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Bombay High Court
Globeop Financial Services India … vs Deputy Commissioner Of State Tax, Mum … on 30 June, 2025
Author: M. S. Sonak
Bench: M. S. Sonak
2025:BHC-OS:10125-DB
Sayyed 21-WP(L).12528.2025.(J).docx
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
WRIT PETITION (L) NO.12528 OF 2025
GlobeOp Financial Services (India)
Private Limited (Surviving entity after
merger of GlobeOp Financial Services
Technologies (India) Private Limited with
GlobeOp Financial Services (India) Private
Limited, effective from 01.02.2022
A company incorporated under the laws
of India, having its registered office at
5th Floor, 501/502, Interface Building
No.16, Malad West, Mumbai Suburban,
Maharashtra - 400 064 ...Petitioner
Versus
1. Deputy Commissioner of State Tax,
(MUM-NOD-E-0901), Malad_West_
501, Nodal-09, Mumbai,
Old Building, Cabin No.C-14,
5th Floor, GST Bhavan, Mazgaon,
Mumbai - 400 010
2. State of Maharashtra,
Through the Commissioner of State
Tax, GST Bhavan, Balwant Singh
Dodhi Marg, Mazgaon,
Mumbai - 400 010
3. Union of India,
Ministry of Finance,
Department of Revenue through
the Secretary (Revenue), North
Block, New Delhi - 110 001 ...Respondents
_____________________________________________________
Mr. Rohan Shah, Senior Advocate a/w Mr. Mohammed Anajwalla,
Ms. Chandni Tanna & Mr. Prathamesh Chavan i/b. India Law Alliance
for the Petitioner.
Ms. Prachi Tatake, Addl. G. P. for Respondent No.1.
Ms. Shruti Vyas a/w Ms. Suman Kumar Das for Respondent No.3.
_____________________________________________________
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CORAM : M. S. Sonak &
Jitendra Jain, JJ.
DATED : 30 June 2025
ORAL JUDGMENT:-(Per M. S. Sonak, J.)
1. Heard learned counsel for the parties.
2. Rule. The Rule is made returnable immediately at the request
of and with the consent of the learned counsel for the parties.
3. This petition challenges the impugned order dated 24
February 2025, issued by the First Respondent, to the extent that it
confirms the GST demand of Rs.
Rs 70,57,98,2018/- for the period April
2020 – March 2021.
4. Mr. Shah, learned senior advocate for the Petitioner, at the
outset submitted that the impugned order is vitiated by non-application
of mind, non-consideration of detailed submissions canvassed by the
Petitioner in its replies dated 27 January 2025 and 6 February 2025. He
pointed out that the so-called reasoning in the impugned order is a
verbatim copy of the statements in the show cause notice dated
28 November 2024 at Exhibit-S. He handed in the chart to demonstrate
that the so-called reasoning and findings are nothing but an exercise of
cutting and pasting statements from the show cause notice. On this
ground, Mr. Shah urged that the impugned order may be quashed and
set aside without relegating the Petitioner to avail up the alternate
remedy.
5. Ms. Tatake and Ms. Vyas submit that the above ground is not
raised in the petition. They submit that the entire reply of the Petitioner
has been reproduced and considered in the impugned order. Therefore,
they submit that this is not a case of non-application of mind or passing
of an unreasoned order.
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6. Ms. Tatake and Ms. Vyas submit that the Petitioner has already
preferred an appeal against an earlier order dated 1 April 2022 denying
the Petitioner the refunds claimed. Therefore, they submit that the
Petitioner should have followed the same course in this matter instead
of challenging the impugned order directly before this Court.
7. The rival contentions now fall for our determination.
8. With the assistance of the learned counsel for the parties, we
have perused the show cause notice dated 28 November 2024 and the
replies filed by the Petitioner on 27 January 2025 and 6 February 2025,
and the impugned order dated 24 February 2025. On a perusal of all
these, we are satisfied that the adjudicating authority has failed to
independently apply its mind to the various contentions raised in the
replies filed on behalf of the Petitioner. Instead, the adjudicating
authority has chosen to copy or rather cut and paste verbatim the
allegations in the show cause notice dated 28 November 2024 to pass
them of as reasons supporting the impugned order.
