Show Cause Notice

GEXCOM/ADJ/GST/0917/2025-Commr-CGST-Hyd · Dated 11.09.2025

Ashwattha Enclave Villa Owners Association, Kompally, Hyderabad, is hereby called upon to show cause as to why tax of Rs. 26,78,400 on maintenance charges collected from members in excess of Rs. 7,500 per member per month during April 2018 to March 2021 should not be demanded and recovered under Section 74(1) of the CGST Act, 2017, together with interest under Section 50 and a penalty equal to the tax.

(ii) why the Noticee should not be held liable for failure to obtain registration under Section 22 of the Act.

Reply to the Notice

DRC-06 · Filed 11.11.2025

The Noticee submits that the maintenance charge never exceeded Rs. 7,400 per villa per month, that contributions to the corpus fund are mutual contributions and not consideration for a supply, and that a single notice consolidating three financial years is bad in law.

The Noticee denies suppression and craves leave to be heard in person before any adverse order is passed.

Annexure A · Collections

Villa maintenance charges · FY 2018-19 to FY 2020-21

FY 2018-19	43,90,000	@18%	7,90,200
FY 2018-19 · club house	30,000	@18%	5,400
FY 2019-20	54,85,000	@18%	9,87,300
FY 2020-21	49,75,000	@18%	8,95,500
Total	1,48,80,000		26,78,400

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The problem

Sixteen years. No order.

A show cause notice issued in May 2008 was never adjudicated. Hearings were fixed four times across thirteen years. In October 2024 the Bombay High Court quashed it for delay the department could not explain.

2008Show cause notice issued on 16 May; replies filed; hearings fixed, none effective
2011A hearing fixed again in December; still no effective hearing
2017A hearing fixed again on 24 February, nine years on
2021A hearing fixed again on 25 February; no video link was provided
2024Quashed by the Bombay High Court on 24 October for inordinate, unexplained delay

Paresh H. Mehta v. Union of India, WP 14213 of 2023, Bombay High Court, 24 October 2024

In the High Court of Judicature at Bombay

Civil Appellate Jurisdiction

Writ Petition No. 14213 of 2023

Paresh H. Mehta, sole proprietor, M/s P. H. Mehta and Co. … Petitioner

versus

The Union of India and others … Respondents

Coram: M.S. Sonak & Jitendra Jain, JJ.24 October 2024

3. The Petition challenges the show cause notice dated 16 May 2008, pending adjudication before the Respondents for the last fifteen years.

8. Nothing was done on the notice for the next five years. On 24 February 2017, almost nine years after its issue, another hearing was scheduled. On 25 February 2021 another was scheduled; a video link was requested and none was provided.

16. The delay is inordinate and, moreover, unexplained. The affidavit filed by the Respondents does not explain it.

21. Accordingly, we quash and set aside the impugned show cause notice dated 16 May 2008 and restrain the Respondents from proceeding further based on it.

The problem, quantified

₹2.37lakh crore

GST evasion detected in FY 2023-24.

Source · DGGI Annual Report 2023-24

Detection has outrun adjudication. Every order that cannot be written in time becomes an appeal.

cases awaiting adjudication on adjudicators' desks: 20,576; cases awaiting adjudication on adjudicators' desks; DAKSH, State of Tribunals 2025
appeals pending across tax tribunals: 4.83 lakh; appeals pending across tax tribunals; GSTAT launch coverage, 2025
spent per case on drafting and corrections: 10 to 12hours; spent per case on drafting and corrections; Field estimate

