Writ relief and GST demand challenge fail where the assessee bypasses appeal and cannot prove bona fide lack of knowledge.

Writ relief against a GST demand and attachment was refused because the assessee bypassed the statutory appellate remedy and did not file any appeal or even attempt to invoke it, moving only a rectification application. The Court did not accept the claim that the show cause notice and DRC-07 order were not communicated or that there was no knowledge of the proceedings, noting that the assessee continued to hold GST registration and was obliged to file regular returns. On that conduct, the Court treated the plea of ignorance as not bona fide and declined equitable interference, leaving the demand and attachment undisturbed.

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Issues: Whether the petitioner was entitled to judicial indulgence against the GST demand and attachment despite not challenging the order in appeal and asserting lack of knowledge of the notice and order.

Analysis: The petition turned on the petitioner's claim that the show cause notice and DRC-07 order were not properly communicated and that it had no knowledge of the proceedings. The Court found that no appeal had been filed and even no attempt to invoke the appellate remedy had been made; instead, only a rectification application was moved. In the circumstances, the assertion of lack of knowledge was not accepted, particularly where the petitioner continued to hold a GST registration and was required to file regular monthly and annual returns. The Court concluded that the conduct disclosed deliberate ignorance and that equity did not favour interference.

Conclusion: The petitioner was not entitled to any indulgence, and the challenge failed.

Final Conclusion: The writ petition was dismissed, leaving the GST demand and consequential attachment undisturbed.

Ratio Decidendi: A writ remedy will not ordinarily be granted where the assessee bypasses the statutory appellate remedy and fails to establish bona fide lack of knowledge of GST proceedings, especially when the surrounding conduct indicates deliberate ignorance.

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