9. Mr. Shah handed in a chart, which establishes the above
referred “cut and paste exercise”. The comparative chart is transcribed
below for the convenience of reference:-
Allegations in the Show Cause Findings in the Impugned Order
Notice dated 28.11.2024 (387) Ex. S dated 24.02.2025 (104) Ex. A
(408) (133)
During the proceeding, in the course of I have perused the contagion of
examination of documents, discussion, etc. taxpayer & arrived to following
following facts/points were noticed: conclusion.
As per Article/Section 1.3 of the service As per Article/Section 1.3 of the
agreement dated 24/08/2015, the service agreement dated
contractor provides to the service provider, 24/08/2015, the contractor provide
free of cost, designated software or to the service provider, free of cost,
hardware computer equipment (the designated software or hardware
technology) required to undertake the computer equipment (the
services which are specified to the technology) required to undertake
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contractor’s clients / project requirement. the services which are specified to the
Such technology shall be returned on contractor’s clients / project
completion of the assignment upon requirement. Such technology shall
request and shall at all times remain the be returned on completion of the
property of the Contractor. assignment upon request and shall at
all times remain the property of the
(409) Contractor.
As per Section 5.1 of the service
As per Section 5.1 of the service
agreement dated 24/08/2015, any
agreement dated 24/08/2015, any
processes, specification, drawing, sketches,
processes, specification, drawing,
models, products, software, sample, tools,
sketches, models, products, software,
computers or other apparatus, programs,
sample, tools, computers or other
technical, scientific or business
apparatus, programs, technical,
information or data, return, or otherwise
scientific or business information or
owned or control by contractor, etc.
data, return, or otherwise owned or
furnished to or acquired by the service
control by contractor, etc. furnished
provider shall remain contractor’s
to or acquired by the service provider
property.
shall remain contractor’s property.
As per the written submission of the As per the written submission of the
taxpayer he has enlisted the taxpayer he has enlisted the
activities/services undertaken, viz. activities/services undertaken, viz.
1. Fund accounting services by computing 1. Fund accounting services by
profit and loss of entire portfolio daily, computing profit and loss of entire
calculation of periodic Net Asset Value portfolio daily, calculation of
and the allocation of returns to the fund periodic Net Asset Value and the
investors for the customers. allocation of returns to the fund
2. Processing of derivative transaction by investors for the customers.
daily reconciliation, trade settlement 2. Processing of derivative
and collateral management and pricing transaction by daily reconciliation,
support: trade settlement and collateral
3. Operations of securities by reconciling management and pricing support.
the cash balances, trades and positions 3. Operations of securities by
between the fund manager and prime reconciling the cash balances,
broker and investigating into trades and positions between the
differences and resolving them for fund manager and prime broker
customers; and investigating into differences
4. Provision of flexible risk management and resolving them for customers
analytics and reporting tools for its 4. Provision of flexible risk
customers: management analytics and
5. Control of Date management by reporting tools for its customers;
maintaining a global centralized 5. Control of Date management by
security master and creating accounts maintaining a global centralized
of securities dealt by customers on the security master and creating
database. accounts of securities dealt by
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6. Preparation of financial statements i.e. customers on the database.
income and expenditure, balance sheet 6. Preparation of financial statements
compilation and analysis. i.e. income and expenditure,
7. Assistance to other stakeholders. balance sheet compilation and
analysis.
Thus, from the above it is presumed/ it 7. Assistance to other stakeholders.
appears that the taxpayer (Service
Provider) had direct access to the end Thus, from the above itis presumed/
users of the Contractor (M/s Globeop it appears that the taxpayer (Service
Financial Services limited, Landon) by way Provider) had direct access to the end
of direct telephonic calls, emails, users of the Contractor (M/sGlobeop
correspondence regarding services Financial Services limited, Landon)
provided as per their requirement, etc. by way of direct telephonic calls,
emails, correspondence regarding
Further, it is proved beyond doubt that due services provided as per their
to access of Software’s and other requirement, etc.
technology of the Contractor to the
Further, it is proved beyond doubt
taxpayer, the taxpayer had become direct
that due to access of Software’s and
access of the documents of the Customers
other technology of the Contractor to
of the Contractor (M/s SS&C Financial
the taxpayer, the taxpayer had
Services Limited) in terms of viewing their
become direct access of the
applications, documents, filling of
documents of the Customers of the
applications, verification of documents,
Contractor (M/s SS&C Financial
fixing matching and un-matching, etc.
