TRANSFORMATIVE LEARNING SOLUTIONS PVT LTD vs COMMISSIONER CENTRAL GOODS AND SERVICE TAX DELHI EAST & ANR.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 24th September 2025 W.P.(C) 4987/2025 & CM APPL. 22937/2025 TRANSFORMATIVE LEARNING SOLUTIONS PVT LTD .....Petitioner Through: Mr. Rajat Mittal, Mr. Suprateek Neogi, Ms. Krati Agrawal, Mr. Subham Kumar & Mr. Priyanshu, Advs. versus COMMISSIONER CENTRAL GOODS AND SERVICE TAX DELHI EAST & ANR. .....Respondent Through: Mr. Anurag Ojha, SSC with Mr. Dipak Raj, Mr. Shashank Kumar, Mr. Karan Aggarwal & Ms. Priyatam Kumar, Advs CORAM: JUSTICE PRATHIBA M. SINGH JUSTICE SHAIL JAIN Prathiba M. Singh, J. (Oral) 1. This hearing has been done through hybrid mode. 2. The present petition has been filed, inter alia, challenging the impugned order dated 31st January, 2025 passed by the Additional Commissioner, Central Goods & Service Tax, Delhi East. Vide the impugned order the demand of Rs. 20,14,98,627/- along with interest and penalty of equivalent amount has been confirmed. Further, the Input Tax Credit (hereinafter “ITC”) to the tune of Rs. 29,33,217/- that had been reversed, has been appropriated. 3. It is stated by the Petitioner that it is engaged in the business of export 2024. One of the objections against which majority of the de