Rs.60,845/- besides interest
    for an amount of Rs.1,87,093/-.

    2.2. The petitioner filed appeal under Section 107 of the GST
    Act which came to be dismissed by Order dated
    29.09.2025.

    2.3. Said Order of the Appellate Authority affirming the Order
    of the Adjudicating Authority is subject-matter of
    challenge in the present writ application.

    3. Ms. Kajal Sahoo, learned Advocate representing the
    petitioner, submitted that the erroneous perception of
    the authorities concerned has compelled the petitioner
    to circumvent the alternative remedial forum and
    approach this Court invoking Article 226 of the
    Constitution of India inasmuch as it is only when the
    registered person avails and utilises the input tax credit
    which is found to have been erroneously claimed interest
    under Section 50(3) of the GST Act would attract. It is
    further submitted that in view of subsequent
    amendment carried in the GST Act by way of insertion of
    Section 128A, the interest and the penalty demanded in
    the adjudication process under Section 73 relating to
    Financial Year 2017-18 has been waived.

    3.1. Referring to certain decisions Ms. Kajal Sahoo, learned
    Advocate strenuously argued that the Appellate

    W.P.(C) No.34660 of 2025 Page 5 of 14
    Authority failed to address the issue raised by the
    petitioner before him and upon erroneous reading of
    provisions of the statute ignored to appreciate that if a
    taxable person has allegedly delayed in filing his return,
    but discharges the liability of only tax on his own
    ascertainment and does not discharge the liability of
    interest, the only recourse available for the Proper
    Officer would be to initiate proceedings under Section
    73(1) of the GST Act for recovery of the amount of “short
    paid” or “not paid” interest on the tax amount. Contrary
    to mandate of statute and interpretation on the point set
    forth by various Courts, the Appellate Authority having
    dismissed the appeal the order impugned would be
    amenable to judicial review under Article 226 of the
    Constitution of India in view of parameters for
    entertainment of writ petition laid down in Larsen and
    Toubro Ltd. Vrs. State of Odisha, (1998) 111 STC 75 (Ori);
    and Sonik Electrochem (P) Ltd. Vrs. State of Orissa, (1994)
    92 STC 117 (Ori).

    3.2. Laying stress upon the discussion made in Hindustan
    Steel Ltd. Vrs. State of Odisha, (1970) 25 STC 211 (SC)
    and Commissioner of Sales Tax Vrs. Sanjiv Fabrics,
    (2010) 35 VST 1 (SC) Ms. Kajal Sahoo, learned Advocate
    would submit that since the petitioner, upon being
    pointed out during the course of audit, voluntarily took
    steps to restore the input tax credit, the imposition of
    penalty is liable to be struck off.

    W.P.(C) No.34660 of 2025 Page 6 of 14

    4. Sri Avinash Kedia, learned Junior Standing Counsel
    appearing for the opposite parties raising strong
    objection against entertainment of writ petition in view of
    Commissioner of Income Tax Vrs. Chhabil Dass Agarwal,
    (2014) 1 SCC 603, Southern Electricity Supply Co. of
    Orissa Ltd. Vrs. Sri Seetaram Rice Mill, (2012) 2 SCC 108;
    Maharashtra Chess Association Vrs. Union of India,
    (2020) 13 SCC 285 would submit that if the exercise of
    jurisdiction by the Appellate Authority ex facie appears
    to be in futility, then this Court would be justified to
    interfere with the order of the statutory authority under
    Article 226, but whereas in the present case the
    petitioner has efficacious alternative remedy available
    and unless it exhausts such remedy, this Court may not
    entertain this writ petition to consider the factual
    dispute set out whether there was wrong availment of
    input tax credit so that provisions of Section 50(3) of the
    GST Act would attract coupled with imposition of
    penalty. It is, therefore, submitted that once the
    petitioner has chosen to approach the Appellate Forum
    provided under the GST Act, the recourse to alternative
    remedy provided under the statute to maintain further
    proceeding therein should be availed of; not otherwise.

    5. Heard arguments advanced by the learned counsel
    appearing for the respective parties and given our
    anxious consideration to the contentions raised by both
    the sides. This Court is convinced that disputed
    W.P.(C) No.34660 of 2025 Page 7 of 14
    question of fact is to be settled by the fact-finding
    authorities in terms of provisions of the GST Act. The
    wrong claim of input tax credit stated to have been
    restored by way of disclosing in DRC-03 and Form
    GSTR-3B is required to be verified and examined by the
    authorities empowered under the said statute. We have
    no occasion to verify such documents as the same are
    not made part of writ petition. Such factual position as
    claimed by the petitioner is also subject to thorough
    examination with reference to the books of account vis-a-
    vis evidence available on record and/or demonstrated by
    the petitioner by adducing such evidence as it may think
    proper.

    6. Though this Court is persuaded to consider that the GST
    Appellate Tribunal can adjudicate the correctness of
    demand raised by levying interest and legal justification
    to impose penalty by instituting proceeding under
    Section 73 of the GST Act, another significant fact which
    brought to the notice by the learned counsel for the
    petitioner is that relegating it to prefer appeal under
    Section 112 of the GST Act would tantamount to
    discharge the obligation which is contrary to statutory
    requirement.

