GST cross-empowerment and disputed classification issues must be pursued in statutory appeal, not writ jurisdiction.

GST enforcement action may be initiated by either the Central or State tax administration notwithstanding the taxpayer's allocation to the other administration, and such cross-empowerment is not invalid on that ground alone. Where the dispute turns on contested questions of classification, alleged suppression, and the propriety of invoking Section 74, the proper course is to pursue the statutory appellate remedy rather than seek writ interference. The court's refusal to examine the merits in writ jurisdiction was therefore treated as appropriate, especially since the taxpayer had already replied to the notice and an efficacious appeal was available under the GST framework.

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Issues: Whether the assessment proceedings could be interfered with in writ jurisdiction on the grounds of cross-empowerment, jurisdiction, classification, and invocation of Section 74, or whether the appellant had to be relegated to the statutory appellate remedy.

Analysis: The appellant's challenge turned on disputed questions of fact relating to classification and the nature of the tax demand. The Court noted that intelligence-based enforcement action may be initiated by either the Central or the State tax administration despite the taxpayer being assigned to the other administration. It further noted that the challenge to the conclusion of suppression and the consequent invocation of Section 74 involved matters that could be examined on appeal, especially where the appellant had already submitted a reply to the notice. In view of the availability of an efficacious appeal under the GST framework, the writ court's refusal to decide the merits and its direction to pursue the appellate remedy was held to be proper.

Conclusion: The challenge to the writ court's order failed. The appellant was rightly relegated to the statutory appeal, and the objections on jurisdiction, classification, and invocation of Section 74 were left to be urged before the appellate authority.

Ratio Decidendi: Where GST disputes involve contested facts on classification, suppression, and jurisdiction, and an effective statutory appeal is available, writ interference is unwarranted and the taxpayer must pursue the appellate remedy; cross-empowerment enforcement by the State is not invalid merely because the taxpayer is registered under the Central administration.

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