The product

One document,
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01
Draft
Legally-reasoned orders composed section by section, in the adjudicator's own voice, every circular and precedent cited and verified.
/Ashwattha Enclave Villa Owners AssociationOIO / 2026 / 0147
DraftingExport order
SCN_0917.pdf 11 ppReply_DRC-06.pdf 7 pp
N
I have read the notice, the reply and the hearing note. One allegation: GST of ₹ 26,78,400 on villa maintenance charges collected above the ₹ 7,500 threshold, FY 2018-19 to FY 2020-21, under Section 74. Drafting the background, then the submissions.
N
Sections 1 to 5 are ready for your review. 11 authorities verified against the corpus; 0 unverified.
Ask for a change in plain language…
Government of India · Ministry of Finance
Office of the Additional Commissioner of Central Tax
F. No. GEXCOM/ADJ/GST/0917/2025DIN 20260613ZX000147AE
Order-in-Original
1. Background facts
Ashwattha Enclave Villa Owners Association, Kompally, Hyderabad, an unregistered association of villa owners, was issued Show Cause Notice GEXCOM/ADJ/GST/0917/2025-Commr-CGST-Hyd dated 11.09.2025 under Section 74 of the CGST Act, 2017, proposing recovery of ₹ 26,78,400 in tax on maintenance charges collected above ₹ 7,500 per member per month during April 2018 to March 2021, with interest and an equal penalty.
2. Submissions of the Noticee
The Noticee filed a written reply contesting the demand. It was submitted that the monthly charge never exceeded ₹ 7,400 per villa, that corpus contributions are not consideration for a supply, and that no suppression is made out.
3. Discussion and findings
Each contention is examined against the record and the governing provisions…
02
Refine
Change any section in plain language; every edit is the adjudicator's call.
/Ashwattha Enclave Villa Owners AssociationOIO / 2026 / 0147
DraftingExport order
SCN_0917.pdf 11 ppReply_DRC-06.pdf 7 pp
N
I have read the notice, the reply and the hearing note. One allegation: GST of ₹ 26,78,400 on villa maintenance charges collected above the ₹ 7,500 threshold, FY 2018-19 to FY 2020-21, under Section 74. Drafting the background, then the submissions.
N
Sections 1 to 5 are ready for your review. 11 authorities verified against the corpus; 0 unverified.
Make §2 firmer on the consolidation point. The reply says one notice for three years is bad in law.
SR
N
Revised §2. The consolidation objection is now recorded with the three years and the three Kerala decisions relied upon. Your call: approve, or edit further.
Ask for a change in plain language…
Government of India · Ministry of Finance
Office of the Additional Commissioner of Central Tax
F. No. GEXCOM/ADJ/GST/0917/2025DIN 20260613ZX000147AE
Order-in-Original
1. Background facts
Ashwattha Enclave Villa Owners Association, Kompally, Hyderabad, an unregistered association of villa owners, was issued Show Cause Notice GEXCOM/ADJ/GST/0917/2025-Commr-CGST-Hyd dated 11.09.2025 under Section 74 of the CGST Act, 2017, proposing recovery of ₹ 26,78,400 in tax on maintenance charges collected above ₹ 7,500 per member per month during April 2018 to March 2021, with interest and an equal penalty.
2. Submissions of the Noticee
The Noticee filed its written reply on 11.11.2025. It objects that a single notice consolidating FY 2018-19 to FY 2020-21 is bad in law, relying on Tharyil Medicals, Lakshmi Mobile Association and RA & Co; it contends that the monthly charge never exceeded ₹ 7,400 per villa, that corpus contributions are not consideration for a supply, and that no suppression is made out.
3. Discussion and findings
Each contention is examined against the record and the governing provisions…
03
Ask the Law
Put a question to the statute book and the case files; get a grounded, cited answer, every claim traced to source.
/Ashwattha Enclave Villa Owners AssociationOIO / 2026 / 0147
DraftingExport order
Ask the Law · GST corpus + case file
Once the monthly charge crosses ₹ 7,500 per member, is the whole amount taxable or only the excess?
The whole amount. Circular 109/28/2019-GST clarifies that where the contribution exceeds ₹ 7,500 per member per month the exemption is lost entirely, not merely on the excess¹.
The exemption at Sl. No. 77 of Notification 12/2017-CT (Rate) is read strictly, and the burden of proving entitlement lies on the association under Section 155². On this record the whole collection is taxable.
Sources
1CBIC Circular 109/28/2019-GSTCircular · 22 Jul 2019 · verified
2Notification 12/2017-CT (Rate), Sl. No. 77; Section 155, CGST ActNotification · Statute · verified
Government of India · Ministry of Finance
Office of the Additional Commissioner of Central Tax
F. No. GEXCOM/ADJ/GST/0917/2025DIN 20260613ZX000147AE
Order-in-Original
1. Background facts
Ashwattha Enclave Villa Owners Association, Kompally, Hyderabad, an unregistered association of villa owners, was issued Show Cause Notice GEXCOM/ADJ/GST/0917/2025-Commr-CGST-Hyd dated 11.09.2025 under Section 74 of the CGST Act, 2017, proposing recovery of ₹ 26,78,400 in tax on maintenance charges collected above ₹ 7,500 per member per month during April 2018 to March 2021, with interest and an equal penalty.
2. Submissions of the Noticee
The Noticee filed a written reply contesting the demand. It was submitted that the monthly charge never exceeded ₹ 7,400 per villa, that corpus contributions are not consideration for a supply, and that no suppression is made out.
3. Discussion and findings
Each contention is examined against the record and the governing provisions…
04
Vault
Every case, notice, and order in one encrypted, on-prem, searchable, audit-ready repository.
/Ashwattha Enclave Villa Owners AssociationOIO / 2026 / 0147
DraftingExport order
VaultSearch cases, notices, orders…14 open matters · 128 documents · on-prem
MatterTypeDemandStatusUpdated
Ashwattha Enclave Villa Owners AssociationOIO / 2026 / 0147Order-in-Original₹ 26.78 LDraft readyToday
M/s Ekthara Logistics Pvt. Ltd.OIO / 2026 / 0141Order-in-Original₹ 1.42 CrIn review08 Jun
M/s Chandravali Foods & BeveragesSCN / 2026 / 0093SCN response₹ 18.9 LIn review05 Jun
M/s Dhruvatara Infraprojects LLPOIO / 2026 / 0132Order-in-Original₹ 87.3 LFiled31 May
M/s Kalyanika TextilesOIO / 2026 / 0119Order-in-Original₹ 11.4 LFiled19 May

