GST investigation records need not be disclosed mid-inquiry; show-cause notices on works contract tax were sustained.

During an ongoing GST investigation, disclosure of the search warrant and internal order sheet was refused because the inquiry under the CGST framework had not reached finality and release of those records could reveal sources of information, impede further investigation, and prejudice possible prosecution. The petitioners were therefore not entitled to certified copies of those documents. Show-cause notices alleging non-payment of GST on works contract services were also upheld, as they were issued in the course of lawful departmental proceedings and were to be adjudicated by the competent tax authority. The writ petitions were dismissed in full and the departmental action was left undisturbed.

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Issues: (i) Whether the petitioners were entitled to certified copies of the search warrant and the order sheet/note sheet during the ongoing GST investigation; and (ii) whether the show-cause notices issued for alleged non-payment of GST on works contract services were liable to be interfered with.

Issue (i): Whether the petitioners were entitled to certified copies of the search warrant and the order sheet/note sheet during the ongoing GST investigation.

Analysis: The search was conducted under Section 67 of the Central Goods and Services Tax Act, 2017 and the inquiry continued thereafter under Section 70 of the Central Goods and Services Tax Act, 2017. The refusal to supply the requested documents was justified on the footing that the investigation had not reached finality and that disclosure of internal papers could reveal the source of information, affect the investigation, and prejudice possible prosecution. The Court accepted that mere issuance of a show-cause notice does not conclude the investigative process and that disclosure at that stage could impede further action.

Conclusion: The petitioners were not entitled to the certified copies sought, and the rejection of their request was upheld.

Issue (ii): Whether the show-cause notices issued for alleged non-payment of GST on works contract services were liable to be interfered with.

Analysis: The notices were issued after search and investigation and were intended to be adjudicated by the competent Central Tax authority. The Court found no illegality in the issuance of the notices and held that the departmental action was in accordance with law.

Conclusion: The show-cause notices were sustained and no interference was warranted.

Final Conclusion: The writ petitions failed in entirety, and the challenged departmental action was left undisturbed.

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