GST adjudication under a composite notice will not usually be interfered with in writ jurisdiction absent a manifest anomaly.

The Kerala HC declined to interfere with a composite show cause notice issued under Section 74 of the CGST Act where adjudication had already commenced on the basis of the taxpayer's reply. Because the taxpayer had been given participation in the process, including cross-examination, the Court found the apprehension of denial of an effective hearing to be premature. It also held that the writ court would not supervise the manner of adjudication or require separate orders for different financial years in the absence of a manifest anomaly. Any grievance against the final adjudication order was left to the statutory remedies under the GST law.

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Issues: Whether the writ petition challenging the composite show cause notice and seeking directions regarding the manner of adjudication, separate orders for different financial years, and further opportunity of hearing was liable to be entertained.

Analysis: The show cause notice was issued under Section 74 of the Central Goods and Services Tax Act, 2017 and the adjudication proceedings had already commenced on the basis of the petitioner's reply. The petitioner had also been granted an opportunity of cross-examination, and the apprehension that an effective hearing would not be granted was held to be premature. In these circumstances, the Court found no reason to direct the adjudicating authority as to how the proceedings should be conducted, and held that any grievance against the final adjudication order could be pursued under the remedies provided by the statute. The composite nature of the notice did not disclose any anomaly warranting interference under Article 226 of the Constitution of India.

Conclusion: The challenge to the show cause notice and the prayer for interference with the ongoing adjudication were rejected, and the writ petition was held to be without merit.

Final Conclusion: Judicial intervention was declined at the stage of pending adjudication, leaving the petitioner to pursue statutory remedies after the adjudication order, if necessary.

Ratio Decidendi: Where adjudication under the GST law has commenced and the taxpayer has been afforded participation including cross-examination, the writ court will ordinarily not interfere with the show cause notice or supervise the manner of adjudication in the absence of a manifest anomaly.

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