w w w . L a w y e r S e r v i c e s . i n



Heritage Lifestyles & Developers and Private Limited, through its Authorized Representative Gayatri Gor v/s The Union of India through the Revenue Secretary Ministry of Finance Department of Revenue North Block New Delhi & Others


Company & Directors' Information:- L & T FINANCE LIMITED [Amalgamated] CIN = U65990MH1994PLC083147

Company & Directors' Information:- S P FINANCE PRIVATE LIMITED [Active] CIN = U65990MH1979PTC021790

Company & Directors' Information:- H & R BLOCK (INDIA) PRIVATE LIMITED [Active] CIN = U72900PN2006PTC128344

Company & Directors' Information:- V L S FINANCE LIMITED [Active] CIN = L65910DL1986PLC023129

Company & Directors' Information:- TO THE NEW PRIVATE LIMITED [Active] CIN = U72900DL2006PTC235208

Company & Directors' Information:- K V DEVELOPERS PRIVATE LIMITED [Active] CIN = U70102DL2012PTC241987

Company & Directors' Information:- L R N FINANCE LIMITED [Active] CIN = U65921TN1992PLC089288

Company & Directors' Information:- S M FINANCE LTD [Active] CIN = L65999TG1984PLC004526

Company & Directors' Information:- J R D FINANCE LTD [Active] CIN = L65999WB1993PLC058107

Company & Directors' Information:- B R D FINANCE LIMITED [Active] CIN = U65910KL1995PLC009430

Company & Directors' Information:- T C I FINANCE LIMITED [Active] CIN = U65920MH1973PLC017042

Company & Directors' Information:- A. V. B. FINANCE PRIVATE LIMITED. [Active] CIN = U65993DL1992PTC049818

Company & Directors' Information:- S M L FINANCE LIMITED [Active] CIN = U65910KL1996PLC010648

Company & Directors' Information:- A TO Z DEVELOPERS LIMITED [Active] CIN = U70200UP2007PLC034064

Company & Directors' Information:- D AND S DEVELOPERS PRIVATE LIMITED [Amalgamated] CIN = U45201DL2004PTC126849

Company & Directors' Information:- S B FINANCE PVT LTD [Strike Off] CIN = U65921TG1988PTC008268

Company & Directors' Information:- V K C DEVELOPERS PRIVATE LIMITED [Active] CIN = U70100KA2007PTC042245

Company & Directors' Information:- INDIA FINANCE LTD. [Active] CIN = L65110WB1984PLC050214

Company & Directors' Information:- A L M DEVELOPERS PRIVATE LIMITED [Active] CIN = U70102UP2010PTC041214

Company & Directors' Information:- J J FINANCE CORPORATION LTD [Active] CIN = L65921WB1982PLC035092

Company & Directors' Information:- G V S FINANCE PVT LTD [Strike Off] CIN = U65921TG1988PTC008269

Company & Directors' Information:- G T P FINANCE LIMITED [Active] CIN = U65921TZ1991PLC003149

Company & Directors' Information:- J G DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200MH2006PTC158684

Company & Directors' Information:- HERITAGE LIFESTYLES & DEVELOPERS PRIVATE LIMITED [Active] CIN = U70102MH2009PTC190870

Company & Directors' Information:- I T DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201DL2006PTC144738

Company & Directors' Information:- S R K FINANCE PRIVATE LIMITED [Active] CIN = U65910UP1994PTC016038

Company & Directors' Information:- C S M DEVELOPERS PRIVATE LIMITED [Active] CIN = U04520MP2005PTC017927

Company & Directors' Information:- R K R DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45201KA2008PTC046539

Company & Directors' Information:- D N J DEVELOPERS PRIVATE LIMITED [Active] CIN = U70109AP2011PTC090762

Company & Directors' Information:- DELHI 6 DEVELOPERS PRIVATE LIMITED [Active] CIN = U70102DL2008PTC183477

Company & Directors' Information:- D S R DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201HR2005PTC035816

Company & Directors' Information:- R N FINANCE LIMITED [Active] CIN = U74899DL1988PLC034289

Company & Directors' Information:- J R D FINANCE LTD [Active] CIN = U65999WB1993PLC058107

Company & Directors' Information:- H D V S DEVELOPERS LIMITED [Active] CIN = U45201WB2004PLC198667

Company & Directors' Information:- C K G FINANCE PRIVATE LIMITED [Active] CIN = U65910KL1996PTC010147

Company & Directors' Information:- L N FINANCE LTD [Active] CIN = U65923WB1991PLC052876

Company & Directors' Information:- R K FINANCE LTD [Active] CIN = L65921WB1983PLC035896

Company & Directors' Information:- V P C L FINANCE LIMITED [Active] CIN = U65920TG1996PLC023172

Company & Directors' Information:- K K B DEVELOPERS PRIVATE LIMITED [Active] CIN = U70100MH2003PTC140111

Company & Directors' Information:- M C DEVELOPERS CO PRIVATE LIMITED [Active] CIN = U45201WB2005PTC103500

Company & Directors' Information:- P A R Y DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC127656

Company & Directors' Information:- N R S DEVELOPERS PRIVATE LIMITED [Active] CIN = U70102DL2007PTC161223

Company & Directors' Information:- J S M FINANCE PVT LTD [Active] CIN = U74140MP1995PTC009542

Company & Directors' Information:- B K DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45201KA2006PTC038528

