Writ interference at show cause notice stage is inappropriate where GST liability turns on disputed facts and jurisdiction.

A writ challenge to show cause notices was not entertained at the notice stage where the dispute depended on factual questions about whether the transactions were high sea sales or were taxable under the Central and State GST laws. The jurisdictional objection itself required examination of the underlying documents, search and survey material, and the facts stated in the notices. Because the petitioner had an opportunity to reply and the statutory authorities had not yet decided the disputed issues, interference under Article 226 was considered inappropriate at that stage.

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Issues: Whether the writ petition challenging the show cause notices was liable to be entertained at the stage of notice in view of the disputed factual questions relating to the nature of the transactions and the alleged absence of jurisdiction.

Analysis: The challenge turned on whether the transactions were in the nature of high sea sales or were taxable under the Central and State GST enactments, which required examination of the underlying documents, the search and survey material, and the facts reflected in the notices. The Court noted that the jurisdictional objection itself depended on factual determination and that the petitioner had an opportunity to place its reply before the authority. In such circumstances, interference under Article 226 at the notice stage was considered inappropriate, particularly where the statutory authorities were yet to decide the disputed issues.

Conclusion: The writ petition was not entertained at the stage of issuance of the show cause notices and the petitioner was relegated to respond before the authorities.

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