Order Date – 03 July 2025

Parties: HYT Engineering Company Private Limited vs. Union of India & Ors.

Facts –

• The Petitioner, HYT Engineering Company Private Limited, was subjected to a special audit under Section 66 of the CGST Act, 2017. The audit findings were emailed to the petitioner on 21st May 2025 with a 7-day deadline for reply. The petitioner failed to respond, leading to the issuance of ADT-04 notice demanding payment.
• The petitioner argued that the audit itself was not permissible under law and that it had not been granted a proper opportunity to respond to the audit report.

Issue –

• Whether the petitioner, having missed the deadline to reply to the special audit findings, could still be granted a fresh opportunity of hearing under the CGST framework?

Order –

• The Division Bench of Hon’ble High Court held that though, the Petitioner has missed the deadline for filing the reply, considering the quantum of demand being raised, it is deemed appropriate to permit the Petitioner to withdraw the present petition with liberty to the Petitioner for filing of a reply and an opportunity of being heard.
• The present petition is dismissed as withdrawn with liberty, as aforesaid.