Company & Directors' Information:- C L DEVELOPERS PVT LTD [Active] CIN = U45400WB1990PTC050024

Company & Directors' Information:- I & D FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1991PTC021369

Company & Directors' Information:- D A P DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U70101WB1997PTC086055

Company & Directors' Information:- UNION FINANCE LIMITED [Strike Off] CIN = U65910GJ1994PLC023717

Company & Directors' Information:- K K S DEVELOPERS INDIA PRIVATE LIMITED [Active] CIN = U45202UR2005PTC031113

Company & Directors' Information:- L N FINANCE PVT LTD [Active] CIN = U65929AS1992PTC003766

Company & Directors' Information:- N B A FINANCE LIMITED [Strike Off] CIN = U74899DL1993PLC052393

Company & Directors' Information:- T P D FINANCE LIMITED [Strike Off] CIN = U67120RJ1994PLC008051

Company & Directors' Information:- D B DEVELOPERS LIMITED [Active] CIN = U45202PN1999PLC013957

Company & Directors' Information:- R G L FINANCE COMPANY PRIVATE LIMITED [Active] CIN = U74899DL1983PTC015809

Company & Directors' Information:- A. M. DEVELOPERS (INDIA) PRIVATE LIMITED [Active] CIN = U70102KA2007PTC044101

Company & Directors' Information:- B R DEVELOPERS PRIVATE LIMITED. [Active] CIN = U45201AS2008PTC008562

Company & Directors' Information:- P P DEVELOPERS PVT LTD [Active] CIN = U70101WB1989PTC045879

Company & Directors' Information:- S K B FINANCE LIMITED [Amalgamated] CIN = U65999WB1996PLC082317

Company & Directors' Information:- J V FINANCE PRIVATE LIMITED [Strike Off] CIN = U74899DL1985PTC067873

Company & Directors' Information:- L C J FINANCE PVT. LTD. [Active] CIN = U65921WB1995PTC068809

Company & Directors' Information:- H L T FINANCE PRIVATE LIMITED [Strike Off] CIN = U65921DL1996PTC078128

Company & Directors' Information:- R D DEVELOPERS PVT LTD [Active] CIN = U45201WB1987PTC042181

Company & Directors' Information:- K R J DEVELOPERS PRIVATE LIMITED [Active] CIN = U67100TN2011PTC082403

Company & Directors' Information:- V M V DEVELOPERS PRIVATE LIMITED [Active] CIN = U70109DL2006PTC149676

Company & Directors' Information:- C S R DEVELOPERS PRIVATE LIMITED [Active] CIN = U70101WB2005PTC102513

Company & Directors' Information:- G R DEVELOPERS PVT LTD [Strike Off] CIN = U70109WB1995PTC074531

Company & Directors' Information:- M L DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200MH2004PTC149835

Company & Directors' Information:- K S DEVELOPERS PRIVATE LIMITED [Converted to LLP] CIN = U45201DL2005PTC139269

Company & Directors' Information:- B F D DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45202KA2011PTC056938

Company & Directors' Information:- HERITAGE FINANCE LTD [Strike Off] CIN = U65191TN1992PLC022640

Company & Directors' Information:- R N C P FINANCE LTD. [Dissolved] CIN = U67120WB1995PLC072339

Company & Directors' Information:- T T FINANCE LIMITED [Amalgamated] CIN = U67120DL1986PLC023168

Company & Directors' Information:- P A V DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400UP2007PTC033209

Company & Directors' Information:- M M V R FINANCE LIMITED [Active] CIN = U65921TZ1997PLC007705

Company & Directors' Information:- D B FINANCE PRIVATE LIMITED [Active] CIN = U65191TN1989PTC016705

Company & Directors' Information:- C H P FINANCE PVT LTD [Active] CIN = U65921PB1992PTC012788

Company & Directors' Information:- N V LIFESTYLES PRIVATE LIMITED [Active] CIN = U52390MH2009PTC191988

Company & Directors' Information:- E D DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400MH2011PTC216103

Company & Directors' Information:- S L B P FINANCE PRIVATE LIMITED [Active] CIN = U74899DL1990PTC041694

Company & Directors' Information:- R S FINANCE PVT LTD [Active] CIN = U65191WB1988PTC044144

Company & Directors' Information:- N. C. DEVELOPERS PRIVATE LIMITED [Active] CIN = U70109PB2008PTC031764

Company & Directors' Information:- S K J DEVELOPERS PRIVATE LIMITED [Active] CIN = U70101WB1997PTC085004

Company & Directors' Information:- I C FINANCE PRIVATE LIMITED [Active] CIN = U65921UP1989PTC011236

Company & Directors' Information:- D V R DEVELOPERS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC074520

Company & Directors' Information:- M D DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201DL2002PTC117983

Company & Directors' Information:- P R DEVELOPERS PRIVATE LIMITED [Active] CIN = U70200UP2006PTC032443

Company & Directors' Information:- A V DEVELOPERS PRIVATE LIMITED [Active] CIN = U74899DL1994PTC062929

Company & Directors' Information:- C C V DEVELOPERS PVT LTD [Active] CIN = U45400WB2006PTC107143

Company & Directors' Information:- M N DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400DL2007PTC164779

Company & Directors' Information:- V K FINANCE PVT LTD [Strike Off] CIN = U67120WB1991PTC052140

Company & Directors' Information:- V S DEVELOPERS PRIVATE LIMITED [Active] CIN = U74899DL2000PTC105589

