ORDER : Krishnan Ramasamy, J. These writ petitions have been filed challenging the four impugned orders dated 22.10.2024 and one impugned order dated 23.10.2024 passed by the respondent. 2. The learned Senior counsel appearing for the petitioner would submit that in these cases, the petitioner, being a club, is exempted from payment of tax for the sale of liquors to its members. Due to some suspicion, the respondents had conducted a surprise inspection at the petitioner's premises on 18.07.2023 and subsequently, the show cause notice was issued by the respondent by alleging that the petitioner has sold the liquors to the outsiders, who are other than its members. However, the respondent had not produced any oral or documentary evidences to substantiate the said allegation. For the said show cause notice, a reply was filed by the petitioner, wherein it has been stated that the petitioner had obtained FL-2 license to serve liquor to its members, for which they are exempted from the payment of tax and accordingly, they had sold the liquors only to its members and not to the outsiders. However, without considering the same, the impugned orders came to be passed by the respondent. 3. Further, he had also referred to the judgement of the Hon'ble Supreme Court in State of West Bengal vs. Kolkata Club reported in (2019) 19 SCC 107 , wherein it has been held that the social clubs are not liable to pay any tax for the sale of liquors to its members. Hence, he requests this Court to set aside the impugned orders passed by the respondent. 4. On the other hand, the learned Special Government Pleader and the learned Standing counsel appearing for the respondents had strongly opposed the submissions made by the petitioner and would submit that there is no dispute on the aspect that the petitioner is exempted from the payment of tax for the sale of liquors to its members. However, in this case, the liquors were sold by the petitioner not only to its members but also to the outsiders, who are other than members. The said aspect came to the knowledge of the respondent at the time of inspection conducted by them at petitioner's premises on 18.07.2023. Subsequently, the show cause notice came to be issued by the respondent, for which the reply was filed by the petitioner. The said aspect came to the knowledge of the respondent at the time of inspection conducted by them at petitioner's premises on 18.07.2023. Subsequently, the show cause notice came to be issued by the respondent, for which the reply was filed by the petitioner. However, in the said reply, they had not denied the allegations made by the respondent. Under these circumstances, the impugned order came to be passed on 22.10.2024. 5. In reply, the learned Senior counsel appearing for the petitioner would submit that the allegations made by the respondents were not supported by any oral or documentary evidences and hence, the petitioner was unable to file any detailed reply for those bald allegations. Further, he would contend that in absence of any evidences, the respondents were not supposed to pass the impugned order. Hence, he requests this Court to set aside the said impugned order. 6. Heard the learned counsel for the petitioner and the learned Special Government Pleader and the learned Standing counsel appearing for the respondents and also perused the materials available on record. 7. In these cases, there is no dispute on the aspect that the petitioner, being a social club, had obtained FL-2 licence for selling liquors to its members, for which they are exempted from payment of tax. The said aspect was fairly admitted by both the parties. 8. Though the petitioner is exempted from payment of tax for sale of liquor to its members, it does not mean that the respondent will not have any power to make inspection at the petitioner's premises to verify as to whether the liquors are sold only to the members or not. If there is any suspicion with regard to the sale of liquors to the outsiders, certainly, the respondent is empowered inspect the petitioner's premises. Accordingly, the inspection was conducted on 18.07.2023, whereby the respondents had come across and obtained some evidences to show that the petitioner has sold the liquors to the outsiders, who are other than its members. 9. However, while issuing the show cause notice, the respondent had not produced any of the evidences, either documentary or oral, to substantiate their allegations against the petitioner. Normally, an allegation has to be supported by any documentary or oral evidences. Any allegation, without such evidences, will only be considered as bald allegations. 9. However, while issuing the show cause notice, the respondent had not produced any of the evidences, either documentary or oral, to substantiate their allegations against the petitioner. Normally, an allegation has to be supported by any documentary or oral evidences. Any allegation, without such evidences, will only be considered as bald allegations. In these cases, no evidences or proofs have been produced by the respondent to substantiate their allegations and hence, in the absence of such evidences or proofs, the petitioner was unable to file a suitable reply for the show cause notice issued by the respondents. Under these circumstances, the impugned order came to be passed by the respondent. Hence, it is clear that the said impugned order has been passed by the respondents, in non-application of mind, without any basis. 10. Therefore, this Court is of the considered view that the said impugned order is liable to be set aside. Accordingly, this Court passes the following order: i) The impugned orders dated 22.10.2024 & 23.10.2024 are set aside and the matters are remanded back to the 1 st respondent for fresh consideration. ii) The petitioner is directed to file their reply along with all the relevant documents, within a period of 4 weeks from the date of receipt of a copy of this order. iii) Thereafter, the respondent is directed to consider the reply filed by the petitioner and pass fresh orders, after providing sufficient opportunity to the petitioner, as expeditiously as possible. 11. With the above directions, these writ petitions are disposed of.No costs. Consequently, the connected miscellaneous petitions are also closed.