This compilation indexes twelve writ petitions decided by five Indian High Courts — Tripura, Karnataka, Bombay, Delhi, and Madras — between December 2025 and June 2026, each engaging Section 168A of the Central Goods and Services Tax Act, 2017. The petitions predominantly challenge the validity of Notification No. 56/2023-Central Tax dated 28 December 2023 (and corresponding state-tax notifications), which purported to extend limitation periods for GST demand and adjudication proceedings. The compilation is designed for GST litigation teams, Big-4 indirect-tax associates, and in-house counsel tracking the evolving judicial landscape on Section 168A limitation-extension challenges across jurisdictions.

Research index only. This page compiles publicly available court orders for reference purposes. Nothing on this page constitutes legal advice, tax advice, or a recommendation to take any action. Readers must verify each ruling against the full original judgment and check for subsequent stays, reversals, or Supreme Court directions before relying on any case.

The statutory framework in one paragraph

Section 168A of the Central Goods and Services Tax Act, 2017 empowers the Government, on the recommendation of the GST Council, to extend any time limit specified in, or prescribed or notified under, the CGST Act, by notification, where the government is satisfied that circumstances exist which make it necessary to do so. The provision was introduced and has been used to extend deadlines applicable to taxpayers and authorities alike — including the limitation periods for issuance of show cause notices and passage of adjudication orders under the demand provisions of the Act. The constitutional and statutory validity of specific notifications issued in exercise of this power, particularly Notification No. 56/2023-Central Tax dated 28 December 2023, forms the central contestation across the twelve cases indexed below.

The 12 rulings

1. Sri Shekhar Chandra Podder vs The Union Of India Represented By The

Bench: Tripura High Court
Date: 30 June 2026
Sections engaged: 168A, 6(2)(b), 74(1), 74(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition was filed as WP(C) No. 285 of 2025 before the High Court of Tripura at Agartala by Sri Shekhar Chandra Podder, proprietor of M/S Shekhar Chandra Podder (GSTIN 16AEYPP1732Q1ZL), against the Union of India and several GST authorities including the Central Board of Indirect Taxes and Customs, the Chief Commissioner of State Tax (Tripura), and the CGST Tripura Division. The text preview identifies the petition as directed against Union of India and multiple GST respondents; the substantive grounds as recorded in the source preview are procedural in nature and the full reasoning is not available in the source extract.

2. M/S. Karnataka Vikas Grameena Bank vs Deputy Commissioner Of Commercial

Bench: Karnataka High Court
Date: 8 April 2026
Sections engaged: 168A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (Writ Petition No. 100806 of 2024, T-RES) was reserved for pronouncement on 9 January 2026 and pronounced on 8 April 2026 before the Karnataka High Court, Dharwad Bench. The petitioner — M/S Karnataka Vikas Grameena Bank, Dharwad — sought writs of certiorari to quash Show Cause Notice No. DCCT(ENF-2)/HBL/SCN-03/2023-24 dated 27 December 2023 and SCN No. ACCT/AUDIT-1/HBL/GST/DRC-1/23-24/B-337 dated 28 December 2023; the challenge as reflected in the source preview is directed at these notices, with Section 168A engaged as part of the proceedings, but the detailed reasoning is not available in the source extract.

3. Refex Industries Limited vs State Of Maharashtra And Ors

Bench: Bombay High Court
Date: 25 March 2026
Sections engaged: 168A, 73(9)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (Writ Petition (L) No. 10353 of 2026) challenged the Notification dated 28 December 2023 issued by the respondent in exercise of powers under Section 168A. The Bombay High Court's attention was drawn by senior counsel to a prior order of this Court in Rite Equipments Pvt. Ltd. vs. State of Maharashtra & Ors. (Writ Petition No. 1443 of 2025, dated 25 February 2026), which itself followed an earlier interim order of a co-ordinate bench in Shyam Udyog vs. Union of India & Ors., indicating that multiple batches of similar Section 168A notification-validity challenges were being tracked together before the Bombay High Court.

4. Saifee Hospital Trust vs The State Of Maharashtra

Bench: Bombay High Court
Date: 13 March 2026
Sections engaged: 168A, 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (Writ Petition No. 4374 of 2025) was filed under Article 226 of the Constitution of India seeking, among other reliefs, a writ of certiorari to quash Notification No. 56/2023-CT dated 28 December 2023 and Notification No. 56/2023-State Tax dated 16 January 2024 as illegal, unconstitutional, and ultra vires. The petitioner also sought quashing of related records; the order was pronounced per Ms. Aarti Sathe, J., and the source preview reflects the prayers but does not disclose the final reasoning in the extract available.

