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WIPRO LIMITED v. THE STATE OF MAHARASHTRA & ORS. – BOMBAY HIGH COURT

High Court, Bombay
G.S. Kulkarni, Justice & Aarti Sathe, Justice

WIPRO LIMITED
v.
THE STATE OF MAHARASHTRA & ORS.

WRIT PETITION (L) No. 4983 of 2026 dated 12.02.2026

Law : GST
Act Name : Central Goods & Service Tax Act, 2017
Relevant Section : Section 75 & 79
Rule Number : Rule 88(C)
Rule Name : Central Goods & Services Tax Rules, 2017
Decision : In favour of assessee

Recovery proceedings – Challenge to DRC-01D intimation & garnishee notice under section 75(10)/79 CGST Act triggered by GSTR-1/GSTR-3B mismatch on credit notes issued as reported in GSTR-1 timely and adjusted in GSTR-3B Jul 2023 – Department initiated automated recovery despite petitioner detailed replies explaining time-barred/timely adjustments & willingness to furnish supporting documents – Bank accounts blocked pre-finalization – Court noted reputed taxpayer with no prior defaults, prior responses adequate prima facie, recovery disproportionate pending verification – Held: Garnishee notices withdrawn – Petitioner to submit complete details within 10 days – Department to examine & decide within 1 month with hearing opportunity.

Represented By:

Counsel for the Petitioner: V.Raghuraman, Senior Advocate, with Raghavendra CP, Sriraj G.Menon, Avesh Ganja, Sandesh Panchal i/by Satyaki Law Associates

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