Company & Directors' Information:- V M DEVELOPERS PRIVATE LIMITED [Converted to LLP] CIN = U45201DL2004PTC130706

Company & Directors' Information:- V. A. DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200DL2007PTC159386

Company & Directors' Information:- N K C M DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201TZ2008PTC014266

Company & Directors' Information:- C AND N FINANCE PRIVATE LIMITED [Strike Off] CIN = U65921DL1998PTC094290

Company & Directors' Information:- R. B. M. DEVELOPERS PRIVATE LIMITED [Active] CIN = U70102DL2008PTC183937

Company & Directors' Information:- C D R FINANCE LIMITED [Strike Off] CIN = U65910TG1995PLC022237

Company & Directors' Information:- J R FINANCE LIMITED [Active] CIN = U65921PB1996PLC017699

Company & Directors' Information:- I C S FINANCE LIMITED [Strike Off] CIN = U65921TZ1987PLC001991

Company & Directors' Information:- A K DEVELOPERS PVT LTD [Active] CIN = U70101WB1996PTC081098

Company & Directors' Information:- S G P DEVELOPERS PRIVATE LIMITED [Active] CIN = U70181DL2005PTC132775

Company & Directors' Information:- D D S FINANCE PRIVATE LIMITED [Strike Off] CIN = U65910DL1996PTC076165

Company & Directors' Information:- K V L FINANCE LIMITED [Strike Off] CIN = U65191TN1989PLC016715

Company & Directors' Information:- D A S FINANCE PVT LIMITED [Strike Off] CIN = U65921PB1993PTC012888

Company & Directors' Information:- J P L DEVELOPERS PRIVATE LIMITED [Active] CIN = U74899DL1994PTC063657

Company & Directors' Information:- U B FINANCE PRIVATE LIMITED [Strike Off] CIN = U74899DL1992PTC051300

Company & Directors' Information:- V L G FINANCE PRIVATE LIMITED [Strike Off] CIN = U65910AP1997PTC027952

Company & Directors' Information:- J B T INDIA DEVELOPERS PVT LTD [Active] CIN = U70101TG2006PTC101984

Company & Directors' Information:- E M S FINANCE PRIVATE LIMITED [Strike Off] CIN = U65921TZ1986PTC001789

Company & Directors' Information:- T P GAYATRI FINANCE COMPANY PRIVATE LIMITED [Active] CIN = U65910UP1995PTC018616

Company & Directors' Information:- B. D. S. K. DEVELOPERS PRIVATE LIMITED [Active] CIN = U70109DL2006PTC154062

Company & Directors' Information:- T D M FINANCE COMPANY PRIVATE LIMITED [Active] CIN = U65923KL1997PTC011601

Company & Directors' Information:- S. F. FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U65921PB1996PTC018702

Company & Directors' Information:- D S L FINANCE PRIVATE LIMITED [Active] CIN = U65921TG1996PTC023898

Company & Directors' Information:- R D P FINANCE PRIVATE LIMITED [Active] CIN = U65929DL1997PTC089092

Company & Directors' Information:- S R K C FINANCE LIMITED [Amalgamated] CIN = U65999TZ1989PLC002445

Company & Directors' Information:- R K N FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1997PTC038377

Company & Directors' Information:- S M K DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201DL2005PTC139327

Company & Directors' Information:- H A FINANCE PRIVATE LIMITED [Strike Off] CIN = U65993DL1987PTC027064

Company & Directors' Information:- H & Z DEVELOPERS PRIVATE LIMITED [Active] CIN = U70101AS2004PTC007381

Company & Directors' Information:- V V A FINANCE LTD [Active] CIN = U65993WB1984PLC037171

Company & Directors' Information:- B M DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400WB2007PTC114990

Company & Directors' Information:- Y B FINANCE PRIVATE LIMITED [Strike Off] CIN = U65921CH1996PTC017745

Company & Directors' Information:- H A DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201DL1997PTC090629

Company & Directors' Information:- N P C DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45201KA1995PTC018516

Company & Directors' Information:- D G L FINANCE LTD [Strike Off] CIN = U67120TG1993PLC015604

Company & Directors' Information:- P M DEVELOPERS PRIVATE LIMITED [Active] CIN = U70102WB2006PTC107087

Company & Directors' Information:- T G DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200MH1996PTC099741

Company & Directors' Information:- R J DEVELOPERS PRIVATE LIMITED [Active] CIN = U70200DL2011PTC215579

Company & Directors' Information:- S T DEVELOPERS COMPANY PVT LTD [Active] CIN = U70101WB1992PTC057111

Company & Directors' Information:- GAYATRI INDIA PRIVATE LIMITED [Active] CIN = U74899DL1995PTC072495

Company & Directors' Information:- S P A DEVELOPERS PRIVATE LIMITED [Active] CIN = U70200WB2010PTC147306

Company & Directors' Information:- A. S. M. Z DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400WB2010PTC144894

Company & Directors' Information:- C B DEVELOPERS PRIVATE LIMITED [Active] CIN = U70101WB1998PTC087986

Company & Directors' Information:- A G S DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC129997

Company & Directors' Information:- T & A DEVELOPERS PRIVATE LIMITED [Active] CIN = U70109DL2013PTC259387

Company & Directors' Information:- S. K. & S. K. DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200MH2007PTC167510

Company & Directors' Information:- M S R FINANCE PVT LTD [Strike Off] CIN = U65191TN1989PTC016789