The product

One document,
four capabilities.

The product

01
Draft
Legally-reasoned orders composed section by section, in the adjudicator's own voice, every circular and precedent cited and verified.
02
Refine
Change any section in plain language; every edit is the adjudicator's call.
03
Ask the Law
Put a question to the statute book and the case files; get a grounded, cited answer, every claim traced to source.
04
Vault
Every case, notice, and order in one encrypted, on-prem, searchable, audit-ready repository.

Legally-reasoned orders composed section by section, in the adjudicator's own voice, every circular and precedent cited and verified.

/Ashwattha Enclave Villa Owners AssociationOIO / 2026 / 0147

DraftingExport order

SCN_0917.pdf 11 ppReply_DRC-06.pdf 7 pp

I have read the notice, the reply and the hearing note. One allegation: GST of ₹ 26,78,400 on villa maintenance charges collected above the ₹ 7,500 threshold, FY 2018-19 to FY 2020-21, under Section 74. Drafting the background, then the submissions.

Sections 1 to 5 are ready for your review. 11 authorities verified against the corpus; 0 unverified.

Make §2 firmer on the consolidation point. The reply says one notice for three years is bad in law.

Revised §2. The consolidation objection is now recorded with the three years and the three Kerala decisions relied upon. Your call: approve, or edit further.

Ask for a change in plain language…

Ask the Law · GST corpus + case file

Once the monthly charge crosses ₹ 7,500 per member, is the whole amount taxable or only the excess?

The whole amount. Circular 109/28/2019-GST clarifies that where the contribution exceeds ₹ 7,500 per member per month the exemption is lost entirely, not merely on the excess¹.

The exemption at Sl. No. 77 of Notification 12/2017-CT (Rate) is read strictly, and the burden of proving entitlement lies on the association under Section 155². On this record the whole collection is taxable.

