Exhaustion of Statutory Remedy: High Court Refuses Interference When Advance Ruling Authority Becomes Functional

1. Case Snapshot

• Case Name: Hemogenomics Private Limited vs Government of NCT of Delhi & Ors.

• Citation: 2026:DHC:5797-DB

• High Court: High Court of Delhi

• Bench: Hon'ble Mr. Justice Anil Kshetarpal and Hon'ble Mr. Justice Amit Mahajan

• Date of Decision: July 21, 2026

• Area of Law: Taxation – Goods and Services Tax (GST); Advance Ruling under CGST Act; Writ Jurisdiction

2. Judgment in Brief

The Delhi High Court disposed of two writ petitions challenging a communication that held the petitioner's diagnostic services liable to GST at 18%. The petitioner had also filed applications before the Authority for Advance Ruling seeking determination of taxability and exemption, which remained pending due to lack of quorum. The Court directed the government to fill the vacancy, which was done. Once the statutory forum became functional, the Court refused to adjudicate the issues in its writ jurisdiction, holding that the questions fell within the specialized domain of the Authority for Advance Ruling. The petitions were disposed of with liberty to pursue remedies before the Authority.

3. Relevant Facts

• The petitioner, a diagnostic services provider, received a communication dated March 25, 2025, stating that its services were liable to GST at 18%.

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