Company & Directors' Information:- 3-D DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400PN2011PTC140578

Company & Directors' Information:- P G DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200MH1996PTC099738

Company & Directors' Information:- N G DEVELOPERS PRIVATE LIMITED [Active] CIN = U70100MH1996PTC099694

Company & Directors' Information:- B P K DEVELOPERS PRIVATE LIMITED [Active] CIN = U70103TN2007PTC062404

Company & Directors' Information:- R B S DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200TN2011PTC082253

Company & Directors' Information:- S S P FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1987PTC014526

Company & Directors' Information:- T. T. M. S. DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400WB2018PTC224382

Company & Directors' Information:- V P DEVELOPERS PRIVATE LIMITED [Active] CIN = U45203MP2007PTC019879

Company & Directors' Information:- J. S. T. DEVELOPERS PRIVATE LIMITED [Active] CIN = U70100HR2015PTC054780

Company & Directors' Information:- N K F DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U70102KA2012PTC064651

Company & Directors' Information:- I. P. DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400DL2009PTC194890

Company & Directors' Information:- S K S & DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200AN2011PTC000153

Company & Directors' Information:- K G DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201WB1997PTC084096

Company & Directors' Information:- C R N FINANCE PRIVATE LIMITED [Strike Off] CIN = U74899DL1994PTC062802

Company & Directors' Information:- R P DEVELOPERS PRIVATE LIMITED [Active] CIN = U70101WB1997PTC084769

Company & Directors' Information:- S F Q DEVELOPERS PRIVATE LIMITED [Active] CIN = U70102UP2015PTC069498

Company & Directors' Information:- I FINANCE COMPANY LIMITED [Active] CIN = U67110DL2011PLC212268

Company & Directors' Information:- A P M DEVELOPERS PRIVATE LIMITED [Active] CIN = U70109WB1998PTC086581

Company & Directors' Information:- D Y DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201DL1996PTC084057

Company & Directors' Information:- S. R. K. DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45201DL1997PTC088685

Company & Directors' Information:- A J S DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC129171

Company & Directors' Information:- GAYATRI DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45201UP2004PTC029234

Company & Directors' Information:- S A V DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200PN2009PTC133464

Company & Directors' Information:- J V D DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200MH2004PTC145503

Company & Directors' Information:- H AND Z FINANCE PRIVATE LIMITED [Active] CIN = U67190MH1995PTC093153

Company & Directors' Information:- N. K. C. DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200WB2011PTC168155

Company & Directors' Information:- R. T. DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45400WB2008PTC127672

Company & Directors' Information:- S M DEVELOPERS PVT. LTD. [Active] CIN = U70101WB1989PTC046737

Company & Directors' Information:- M H DEVELOPERS PVT LTD [Active] CIN = U45201WB2006PTC109466

Company & Directors' Information:- P S DEVELOPERS PVT LTD [Strike Off] CIN = U45202WB1990PTC050298

Company & Directors' Information:- Y AND K FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U74899DL1985PTC019837

Company & Directors' Information:- S F G DEVELOPERS PRIVATE LIMITED [Active] CIN = U70101DL1997PTC089277

Company & Directors' Information:- S L P FINANCE PRIVATE LTD. [Strike Off] CIN = U65923DL1985PTC021970

Company & Directors' Information:- V M FINANCE LIMITED [Strike Off] CIN = U65910PB1996PLC018339

Company & Directors' Information:- D S K FINANCE LIMITED [Strike Off] CIN = U65910UP1988PLC010317

Company & Directors' Information:- G B V FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U65110UP1988PTC010219

Company & Directors' Information:- B H FINANCE PRIVATE LIMITED [Strike Off] CIN = U65922KA1995PTC018390

Company & Directors' Information:- M .R .S . FINANCE LIMITED [Strike Off] CIN = U65929DL1995PLC067184

Company & Directors' Information:- H D FINANCE LTD [Strike Off] CIN = U67120DL1986PLC023675

Company & Directors' Information:- P R K FINANCE P LTD [Strike Off] CIN = U65191TN1995PTC033478

Company & Directors' Information:- D D DEVELOPERS PRIVATE LIMITED [Active] CIN = U70109BR2007PTC024290

Company & Directors' Information:- T C G DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200MH2005PTC153314

Company & Directors' Information:- H R S DEVELOPERS LIMITED [Strike Off] CIN = U45209PB2010PLC033782

Company & Directors' Information:- U R K DEVELOPERS LIMITED [Active] CIN = U70101RJ1994PLC008179

Company & Directors' Information:- A S DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45201MH2007PTC175008

Company & Directors' Information:- J. D. J. DEVELOPERS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45400MH2012PTC237105

Company & Directors' Information:- A. K. A. DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400UP2007PTC033371

Company & Directors' Information:- K K R DEVELOPERS INDIA PRIVATE LIMITED [Strike Off] CIN = U45203TG2011PTC077776

Company & Directors' Information:- HERITAGE CORPORATION INDIA LIMITED [Strike Off] CIN = U70102UP2012PLC053644

Company & Directors' Information:- J A DEVELOPERS PRIVATE LIMITED [Active] CIN = U45202WB1999PTC090575

Company & Directors' Information:- M AND R DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45400JK2012PTC003492

Company & Directors' Information:- J S O DEVELOPERS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U45400DL2008PTC185170

Company & Directors' Information:- D G M DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200HR2008PTC037623

Company & Directors' Information:- R R DEVELOPERS PVT LTD [Active] CIN = U45203TG1989PTC010727

