Jurisdictional challenge to tax adjudication over alleged time-barred notice and demands beyond the original show cause notice.

The article concerns a challenge to an adjudication order on jurisdictional grounds, where the petitioner argued that a later show cause notice was issued after limitation and that the final demand exceeded the scope of the original notice. The original notice reportedly proposed only IGST, while the later notice introduced enhanced CGST and SGST demands. It was also contended that the impugned order dropped the IGST demand but imposed substantial CGST and SGST liability beyond the notice. The High Court directed a counter affidavit and granted interim protection by staying the operation of the adjudication order until the next date.

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Issues: Whether the adjudication order was without jurisdiction on the grounds that the subsequent show cause notice was issued after limitation and that the final demand travelled beyond the original show cause notice.

Analysis: The petitioner challenged the impugned adjudication on the basis that the original notice proposed only IGST demand, while the later notice introduced enhanced demands including CGST and SGST after the stated limitation period. It was further contended that the impugned order dropped the IGST demand but imposed substantial CGST and SGST demands far beyond the scope of the original notice. The matter was found to require consideration, and counter affidavit was called for.

Outcome: Interim protection was granted by staying the effect and operation of the adjudication order until the next date of listing.

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