Interim Relief Granted in Absence of Constituted Appellate Tribunal: Following Precedent

By | January 27, 2025

 Interim Relief Granted in Absence of Constituted Appellate Tribunal: Following Precedent

Summary:

In this case, the assessee challenged an order passed by the first appellate authority. However, the Appellate Tribunal had not yet been constituted, preventing the assessee from filing an appeal there. The assessee approached the court seeking interim relief. Citing a previous decision in Maa Tarini Traders v. State of Odisha, the court granted the interim relief subject to the assessee depositing 10% of the disputed tax amount.

Facts of the Case:

  • The assessee was aggrieved by an order passed by the first appellate authority.
  • The Appellate Tribunal had not yet been constituted.
  • The assessee filed a petition seeking interim relief to challenge the first appellate order.

Decision:

  • Following Precedent: The court cited the decision in Maa Tarini Traders v. State of Odisha to grant interim relief to the assessee.
  • Deposit of 10% Tax: The court granted the interim relief subject to the assessee depositing 10% of the disputed tax amount.

Key Points:

  • Interim Relief in Absence of Tribunal: This case highlights the possibility of obtaining interim relief even when the Appellate Tribunal is not yet constituted.
  • Conditions for Interim Relief: The court may impose conditions on the interim relief, such as requiring a deposit of a portion of the disputed tax amount.

Conclusion:

This case demonstrates that taxpayers can seek interim relief to protect their interests even when the Appellate Tribunal is not yet functional. By following established precedents and complying with the court’s conditions, assessees can secure some protection while awaiting the opportunity to appeal their cases before the appropriate tribunal.

HIGH COURT OF ORISSA
ATC Telecom Infrastructure (P.) Ltd.
v.
State of Odisha
Arindam Sinha and M.S. Sahoo, JJ.
W.P.(C) No.12621 of 2024
JANUARY  9, 2025
Deepro Sen, Adv. for the Petitioner. Sunil Mishra, Standing Counsel for the Respondent.
ORDER
1. Mr. Sen, learned advocate virtually appears on behalf of petitioner and with reference to order dated 3rd December, 2024 causes handing up of Form GST DRC-0 3 dated 7th January, 2025 on submission, further 10% of the demand to entitle his client having relief on precedent of order dated 16th February, 2024 in W.P.(C) no.42015 of 2023 (M/s. Maa Tanini Traders v. State of Odisha and others) was deposited. This is because Tribunal has not been constituted for his client to prefer and prosecute statutory appeal.
2. Mr. Mishra, learned advocate, Standing Counsel appears on behalf of revenue.
3. We have respectfully agreed and followed view taken in order dated 16th February, 2024 (supra). As such, petitioner is entitled to the relief by precedent of said order. In the circumstances, impugned garnishee order is set aside and quashed. Petitioner will apply, obtain certified copy of this order and produce before its banker for release of the frozen amount. Mr. Sen submits, his client is not giving up the grounds of appeal available to it. Petitioner can file and prosecute statutory appeal on constitution of the Tribunal.
4. The writ petition is disposed of.
Category: GST

About CA Satbir Singh

Chartered Accountant having 12+ years of Experience in Taxation , Finance and GST related matters and can be reached at Email : Taxheal@gmail.com