5. Rite Equipments P Ltd vs State Of Maharashtra

Bench: Bombay High Court
Date: 25 February 2026
Sections engaged: 168A, 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (Writ Petition No. 1443 of 2025) expressly challenged the Notification dated 28 December 2023 issued in exercise of powers under Section 168A of the Central Goods and Service Tax Act, 2017. Senior counsel referred the court to the earlier interim order passed by a co-ordinate bench of the Bombay High Court in Shyam Udyog vs. Union of India & Ors. (Writ Petition (L) No. 10058 of 2025), in which liberty was granted to parties to apply in the event the matter before the Supreme Court was disposed of; the source preview indicates the court was engaged with the question of notification validity pending a Supreme Court outcome.

6. Anil Kumar vs Sales Tax Officer Class Ii/Avato Ward

Bench: Delhi High Court
Date: 21 January 2026
Sections engaged: 168A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (W.P.(C) 843/2026 & CM APPL. 4124/2026) was taken up for final disposal at the hearing stage by consent. The petitioner, Anil Kumar (trading as N.S. Super Mart), challenged a show cause notice dated 15 December 2023 proposing a tax demand of Rs. 10,91,910/- on grounds including alleged excess Input Tax Credit on account of mismatch in GSTR-2A and GSTR-3B, non-reversal of Input Tax Credit relating to exempt supplies, and Input Tax Credit claimed in respect of dealers whose registrations had been cancelled; the petitioner additionally contended that the impugned show cause notice was uploaded on the GST portal under the "Additional Notices and Orders" tab in a manner that did not come to the petitioner's knowledge.

7. Abdul Kader M vs The State Tax Officer

Bench: Madras High Court
Date: 8 January 2026
Sections engaged: 168A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (W.P.(MD) No. 311 of 2026) was filed before the Madurai Bench of the Madras High Court, praying for a writ of certiorari to call for records relating to Notification No. 09/2023-Central Tax dated 31 March 2023 and Notification No. 56/2023-Central Tax dated 28 December 2023, along with the consequential assessment order passed against GSTIN 33BREPM1149N1ZN for the assessment year 2019-20 vide Reference No. ZD330724341969W dated 30 July 2024. The petition also challenged corresponding State proceedings under G.O. Ms. No. 41 dated 5 April 2023.

8. Aryansh Alloys Through Its Proprietor vs Commissioner Of Delhi Goods And

Bench: Delhi High Court
Date: 22 December 2025
Sections engaged: 73, 168A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (W.P.(C) 19472/2025) challenged the Show Cause Notice dated 23 September 2023 and the consequent demand order dated 26 December 2023 passed by the Sales Tax Officer Class II/AVATO Ward 63, Zone 6, Delhi for the tax period July 2017 to March 2018, as well as the vires of the impugned notifications. The source preview notes that this petition is similar to a batch of petitions wherein the impugned notifications were challenged, with W.P.(C) No. 16499/2023 titled DJST Traders Private Limited v. Union of India & Ors. identified as the lead matter in that batch.

9. Tvl Voylla Fashions Private Limited vs The Assistant Commissioner (St) (Fac)

Bench: Madras High Court
Date: 17 December 2025
Sections engaged: 168A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (W.P.(MD) No. 36017 of 2025) was filed before the Madurai Bench of the Madras High Court by Tvl Voylla Fashions Private Limited (GSTIN 33AADCV8345F1ZB), praying for a writ of certiorari to quash records relating to Notification No. 09/2023-Central Tax dated 31 March 2023 and Notification No. 56/2023-Central Tax dated 28 December 2023, along with the consequential assessment order passed against the petitioner's GSTIN. The petition also challenged corresponding State proceedings under G.O. Ms. No. 41 dated 5 April 2023, following a pattern consistent with similar notification-validity challenges filed before the Madurai Bench.

10. Santosh Kumar Pandey vs Union Of India And Ors

Bench: Delhi High Court
Date: 17 December 2025
Sections engaged: 168A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (W.P.(C) 15796/2025) challenged the impugned orders dated 7 April 2024 and 22 April 2024 passed by the Sales Tax Officer Class II/Avato Ward 51, Zone 3, Delhi, arising from Show Cause Notices dated 16 December 2023 and 23 December 2023. Per the source preview, the demand raised against the petitioner for Financial Year 2018-19 was Rs. 14,65,398/- under each of the two impugned orders; the petition additionally challenged the notifications, following the broader batch pattern tracked before the Delhi High Court.

11. Hitachi Systems India (P) Ltd vs Union Of India & Ors

Bench: Delhi High Court
Date: 17 December 2025
Sections engaged: 168A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (W.P.(C) 19094/2025) challenged the impugned order dated 24 December 2023 passed by the Sales Tax Officer Class II/AVATO Ward 202, Zone 11, Delhi, as well as the Show Cause Notice dated 28 September 2023 issued for the tax period July 2017 to March 2018, and the vires of the impugned notifications. The source preview states that this petition is similar to a batch of petitions wherein the impugned notifications were challenged, consistent with the wider Section 168A notification-validity batch proceedings before the Delhi High Court.

