Interim protection in GST adjudication granted to preserve jurisdictional challenges to show cause notices pending writ review.

Interim protection was granted where writ petitions challenged the jurisdiction and validity of GST show cause notices in Form GST DRG-01 and the adjudication was poised to proceed with a fixed personal hearing. The HC found the refusal to adjourn and the imminent ex parte adjudication to be in undue haste, and held that arguable jurisdictional issues required consideration. To preserve the subject matter of the writ petitions, the Court directed the Adjudicating Authority to grant an adjournment and to fix the hearing after 23.6.2026, so the hearing scheduled for 19.6.2026 could not proceed.

---

---

Issues: Whether interim protection was warranted against the continuation of the GST adjudication proceedings and the fixed personal hearing while the writ petitions challenging the jurisdiction and validity of the show cause notices remained pending.

Analysis: The writ petitions questioned the jurisdiction and validity of the show cause notices issued in Form GST DRG-01. The Adjudicating Authority had fixed a final personal hearing for the next day and indicated that an ex parte final order could follow under Section 74(1) with tax, interest and penalty. In view of the pending writ petitions, the Court found the adjournment refusal and the imminent hearing to be in undue haste and held that the petitioners had raised arguable issues requiring consideration. Interim interference was considered necessary to preserve the subject matter of the writ petitions.

Conclusion: The Adjudicating Authority was directed to grant an adjournment and fix the hearing after 23.6.2026, and the hearing scheduled for 19.6.2026 was not to proceed.

Ratio Decidendi: Where a writ petition raises arguable jurisdictional challenges to GST show cause notices, the Court may grant interim protection to prevent the adjudication from reaching an irreversible stage and preserve the subject matter pending consideration of the writ.

---