Shree Mangal Proteins Limited Vs Superintendent (Rajasthan High Court)
Summary: The petitioner, M/s Shree Mangal Proteins Limited, challenged the appellate order dated 19.01.2026 by which its appeal against the Order-in-Original dated 22.08.2024 was rejected on limitation. The Order-in-Original had raised a GST demand of Rs. 7,48,336/- for financial year 2019-20 on account of alleged wrongful availment of Input Tax Credit.
The appeal against the Order-in-Original was filed on 29.01.2025. According to the petitioner, the Show Cause Notices dated 29.05.2024 and 03.08.2024 were not effectively served and were merely uploaded on the GST portal. The petitioner consequently did not submit replies to those notices. It was further submitted that the Order-in-Original dated 22.08.2024 was also not served manually or in hard copy and was merely uploaded on the GST portal. The petitioner therefore claimed that it had no knowledge of the order and could not file the appeal within the prescribed period.
The petitioner further contended that the Order-in-Original was passed pursuant to the Show Cause Notice dated 03.08.2024 and not the earlier notice dated 29.05.2024, and that the prescribed period for responding to the later notice was not effectively available. According to the petitioner, the order was therefore passed without an effective and meaningful opportunity to respond. It was also submitted that the appellate authority had rejected the appeal solely on limitation without adjudicating the dispute on merits.
