Kudos Facililty Services Vs State of Andhra Pradesh (Andhra Pradesh High Court)
The writ petition was filed challenging the assessment order dated 12.06.2024 and the consequent notice of attachment in Form GST DRC-16 dated 19.12.2025 issued by the third respondent. The petitioner contended that the assessment order was illegal as it did not contain a Document Identification Number (DIN) and that the pre-show cause notice in Form DRC-01A dated 22.12.2023 and show cause notice in Form DRC-01 dated 02.12.2023 did not bear the signature of the issuing authority.
The petitioner, a registered dealer under the GST Act, 2017 engaged in supplying manpower services to APSRTC, was issued notices after discrepancies were noticed in returns for the period 2019–2020. The petitioner claimed inability to verify the notices on the portal due to lack of proper knowledge and also stated that its Managing Partner was unwell. As no objections were filed, the assessment order was passed on 12.06.2024.
An appeal filed on 12.09.2024 was rejected on 16.07.2025. Thereafter, notice for attachment and sale of movable property under Section 79 of the GST Act was issued on 19.12.2025, prompting the present writ petition.
The Court observed that the assessment order was uploaded on the portal on the date of its issuance. It noted that prior to issuance of pre-show cause and show cause notices, the petitioner had filed objections on 06.05.2023 to a notice in GST ASMT-10 dated 06.04.2023 relating to the same tax period. Therefore, the Court held that the petitioner was aware of the initiation of assessment proceedings. The plea that the petitioner had no proper knowledge to verify the portal was rejected.
