Section 174 of the CGST Act, 2017 — Transitional Provisions –- The appeals were filed from the common judgment dated 11.01.2019. By judgment of even date, two questions have been formulated for decision, which are, Whether Section 174(2) is ultra vires, beyond the legislative competence of the State Legislature and contrary to Section 19 of CAA 2016; whether Section 174(2) confers a right or a vested right or accrued right to proceed to reopen assessments for enforcing the legal obligation/liability arising before 16.09.2016 or not. The court observed that both the questions have been answered in decision dated 30.11.2022 against the Dealers and the very same points arise in the instant batch of appeals.

Held that:-The Hon’ble High Court dismissed the appeals.