    6.1. Elaborating her argument, Ms. Kajal Sahoo, learned
    Advocate submitted that the Appellate Authority having
    not rectified the defective recording of figures in the

    W.P.(C) No.34660 of 2025 Page 8 of 14
    Order-in-Original the petitioner is obligated to make
    further deposit in terms of Section 112(8)1 of the GST
    Act for filing of appeal before the GST Appellate Tribunal.

    6.2. The Show Cause Notice dated 28.04.2023 (Annexure-1)
    reveals that:

    “However, the noticee the reversed ITC of Rs.1,77,136
    (IGST) out of total ineligible ITC of Rs.6,08.455/- vide
    Form DRC-03 Debit entry No. DC2101200032828 dated
    15.01.2020 and the remaining ITC of Rs.4,31,319/- is
    stated to have been reversed in Form GSTR-3B for the tax
    period October, 2019. In this regard, a copy of Letter
    No.MEL/GST/21-22/07, dated 26th April, 2021 is
    enclosed as Annexure-I. The notice thus, is required to
    pay interest for late reversal of such credit under Section
    50(1)
    of the CGST Act, 2017 read with Section 20(xxv) of
    the GST Act, 2017.”

    6.3. The Order-in-Original, dated 15.12.2023 was passed by
    the Superintendent, CGST & Central Excise, Balasore-I
    Range, Balasore with the following order:

    “9.0. In view of the above discussion and findings, I pass
    the following order:

    Order

    1 Sub-section (8) of Section 112 of the GST Act reads thus:

    “(8) No appeal shall be filed under sub-section (1), unless the appellant has
    paid–

    (a) in full, such part of the amount of tax, interest, fine, fee and penalty
    arising from the impugned order, as is admitted by him; and

    (b) a sum equal to ten per cent. of the remaining amount of tax in dispute, in
    addition to the amount paid under sub-section (6) of Section 107, arising
    from the said order, subject to a maximum of twenty crore rupees, in
    relation to which the appeal has been filed.”

    W.P.(C) No.34660 of 2025 Page 9 of 14

    (i) I charge and order for recovery of interest of
    Rs1,87,093/- (Rupees One Lakh Eighty-Seven
    Thousand Ninety-three Only) (IGST: Rs.1,87,093/-)
    for the F.Y. 2017-18, in terms of Section 73(9) read
    with Section 50 of the CGST/OGST Act, 2017 read
    with Section 20(xxv) of IGST Act, 2017.

    (ii) Since the said noticee voluntarily paid/reversed
    Rs.4,805/- (Rupees thousand eight hundred and
    five) only through DRC-03 [Debit entry Sl No.
    DC2106210040487 dt 29 06.2021]. I order for
    appropriation of the said amount towards payment
    of interest charged and confirmed at sl. No.(i) above.

    (iii) I hereby impose penalty of Rs.60,845/ (Rupees
    Sixty Thousand Eight Hundred Forty Five) only
    being equivalent to 10% of wrongly availed ITC
    (availed ITC of Rs.6,08,4S5/- (IGST head), but
    subsequently reversed] whichever is higher, upon
    the noticee under Section 73(9) of the CGST/OGST
    Act, 2017 read with Section 20(xxv) of the IGST Act,
    2017.”

    6.4. It is apparent from the above that the liability of the
    petitioner under Section 73 has been determined by
    raising demand in respect of voluntary reversal of input
    tax credit, interest and penalty. They do not involve
    component of disputed tax. Nevertheless, the Form GST
    DRC-07 dated 18.02.2023 reflects as follows:

    Sr. Tax Turno Plac Act Tax/ Inte Pen Fee Oth Total
    No. rate ver e of cess rest alty ers
    (%) supp
    ly
    1 18 794,4 Odis IGS 187, 0.0 60,8 0.0 0.00 247,
    59,53 ha T 093. 0 45.0 0 938.

    9.00 00 0 00

    W.P.(C) No.34660 of 2025 Page 10 of 14

    6.5. Ex facie it is discernible from the above table that
    amount of Rs.1,87,093/- demanded towards “Interest”

    vide Form GST DRC-07 has been shown under the
    heading “Tax”. It was submitted that due to such
    apparent mistake in the adjudication order, which the
    Appellate Authority failed to diligently perceive while
    disposing of appeal under Section 107 of the GST Act,
    the petitioner is put to prejudice. In order to file appeal
    before the Goods and Services Tax Appellate Tribunal
    assailing the Appellate Order, the petitioner is required
    to make deposits in terms of Section 112(8) of the GST
    Act. The deposit contemplated under said sub-section
    does not encompass amount towards interest or penalty,
    rather the petitioner is required to make pre-deposit
    towards “remaining amount of tax in dispute”. It is
    vehemently contended by Ms. Kajal Sahoo, learned
    Advocate that serious prejudice would be caused if the
    petitioner is relegated to approach the Goods and
    Services Tax Appellate Tribunal as Sri Avinash Kedia,
    learned Junior Standing Counsel expressed that there is
    no provision for the Appellate Authority to recall the
    Order-in-Appeal as the appeal has been rejected on
    merit on 29.09.2025.

