Jurisdiction under DGGI notice-allocation rules upheld, with remaining objections left for adjudication on the taxpayer's response.

Jurisdiction for adjudicating DGGI show cause notices was assessed under the circular framework governing allocation where multiple notices are issued and the highest demand is in a notice relating to a noticee registered at Thane. The court treated the challenged notice as falling within the allocation mechanism and, in light of Notification No. 02/2022-Central Tax conferring All India jurisdiction on specified Additional/Joint Commissioners, rejected the objection that the Additional/Joint Commissioner of Central Tax, Thane lacked jurisdiction. Other objections were not examined at the show cause notice stage and were left open for response before the adjudicating authority, which was required to pass a speaking order after considering all defences.

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Issues: Whether the Additional/Joint Commissioner of Central Tax, Thane had jurisdiction to adjudicate the impugned show cause notice in view of the circular governing DGGI notices and allocation of adjudication where multiple notices are issued and the highest demand is in a notice concerning a noticee registered at Thane.

Analysis: The challenge to jurisdiction was tested against the circular regime applicable to DGGI-issued show cause notices and the empowerment of specified Additional/Joint Commissioners of Central Tax with All India jurisdiction under Notification No. 02/2022-Central Tax dated 11.03.2022. On the statement that multiple notices had been issued and the highest proposed demand was in the notice issued to an entity registered at Thane, the case fell within the scope of the circular's allocation mechanism. The Court also declined to examine the remaining objections at the show cause notice stage, leaving them open for response before the adjudicating authority, who was required to pass a speaking order after considering all defences.

Conclusion: The objection that the Additional/Joint Commissioner of Central Tax, Thane lacked jurisdiction was rejected, and the matter was left to be adjudicated by the competent authority after considering the petitioner's response.

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