Ravi Nath Tilhari, J.

1. Heard Sri G.Narendra Chetty, learned counsel for the petitioner and Sri S.A.V.Sai Kumar, learned Assistant Government Pleader for Commercial Tax appearing for the respondents 1 and 2.

2. This Writ Petition under Article 226 of the Constitution of India has been filed challenging the order of assessment passed by the 1st respondent under Section 73 of the State Goods and Services Tax Act and Central Goods and Services Tax Act, 2017, dated 27.02.2023 for the financial year 2020-21.

3. The order was appealable under Section 107 of the Act. A period of limitation prescribed is three months and in case of delay, if the appellate authority is satisfied with the cause shown, can condone the delay of one month only, after expiry of the limitation period under sub-section (4) of Section 107 of the Act.

4. Learned counsel for the petitioner submits that total period of limitation including the condonable period expired in the month of June, 2023. The appeal was not filed. This writ petition was filed in the month of December, 2025, after almost two and half years.

5. The impugned order passed under the statute had attained finality as the petitioner did not challenge the same.

6. Learned counsel for the petitioner tries to submit that there is explanation for the laches in filing the writ petition, as in para No.11, which is reproduced as under:

                  “I respectfully submit that, though the impugned Order is dated 27-02-2023, as stated above one of the J.V. Partners was already declared insolvent by the NCLT and is under liquidation and insolvency proceedings are pending against the other J.V. Partner against which Appeal was filed before NCLAT, Chennai, in which stay was granted, and due to the said litigation and various difficulties being faced by it due to non- payment of the full bill amounts and GST amounts by the Government Contractees, many of the employees of the Petitioner, including the Accountant who was looking after its tax affairs had left the service of the Petitioner, and the Petitioner could not take steps for challenging the impugned order. However, recently, the First Respondent has initiated coercive steps for recovery and issued Garnishee Notice vide Rc. No. 37AABTA4559P1Z6/2025, dated 16-09-2025, to the Executive Engineer, Nellore Central Division, Nellore/Fourth respondent herein, for whom the Petitioner has executed Works Contract, for recovery of the disputed tax, interest and penalty under the impugned order as well as some other amounts and therefore the Petitioner is now constrained to approach this Hon'ble High Court.”

7. The aforesaid explanation is without specifications. Even the dates have not been mentioned. The cause stated, in our view cannot said to be coming in the way of filing the appeal to challenge the impugned order. Even as per the explanation some other legal proceedings before appellate tribunal were taken. Then, the petitioner could certainly have taken legal recourse against the impugned order as well. The explanation does not inspire confidence into its genuineness or correctness. It does not amount to sufficient cause. The writ petition has been filed after almost two and half years of the order, which attained the finality under the statute. Laches are unexplained to the satisfaction of the Court.

8. In Neelima Srivastava v. State of Uttar Pradesh((2021) 17 SCC 693), the Hon’ble Apex Court reiterated that it is not permissible for the parties to reopen the concluded judgments of the Court as the same may not only tantamount to an abuse of the process of the Court but would have far reaching adverse effect on the administration of justice. Paragraph-35 of Neelima Srivastava(supra) reads as under:

                  “35. Thus, it is very well-settled that it is not permissible for the parties to reopen the concluded judgments of the court as the same may not only tantamount to an abuse of the process of the court but would have far-reaching adverse effect on the administration of justice.”

9. We, cannot in the exercise of writ jurisdiction, permit reopening of the matter for an order which attained finality long back under the statute.

10. We are not inclined to entertain the writ petition.

11. The Writ Petition is dismissed. There shall be no order as to costs.

As a sequel, interlocutory applications pending if any, shall stand closed.