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

Judgment text excerpt

$~8 * 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 Signature Not Verified Digitally Signed By:KESHAV W.P.(C) 4987/2025 Page 1 of 7 Signing Date:26.09.2025 20:24:13 of Ayurvedic cosmetic goods. The background of the case giving rise to the present petition is that sometime in 2022, an audit of the Petitioner was conducted by the CGST Department for the period 2017-18 to 2021-22, on the basis of the documents submitted by the Petitioner. In the course of the said audit, certain objections were raised by the CGST Department including availing of ITC, which were communicated to the Petitioner Firm on 25th January, 2024 and 31st January, 2024. One of the objections against which majority of the dema