Show-cause notice challenge failed where no final liability was and jurisdiction under CGST rules was upheld.

A writ petition against a show-cause notice was not entertained where no final determination of liability had yet been made, and the petitioner was left to file objections and a further reply before a reasoned speaking order. The jurisdictional challenge to the notice also failed: the relevant orders vested authority in the Deputy or Assistant Commissioner under the CGST framework with jurisdiction under Rule 11 of the Rules, and the description or rubber stamp below the signature was treated as immaterial. The writ petition was dismissed, with liberty to pursue objections before the authority and then avail statutory remedies.

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Issues: Whether the writ petition challenging the show-cause notice was maintainable, and whether the notice suffered from lack of jurisdiction on the ground that the signatory authority was a CGST officer under the Health Security se National Security Cess framework.

Analysis: The challenge was directed against a show-cause notice and no final determination of liability had yet been made. The petitioner was held entitled to file objections and further reply, after which the authority could pass a reasoned and speaking order. The jurisdictional objection was rejected because the relevant orders vested authority in the Deputy or Assistant Commissioner under the CGST set-up with jurisdiction under Rule 11 of the Rules, and the description or rubber stamp below the signature was treated as immaterial.

Outcome: The writ petition was dismissed, with liberty to pursue objections before the authority and thereafter avail statutory remedies.

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