(1.) By this writ application under Article 226 of the Constitution of India, the writ applicant, a proprietary concern, through its proprietor, has prayed for the following reliefs:
(2.) It appears from the materials on record that a search was carried out under Section 67 of the Central Goods and Services Tax Act, 2017 [for short, 'the CGST Act, 2017'] at the office premises of the writ applicant situated at the Udhana Udhyog Nagar, Udhana, Surat. A panchnama dated 3rd April 2019 came to be drawn of the search which was undertaken. It appears that one Shri Rajesh Kumar Ohlan, a Senior Intelligence Officer, Directorate General of Goods and Services Tax Intelligence, DGGI, Ahmedabad Zonal Unit, Ahmedabad carried out the search in the presence of two panch witnesses. The panchnama is annexed at Annexure : 'B' (page : 20 of the paper book). After the search was carried out, a summons came to be issued under Section 70(1) of the CGST Act, 2017 by the office of the Deputy Commissioner of State Tax. The writ applicant herein replied to the said summon by letter dated 7th February 2020. The reply reads thus:
(3.) Thereafter, one another summons came to be issued dated 15th February 2020 under Section 70 of the CGST Act, 2017. The writ applicant once again replied to the said summons vide letter dated 17th February 2020. The reply reads thus: