Synopsis

This judgment by a Division Bench of the Delhi High Court dismisses a writ petition filed by a proprietary firm engaged in courier services, challenging an Order-in-Original (OIO) passed under Section 74 of the Central Goods and Services Tax (CGST) Act, 2017. The OIO confirmed a substantial tax demand of over ₹3 crores against the petitioner. The petitioner raised multiple grounds, including violation of natural justice (non-supply of relied-upon documents), non-application of mind by the adjudicating authority, and erroneous valuation. The High Court refused to entertain the petition, holding that an efficacious alternative remedy by way of an appeal under Section 107 of the CGST Act was available and that the petitioner's grievances did not fall within the recognized exceptions to the rule of exhaustion of statutory remedies.

1. Heading for the judgment

Citation: M/s Power Line Air Express v. Principal Commissioner of Central Goods & Service Tax & Ors., W.P.(C) 3328/2026, decided on 16.03.2026 (Delhi High Court - DB)
Coram: Hon'ble Mr. Justice Nitin Wasudeo Sambre and Hon'ble Mr. Justice Ajay Digpaul (Division Bench)
Core Law: Central Goods and Services Tax Act, 2017 (CGST Act).

Delhi High Court dismisses writ petition challenging GST demand, holds that availability of statutory appeal under Section 107 of CGST Act bars interference under Article 226.

2. Legal framework

This judgment is a classic application of the principle that High Courts will not ordinarily exercise their extraordinary writ jurisdiction when an efficacious alternative statutory remedy is available.

• Central Goods and Services Tax Act, 2017 (CGST Act):
  Section 70:

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