Writ jurisdiction over tax show-cause notices is limited where jurisdictional objections can be examined by the issuing authority.

A writ petition challenging a demand-cum-show-cause notice is ordinarily not entertained unless the notice is shown to be without inherent jurisdiction. Jurisdictional objections based on the absence of a proper notification and the character of supply of ENA involved mixed factual and legal questions that were suitable for examination by the issuing authority. Executive correspondence from the State Government, by itself, was insufficient to establish GST exemption. The notice was therefore not treated as a nullity, and interference at the threshold was declined, leaving the petitioner to file objections before the authority.

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Issues: Whether interference was warranted with the order rejecting the writ petition challenging the demand-cum-show-cause notice and whether the petitioner could be relegated to respond before the statutory authority.

Analysis: A writ petition against a show-cause notice is ordinarily not entertained unless the notice is shown to be without inherent jurisdiction. The jurisdictional objection raised against the notice, including the contention based on absence of a proper notification and the nature of supply of ENA, involved factual and legal questions that could appropriately be examined by the authority issuing the notice. The petitioner's reliance on executive correspondence of the State Government could not, by itself, establish exemption from GST. The notice was therefore not treated as a nullity so as to justify interference at the threshold.

Conclusion: Interference with the order under appeal was declined, and the petitioner was left to submit objections before the authority.

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