Disposed¶39

M/s. Pakala Janardhan, v. The Assistant Commissioner of State Tax

Andhra Pradesh HC9 Mar 2026WP/27729/2024

Case brief

AI extract

What is this about?

Batch disposal (Art. 226, High Court of A.P. at Amaravati, 10.03.2026) of writ petitions by works contractors challenging 18% GST levy on works done for TTD contrary to Ministry of Finance rate/exemption notifications, and a Form DRC-01 show cause notice dated 26-09-2025 for period 2021-22, incl. prayer that EO-TTD pay balance 6% with interest and penalty; disposed of in terms of judgment dated 03.03.2026 in W.P.No.33250 of 2022; no costs; misc. applications closed.

What did the court decide?

Batch of writ petitions disposed of in terms of the judgment dated 03.03.2026 in W.P.No.33250 of 2022; no order as to costs; pending miscellaneous applications, if any, stand closed. ¶39

M/s. Pakala Janardhan, Vs The Assistant… — GST and Indirect Tax | Andhra Pradesh HC (2026)

What the court decided

AI extract

Outcome

Batch of writ petitions disposed of in terms of the judgment dated 03.03.2026 in W.P.No.33250 of 2022; no order as to costs; pending miscellaneous applications, if any, stand closed.

¶39

Issue for consideration

Whether the action of the Assistant Commissioner (ST) in taxing the works done to TTD @ 18%, treating them as not falling within the scope of the Ministry of Finance notifications, is illegal, arbitrary and without jurisdiction. +1 more

¶23

Ratio / Principle

The issues raised in the present set of writ petitions are covered by the judgment of this Court dated 03.03.2026 in W.P.No.33250 of 2022.

¶38

Key takeaways

The writ petitions are disposed of in terms of the said judgment dated 03.03.2026, with no order as to costs.ratio¶39
As a sequel, pending miscellaneous applications, if any, shall stand closed.ratio¶40

Detailed headnote1 paragraphs

Common Order (per R. Raghunandan Rao, J; bench with T.C.D. Sekhar, J), High Court of Andhra Pradesh at Amaravati, 10.03.2026: A batch of eleven writ petitions led by W.P.No.35178 of 2025 (P Venugopal Naidu, works contractor v. Union of India, State of A.P., the Assistant Commissioner (ST) Tirupati-II Circle, and TTD officials) was disposed of. The petitions challenged, per the cause title/prayer, the taxation of works done for Tirumala Tirupati Devasthanams at 18% despite Ministry of Finance notifications (Nos. 11/2017-CT(Rate), 12/2017-CT(Rate), 24/2017-CT, 20/2017-CT (Rate), 31/2017, 1/2018-Central Tax (Rate) and 50/2018-Central Tax), sought restraint of further proceedings on a show cause notice dated 26-09-2025 in Form DRC-01 for the period 2021-22, and directions to the Executive Officer, TTD to pay the balance 6% with interest and penalty. Holding the issues raised to be covered by its earlier judgment dated 03.03.2026 in W.P.No.33250 of 2022, the Court disposed of the batch in terms of that judgment, with no order as to costs, and closed pending miscellaneous applications. No independent merits adjudication occurs in this order; the substantive holdings lie in the judgment of 03.03.2026, which is not reproduced here.

¶1

APHC010680322025

¶2

IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction)

¶3

[3529]

¶4

TUESDAY, THE TENTH DAY OF MARCH TWO THOUSAND AND TWENTY SIX

¶5

PRESENT

¶6

THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO

¶7

THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR

¶8

WRIT PETITION Nos: 35178 of 2025, 18334, 27727, 27728, 27729 & 27799 of 2024 and 541, 10342, 10446, 14428 & 14443 of 2025

¶9

WRIT PETITION NO: 35178/2025

¶10

Between:

¶11

P VENUGOPAL NAIDU, WORKS CONTRACTOR S/O. LATE. P.VENKATA SUBBAIAH NAIDU, AGED ABOUT 50 YEARS, OCC BUSINESS, 6-7-567/301, SAI PRANEETHA REDDY NILAYAM, SRIPURAM COLONY, TIRUPATHI, TIRUPATHI -517501, ANDHRA PRADESH.

