Writ interference under GST was refused where an efficacious appeal existed and the penalty order was reasoned and evidence-based.

Writ interference was declined because the statutory appeal under Section 107 of the CGST Act remained an efficacious remedy for factual and legal challenges, and the petitioners had not shown any basis to bypass it. The Court also found no violation of natural justice or lack of sustainable findings in the penalty order under Section 122(1A), since the adjudicating authority relied on statements, electronic records, WhatsApp chats, and admissions indicating knowledge and participation in fake invoices, bogus e-way bills, and hawala routing. The reasoned penalty order was left undisturbed.

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Issues: (i) Whether the writ petition was entertainable despite the availability of the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017; (ii) whether the impugned order warranted interference on the ground of violation of natural justice and lack of sustainable findings for penalty under Section 122(1A) of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the writ petition was entertainable despite the availability of the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: The petitioners elected to seek a merits-based order instead of pursuing the appellate remedy. The Court nonetheless examined the matter on merits, but noted that the statutory appeal remained an efficacious remedy for factual and legal challenges.

Conclusion: The availability of appeal did not result in interference under writ jurisdiction, and the petition was not accepted on this ground.

Issue (ii): Whether the impugned order warranted interference on the ground of violation of natural justice and lack of sustainable findings for penalty under Section 122(1A) of the Central Goods and Services Tax Act, 2017.

Analysis: The investigation material, statements of the petitioners, electronic records, WhatsApp chats, and admissions regarding fake invoices, bogus e-way bills, and hawala routing were relied upon by the adjudicating authority. The findings recorded in the order showed the petitioners' knowledge, consent, and active participation, and the Court found that the order was a reasoned one and that no procedural unfairness or absence of findings was made out.

Conclusion: No violation of natural justice or infirmity in the findings was established, and the penalty under Section 122(1A) of the Central Goods and Services Tax Act, 2017 was not interfered with.

Final Conclusion: The writ challenge to the penalty order failed, and the impugned adjudication was left undisturbed.

Ratio Decidendi: A writ court will not interfere with a reasoned penalty order under the GST law where the record contains substantive findings based on statements, electronic evidence, and admissions showing participation in fraudulent availment of input tax credit, especially when an efficacious statutory appeal is available.

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