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A show cause notice issued in disregard of a binding and unchallenged advance ruling was treated as non-est because the ruling had attained finality between the parties and remained operative under the CGST framework. The Court held that, where the invalidity of the notice was apparent on the face of the record, the petitioner was not required to first reply to the notice or pursue the statutory remedy. It therefore exercised writ jurisdiction under Article 226 and quashed the notice as lacking foundation.
A show cause notice issued in disregard of a binding and unchallenged advance ruling was treated as non-est because the ruling had attained finality between the parties and remained operative under the CGST framework. The Court held that, where the invalidity of the notice was apparent on the face of the record, the petitioner was not required to first reply to the notice or pursue the statutory remedy. It therefore exercised writ jurisdiction under Article 226 and quashed the notice as lacking foundation.
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