Services Limited) in terms of viewing
After processing by the taxpayer, the said
their applications, documents, filling
applications/documents later on becomes
of applications, verification of
available to the Contractor and his
documents, fixing matching and un-
Customers. Thus, in said services three
(134)
parties, viz M/s SS&C Financial Services
matching, etc. After processing by the
Limited, the Customers of M/s SS&C
taxpayer, the said applications /
Financial Services Limited and the
documents later on becomes
taxpayer were involved. Thus, this type of
available to the Contractor and his
service didn’t qualify as “Export of
Customers. Thus, in said services
Services” & becomes “Intermediary” as per
three parties, viz M/s SS&C Financial
the provisions contained
Services Limited, the Customers of
(410)
M/s SS&C Financial Services Limited
u/s 13(8) (b) of the Integrated Goods and
and the taxpayer were involved.
Services Act, 2017. Thus, as per the
Thus, this type of services didn’t
provisions of law, the Zero-rated supply
qualify as “Export of Services” &
claim of Rs.193,82,11,757/- made by the
becomes “Intermediary” as per the
taxpayer was not admissible and becomes
provisions contained
Intermediary. This was brought to the
(134)
notice of the taxpayer’s representatives. It
u/s 13(8) (b) of the Integrated Goods
was also brought to their notice that the
and Services Act, 2017. Thus, as per
taxpayer had claimed an excess refund on
the provisions of law, the Zero-rated
Intermediary transactions which become
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inadmissible and shall be reduced as per supply claim of Rs.193,82,11,757/
the provisions of law. made by the taxpayer was not
admissible and becomes
(410) Intermediary. This was brought to the
Without prejudice, to the Circular as well notice of the taxpayer’s
as the Judgements quoted in reply by the representatives. It was also brought
taxpayer, the fact that the taxpayer has not to their notice that the taxpayer had
provided the details as mentioned in point claimed an excess refund on
no. 5 above cannot be changed. The Intermediary transactions which
citations given by the taxpayer are becomes inadmissible and shall be
applicable only in the event of he should reduced as per the provisions of law.
have produced all the details sought by
this office for examination during the [This Paragraph is not in the Impugned
refund proceeding. The taxpayer has not Order]
provided details sought and concealed the (134)
facts.
As per Section 13(8) (b) of the IGST
Act, the place of supply of
As per Section 13(8) (b) of the IGST Act,
“intermediary services” shall be the
the place of supply of “intermediary location of the supplier of services.
services” shall be the location of the
Since the place of supply of services,
supplier of services. Since the place of in the instant case is in taxable
supply of services, in the instant case is in
territory of India, the said
taxable territory of India, the said intermediary services cannot be
intermediary services cannot be treated as
treated as an export of services under
an export of services under the provisions the provisions of the GST laws.
of the GST laws.
In order to classify as ‘export of
In order to classify as ‘export of service’, as service’, as per section 2(6) of the
per section 2(6) of the Integrated Goods Integrated Goods and Services Tax
and Services Tax Act, 2017, one of the Act, 2017, one of the crucial
crucial conditions as contained under sub- conditions as contained under sub-
clause (iii) is that the place of supply of clause (iii) is that the place of supply
service should be outside India. of service should be outside India.
