Statutory appellate remedy governs consequential GST refund disputes where fresh rejection rests on independently reasoned claim examination.

A writ challenge to rejection of a consequential GST refund should ordinarily proceed through the statutory appeal where the rejection independently examines the claim on legally permissible grounds. The earlier appellate order set aside the prior rejection on specified grounds but did not mandate unconditional refund release or bar fresh examination. The subsequent order gave reasons on turnover reconciliation and refund computation; its legality and the appellate order's scope could be fully assessed in an appeal under the CGST Act. As the rejection was not shown to be without jurisdiction, the statutory appellate remedy applies.

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Issues: Whether the writ petition challenging rejection of a consequential GST refund should be entertained despite the availability of a statutory appeal.

Analysis: The appellate order had set aside the earlier rejection on specified grounds but had neither directed unconditional release of the refund nor precluded fresh examination on other legally permissible grounds. The subsequent rejection order independently examined the refund claim and recorded reasons concerning turnover reconciliation and refund computation. The legality of those reasons and the scope and effect of the appellate order could be comprehensively examined in an appeal under Section 107 of the Central Goods and Services Tax Act, 2017. The rejection order was therefore not shown to be non est or wholly without jurisdiction so as to justify writ interference.

Conclusion: The writ petition was not maintainable for interference in the circumstances, and the petitioner was required to pursue the statutory appellate remedy.

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