learned Senior Standing Counsel for Central Board of
Indirect Taxes and Customs (CBIC) appearing for
respondent No.3.
2. Petitioner-company is a registered tax payer having
GSTIN No:36AASCS5503K1ZW. It has been subjected
to the proceedings under Section 73 of the Central Goods
and Services Tax Act, 2017 (for short ‘CGST Act’) for the
financial year 2020-2021 vide show cause notice dated
27.11.2024, issued by Assistant Commissioner (CT),
Nampally-1 Circle, Hyderabad, in Form GST DRC-01.
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Thereafter, the order-in-original was passed on 28.02.2025,
by the Assistant Commissioner (ST) GST, Abids Division,
Hyderabad, respondent No.2, imposing liability of
Rs.96,30,225.26 ps. Petitioner has assailed it in the
instant writ petition on the ground that investigation, in
respect of availment of Input Tax Credit (ITC) by the
petitioner on invoices, without receipt of goods or services
from certain suppliers, was conducted and concluded by
respondent No.3- Additional Director, Director General
of GST Intelligence (DGGI), under the provisions of
Sections 74(5) and 74(6) of the CGST Act and the
corresponding provisions of Telangana Goods and
Services Tax Act, 2017 (for short ‘the TGST Act’), after
the petitioner paid GST of Rs.1,50,85,580/- along with
interest of Rs.41,33,682/- and penalty of Rs.22,62,838/-,
and submitted letters dated 29.12.2022, 08.03.2022,
01.12.2023 and 02.02.2024, to the Principal
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