We now discuss Inter-state provisions as We now discuss Inter-state provisions
well as Intra State provisions under the as well as Intra State provisions
GST laws as follows: under the GST laws as follows: —
Inter State provisions are contained
Inter State provisions are contained under under section 7 of the Integrated
section 7 of the Integrated Goods and Goods and Services Tax Act, 2017
Services Tax Act, 2017 and since none of and since none of the specific
the specific provisions are applicable, provisions are applicable, residuary
residuary provision contained under provision contained under section
section 7(5)(c) shall be made applicable in 7(5)(c) shall be made applicable in
the case of intermediary service, which the case of intermediary service,
states that inter-state supply of goods or
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services or both in the taxable territory which states that inter¬ state supply
shall be treated to be a supply of goods or of goods or services or both in the
services or both in the course of inter-state taxable territory shall be treated to be
trade or commerce, however, the same a supply of goods or services or both
should not be an intra-state supply and in the course of inter-state trade or
should not be covered elsewhere in section commerce, however, the same should
7 of the IGST Act. not be an intra-state supply and
should not be covered elsewhere in
Section 8 of the Integrated Goods and section 7 of the IGST Act.
Services Tax Act, 2017 deals with the
Section 8 of the Integrated Goods
provisions of intra¬ state. Applying the
and Services Tax Act, 2017 deals with
provisions of section 8(2) which states that
the provisions of intra¬ state.
‘subject to the provisions of section 12, in
Applying the provisions of section
case where the location of the supplier and
8(2) which states that ‘subject to the
the place of supply of services are in the
provisions of section 12, in case
same state or in the same union territory,
where the location of the supplier
the supply of service shall be treated as
and the place of supply of services
intra-state supply’.
are in the same state or in the same
The above provisions of inter-state supply union territory, the supply of service
and intra-state supply has clarity when shall be treated as intra-state supply’.
both the recipient and the supplier of The above provisions of inter-state
services are located in India. However as supply and intra-state supply has
in the subject case, when the recipient is clarity when both the recipient and
located outside India provisions of section the supplier of services are located in
7(5)(c) shall be applicable. Section 7(5)(c) India. However as in the subject case,
is reproduced as under: — when the recipient is located outside
India provisions of section 7(5)(c)
(411) shall be applicable. Section 7(5)(c) is
Supply of goods or services or both– reproduced as under
a. supplier is located in India and the
place of supply is outside India. Supply of goods or services or both–
b. To or buy a Special Economic Zone a. supplier is located in India and the
developer or a Special Economic Zone place of supply is outside India.
unit: or b. To or buy a Special Economic Zone
c. In the taxable territory, not being an developer or a Special Economic
intra-State supply and not covered Zone unit or
elsewhere in this section, shall be c. In the taxable territory, not being
treated to be a supply of goods or an intra-State supply and not
services or both in the course of inter- covered elsewhere in this section,
State¬ trade or commerce. shall be treated to be a supply of
goods or services or both in the
As per intra-state provisions contained in course of inter-State trade or
Section 8(2), the said provisions are commerce
subject to the provisions of section 12 of (135)
the IGST Act. As per section 12, the As per intra-state provisions
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provisions of section 12 would be contained in Section 8(2), the said
applicable only for determining the place provisions are subject to the
of supply of service where the location of provisions of section 12 of the IGST
supplier of services and the location of Act. As per section 12, the provisions
recipient of the services is in India. When of section 12 would be applicable
recipient is located outside India the said only for determining the place of
provisions of section 12 cannot be made supply of service where the location
applicable and since provisions of section of supplier of services and the
8(2) are inter-linked with provisions of location of recipient of the services is
section 12, the same cannot be made in India. When recipient is located
applicable in case the recipient of service is outside India the said provisions of
located outside India. section 12 cannot be made applicable
and since provisions of section 8(2)
Thus, we find that in case the intermediary are inter-linked with provisions of
services are provided to the recipient section 12, the same cannot be made
located outside India, the inter-state applicable in case the recipient of
provisions as contained under section 7(5) service is located outside India.
(c) shall be applicable and hence IGST is
payable under such transaction. Thus, we find that in case the
intermediary services are provided to
In the instant case, the place of supply the recipient located outside India,
shall be location of the supplier of services, the inter-state provisions as
i.e., in India and, therefore, such contained under section 7(5)(c) shall
‘intermediary services’ cannot be classified be applicable and hence IGST is
as ‘export of services’. In case the payable under such transaction.
intermediary services are provided to the
recipient located outside India, the inter- In the instant case, the place of
State provisions as contained under supply shall be location of the
section 7(5)(c) shall be applicable and, supplier of services, i.e., in India and,
hence, IGST is payable on the above therefore, such ‘intermediary services’
transaction. cannot be classified as ‘export of
services’. In case the intermediary
Supply of services by the applicant will be services are provided to the recipient
treated as ‘inter-State supply’ covered located outside India, the inter-State
under section 7(5)(c) of the IGST Act and provisions as contained under section
IGST is applicable on the aforesaid 7(5)(c) shall be applicable and,
transaction, which is required to pay by hence, IGST is payable on the above
the taxable person (TP) as per the transaction.
provision of Law.
