Statutory appellate remedy under Section 107 CGST Act precludes writ jurisdiction for challenging adjudication orders.

The Petitioner, a proprietorship concern providing courier agency services, challenged an Order-in-Original (OIO) dated 18.12.2025, which confirmed a tax demand of ₹3,00,14,058 under Section 74(9) of the CGST Act

The proceedings originated from summons issued in February 2025, followed by a Show Cause Notice (SCN) dated 30.06.2025 alleging suppression of tax liability for the period 2018-19 to 2023-24

The Petitioner submitted that it had provided necessary documents and a detailed reply; however, it alleged that the Relied Upon Documents (RUDs) were never supplied, the summons were not properly served, and the adjudicating authority failed to consider its defense, resulting in a violation of natural justice and non-application of mind

1. Whether the High Court should entertain a writ petition under Article 226 of the Constitution when an efficacious alternative statutory remedy is available under Section 107 of the CGST Act

2. Whether the alleged procedural infractions, such as non-supply of RUDs and non-consideration of the Petitioner's reply, constitute sufficient grounds to bypass the statutory appellate process

Section 107 of the CGST Act, 2017, which mandates a statutory appellate remedy for persons aggrieved by an adjudicating authority's order

Writ jurisdiction under Article 226 is discretionary and should be withheld if an alternative remedy exists, as held in Whirlpool Corporation v. Registrar of Trademarks, Mumbai and Harbanslal Sahnia v. Indian Oil Corpn. Ltd.

The Court noted that the Petitioner’s challenges—specifically regarding the non-supply of documents, service of summons, and the adjudicating authority’s alleged failure to consider the evidence—are matters rooted in the adjudicatory record

The Court reasoned that resolving these disputes requires a factual examination of the SCN, the correspondence between the parties, and the service records, all of which fall within the specialized domain of the appellate authority

The Court emphasized that mere dissatisfaction with the adjudicating authority's appreciation of the record does not entitle a party to bypass the statutory framework

Since the issues raised were not outside the appellate framework, the extraordinary jurisdiction of the High Court was deemed inappropriate

The Court granted the Petitioner liberty to approach the competent appellate authority and clarified that it had not expressed any opinion on the merits of the case