This compilation indexes twelve rulings — from High Courts across India and the Customs, Excise and Service Tax Appellate Tribunal — in which proceedings were initiated or challenged under Section 73(1) of the CGST/SGST/Finance Act framework. The rulings span March to June 2026 and arise from writ petitions and service tax appeals filed by taxpayers contesting demand notices, orders-in-original, and adjudication proceedings. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured first-pass reference before accessing the full judgments.

Research index only. This page is a case-law reference compilation and does not constitute legal or tax advice. Readers must verify each ruling against the full judgment text and check for any subsequent stay, reversal, or appeal before relying on it in any matter.

The statutory framework in one paragraph

Section 73(1) of the Central Goods and Services Tax Act, 2017 (and its mirror provisions in State GST enactments) empowers a proper officer to issue a show cause notice to a taxable person where it appears that tax has not been paid, has been short-paid, has been erroneously refunded, or where input tax credit has been wrongly availed or utilised — in cases not involving fraud, wilful misstatement, or suppression of facts. The section prescribes that the proper officer shall serve notice on the person chargeable with tax, requiring them to show cause as to why the tax amount, along with applicable interest and penalty, should not be demanded. Parallel provisions exist in the Finance Act, 1994 (governing pre-GST service tax) and in respective State GST enactments, which operate on substantially similar language for non-fraud demand scenarios.

The 12 rulings

1. M/S Md Alal Uddin vs The Union Of India And 5 Ors

Bench: Gauhati High Court
Date: 12 June 2026
Sections engaged: 73(1), 75, 77, 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as Writ Petition (C) No. 4367/2023 before the Gauhati High Court (High Court of Assam, Nagaland, Mizoram and Arunachal Pradesh), challenging an order or proceeding under the CGST framework. Per the source preview, the challenge made in the present writ petition is to a matter involving the Central Goods and Services Tax, Tezpur Division, with the State Bank of India and ICICI Bank also listed as respondents, suggesting the petition may involve attachment or banking-related proceedings alongside the substantive demand.

2. M/S Eastern Gas And Associates vs The Union Of India And 2 Ors

Bench: Gauhati High Court
Date: 12 June 2026
Sections engaged: 73(1), 73(2), 75, 77, 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (WP(C)/3085/2023) challenges Order-in-Original No. GD/AC/29/GHY/AUDIT/CGST/2022-23, dated 17.05.2022, passed by the Assistant Commissioner, Central Goods and Services Tax, whereby a Demand-cum-Show Cause Notice dated 18.10.2019 was confirmed and a service tax demand of Rs. 5,57,627/- was raised against the petitioner, a partnership firm registered under the Partnership Act, 1932 with its place of business at Bamunimaidan, Guwahati.

3. M/S North Western Carrying Corporation vs Union Of India

Bench: Gujarat High Court
Date: 10 June 2026
Sections engaged: 173, 174, 73(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Special Civil Application No. 496 of 2019, the petitioner's counsel fairly submitted at the outset that the issue raised — namely the challenge to the impugned Show Cause Notice dated 13.03.2018 issued under Section 73(1) of the Finance Act, 1994 — already stands concluded by the judgment dated 29.01.2020 passed by a Coordinate Bench of the Gujarat High Court in Special Civil Application No. 20748 of 2018 and allied matters in the case of Sahitya Mudranalaya Pvt. Ltd. vs. Additional Director General, 2021 (46) G.S.T.L. 245 (Guj.), and submitted that the petitioner may be relegated to face the adjudication proceedings.

4. M/S Tata Projects Limited vs Union Of India And 4 Ors

Bench: Gauhati High Court
Date: 8 June 2026
Sections engaged: 107, 108, 112, 73(1), 74(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (WP(C)/2922/2025) was filed before the Gauhati High Court by M/S Tata Projects Limited, Assam, represented by its Deputy General Manager – Finance and Accounts, challenging proceedings involving the CGST Commissioner (Audit), Shillong, and the Joint Commissioner, CGST and CX, Guwahati. Per the source preview, a linked case, WP(C)/20/2026, filed by M/S Quantum Infratech, Assam, was also tagged with this matter, indicating the High Court was hearing related challenges together.

5. M/S Mahesh Kumar Chanani And Anr vs The Union Of India And 2 Ors

Bench: Gauhati High Court
Date: 4 May 2026
Sections engaged: 73(1), 107
Outcome: Outcome not specified in source
Procedural / substantive ground: By way of Writ Petition (C) No. 5050/2024 under Article 226 of the Constitution of India, the petitioner — a proprietorship firm having its office at SBI Colony, Bishnupally, Hojai, Assam — called in question, inter alia, the legality and validity of an adjudicating order, with the challenge heard by the Gauhati High Court on 04.05.2026. The petition was filed against orders of the Assistant Commissioner, Central Goods and Service Tax and Central Excise, Guwahati Division-II.

