Statutory appellate remedies preclude writ jurisdiction over GST orders involving factual disputes regarding corrigenda.

The petitioner was served a Show Cause Notice (SCN) dated 28.06.2025 under Section 74 of the CGST Act, 2017, alleging wrongful availment of Input Tax Credit (ITC) from a non-existent firm for the Financial Year (FY) 2018-2019.

During the adjudication process, the petitioner contended that transactions with the firm occurred in FY 2019-2020, not 2018-2019.

Consequently, the Respondent issued a corrigendum on 22.12.2025, amending the assessment period to include FY 2019-2020.

An Order-in-Original was subsequently passed on 29.12.2025, confirming a demand of ₹42,66,108/-.

The petitioner challenged the SCN, the corrigendum, and the final order through this writ petition, alleging that the corrigendum was an illegal attempt to bypass the statutory limitation for FY 2019-2020, which expired on 30.09.2025.

1. Whether the inclusion of FY 2019-2020 via a corrigendum amounts to the initiation of fresh proceedings beyond the permissible scope of rectification.

2. Whether the impugned corrigendum is hit by the bar of statutory limitation.

3. Whether the High Court should exercise its extraordinary writ jurisdiction under Article 226 despite the availability of an alternative statutory remedy under Section 107 of the CGST Act.

The Court primarily considered Section 160 of the CGST Act, which protects proceedings from invalidity due to mistakes or omissions if they conform to the Act's purpose.

Section 161, which permits the rectification of clerical or arithmetic errors apparent on the face of the record.

The Court relied on the principles established in Whirlpool Corporation v. Registrar of Trademarks and Commissioner of State Tax v. Commercial Steel Ltd., which mandate that writ jurisdiction should not be exercised when an efficacious alternative remedy exists, except in cases of fundamental rights breaches, natural justice violations, excess of jurisdiction, or challenges to statutory vires.

The court applied the doctrine from Syed Yakoob v. K.S. Radhakrishnan, stating that a writ of certiorari is supervisory and constrained to manifest errors of law rather than a reappreciation of facts.

The petitioner argued that adding an entire financial year via corrigendum created a fresh liability and circumvented limitation periods, rendering the officer functus officio regarding FY 2019-2020.

The Respondent countered that the corrigendum merely corrected a typographical error regarding the tax period for a transaction already under investigation.

The High Court observed that determining whether the corrigendum constituted a valid rectification under Section 161 or a fresh proceeding requires a detailed appreciation of facts and evidence.

Since Section 107 of the CGST Act provides a specific appellate mechanism for such grievances, and because the petitioner failed to demonstrate that the case fell within the recognized exceptions to the rule of alternative remedy, the Court held that a writ was not the appropriate vehicle for relief.

The Court emphasized that mere disagreement with an adjudicating authority’s conclusion does not justify bypassing statutory appeals.

The Court held that since an efficacious alternative remedy is available under Section 107 of the CGST Act read with Rule 109A, it would refrain from interfering with the Order-in-Original.

The Court granted the petitioner liberty to approach the appropriate appellate authority and clarified that it had expressed no opinion on the merits of the case.