HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 2474/2026 Rajasthan State Pollution Control Board ----Petitioner Versus Joint Commissioner Of Central Tax ----Respondent For Petitioner(s) : Mr. Siddharth Ranka For Respondent(s) : Mr. Kinshuk Jain, Senior Standing Counsel Mr. Kuldeep Singh, AAAG Ms. Yuvika Pilania, AGC Mr. Arun Kumar, AGC Mr. Yuvraj Singh Rajawat HON'BLE MR. JUSTICE INDERJEET SINGH HON'BLE MR. JUSTICE RAVI CHIRANIA

Order

17/02/2026 Learned counsel for the petitioner submits that the issue involved in this writ petition has been considered and decided by the co-ordinate Bench of this Court in the matter of M/s Kota Metals & Anr. Vs. The Addl. Commissioner (Adjudication) & Ors. In D.B. Civil Writ Petition No.19707/2025, wherein on 16.12.2025, following order was passed:-

“1. It is stated that the show cause notice under Section 74 of the Central Goods and Services Tax Act, 2017 has been issued for the years 2018-2019 to 2023-2024 through a single show cause notice and adjudicatory order has also been passed for all the years together.

2. Learned Senior Counsel appearing for the petitioners submits that the issue of limitation, cross- examination and the benefit from one year to another, are required to be examined and common notice for various years itself is bad in law.

3. Learned Senior Counsel also relies on the interim orders passed by this Court in the cases of “M/s Shree Balaji Industries Laxminarayanpuri vs. The Additional Commissioner, Central Goods and Services Tax & Ors.” (D.B. Civil Writ Petition No.7306/2025) and “M/s Meridean Overseas Education Consultants Private Limited vs. Union of India” (D.B. Civil Writ Petition No.15990/2025), where such notices for various years were found prima facie to be erroneous and the concerned petitioners were protected.

4. Issue notice to respondents.

5. Mr. Vedant Agrawal along with Mr. Rajat Sharma, learned counsels accept notice on behalf of the respondents No.1 to 4.

6. Ms. Mahi Yadav, learned Additional Advocate General, accepts notice on behalf of the respondent Nos.5 & 6.

7. Therefore, service is treated as complete.

8. Reply to the writ petition be filed. The same may be filed within four weeks.

9. List this case after four weeks.

10. Meanwhile, the effect and operation of the adjudication order dated 12.09.2025 passed under Section 74 of CGST Act shall remain stayed.”

In that view of the matter, notice be issued to the Mr. Kinshuk Jain, learned counsel accepts notice on behalf of List for final disposal after four weeks.

In the meanwhile, no coercive action shall be taken against the petitioner.

Liberty is granted to the respondents to file appropriate application for vacation/modification of this order.

(RAVI CHIRANIA),J (INDERJEET SINGH),J PAYAL/TUSHAR /63