Company & Directors' Information:- N S M DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200DL2008PTC175372

Company & Directors' Information:- T AND C FINANCE LIMITED [Strike Off] CIN = U67120RJ1996PLC012576

Company & Directors' Information:- B S DEVELOPERS PRIVATE LIMITED [Converted to LLP] CIN = U45102MH2006PTC158721

Company & Directors' Information:- W S FINANCE PRIVATE LIMITED [Strike Off] CIN = U65192UP1996PTC020243

Company & Directors' Information:- J. M. DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200DL2007PTC159432

Company & Directors' Information:- S A C FINANCE COMPANY PVT LTD [Active] CIN = U65999WB1985PTC039002

Company & Directors' Information:- M B DEVELOPERS PVT LTD [Strike Off] CIN = U70101WB1990PTC049368

Company & Directors' Information:- S. M. DEVELOPERS PVT. LTD. [Strike Off] CIN = U70102WB1995PTC072333

Company & Directors' Information:- N. A. K. DEVELOPERS PVT. LTD. [Strike Off] CIN = U45201WB1997PTC085737

Company & Directors' Information:- N A E DEVELOPERS PVT LTD [Strike Off] CIN = U45201WB1997PTC085738

Company & Directors' Information:- S G DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400DL2008PTC178891

Company & Directors' Information:- G AND A DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200MH2003PTC141220

Company & Directors' Information:- K K DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400UP2007PTC034070

Company & Directors' Information:- M A DEVELOPERS PRIVATE LIMITED [Active] CIN = U45201MH2003PTC143483

Company & Directors' Information:- M N G DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200MH1999PTC119682

Company & Directors' Information:- M M K DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200MH2005PTC155110

Company & Directors' Information:- B C S DEVELOPERS PRIVATE LIMITED [Active] CIN = U70100MH2005PTC154047

Company & Directors' Information:- A R H DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45400UP2010PTC042708

Company & Directors' Information:- G M K DEVELOPERS PRIVATE LIMITED [Active] CIN = U70102TG2006PTC050871

Company & Directors' Information:- P S DEVELOPERS (INDIA) PRIVATE LIMITED [Active] CIN = U45200WB2007PTC113366

Company & Directors' Information:- P A DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400WB2008PTC124648

Company & Directors' Information:- M. J. DEVELOPERS PRIVATE LIMITED [Active] CIN = U45400WB2011PTC166506

Company & Directors' Information:- G D DEVELOPERS PVT LTD [Active] CIN = U70101WB1988PTC043611

Company & Directors' Information:- M R DEVELOPERS PVT LTD [Active] CIN = U70101WB1995PTC072428

Company & Directors' Information:- G M DEVELOPERS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45203AR2012PTC008356

Company & Directors' Information:- B & Z DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U70101AS2004PTC007611

Company & Directors' Information:- A C T DEVELOPERS PVT LTD [Active] CIN = U99999DL1980PTC011066

Company & Directors' Information:- G S K DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45201DL2006PTC146440

Company & Directors' Information:- UNION DEVELOPERS PRIVATE LIMITED [Active] CIN = U45200DL2007PTC160195

Company & Directors' Information:- D D V DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U70101DL2005PTC136378

Company & Directors' Information:- T M J DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U70101KA2011PTC058190

Company & Directors' Information:- S R E LIFESTYLES PRIVATE LIMITED [Strike Off] CIN = U52100KA2010PTC056316

Company & Directors' Information:- C C FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1997PTC037805

Company & Directors' Information:- DELHI DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U70101DL1993PTC052594

Company & Directors' Information:- S R B FINANCE LIMITED [Strike Off] CIN = U65910UP1988PLC010045

Company & Directors' Information:- P V FINANCE PRIVATE LIMITED [Strike Off] CIN = U65993DL1987PTC027270

Company & Directors' Information:- R V S FINANCE PRIVATE LIMITED [Strike Off] CIN = U65990KA1995PTC018436

Company & Directors' Information:- A B P DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U70109DL1991PTC046395

Company & Directors' Information:- L R DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45201WB1997PTC084844

Company & Directors' Information:- P AND B FINANCE PVT LTD [Strike Off] CIN = U99999MH1986PTC038841

Company & Directors' Information:- B B P FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U65921PB1996PTC018183

Company & Directors' Information:- H AND R BLOCK (INDIA) PRIVATE LIMITED [Strike Off] CIN = U00892PN2006PTC128344

Company & Directors' Information:- P N DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200MH1998PTC115864

Company & Directors' Information:- NEW INDIA FINANCE LTD. [Strike Off] CIN = U65999WB1991PLC051652

Company & Directors' Information:- B. C. B. DEVELOPERS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U45400WB2008PTC125472

Company & Directors' Information:- A E FINANCE PRIVATE LIMITED [Active] CIN = U65999TZ1990PTC002905

Company & Directors' Information:- J L DEVELOPERS PVT LTD [Strike Off] CIN = U45201WB1980PTC032702

Company & Directors' Information:- M. H. DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200DL2006PTC154692

Company & Directors' Information:- L R FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U65910UP1988PTC009758

Company & Directors' Information:- S B M FINANCE LIMITED [Strike Off] CIN = U65921PB1994PLC014374

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Company & Directors' Information:- V Y P DEVELOPERS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC066375

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Company & Directors' Information:- R S DEVELOPERS PVT LTD [Active] CIN = U70101CH1990PTC010274

