In a recent decision, the Allahabad High Court addressed a case involving M/s Krishi Rakchha Sewa Kendra, where the petitioners contested an adjudication order under the UPGST Act. The order, dated August 30, 2024, determined a tax liability of ₹41,71,718, but the petitioners argued that the proceedings were flawed. They claimed that no show cause notice (SCN) or adjudication order was ever properly served, and that the proceedings were initiated using an incorrect GSTIN, with references to GSTINs of other assessees.

The State counsel acknowledged these errors and requested a remand, citing a precedent from a similar case, M/s Riya Construction v. State of U.P. The primary issue was whether an adjudication order issued under an incorrect GSTIN and with an enhanced tax demand beyond the SCN could be legally upheld. Upon review, the Court identified significant factual errors, including the issuance of SCNs and adjudication orders under unrelated GSTINs, and tax determinations that exceeded the proposed liabilities.

As a result, the Court deemed the proceedings fundamentally defective, nullifying the entire adjudication process. It set aside the impugned SCNs and orders from May 22, 2024, August 30, 2024, August 11, 2025, and August 31, 2025. The Court allowed for the issuance of a fresh SCN under Section 73 within a month, exempting it from the limitation period due to the remand under Article 226. Additionally, any interim attachment orders were quashed, providing a fresh start for the adjudication process.