Writ interference with fiscal show-cause notices remains exceptional, though limited abeyance may be granted pending circular clarification.

Interference with a fiscal show-cause notice in writ jurisdiction is exceptional and is ordinarily refused unless there is want of jurisdiction, reopening of a settled position, prejudgment, or mala fides. The challenged notice did not fall within those narrow exceptions, so it was not quashed. However, because the dispute depended on the applicability of the customs drawback circular in the post-GST period and clarification from the departmental board was expected, the notice was kept in abeyance for eight weeks as limited protective relief.

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Issues: Whether a show-cause notice in a fiscal matter ought to be quashed in writ jurisdiction, and whether limited protective relief could be granted pending clarification from the departmental board.

Analysis: Interference with a show-cause notice under writ jurisdiction is exceptional and ordinarily unwarranted. In fiscal matters, the rule against interference is applied with particular rigour, and quashing is justified only in rare situations such as want of jurisdiction, reopening of a settled position, prejudgment, or mala fides. The impugned notice did not satisfy any of those exceptions, so it was not liable to be quashed. At the same time, the controversy turned on the applicability of the relevant customs drawback circular in the post-GST period, and the departmental assurance that clarification would be issued justified a short protective suspension of the notice.

Conclusion: The challenge to the show-cause notice failed on merits, but the notice was kept in abeyance for eight weeks to enable clarification on the disputed circular and its post-GST applicability.

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