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Availability of an efficacious statutory appeal materially constrains Article 226 writ jurisdiction in GST adjudication. Once show-cause proceedings culminate in an Order-in-Original, disputes over overlapping State and Central input tax credit proceedings, factual and evidentiary material, and a multi-year notice should ordinarily be examined on appeal. A statutory pre-deposit obligation and the earlier filing of a writ during pending notice proceedings do not alone justify bypassing that remedy. Absent patent jurisdictional infirmity, appellate review remains available on all permissible grounds; the writ petition was dismissed with liberty to appeal.
Availability of an efficacious statutory appeal materially constrains Article 226 writ jurisdiction in GST adjudication. Once show-cause proceedings culminate in an Order-in-Original, disputes over overlapping State and Central input tax credit proceedings, factual and evidentiary material, and a multi-year notice should ordinarily be examined on appeal. A statutory pre-deposit obligation and the earlier filing of a writ during pending notice proceedings do not alone justify bypassing that remedy. Absent patent jurisdictional infirmity, appellate review remains available on all permissible grounds; the writ petition was dismissed with liberty to appeal.
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TaxTMI 
TaxTMI 
