GST: Can a single composite Order to company and it’s Managing Director survive?

Facts of the case:-

After a tax investigation, the authorities issued an order on December 30, 2025, that hit both Sugna Metal Limited and its Managing Director, Bharat Kumar Agarwal, with heavy penalties.

The order demanded over ₹2.2 crore for wrongly claimed tax credits and another ₹38 lakh for passing on credits without actually supplying goods. Because the tax office grouped the company and the Managing Director together in one single summary document (Form DRC-07), Mr. Agarwal found himself in a legal jam.

Since he isn’t personally registered for GST, he had no way to use the official system to file his own separate appeal against the ₹2.59 crore personal penalty they charged him. Essentially, he was being held personally liable but was blocked from defending himself in court because of a paperwork technicality.

Issue Involved In This Case

Whether a Managing Director who lacks personal GST registration be granted a temporary registration number to exercise their right to appeal, especially when a single composite order (Form GST DRC-07) was issued against both them and their company, effectively blocking them from filing a separate legal challenge?

Decision Of The Court :-

The Telangana High Court ruled that the Managing Director can request a temporary identification number under Rule 16A of the CGST (Amendment) Rules, 2025, affirming his right to appeal.

The Court ordered tax authorities to issue two separate revised summary orders in Form GST DRC-07—one for the Company and one for the Managing Director—within two weeks.

The appeal period will start only after these new orders are issued. Mr. Agarwal must apply for temporary registration within one week, and the authority must grant it within a week thereafter.