Binding advance ruling barred a conflicting show cause notice, and writ relief was available without forcing statutory adjudication.

An unchallenged advance ruling remained binding on the authorities under Section 103(2) of the CGST Act until treated as void under Section 104(1); the impugned show cause notice, issued in conflict with that finality, was therefore without foundation and could not be sustained. Because the effect of the notice was already apparent from the record, the petitioner was not required to undergo the statutory adjudication process before seeking relief. The High Court held that writ jurisdiction under Article 226 was available and quashed the notice.

---

---

Issues: Whether the show cause notice could be sustained despite an earlier advance ruling between the parties having attained finality, and whether the petitioner could be relegated to the statutory adjudication remedy.

Analysis: The advance ruling, being unchallenged and not declared void, remained binding on the authorities under Section 103(2) of the Central Goods and Services Tax Act, 2017 until it was treated as void under Section 104(1) of the same Act. In view of that finality, the impugned notice proceeded in conflict with the settled position and was without foundation. The Court held that where the consequence of the notice was apparent from the record, no useful purpose would be served by driving the petitioner to reply and undergo adjudication. The extraordinary writ jurisdiction under Article 226 of the Constitution of India was therefore available.

Conclusion: The show cause notice was quashed and set aside. The petitioner succeeded.

---