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Company & Directors' Information:- A P R DEVELOPERS PRIVATE LIMITED [Active] CIN = U74899DL1996PTC079445

Company & Directors' Information:- N A DEVELOPERS PRIVATE LIMITED [Active] CIN = U70109DL2006PTC152389

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Company & Directors' Information:- D & C DEVELOPERS PRIVATE LIMITED [Active] CIN = U70101GJ2009PTC056789

Company & Directors' Information:- J K DEVELOPERS PVT LTD [Strike Off] CIN = U45201GJ1995PTC026279

Company & Directors' Information:- C T S DEVELOPERS PRIVATE LIMITED [Amalgamated] CIN = U45201GJ2004PTC045082

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Company & Directors' Information:- NEW INDIA CORPORATION PRIVATE LIMITED [Strike Off] CIN = U36999TN1940PTC001776

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Company & Directors' Information:- A R FINANCE PVT LTD [Strike Off] CIN = U65921PB1989PTC009778

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Company & Directors' Information:- K. K. P. DEVELOPERS PRIVATE LIMITED [Strike Off] CIN = U45200MH1997PTC110743

Company & Directors' Information:- L.T.D DEVELOPERS PRIVATE LIMITED [Active] CIN = U70109HR2017PTC069072

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    Writ Petition (ST.) No. 3705 of 2020

    Decided On, 05 November 2020

    At, High Court of Judicature at Bombay

    By, THE HONOURABLE MR. JUSTICE UJJAL BHUYAN & THE HONOURABLE MR. JUSTICE ABHAY AHUJA

    For the Petitioner: Bharat Raichandani i/b M/s. UBR Legal, Advocates. For the Respondents: R1, R2 & R4 to R10, Pradeep S. Jetly, Senior Advocate with Jitendra Mishra, Advocate.