Supply of services by the applicant
will be treated as ‘inter-State supply’
covered under section 7(5)(c) of the
IGST Act and IGST is applicable on
the aforesaid transaction, which is
required to pay by the taxable person
(TP) as per the provision of Law.
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In view of the above discussion the
contention of taxpayer is not
accepted & liability is raised.
10. In the case of Piramal Enterprises Limited vs. The State of
Maharashtra & Anr. Writ Petition No.2836 of 2021 disposed of on 11
June 2024, a Co-ordinate Bench of this Court, of which one of us
(Jitendra Jain, J.) was a party set aside the impugned order after
finding that there was no independent application of mind but the
contents of a notice issued by the Service Tax Authorities was verbatim
copied/borrowed by the VAT authorities.
11. In the above regard, a reference can be made to paragraph 70
of the above decision which reads as follows:-
“70. We are also in agreement with the contention as urged on behalf
of the petitioner when the petitioner urges that the impugned review
order is bad in law for the reason that there is non-application of mind
by the reviewing authority in passing such order on another aspect. In
this regard we find that when the reviewing authority intended to
confine itself to the value assigned to the intangible assets as
contained in Schedule 3.3 read with Section 3.3 and Section 2.5, the
same has been borrowed / copied from the service tax demand notice
in ad-verbatim manner. This is clear from the comparative extracts of
the service tax demand notice and the extract of the impugned order
and more particularly from perusal of paragraphs 13 to 26 and 30 to
31 of the impugned order when examined against paragraph 4, 5.1 to
5.4, 6.1 and 10 of the Service Tax demand notice, where the
impugned order has clearly copied and pasted the findings and
reasoning as contained in the service tax demand notice issued to the
petitioner in regard to BTA. In this context we may also observe that
the parameters of proceedings for levy of service tax, as it then stood
under the provisions of the Finance Act,1994, could not have been
borrowed to be made applicable for levy of VAT under the MVAT Act.
We hence, wonder as to how the Reviewing Authority could verbatim
borrow / copy the contents of the notice issued by the Service Tax
Authority.”
12. The argument that the above ground is not raised or that such
a ground does not indicate a lack of deliberation or render the
impugned order unreasoned is misconceived. In Ground ‘G.1’, the
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Petitioner has clearly alleged that the impugned order is silent and
issued with a complete lack of deliberation. There are grounds asserting
that the impugned order is unreasoned and therefore violates natural
justice. Additional grounds claim that the order is vitiated due to non-
application of mind. Furthermore, it is argued that the impugned order
fails to cite or analyse any specific legal provision, judgment, or
proposition, which again demonstrates a clear lack of deliberation.
Detailed grounds also highlight that several contentions raised in the
replies have not been considered. In Ground ‘G’ concerning non-
application of mind, the Petitioner has relied upon the decision in the
case of Piramal Enterprises Limited (supra). Under these circumstances,
the contention that no grounds were raised in the petition is quite
misconceived and cannot be upheld.
13. Besides the grounds, the adjudicating authority is obliged to
issue an order after thoroughly considering all relevant arguments and
to state the reasons supporting its decision briefly. Any decision made
without considering the main contentions or without providing any
supporting reasons would be indicative of a lack of application of mind.
Simply cutting and pasting the allegations in the show cause notice or
mechanically reciting them verbatim does not inspire confidence that
due consideration has been shown to the cause, and the decision is
made after its due consideration. Ultimately, these are aspects of
natural justice principles that should guide the decision-making process
in such cases. As is well settled, in these matters, we focus on the
process of decision-making rather than the final outcome.
