Statutory appellate remedy prevails over writ review where IGST objections under Rule 28 require factual examination.

An order-in-original raising IGST demands was held to be challengeable through the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017, rather than by writ petition. The Court noted that the objections based on Rule 28 of the Central Goods and Services Tax Rules, 2017 and the CBIC circular involved detailed factual examination, which was better left to the appellate authority. It also observed that the appellate forum could examine the petitioner's contentions independently, without being influenced by the findings in the order-in-original. The writ petition was not entertained and the petitioner was relegated to the statutory appellate remedy.

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Issues: Whether the writ petition challenging the order-in-original raising IGST demands should be entertained when an efficacious statutory appeal was available, and whether the factual objections based on Rule 28 of the Central Goods and Services Tax Rules, 2017 and the CBIC circular required writ adjudication.

Analysis: The impugned order was appealable under Section 107 of the Central Goods and Services Tax Act, 2017. The objections raised required detailed factual examination on the applicability of Rule 28 of the Central Goods and Services Tax Rules, 2017 and the circular relied upon, which could appropriately be examined by the appellate authority. The Court also observed that the appellate forum could consider the petitioner's contentions without being influenced by the findings in the order-in-original.

Conclusion: The writ petition was not entertained and the petitioner was relegated to the statutory appellate remedy.

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