Facts of the Case
The present writ petition was filed under Article 226 of the
Constitution of India challenging the Order-in-Original dated 27 January 2025,
whereby a demand of ₹1,14,114 along with penalty was raised against the
Petitioner.
The case arose from an investigation conducted by the CGST
Department into multiple firms allegedly involved in fraudulent availment of
Input Tax Credit (ITC) through issuance of goods-less invoices. It was revealed
that several supplier firms were non-existent and were created solely to pass
on fake ITC without actual supply of goods.
The Petitioner’s firm, M/s Aura Interior Hardware, was identified as one of the entities involved in the chain of transactions and was accordingly subjected to tax demand and penalty.
Issues Involved
- Whether
the writ petition is maintainable in cases involving fraudulent availment
of ITC.
- Whether
principles of natural justice were violated due to alleged non-service of
show cause notice and absence of personal hearing.
- Whether
the impugned order was barred by limitation.
- Whether the Petitioner can bypass the statutory appellate remedy under the CGST Act.
Petitioner’s Arguments
- The
Petitioner contended that no Show Cause Notice was issued and no personal
hearing was granted.
- It
was argued that proceedings for certain financial years were not properly
initiated.
- The
Petitioner further claimed that the impugned order was passed beyond the
limitation period.
- The challenge was made directly before the High Court instead of availing the appellate remedy.
Respondent’s Arguments
- The
Department submitted that proper opportunities of personal hearing were
granted on multiple dates.
- It
was argued that the Petitioner failed to appear and the order was rightly
passed ex parte based on available records.
- The
Department established that fake ITC was availed through non-existent
supplier firms issuing invoices without actual supply.
- It was further contended that the impugned order is appealable under Section 107 of the CGST Act and the writ petition is not maintainable.
Court’s Findings / Order
The Delhi High Court held:
- The
allegation of non-service of notice and lack of hearing was incorrect as
multiple opportunities were granted.
- The
impugned order clearly covered the relevant period and was passed within
the limitation period.
- The
case involved serious allegations of fraudulent ITC through fake firms and
invoices.
- The
writ jurisdiction under Article 226 should not be exercised in such
matters involving disputed facts and fraud.
- The Court relied on Mukesh Kumar Garg vs. Union of India & Ors. holding that writ jurisdiction should not be used in fraudulent ITC cases.
Important Clarification by Court
- Writ
jurisdiction is not appropriate in cases involving fraudulent ITC
and complex factual disputes.
- The
CGST appellate mechanism must be exhausted before invoking writ
jurisdiction.
- Fraudulent
ITC practices pose a serious threat to the GST regime and public revenue.
- Courts will not entertain petitions from litigants attempting to bypass statutory remedies or delay proceedings.
Sections / Provisions Involved
- Article
226 of the Constitution of India
- Section
16, CGST Act (Input Tax Credit)
- Section
107, CGST Act (Appeal)
- Section 122(1) & 122(3), CGST Act (Penalties)
Link to download the order - https://delhihighcourt.nic.in/app/showFileJudgment/PMS10072025CW95242025_172100.pdf
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