Constitutional challenge to IGST source rule treated as ultra vires after a connected petition decided the same issue.

An identical constitutional challenge to section 13(8)(b) of the Integrated Goods and Services Tax Act, 2017 was already decided in a connected writ petition on the same day, so no separate merits adjudication was required in the tagged petition. The impugned provision was treated as ultra vires and unconstitutional, and the writ petition was disposed of consistently with that earlier determination. The stated principle is that where a connected matter conclusively decides an identical challenge, the same legal consequence follows for the companion petition.

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Issues: Whether section 13(8)(b) of the Integrated Goods and Services Tax Act, 2017 is illegal, null and void, ultra vires and unconstitutional.

Analysis: The petition raised an identical constitutional challenge that had already been considered in a connected writ petition decided by a separate judgment and order on the same day. In view of that adjudication, no further independent order was required in this petition.

Conclusion: The challenge to section 13(8)(b) of the Integrated Goods and Services Tax Act, 2017 succeeded, and the provision was treated as ultra vires and unconstitutional.

Final Conclusion: The writ petition stood disposed of in line with the decision striking down the impugned provision.

Ratio Decidendi: Where an identical constitutional challenge is conclusively decided in a connected matter, the same legal consequence follows for the tagged petition without the need for separate merits adjudication.

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