¶12

...PETITIONER

¶13

AND

¶14

UNION OF INDIA, REPRESENTED BY ITS SECRETARY, MINISTRY OF FINANCE, 4TH FLOOR, A-WING, SHASTRI BHAWAN NEW DELHI - 110001. 2) .

¶15

THE STATE OF ANDHRA PRADESH, REP. BY ITS PRINCIPAL SECRETARY TO GOVERNMENT, REVENUE (CT-I) DEPARTMENT, VELAGAPUDI, AMARAVATHI, GUNTUR DISTRICT, ANDHRA PRADESH. 3)

¶16

THE ASSISTANT COMMISSIONER ST, TIRUPATI -II CIRCLE, TIRUPATI, SRI BALAJI DISTRICT

¶17

THE EXECUTIVE OFFICER, TIRUMALA TIRUPATI DEVASTHANAMS, TIRUPATI, CHITTOOR, SRI BALAJI DISTRICT. 5)

¶18

¶19

RRR,J & TCDS,J W.P.No.35178 of 2025 & batch

¶20

THE CHIEF ENGINEER, TIRUMALA TIRUPATI DEVASTHANAMS, TIRUPATI, CHITTOOR, SRI BALAJI DISTRICT. 6)

¶21

THE CHIEF COMMISSIONER OF STATE TAX COMMERCIAL TAXES, D.NO. 5-59, RK SPRING VALLEY APARTMENTS, BANDAR ROAD, EDUPUGALLU VILLAGE, KANKIPADU MANDAL, VIJAYAWADA, KRISHNA DISTRICT -521144, ANDHRA PRADESH

¶22

...RESPONDENT(S):

¶23

Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased topleased to issue an appropriate writ, order or direction particularly in the nature of Writ of MANDAMUS (i) declaring the action of the Assistant Commissioner (ST), Tirupati-ll Circle, Tirupati in not considering the Notification Nos. 11/2017-CT(Rate) dated 28-06-2017, 12/2017-CT(Rate) dated 28-06-2017 and 24/2017-CT dated 21- 08-2017, 20/2017-CT (Rate) dated 22-08-2017 31/2017 dated 13-10-2017, 1/2018-Central Tax (Rate) dated 25-01-2018, 50/2018-Central Tax dated 13-09-2018 issued by the Ministry of Finance, Union of India and taxing the works done to TTD @ 18percent treating it as not falling within the scope of the above Notifications as illegal, arbitrary, improper, unjust, improper, without jurisdiction and authority of law, contrary to the notifications and the provisions of GST Act 2017, violative of principles of natural justice and articles 14, 19(1) (g), 21, 265 and 300-A of the Constitution of India and consequently to set aside the same or alternatively (ii) declare the inaction on the part of the Executive Officer, TTD in not considering the representations made by the Petitioner to it either to pay the enhanced rate of 6percent as levied by the GST authorities with penalty and interest or (iii) to give clarification pursuant to the letter addressed by the Executive Officer , TTD dated 22-04-2018 to the Chief Commissioner, State GST to grant necessary instructions and to refrain the Assistant Commissioner (ST) , GST Department not to issue any further communication pursuant to the show cause notice dated 26-09-2025 in Form DRC -01 for the period 2021-22 as he is also a Government Official who has to wait for the instructions to be issued by the State GST Chief Commissioner and consequently to direct the Chief Commissioner to issue instructions accordingly or (iv) to direct the Executive Officer to pay balance amount of 6percent along with interest and penalty as levied in the show cause notice (iv) and pass

¶24

¶25

RRR,J & TCDS,J W.P.No.35178 of 2025 & batch

¶26

IA NO: 1 OF 2025

¶27

Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased to grant stay all further proceedings arising out of impugned Show cause notice dated 26-09-2025 issued by the Assistant Commissioner (ST)-II Tirupathi- II Circle Tirupathi and pending disposal of the writ petition and pass

¶28

Counsel for the Petitioner:

¶29