Sources

1CBIC Circular 109/28/2019-GSTCircular · 22 Jul 2019 · verified
2Notification 12/2017-CT (Rate), Sl. No. 77; Section 155, CGST ActNotification · Statute · verified

VaultSearch cases, notices, orders…14 open matters · 128 documents · on-prem

MatterTypeDemandStatusUpdated

Ashwattha Enclave Villa Owners AssociationOIO / 2026 / 0147Order-in-Original₹ 26.78 LDraft readyToday

M/s Ekthara Logistics Pvt. Ltd.OIO / 2026 / 0141Order-in-Original₹ 1.42 CrIn review08 Jun

M/s Chandravali Foods & BeveragesSCN / 2026 / 0093SCN response₹ 18.9 LIn review05 Jun

M/s Dhruvatara Infraprojects LLPOIO / 2026 / 0132Order-in-Original₹ 87.3 LFiled31 May

M/s Kalyanika TextilesOIO / 2026 / 0119Order-in-Original₹ 11.4 LFiled19 May

Office of the Additional Commissioner of Central Tax

Hyderabad Commissionerate

GEXCOM/ADJ/GST/0917/2025-Commr-CGST-HydDated 11.09.2025

Show Cause Notice

Ashwattha Enclave Villa Owners Association, Kompally, Hyderabad, an unregistered association of villa owners, is hereby called upon to show cause to the Additional Commissioner of Central Tax, Hyderabad, within thirty days of receipt of this notice, as to why:

(i) tax of ₹ 26,78,400 (CGST ₹ 13,39,200; SGST ₹ 13,39,200) on maintenance charges collected from members in excess of ₹ 7,500 per member per month during April 2018 to March 2021 should not be demanded and recovered under Section 74(1) of the CGST Act, 2017;

(ii) interest under Section 50 and a penalty equal to the tax under Section 74(1) read with Section 122(2)(b) should not be imposed.

(Sd/-)
Additional Commissioner

Government of India · Ministry of Finance

Office of the Additional Commissioner of Central Tax

F. No. GEXCOM/ADJ/GST/0917/2025DIN 20260613ZX000147AE

Order-in-Original

1. Background facts

Ashwattha Enclave Villa Owners Association, Kompally, Hyderabad, an unregistered association of villa owners, was issued Show Cause Notice GEXCOM/ADJ/GST/0917/2025-Commr-CGST-Hyd dated 11.09.2025 under Section 74 of the CGST Act, 2017, proposing recovery of ₹ 26,78,400 in tax on maintenance charges collected above ₹ 7,500 per member per month during April 2018 to March 2021, with interest and an equal penalty.

2. Submissions of the Noticee

The Noticee filed a written reply contesting the demand. It was submitted that the monthly charge never exceeded ₹ 7,400 per villa, that corpus contributions are not consideration for a supply, and that no suppression is made out.

3. Discussion and findings

Each contention is examined against the record and the governing provisions…

The benchmark

Measured against the adjudicator.

Not invented examples. Orders real adjudicators have already signed are the answer key.

20minutes

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By hand: days to weeks.

The signed orderThe draft

Governing sectionSection 74=Section 74
Extended periodInvoked=Invoked
PenaltyEqual penalty · ₹ 26,78,400=Equal penalty · ₹ 26,78,400
Demand confirmed₹ 26,78,400=₹ 26,78,400
Operative decisionConfirmed=Confirmed, every run

One case from the corpus, anonymized. The same five lines hold on every case scored.

NDrafting · ¶ 5.1.10

Returned to the adjudicator

Paragraph 5.1.10 not drafted

The notice invokes the extended period, but the record before me shows non-registration and non-filing and no further positive act. On this material I cannot find intent to evade under Section 74, so I have not confirmed the demand of ₹ 26,78,400 on that footing. Paragraph 5.1.10 is left for your determination, with both readings set out.

Reading 1

Suppression established

Non-registration plus non-declaration of known receipts meets Explanation 2 to Section 74; the extended period and the equal penalty stand.

Reading 2

Not established

The case falls to Section 73: three-year limitation, and penalty of ten per cent of the tax or ₹ 10,000, whichever is higher.

Take the first readingTake the secondDraft 5.1.10 myselfawaiting SR

Fail-safe

When the system is not sure, it does not make things up. It puts the adjudicator back in charge, surfaces its reasoning, and works the question through with the adjudicator to the final answer.

It under-confirms rather than inventing a demand, so nothing ultra vires reaches a signature.

Figures are from the current evaluation corpus of real adjudicated cases scored against their signed orders; the corpus and per-dimension results grow each cycle. Taxpayer particulars in benchmark files are handled under strict confidentiality on Indian infrastructure.

Authority stays with the officer.The AI proposes; the officer decides,section by section, signature by signature.

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