M/S WALSONS SERVICES PVT. LTD. vs SALES TAX OFFICER/CLASS II (STO), DGST & ANR.

Judgment text excerpt

$~27 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 14th November, 2025 + W.P.(C) 16730/2025 & CM APPL. 68728/2025 M/S WALSONS SERVICES PVT. LTD. .....Petitioner Through: Mr. Akshay Allagh, Adv. versus SALES TAX OFFICER/CLASS II (STO), DGST & ANR. .....Respondents Through: Mr. Akshay Amritanshu, Senior Standing Counsel, Ms. Drishti Rawal, Mr. Mayur Goyal & Mr. Sarthak Srivastava, Advs. Ms. Vaishali Gupta & Ms. Ishika Baheti, Adv. for GNCTD. CORAM: JUSTICE PRATHIBA M. SINGH JUSTICE SHAIL JAIN JUDGMENT Prathiba M. Singh, J. 1. This hearing has been done through hybrid mode. 2. The Petitioner - Smt. Sunita Rani has filed the present Petition under Articles 226 and 227 of the Constitution of India, inter alia, challenging the impugned order dated 2nd August 2024, passed by the Assistant Commissioner, Ward 201, Zone-11, Delhi for the tax period April 2019 to March 2020 (hereinafter, ‘impugned order’). The Petitioner has also challenged the Show Cause Notice dated 29th May, 2024 passed by the Sales Tax Officer Class II/AVATO, Ward 201, Zone 11, Delhi (hereinafter, ‘impugned SCN’). Signature Not Verified Signed By:TANISHKA W.P.(C) 16730/2025 Page 1 of 9 GUPTA Signing Date:17.11.2025 17:09:10 3. Vide the impugned order, a tax demand of Rs. 44,84,321/- and a total demand to the tune of Rs. 86,63,462/- has been raised against the Petitioner. 4. Additionally, the present petition also challenges the vires of the following notifications: ● Notification No. 9/2023- Central Tax dated 31st March, 2023; ● Notification No. 56/2023- Central Tax dated 28th December, 2023; ● Notification No. 9/2023- State Tax dated 22nd June, 2023; ● Notification No. 56/2023- State Tax dated 11th July, 2024 (hereinafter, ‘the impugned notifications’). 5. The challenge in the present petition i