6. District Information Technology vs Gurugram

Bench: Custom, Excise & Service Tax Tribunal
Date: 28 April 2026
Sections engaged: 73(1), 75
Outcome: Outcome not specified in source
Procedural / substantive ground: Service Tax Appeal No. 60529 of 2021 before the Customs, Excise and Service Tax Appellate Tribunal, Chandigarh (Regional Bench), arose out of Order-in-Original No. 1-21/ST/COMMR/VMJ/RTK/2021-22 dated 25.06.2021 passed by the Commissioner of Central GST, Rohtak. Per the source preview, the matter is a batch of fifteen appeals involving District Information Technology Societies across Haryana (including Gurugram, Charkhi Dadri, Kurukshetra, Panipat, Kaithal, Rohtak, Jhajjar, Mahendragarh, Jind, Ambala, Palwal, Panchkula, Yamunanagar, Rewari, and others), with service tax demands and penalties of corresponding amounts raised against each appellant.

7. M/S Indian Tributes vs The Union Of India

Bench: Patna High Court
Date: 22 April 2026
Sections engaged: 169, 73(1), 73(9)
Outcome: Outcome not specified in source
Procedural / substantive ground: Civil Writ Jurisdiction Case No. 9172 of 2025 was filed before the High Court of Judicature at Patna seeking to quash the order dated 30.04.2024, passed under Section 73 of the Bihar Goods and Services Tax Act, 2017, issued by the Assistant Commissioner of State Tax, Gandhi Maidan Circle, Patna. The petitioner, M/s Indian Tributes through its proprietor Mohammad Gohar, challenged the order against respondents including the Union of India through the Commissioner of CGST, Patna, and the State of Bihar through the Secretary, Commercial Tax Department.

8. WP(C)/5236/2022 vs Unspecified respondent

Bench: Gauhati High Court
Date: 21 April 2026
Sections engaged: 73(1), 66D
Outcome: Outcome not specified in source
Procedural / substantive ground: In W.P.(C) No. 5236/2022, the petitioner Sri Samujjal Phukan, engaged in the business of transportation of goods by road within the District of Dibrugarh, Assam and its neighbouring districts, challenged a show cause notice issued under a Central Goods & Service Tax demand proceeding; the judgment was reserved on 09.01.2026 and the full judgment was pronounced on 21.04.2026. The respondents included the Additional Commissioner, Central Goods & Service Tax, Dibrugarh, and the Additional Commissioner, Central Goods & Service Tax, Aizawl.

9. Hudson Insurance Brokers Private vs Union Territory Of Chandigarh And Ors

Bench: Punjab-Haryana High Court
Date: 17 April 2026
Sections engaged: 61, 73(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: In CWP-8559-2026, the petitioner — a company engaged in insurance brokerage and advisory within the financial and insurance services sector, duly registered under the GST regime — filed a writ petition under Articles 226/227 of the Constitution of India being aggrieved by an impugned order dated 24.12.2025 passed by the Commercial Tax Officer, Ward-3, Chandigarh, whereby a GST demand was raised against the petitioner. The judgment was reserved on 20.03.2026 and the full judgment was pronounced on 17.04.2026.

10. Samaridhhi Indusries vs Union Of India

Bench: Madhya Pradesh High Court
Date: 7 April 2026
Sections engaged: 73(1), 61(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Writ Petition No. 27203 of 2025, a show cause notice dated 31.05.2024 was issued under Section 73(1) of the MPGST Act, 2017, and an Order-in-Original dated 20.08.2024 was passed by the Assistant Commissioner, State Goods and Service Tax Department, Circle 3, Division 1, Bhopal, levying an amount of Rs. 15,22,810/- as tax, interest, and penalty for the assessment year April 2019 to March 2020; the petitioner admittedly did not file a reply to the show cause notice and did not file an appeal within the limitation period before the Appellate Authority.

11. M/S.Gi Technology Private Limited vs The Assistant Commissioner

Bench: Madras High Court
Date: 30 March 2026
Sections engaged: 73(1), 20
Outcome: Outcome not specified in source
Procedural / substantive ground: In WP No. 11970 of 2026, the petitioner filed a writ of certiorari under Article 226 of the Constitution of India seeking to quash Show Cause Notice No. 37/2024-(GST-AC) dated 30.05.2024 with DRC-01 dated 31.05.2024, and the consequential Order-in-Original No. 92/2024 (GST-AC) dated 28.08.2024 along with DRC-07 dated 30.08.2024, on the grounds that the same were illegal, arbitrary, unreasonable, and without jurisdiction under the provisions of the Goods and Service Tax Act, 2017. The respondent is the Assistant Commissioner of GST and Central Excise, Perungudi Division, Chennai South Commissionerate.

