Alternate-remedy rule bars writ challenge where GST tax classification and exemption disputes belong in statutory appeal.

Writ interference was declined because the dispute concerned tax classification, taxability of annuity receipts, and interpretation of exemption notifications under the CGST framework, all matters ordinarily suited to the statutory appellate process. The Court found no established violation of natural justice, no patent lack of jurisdiction, and no other recognised exception to the alternate-remedy rule. Departmental circulars did not make the appeal ineffective. The petitioner was therefore required to pursue the statutory appeal remedy under Section 107 of the CGST Act.

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Issues: Whether the writ petition was maintainable in view of the statutory appellate remedy, and whether any recognised exception to the alternate-remedy rule was made out on the grounds of lack of jurisdiction, violation of natural justice, or constitutional challenge.

Analysis: The Court held that the impugned show cause notice and adjudication order were issued by officers traceable to the statutory notifications and the CGST framework, and that the challenge essentially concerned classification of services, taxability of annuity receipts, and interpretation of exemption notifications. Those questions involved adjudicatory and factual examination, which are ordinarily amenable to the appellate mechanism under the CGST Act. The Court found no demonstrated violation of natural justice, no patent lack of jurisdiction, and no circumstance bringing the case within the recognised exceptions permitting immediate writ interference. The existence of departmental circulars did not render the statutory appeal ineffective.

Conclusion: The writ petition was not maintainable at the threshold and the petitioner was relegated to the statutory appeal remedy under Section 107 of the CGST Act.

Ratio Decidendi: Where the dispute turns primarily on tax adjudication, classification, and exemption under the CGST framework, and no recognised exception to the alternate-remedy rule is established, the High Court should decline writ interference and require the assessee to pursue the statutory appeal.

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