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Availability of an efficacious statutory GST appeal generally weighs against writ adjudication of challenges to a consolidated show-cause notice. Objections that the notice is barred by limitation, issued without jurisdiction, or impermissibly combines separate financial years may involve disputed questions of fact and law suitable for appellate examination. The statutory appeal under Section 107 of the CGST Act preserves those objections for determination. The writ petition was relegated to that remedy, subject to an adjusted pre-deposit, with no coercive action until the appeal attains finality.
Availability of an efficacious statutory GST appeal generally weighs against writ adjudication of challenges to a consolidated show-cause notice. Objections that the notice is barred by limitation, issued without jurisdiction, or impermissibly combines separate financial years may involve disputed questions of fact and law suitable for appellate examination. The statutory appeal under Section 107 of the CGST Act preserves those objections for determination. The writ petition was relegated to that remedy, subject to an adjusted pre-deposit, with no coercive action until the appeal attains finality.
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TaxTMI 
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