Writ jurisdiction is declined where statutory appeal adequately addresses evidentiary and adjudicatory grievances.

The Petitioner challenged the Order-in-Original dated 29 December 2025 passed under Section 74 of the Central Goods and Services Tax Act, 2017 (“CGST Act”).

The order confirmed GST demands of ₹1,41,70,592 for 2018–19 to 2023–24 and ₹8,94,692 for 2024–25, along with applicable interest and penalty.

The proceedings arose from an investigation involving a search of the residential and business premises of a third party, Mr. Kapil Arora, Proprietor of M/s Arora Communication.

The Department relied on electronic data allegedly recovered from a seized laptop, loose papers, receipts, statements, and other investigation material to allege unaccounted transactions involving the Petitioner.

The Petitioner alleged violation of natural justice, non-consideration of its reply, inadequate service of hearing notices, denial of effective personal hearing and cross-examination, inadmissibility and lack of authentication of electronic evidence, and impermissible initiation of proceedings despite an earlier statutory audit under Section 65 of the CGST Act.

The Respondents objected to maintainability on the ground that the impugned order was appealable under Section 107 of the CGST Act and that the recognised exceptions to the alternative-remedy rule were not attracted.

Whether the High Court should entertain the writ petition under Article 226 despite the efficacious statutory appeal available under Section 107 of the CGST Act

Whether the alleged defects in service of hearing notices, denial of effective hearing, and non-consideration of the Petitioner’s reply constituted a patent violation of natural justice warranting writ interference

Whether the challenges concerning electronic evidence, forensic authentication, denial of cross-examination, and the effect of the prior statutory audit raised exceptional jurisdictional or natural-justice grounds, rather than matters for the statutory appellate authority

Section 107 of the CGST Act provides a comprehensive and efficacious statutory appellate remedy against adjudication orders.

Although the existence of an alternative remedy is not an absolute bar to Article 226 jurisdiction, constitutional courts ordinarily exercise restraint where the statutory framework provides an effective appellate mechanism.

Relying on Assistant Commissioner of State Tax v. Commercial Steel Limited, (2022) 16 SCC 447, the Court reiterated that writ jurisdiction may nevertheless be exercised in exceptional cases involving breach of fundamental rights, violation of principles of natural justice, excess of jurisdiction, or a challenge to the vires of legislation or delegated legislation.

A mere assertion of such grounds is insufficient and the Court must independently assess whether the facts justify bypassing the statutory remedy.

Questions concerning appreciation of evidence, evidentiary value, factual findings, adequacy of reasons, admissibility and authentication of electronic records, cross-examination, and overlap with earlier proceedings ordinarily fall within the appellate authority’s jurisdiction.

The Court held that the Petitioner had participated in the adjudication proceedings: hearings were scheduled on 6, 12 and 19 December 2025, and its authorised representative appeared on 19 December 2025 and submitted a detailed written reply.

Accordingly, the grievance was not a complete denial of opportunity but primarily concerned the manner in which the adjudicating authority evaluated the defence; that contention did not, by itself, establish a natural-justice violation.

The Court also found that the impugned order noticed the Petitioner’s reply, while the adequacy of the reasons and treatment of individual objections were matters concerning the correctness of adjudication.

The objections to the electronic material, forensic report, cross-examination, and prior statutory audit required examination of the original record, investigation material, documentary and electronic evidence, statements, and the adjudicating authority’s findings.

These were disputed questions of fact and law that the appellate authority was competent to determine under Section 107.

Since the Department asserted that the order rested on cumulative material and not solely on statements or electronic data, the Court declined to decide the evidentiary issues in writ jurisdiction or prejudice the statutory appeal.

No patent violation of natural justice, excess of jurisdiction, or other exceptional circumstance was established.

The writ petition and pending applications were consequently dismissed, while liberty was granted to the Petitioner to pursue the statutory appeal under Section 107 of the CGST Act.

The Court expressly left all questions of fact and law open for consideration by the appellate authority.

It further directed that, if an appeal was filed, the period during which the writ petition remained pending would not be reckoned for limitation purposes, subject to the appellate authority deciding limitation in accordance with law.