Writ interference at show cause stage is exceptional when GST objections involve disputed facts and can be raised in adjudication.

A writ petition under Article 226 challenging a GST show cause notice raising disputed factual and statutory objections was not entertained because such matters should ordinarily be answered in the statutory adjudication process. The High Court held that objections that the penal provision came into force later and that the petitioner was not a taxable person could be raised before the adjudicating authority in reply to the notice. It applied the settled principle that writ interference at the show cause stage is exceptional, particularly where factual adjudication is required and an efficacious alternative remedy exists. The petitioner was relegated to contest the notice on merits before the competent authority.

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Issues: Whether a writ petition under Article 226 of the Constitution of India was maintainable to challenge a show cause notice raising disputed factual issues under the goods and services tax law.

Analysis: The petitioner challenged the notice on the ground that the relevant penal provision was brought into force later and that he was not a taxable person. The Court held that such objections could be raised before the adjudicating authority by filing a reply to the notice. It applied the settled principle that interference at the stage of a show cause notice is exceptional and that writ jurisdiction is not normally invoked where the controversy requires factual adjudication and an efficacious alternative remedy is available.

Conclusion: The writ petition was not entertained and the petitioner was relegated to pursue the objection and adjudication process under the statute.

Final Conclusion: The challenge to the show cause notice was declined at the threshold, leaving the statutory adjudication process open for the petitioner to contest the notice on merits.

Ratio Decidendi: A show cause notice involving disputed facts and statutory objections should ordinarily be answered in the statutory adjudication process, and writ interference is unwarranted in the absence of exceptional circumstances.

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