12. I Money Wallet Private Limited Through vs Sales Tax Officer Class Ii / Avato, Ward

Bench: Delhi High Court
Date: 16 December 2025
Sections engaged: 168, 168A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (W.P.(C) 19030/2025) was filed by I Money Wallet Private Limited through its director, challenging the impugned order dated 28 August 2024 arising from Show Cause Notice dated 20 May 2024 passed by the Sales Tax Officer Class II/Avato Ward 64, Zone 4, Delhi for the tax period April 2019 to March 2020, along with the vires of the impugned notifications. The source preview notes that the challenge is similar to a batch of petitions where the impugned notifications were challenged, with W.P.(C) No. 16499/2023 (DJST Traders Private Limited v. Union of India & Ors.) identified as the lead matter; the parties were heard at length on 22 April 2025 regarding the validity of the impugned notifications.

Patterns across these 12 rulings

Notification No. 56/2023-Central Tax as the common target. Across the Bombay, Delhi, Madras, Tripura, and Karnataka High Courts, the predominant challenge is directed at Notification No. 56/2023-Central Tax dated 28 December 2023 (and corresponding state-tax notifications), which extended limitation periods for GST proceedings under the authority of Section 168A. The repetition of this specific notification across all twelve cases identifies it as the focal point of the current wave of Section 168A litigation.
Batch-petition approach in Delhi and Madras. Multiple Delhi High Court petitions (cases 8, 10, 11, and 12) expressly reference W.P.(C) No. 16499/2023 (DJST Traders Private Limited v. Union of India & Ors.) as the lead matter in a batch, indicating the court is managing a significant volume of similarly-situated petitions collectively. The Madurai Bench of the Madras High Court similarly addresses materially identical prayers across cases 7 and 9.
Cross-bench tracking in Bombay. The Bombay High Court cases (3, 4, and 5) demonstrate active cross-bench tracking: the Refex Industries petition (case 3) was directed to the Rite Equipments order (case 5), which itself followed the Shyam Udyog interim order. This co-ordinate-bench referencing pattern reflects the Bombay High Court's approach of harmonising interim positions pending a Supreme Court outcome.
Absence of final substantive rulings on the merits in the source data. None of the twelve cases in this compilation carries a definitive outcome on the merits — all twelve carry the outcome designation "Outcome not specified in source." This reflects the pendency of the core Section 168A notification-validity question, likely because final adjudication is awaited at the Supreme Court level, as alluded to in the Bombay High Court orders.
Demand-period and tax-period variation across petitioners. The tax periods under challenge range from July 2017–March 2018 (cases 8 and 11, Delhi) to April 2019–March 2020 (case 12, Delhi) and assessment year 2019-20 (cases 7 and 9, Madras), reflecting that the Section 168A extension notification's reach is being litigated across multiple financial years and not limited to any single demand cycle.

How to use this compilation

This index is designed as a starting point for identifying relevant judicial activity on Section 168A GST notification-validity challenges across High Courts. Each entry provides the court, date, writ petition number (where available in the source preview), and sections engaged so that a researcher can locate the full judgment through indiankanoon.org, the respective High Court's official portal, or a subscribed legal database. The absence of a recorded outcome in any entry means only that the source extract did not disclose a final determination — it does not mean the petition was dismissed or allowed. Researchers must retrieve the full judgment to ascertain the actual disposal.

Before placing reliance on any ruling listed here, verify whether a subsequent appeal, Letters Patent Appeal, or Special Leave Petition has been filed before a higher court, and whether any stay or reversal is in force. Given that several Bombay High Court orders explicitly flag a pending Supreme Court proceeding on the Section 168A notification-validity question, the Supreme Court's position — when available — will likely be determinative across many of these batch petitions. Parallel CBDT and CBIC circulars, if any, clarifying the scope of limitation extensions should also be checked against the notification under challenge.

For in-house teams and practitioners using this compilation to assess exposure on open GST demands, note that the mix of courts, tax periods, and demand amounts across these twelve cases illustrates that the Section 168A challenge has been raised by taxpayers of varying sizes and sectors — from a regional rural bank (case 2) to a hospital trust (case 4) to individual proprietors (cases 6 and 10). The cross-jurisdictional spread means that the governing precedent for a given taxpayer will depend on the territorial jurisdiction of the demand authority, and practitioners should track the specific High Court that covers their jurisdiction for the most relevant disposals.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 168A GST Notification Validity: 12 High Court Writ Petition Rulings (2025-2026)