The petitioner challenges the impugned best judgment assessment proceedings dated 05.10.2020 for the month of March, 2020 passed by the 1st respondent and his consequential Garnishee notice dated 10.11.2020 issued to 3rd respondent, as illegal. One of the grounds for not filing returns and non-payment of the tax for the relevant period by the petitioner as projected by the petitioner is that the petitioner entered into contract with the A.P. State Fibernet Limited (APSFL) (an Undertaking of Government of Andhra Pradesh), Vijayawada for supply, erection, installation and commissioning of Optical Fiber Cable Operations and Maintenance of A.P. Fiber Grid Phase-I and II and in that contract the petitioner concern has to receive Rs.150 crores from APSFL. The same is outstanding since long and in that context the petitioner filed writ petition No.10218/2020 wherein interim direction was also given by this Court to the APSFL to consider the representation of the petitioner and pass appropriate orders. But still the petitioner has not received the contractual amount and therefore, the petitioner could not pay the tax due to the department and since the payment was not made, the returns submitted in the online portal were not received. However, in the meanwhile, the 1st respondent issued notices and passed best judgment proceedings without considering representations of the
