WRIT TAX No. 2097 of 2026 at Allahabad

HIGH COURT OF JUDICATURE AT ALLAHABAD WRIT TAX No. - 2097 of 2026 M/s Comfort Battery …..Petitioner(s) Versus Additional Commissioner Central Goods and Services Tax …..Respondent(s) Counsel for Petitioner(s) : Aditya Pandey, Himanshu Mishra Counsel for Respondent(s) : Priyanka Midha, Dhananjay Awasthi Court No. - 3 HON'BLE SAUMITRA DAYAL SINGH, J. HON'BLE SWARUPAMA CHATURVEDI, J. 1. Heard Sri Aditya Pandey, learned counsel for the petitioner, Ms. Priyanka Midha, learned counsel for the revenue and perused the record. 2. Present petition has been filed for the following relief: "I. Issue a suitable writ, order or direction in the nature of certiorari for quashing the impugned order dated 15.12.2025 passed by the respondent under section 74 of the UPGST/CGST Act for the F.Y. 2018-19 to 2022-23 (Annexure-1 to the writ petition). II. Issue a suitable writ, order or direction in the nature of certiorari for quashing the impugned notice dated 24.6.2025 was issued alongwith Form GST DRC-01 dated 26.6.2025 issued by the respondent (Annexure-2 to the writ petition)." 3. Submission is, in the show cause notice-DRC-01 in the column meant for specification of demand of penalty proposed to be c