Writ interference against tax notices declined where service tax and GST liability raised disputed factual questions.

Where alleged service tax and GST liability turns on disputed facts, writ interference to quash a show cause notice and summons is ordinarily unwarranted, and the assessee must respond before the competent statutory authority. The writ court declined to intervene at the threshold because the controversy concerned whether the activities attracted tax under the Finance Act, 1994 and the CGST Act, 2017. The request for supply of documents was also left to be decided by the appropriate authority in accordance with law, and the petitioner was directed to participate in the pending proceedings.

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Issues: Whether the writ court should interfere to quash the show cause notice and summons issued in connection with alleged liability under the service tax and GST regimes, and whether the petitioner's request for supply of documents required interference.

Analysis: The proceedings arose from an inquiry into alleged non-discharge of liability under the Finance Act, 1994 and the Central Goods and Services Tax Act, 2017. The controversy involved disputed questions of fact, including whether the petitioner's activities attracted service tax and GST. In such a situation, the petitioner was required to respond before the competent statutory authority, and a writ petition was not the proper forum for quashing the notice and summons at the threshold. As to the pending request for documents, the appropriate authority was competent to decide it in accordance with law.

Conclusion: Interference was declined. The writ petition did not succeed and the petitioner was left to participate in the proceeding before the opposite parties.

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