12. Sri Gouribidanur Venkatakrishna Kumar vs The Asst Commissioner

Bench: Karnataka High Court
Date: 27 March 2026
Sections engaged: 73(1), 85
Outcome: Outcome not specified in source
Procedural / substantive ground: In Writ Petition No. 100372 of 2024 (T-RES) before the Karnataka High Court, Dharwad Bench, the petitioner called in question the order dated 31.08.2023 passed by the Assistant Commissioner, CGST-Central Excise, Hubli Division, and issued on 25.09.2023, bearing No. BEL-EXCUS-000-HBL-AC-MR-24-2023-24-ST, which determined service tax liability, penalty, and late fee against the petitioner, combining three different assessment years.

Patterns across these 12 rulings

Writ petitions as the predominant challenge route. Across the majority of these cases, taxpayers approached High Courts under Articles 226/227 of the Constitution of India directly against orders-in-original or show cause notices, rather than exhausting the statutory appellate hierarchy first. Cases 1, 2, 4, 5, 7, 8, 9, 10, 11, and 12 all follow this pattern, raising recurring questions about the availability and adequacy of the appeal remedy under the GST framework.
Batch and linked-case filing. In at least two instances, the proceedings involved multiple related parties or linked writ petitions being heard together. Case 4 (M/S Tata Projects Limited) has a formally linked case (WP(C)/20/2026, M/S Quantum Infratech), and Case 6 (District Information Technology) is a batch of fifteen appeals involving District IT Societies across multiple Haryana districts — reflecting a pattern of coordinated litigation on common legal questions.
Pre-GST service tax demands under Section 73(1) of the Finance Act, 1994 continuing to generate litigation. Cases 3, 6, 8, and 12 all involve proceedings that originated from service tax demands under the pre-GST regime (Finance Act, 1994 / service tax framework), yet are still being adjudicated in 2026, illustrating the long tail of legacy service tax litigation continuing alongside GST-era disputes.
Orders-in-original challenged on procedural grounds. Several cases, including Cases 2, 10, 11, and 12, involve challenges to orders-in-original passed following show cause notices where the taxpayer either did not reply to the notice or did not appeal within the limitation period, with the writ petition used as the recourse of last resort. Case 10 (Samaridhhi Industries) is explicit in the preview that the petitioner did not file a reply to the show cause notice and did not appeal in time.
Geographic concentration in north-eastern and central India. Five of the twelve cases (Cases 1, 2, 4, 5, and 8) were heard by the Gauhati High Court, reflecting a concentration of Section 73(1) writ litigation before that court during this period. The remaining cases are spread across Gujarat, Madhya Pradesh, Patna, Punjab-Haryana, Madras, and Karnataka, confirming the all-India reach of these procedural challenges.

How to use this compilation

This compilation is intended as a first-pass research index, not a substitute for reading the full judgment in any individual case. Researchers should retrieve the complete order for each case from the relevant court portal (indiankanoon.org, the Gauhati High Court portal, Madras High Court's JUDIS system, or other official portals as applicable) before drawing any conclusions about the ratio, the operative order, or the relief granted. The source previews reproduced here are truncated and do not capture the full reasoning, dispositive direction, or any interim relief directions issued by the court.

Given that the outcome direction for all twelve cases is recorded as "Outcome not specified in source," researchers must independently verify the final operative order in each matter. Writ petitions of this nature can result in a range of directions — dismissal at the admission stage, remand to the adjudicating authority, stay of demand, quashing of notice, or relegation to the statutory appeal remedy — and none of these should be assumed from the procedural summary alone. Researchers should also check whether any subsequent appeal, special leave petition, or review has been filed against the ruling, particularly for cases decided by single-judge benches where a division bench appeal may be pending.

Finally, practitioners should cross-check the status of any CBIC circular, instruction, or trade notice that may have been issued with reference to the specific legal questions raised in these matters. The CBIC periodically issues clarifications on procedural aspects of Section 73(1) proceedings, limitation periods, and the scope of natural justice requirements, and such administrative guidance may operate alongside or independently of the judicial rulings indexed here.

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 73(1) GST Demand Notices: 12 High Court & Tribunal Rulings (2026)