Judgment Text

Abhay Ahuja, J.1. Heard. Rule. Rule made returnable forthwith. By the consent of the Counsel for the parties, the matter is taken up for final hearing.2. Being aggrieved and dissatisfied by the inaction on the part of the Respondent authorities in not giving Input tax credit to the claim of the Petitioner pursuant to the Board Circular No. 39/13/2018-GST dated 3rd April, 2018, the Petitioner has sought to not only challenge the said inaction but also to challenge the vires of Rule 117 and Rule 118 of the Central Goods and Service Tax Rules, 2017 as null and void and ultra vires Section 140 (1), Section 140 (3) and Section 9 of the Central Goods and Services Tax Act, 2017 and Article 14, 19, 246, 248, 265, 268A, 286 and 302 read with entry 41 and 83 of list 1 of Schedule VII of the Constitution of India and as also being beyond the legislative competence of the Parliament under Article 269-A of the Constitution of India and has prayed for the following reliefs:-(a) that this Hon'ble Court may be pleased to issue Any writ, order or direction more particularly in the nature of a Writ of Declaration to declare Rule 117 and Rule 118 of Central Goods and Service Tax rules 2017 as null, void and ultra vires of Section 140(1), Section 140(3) and Section 9 of Central Goods and Service tax Act 2017 and Article 14, 19, 246, 248, 265, 268A, 286 and 302 read with Entry 41 and 83 of List 1 of VII Schedule of the Constitution of India and as also being beyond the legislative competence of Parliament under Article 269A of the Constitution of India in so far as it is impugned and pass such further or other orders as this Hon'ble Court may deem fit and necessary in the facts and circumstance of the case and thus render justice;(b) that this Hon'ble Court be pleased to issue a Writ of Certiorari or a writ in the nature of Certiorari or any other writ, order or direction under Article 226 of the Constitution of India calling for the records pertaining to the Petitioner's case and after going into the validity and legality of the provisions, direct the Respondents to pass such directions to allow the petitioner to file Tran-1 electronically and carry forward the eligible cenvat credit in the electronic credit ledger/ Input tax credit account;(c) that this Hon'ble Court be pleased to issue a writ of mandamus or any other writ in the nature of Certiorari or any other writ, order or direction under Article 226 of the Constitution of India calling for the records pertaining to the Petitioner case and direct Respondents to either accept copy of TRAN-1 in physical form and give due credit from back end or allow to file the declaration under TRAN-1 electronically and reflect the said input tax credit in the electronic credit ledger / input tax credit account.3. It is submitted that the Petitioner is a Private limited company, inter-alia engaged in the business of construction and development of real estate for the purpose of sale to prospective buyers and is registered as a dealer under the provisions of the Maharashtra Value Added Tax Act, 2002 (the “MVAT Act”) as well as registered under the provisions of the Central Goods and Services Tax Act, 2017 (“CGST Act”) as a ‘service provider’ and also as “registered dealer”.4. It is submitted that under the pre-GST regime, the Petitioner was paying Service tax on the services and filing returns. It was therefore availing credit/set off of service tax paid on input service. Under the pre-GST regime, the Petitioner was also paying MVAT on the sale of goods, filing returns and also availing credit/set off of MVAT.5. Post introduction of the CGST Act, 2017 with effect from 01.07.2017, pursuant to the transitional provisions contained in Chapter XX of the CGST Act, 2017 as well as under Chapter XX of the Maharashtra Goods and Services Tax Act, 2017 (“MGST Act”), the Petitioner was entitled to carry forward Input tax credit as on 30.06.2017 in the TRAN-1 form for the period from 01.07.2016 to 30.06.2017 totaling an amount of Rs. 79,44,237.61/-, under Section 140 of the CGST Act read with Rule 117 of the CGST Rules and Rule 118 of the MGST Rules.6. Petitioner submits that Section 140 of the CGST Act read with Rule 117 of the CGST Rules requires a migrated registered supplier to file a declaration (in electronic form) under form TRAN–1 intimating/disclosing details of CENVAT credit of tax paid on inputs, capital goods, input services in order to carry forward the same to the electronic credit ledger/input tax credit account under the CGST Act, 2017. The declaration/form was required to be filed within a period of 90 days from the appointed date i.e. 01.07.2017, which time limits were extended to 27.12.2017, then to 31.03.2019 and finally to 31.12.2019. It is submitted that the said form TRAN–1 was notified in August, 2017 and the online functionality to file the said form was deployed on GST portal only on 21.08.2017.7. It is submitted that the Petitioner could not file the TRAN–1 by 27.12.2017 due to lack of awareness of the procedures, technical glitches, GST being new and a complex system to operate. The Petitioner has annexed screenshot being Exhibit-H to the Petition to demonstrate technical glitches.8. It is submitted by the Petitioner that upon inquiry about the form TRAN–1, the Petitioner was assured that sufficient time would be provided and further extension beyond 27th December, 2017 would be granted as there were lots of other extensions taking place in the implementation of various modules/forms of GST.9. Petitioner then wrote a letter dated 7.5.2018 to Respondent No. 5 informing the latter that it was unable to fill up and file TRAN–1 form within the appointed due time. Petitioner also drew the attention of Respondent No. 5 towards CBIC Circular dated 3.4.2018, wherein opportunity to file TRAN-1 was given to all assessees who were unable to file the TRAN-1 due to technical difficulties and to make an application for the redressal of grievances. By the said letter, Petitioner provided details as per Circular No. 39/13/2018-GST dated 03.04.2018 and requested Respondent No. 5 to redress its grievances.10. It is submitted that vide letter dated 18.05.2018, Respondent No. 7 requested the Petitioner for documents/information which were provided to the said Respondent vide letters dated 18.05.2018 and 21.05.2018.11. It is the case of the Petitioner that vide letter dated 24.05.2018, Respondent No. 7 after due verification of the claim of the Petitioner relating to CENVAT Credit/ITC forwarded the application for further disposal to Respondent No. 8 inter-alia stating that the application has been filed by the tax payer on 7.5.2018, which was within the stipulated date i.e. 10.05.2018 as extended by the Bombay High Court.12. It is submitted that vide E-mail dated 18.09.2018, Respondent No. 5 wrote to the GSTN Nodal Officer seeking to know the status of the application.13. Further by letter dated 25.09.2018, Petitioner wrote letter to Respondent No. 9 stating that since it was unable to file TRAN-1 due to technical glitches it had submitted TRAN-1 manually for verification and requested Respondent No. 9 to activate TRAN-1 portal to enable Petitioner to file TRAN-1 electronically and to claim credit in electronic credit ledger.14. Vide letters dated 11.12.2018, 12.12.2018 and 31.03.2019, Petitioner sent reminders to the Respondents with respect to its application made pursuant to the CBIC circular dated 3.04.2018.15. Petitioner submits that since the Petitioner has not received any clarity from the Respondents with regard to the carry forward of the CENVAT credit in respect of its application, it has been left with no option but to file the present Petition as a result of the hardship caused to the Petitioner. Petitioner has also raised grounds challenging the vires of Rule 117 and Rule 118 of the CGST Rules as ultra vires Sections 140 (1), 140 (3) and Section 9 of the CGST Act as well as ultra vires the Constitution of India as mentioned above.16. Respondents have filed reply submitting that the issue involved in the Petition is no more res-integra and is covered by the Judgment dated 20.03.2020 passed by this Court in the case of NELCO Limited V/s Union of India and Ors. (Writ Petition No. 6998 of 2018). It is submitted that Petitioner’s application for manual GST TRAN-1 dated 7.5.2018 pursuant to the Board Circular No 39/13/2018-GST dated 3rd April, 2018 was sent for verification to the Additional Commissioner, Nodal Officer IT Grievance Redressal (ITGRC) Mechanism , CCO, CGST and Central Excise, Mumbai Zone for further action. However, the Petitioner’s application was not approved by the ITGRC under the category description “The Tax Payer has neither tried for saving/submitting or filing TRAN-1”.17. In the affidavit-in-reply it has also been stated that though the Petitioner was found to be eligible for credit amounting to Rs. 78,62,466/-, it was denied by ITGRC as there was no log of such attempt made by it.17.1. Petitioner has filed affidavit in rejoinder stating that the NELCO decision (Supra) is not applicable to the facts of the present case as the same are distinguishable on facts.18. Mr. Raichandani, learned counsel for the Petitioner has specifically drawn our attention to Exh. “N” to the Writ Petition being communication dated 24.5.2018 to submit that the application of the Petitioner for manual GST TRAN-1 in terms of the said circular dated 3.4.2018 which has been filed within time has been verified by the jurisdictional office. He would submit that when Respondents themselves have verified the input tax credit due to the Petitioner and when the Respondents themselves have found that the Petitioner is eligible for credit amounting to Rs. 78,62,466/-, then a technicality raised by ITGRC cannot deprive the Petitioner of the due credit in its credit ledger and prays that this Petition be accordingly allowed. Learned counsel for the Petitioner has relied upon the Supreme Court decision in the case of Mangalore Chemicals and Fertilizers Ltd. Vs. Deputy Commissioner [1991 (55) ELT 437 (SC)].19. On the other hand, Mr. Jetley, learned counsel for the Respondents would submit that the said circular has been issued only to address the difficulties due to technical glitches on the GST Portal in respect of tax payers who were not able to complete TRAN-1 procedure before 27.12.2019 which is not the case of the Petitioner here. He reiterates that in fact ITGRC has clearly denied eligibility of input tax credit to the Petitioner on the ground that the tax payer has neither tried for saving/submitting or filing TRAN-1.20. We have heard learned counsel Shri Bharat Raichandani for the Petitioner and Shri Pradeep Jetley alongwith Shri J. B. Mishra for the Respondents. We have also perused the papers and proceedings in this Petition.21. This is a case, where admittedly Petitioner could not file GST TRAN-1 on or before 27.12.2017 but had manually applied for GST TRAN-1 on 7.5.2018 as per Circular dated 03.04.2018 within the timeline as per the date extended by this Court. Also admittedly the Respondents have found the Petitioner to be eligible for credit amounting to Rs. 78,62,466/-. But the credit for the same has been denied as the ITGRC found that the Petitioner has not tried to save or submit or file TRAN-1 before 27.12.2017. We are informed by the learned counsel for the Petitioner which is not controverted by the learned Sr. counsel for the Respondents that this information of rejection of the Petitioner’s application for manual GST TRAN-1 has not been communicated to the Petitioner despite several reminders/ communications from the Petitioner and it is only by way of the affidavit in reply filed to this Petition that the Petitioner has become aware of the rejection.22. Be that as it may, it is true that the above circular has been issued keeping in mind cases where difficulties have been faced by a section of tax payers owing to technical glitches on the GST Portal. However, the facts of this case are peculiar in as much as the respondents themselves admitted that the Petitioner is eligible for input tax credit but have rejected the claim because the ITGRC has not approved it saying that the tax payer has neither tried for saving/submitting or filing TRAN-1. There is no further explanation or clarification on this issue by the Respondents except to state the ITGRC description viz. “The tax payer has neither tried for saving/submitting or filing TRAN- 1”. Therefore it would be not necessary for us to even deal with the Circular under which the application for manual TRAN-1 has been made. When there is no dispute to the fact that the Petitioner is otherwise eligible for credit of Rs. 78,62,466/- then to deny the benefit of such Input credit merely on technical grounds cannot be justified. Merely on technical ground an admitted input credit is sought to be denied to the Petitioner. That according to us would be wholly unfair and a travesty of justice. It is in these facts and circumstances that we are compelled to invoke our writ jurisdiction in this case.23. In this context, we would like to refer to the Supreme Court decision in the case of Mangalore Chemicals and Fertilizers Ltd. Vs. Deputy Commissioner (Supra). That was a case where there was no dispute that the appellant was entitled to the benefit of an exemption under notification dated 30.06.1969 nor there was a dispute that the refunds were eligible to the adjusted against sales tax payable for respective years, but the only controversy was whether the appellant not having actually secured “prior permission” would be entitled to adjustment having regard to the words of notification of 11th August 1975, that until permission of renewal is granted by the Deputy Commissioner of Commercial Taxes, the new industry should not be allowed to adjust the refunds. Hon’ble Supreme Court aptly summarized the contention as under:-“The contention virtually means this : “No doubt you were eligible and entitled to make the adjustments. There was also no impediment in law to grant you such permission. But see language of Clause 5. Since we did not give you the permission you cannot be permitted to adjust” Is this the effect of the law?” 24. After considering the arguments of the counsel and after considering its own decisions in various cases including the decision in the case of Kedarnath Jute Manufacturing Co. V/s. Commissioner of Income Tax, Supreme Court allowed the appeal while quoting Lord Denning [in the case of Wells Vs. Minister of Housing and Local Government: 1967 (1) WLR 1000 ] as under :“Now I know that a Public Authority cannot be estopped from doing its public duty, but I do think it can be estopped

