Alternate Remedy Prevails

In a clear reiteration of judicial restraint in tax matters, the Delhi High Court has reinforced that writ jurisdiction is not a substitute for statutory appeals under GST law. 

Even where allegations of natural justice violations and flawed valuation are raised, the Court held that such issues, being deeply rooted in factual adjudication, must be tested before appellate authorities under Section 107 of the CGST Act.

The Supreme Court’s refusal to interfere, coupled with a pragmatic relaxation on limitation, reflects a calibrated approach: preserving procedural discipline while ensuring that access to remedies is not unduly prejudiced. 

The ruling sends a strong signal that GST litigation must ordinarily follow the statutory hierarchy, with writ intervention remaining an exception rather than the rule.