    6.6. This Court perceived that if the petitioner is directed to
    avail the alternative remedy available under Section 112,
    justice would not be subserved. A bare perusal of Show

    W.P.(C) No.34660 of 2025 Page 11 of 14
    Cause Notice, Order-in-Original and the Order-in-Appeal
    clearly evince that the demand of reversal of input tax
    credit, interest and penalty raised in the Order-in-
    Original has been confirmed in the appeal under Section
    107 of the GST Act.

    6.7. It is brought to the notice of this Court by the learned
    Junior Standing Counsel appearing for respective parties
    that during pendency of the writ petition, being filed on
    27.11.2026, exercising power under Section 161 of the
    GST Act, a Rectified Order-in-Original has been passed
    on 28.01.2026 by the Superintendent of CGST & Central
    Excise, with the following conclusion:

    “In exercise of the powers conferred under Section 161 of
    the CGST/OGST Act, 2017, I hereby rectify the error in
    Form GST DRC-07. The demand of Rs.1,87,093/- is
    hereby reclassified from the head of „Tax‟ to „Interest‟. A
    summary of this rectification is being issued in Form GST
    DRC-08 accordingly. The total amount remains
    unchanged. The interest and penalty components shall
    remain as originally adjudicated. This rectification is
    issued solely to correct the head of account from „Tax‟ to
    „Interest‟ as per the directions of the Hon‟ble High Court of
    Orissa.2″

    2 This Court vide Order dated 15.01.2026, while considering the contentions and
    submissions of learned Advocate for the petitioner, directed as follows:

    “It is pointed out by Ms. Kajal Sahoo, learned Advocate that the impugned order
    under challenge is relating to demand pertaining to interest amounting
    Rs.1,87,093/-. However, while entering the figure in Form GST DRC-07, it is
    reflected as IGST.

    Apparently, mistake has crept in, which needed rectification by the Department
    suo motu.

    At the request of Mr. Kedia, learned Junior Standing Counsel for the Department,
    list this matter on 22nd January, 2026, enabling him to obtain instruction(s).”

    W.P.(C) No.34660 of 2025 Page 12 of 14

    6.8. Opposing entertainment of writ petition, it is submitted
    by the learned Junior Standing Counsel that now that
    the Adjudication Order is rectified suitably, the
    petitioner can approach the Appellate Tribunal. On the
    query from the Bench that the Appellate Authority is
    required to modify his Order-in-Appeal by rectifying his
    order suo motu in order to facilitate the petitioner to file
    appeal under Section 112, he expressed inability as
    period of limitation for such action by the Appellate
    Authority under Section 161 has already lapsed.

    6.9. Ms. Kajal Sahoo, learned Advocate argued that since the
    Appellate Authority is not in a position to rectify such
    mistake in tune with Rectified Order-in-Original dated
    28.01.2026, attempts to file the appeal before the Goods
    and Services Appellate Tribunal would be futile
    inasmuch as the online system of filing of appeal would
    not allow the petitioner to do so without pre-deposit
    (percentage of remaining amount of tax) being made
    under sub-section (8) of Section 112 of the GST Act. If
    the petitioner is directed to avail remedy of appeal, then
    it would be mandatory requirement to deposit ten
    percent of “interest” component which is wrongly
    affirmed in the Appeal as if it is forming part of “Tax”.
    Learned Junior Standing Counsel has conceded to such
    submission.

    W.P.(C) No.34660 of 2025 Page 13 of 14

    6.10. Faced with such situation, this Court is, therefore,
    inclined to interfere with the Order-in-Appeal dated
    29.09.2025 passed by the Additional Commissioner of
    GST (Appeal) in Appeal bearing No.391/BBSR-
    GST/APPEAL/2024.

    7. Under the above premises, the Order-in-Appeal dated
    29.09.2025 passed by the Additional Commissioner of
    GST (Appeal) in Appeal bearing No.391/BBSR-
    GST/APPEAL/2024 is set aside and the matter is
    remitted to the Appellate Authority for deciding the
    appeal on merit afresh without being swayed away by
    earlier order and pass appropriate order in accordance
    with law after hearing the petitioner.

    8. In the result, the writ petition including pending
    Interlocutory Application(s), if any, stands disposed of.

    (HARISH TANDON)
    CHIEF JUSTICE

    (MURAHARI SRI RAMAN)
    JUDGE

    Signature Not
    Verified
    Digitally Signed
    Signed by: ASWINI KUMAR
    SETHY
    Designation: Personal
    Assistant (Secretary in High Court of Orissa, Cuttack
    charge)
    Reason: Authentication The 15th July, 2026//Aswini/Laxmikant
    Location: ORISSA HIGH
    COURT, CUTTACK
    Date: 15-Jul-2026 16:38:17
    W.P.(C) No.34660 of 2025 Page 14 of 14



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