14. We have also examined the replies filed by the Petitioner to
the show cause notice. The Petitioner has put forward several
contentions, relying on at least nine precedents they claim support their
position, as well as the Board Circular dated 20 September 2021. From
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the impugned order, we observe that although there may be a reference
to this Circular and the decisions, these have not been addressed. The
impugned order does not specify why such decisions are irrelevant or
distinguishable, nor why the cited Circular does not apply. This was
expected of the adjudicating authority. The failure to consider the
contentions raised or the precedents relied upon, combined with the
cut-and-paste approach mentioned earlier, also suggests a lack of
proper consideration, which invalidates the impugned order.
15. Section 73(9) of the Central Goods and Services Tax Act, 2017
(CGST Act) which is similar to the corresponding provisions in the
Maharashtra Goods and Services Tax Act, 2017 (MGST) provides that
the proper officer shall, after considering the representation, if any,
made by person chargeable with tax, determine the amount of tax,
interest and a penalty equivalent to ten percent of tax or ten thousand
rupees, whichever is higher, due from such person and issue an order.
The italicized portion implies and requires that the proper officer must
apply his or her mind to the representation made and only after that,
issue an order. The phrase ‘consider’ does not mean that the contents of
the representation are transcribed in the impugned order and without
any discussion on the contentions raised, a conclusion is reached. In this
case, the so-called reasoning is merely a cut-and-paste of most of the
contents of the show cause notice, as noticed above.
16. The term ‘consider’ has been a subject of several judicial
pronouncements. It means examining or weighing the merits of matters.
The “Chambers Dictionary” defines this as ‘looking at attentively or
carefully’. The “Standard Dictionary” describes this term as thinking
with deliberate care or giving heed. In the case of Union of India & Anr.
vs. Tulsiram Patel1, the Court clarified that ‘consider’ means to
1 (1985) SCC OnLine SC 178
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contemplate mentally, fix the mind upon, think over, meditate, reflect,
give heed, or take note, implying a deliberate, attentive mental process.
In S. Kiranmayi vs. Sri N. Sambasiva Rao 2, the Court held that ‘consider’
involves careful thought, review and weighing of factors.
17. Similarly, Section 75(6) of the CGST Act provides that the
proper officer, in his order, shall set out the relevant facts and the basis
of his decision. The emphasis of this provision is on the ‘basis of
decision’. This means the emphasis is on the reasons that support the
decision. Merely cutting and pasting the allegations from the show
cause notice does not amount to giving any independent reasons after
due consideration the assessee’s contentions or after due application of
mind to those contentions.
18. For all the above reasons, we are satisfied that the impugned
order warrants interference on the ground urged.
19. The objection regarding the alternative remedy does not hold
in this case. Firstly, it is not the case that an appeal has been filed
against the impugned order. Secondly, an appeal was made against the
order dated 1 April 2022, which included reasons; however, those
reasons did not appeal to the Petitioner. Thirdly, since this is a case of
complete non-application of mind and violation of principles of natural
justice, there is no point in directing the Petitioner to pursue the
alternative remedy of appeal. A clear breach of natural justice is an
exception to the general rule that statutory remedies should usually be
exhausted before seeking this Court’s extraordinary intervention. In any
event, we do not intend to annul the impugned order on its substance.
Nonetheless, we are intervening because the decision-making process
involved a breach of the principles of natural justice and fair play.
2 2017 SCC OnLine Hyd. 164
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20. For all the above reasons, we quash and set aside the
impugned order dated 24 February 2025 and remand the matter to the
adjudicating authority for fresh consideration and disposal of the show
cause notice within three months of the uploading of this order.
Needless to add that the principles of natural justice will have to be
followed, and this would include giving an opportunity of hearing to the
Petitioner and considering the Petitioner’s replies/representations. All
contentions of all parties on merits are, however, left open.
21. The Rule is made absolute in the above terms without any
order for costs.
22. All concerned must act on an authenticated copy of this order.
(Jitendra Jain, J.) (M. S. Sonak, J.)
Signed by: Sayyed Saeed Ali
Designation: PA To Honourable Judge
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Date: 07/07/2025 15:11:30
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