Interference with a show cause notice is unwarranted unless it...

Interference with a show cause notice is unwarranted unless it is ex facie without jurisdiction. Here, the GST dispute over an offshore construction contract turned on factual questions, including local procurement, shipments from the India office, and consolidation of Mauritius site accounts in the Indian company's financials. Those features had a bearing on the territorial applicability of GST, so the notice was not patently without jurisdiction and could not be quashed in writ proceedings as premature. The cited advance-ruling decision was distinguished because it did not arise from a writ challenge to a notice on disputed facts.

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