(1.) Heard Mr. Tushar Jarwal, learned counsel appearing on behalf of Mr. Mamilla Ashwin Reddy, learned counsel for the petitioner and Mr. K.Raji Reddy, learned Senior Standing Counsel, Commercial Tax for the respondents.
(2.) By filing this petition under Article 226 of the Constitution of India, petitioner has challenged legality and validity of the order dtd. 4/2/2022 issued by the 3rd respondent levying total tax (CGST + SGST) of Rs.2,21,38,236.40 for the audit period April, 2019 to March, 2020 as well as the consequential notice dtd. 8/6/2022.
(3.) Petitioner before us is a private limited company registered under the provisions of the Companies Act, 1956, having its registered office at Bengaluru in the State of Karnataka though it has its business presence in various States including the State of Telangana. Petitioner under the trade name 'Ola' is engaged in the business of providing internet platform/mobile application services where the driver partners provide passenger transportation services to the customers. It is clarified that petitioner per se is not engaged in providing passenger transportation service. It is only providing an electronic platform to the driver partners and to the customers.