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from relying upon a technicality and this is a technicality”.25. Supreme Court also quoted Francis Bennion in his “Statutory Interpretation”, 1984 edition at page 683 as under:“Unnecessary technicality : Modern Courts seek to cut down technicalities attendant upon a statutory procedure where these cannot be shown to be necessary to the fulfillment of the purposes of the legislation.” 26. The above decision and particularly the above quotes to our mind aptly describe the situation at hand.27. In view of our above discussion, as admittedly in this case the Respondents have found the Petitioner to be eligible for input credit amounting to Rs. 78,62,466/-, in our view the finding of the ITGRC would in the face of the admission by the Respondents to the amount of credit, would be a mere technicality which cannot come in the way of substantial justice.28. Accordingly, we direct the Respondents to accept the TRAN-1 filed by the Petitioner and to give the due of input tax credit of Rs. 78,62,466/- in the electronic credit ledger/input tax credit of the Petitioner within two weeks from the date of this order.29. In view of our above order, we do not consider it necessary to examine the Petitioner’s challenge to the vires of Rules 117 and 118 of the Central Goods and Services Tax Rules, 2017.30. The Petition is accordingly allowed in the above terms. However, there shall be no order as to costs.31. This order will be digitally signed by the Personal Assistant of this Court. Associate of this Court is permitted to forward the parties copy of this order by email. All concerned to act on digitally signed copy of this order.
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