KURLON RETAIL LIMITED vs SALES TAX OFFICER & ORS.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision: 28th August, 2025 W.P.(C) 13121/2025, CM APPL. 53682/2025 & CM APPL. 53683/2025 KURLON RETAIL LIMITED .....Petitioner Through: Mr. Manish Mishra, Ms. Joybrata Misra and Mr. Sameer Samal, Advs. versus SALES TAX OFFICER & ORS. .....Respondents Through: Mr. Sumit K. Batra, Adv. CORAM: JUSTICE PRATHIBA M. SINGH JUSTICE SHAIL JAIN JUDGMENT Prathiba M. Singh, J. 1. This hearing has been done through hybrid mode. 2. The present petition has been filed, inter alia, challenging the impugned order dated 21st August, 2024 passed in respect of Financial Year 2019-20 by the office of Sales Tax Officer Class II/ AVATO, Delhi, raising a demand of Rs. 31,58,436/- under the head of ‘net access ITC availed’. The petition also challenges the vires of Notification No. 56/2023-Central Tax dated 28th December, 2023 and Notification No. 56/2023-State Tax dated 7th July, 2024 (hereinafter ‘impugned notifications’). 3. The validity of the impugned notifications was under consideration before this Court in a batch of petitions with the lead petition being W.P.(C) 4. Submissions have been heard in part. The broad challenge to both sets of Notification