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HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR

D.B. Civil Writ Petition No. 3665/2026

M/s N.a Enterprises, Through Its Proprietor Shri Anil Kumar Gupta F-540, Road No-1D, Vki Area, Jaipur- 302013 (Rajasthan)

----Petitioner

Versus

1. Union Of India, Through Secretary Finance, Ministry Of Finance, North Block, New Delhi- 110001

2. Additional Commissioner, Central Goods And Service Tax Department, Ncrb, Statue Circle, C-Scheme, Jaipur.

3. State Of Rajasthan, Through Secretary Finance, Secretariat, Janpath, Jaipur- 302015

----Respondents

For Petitioner(s) : Mr. Sarvesh Jain For Respondent(s) : Mr. Rohan Mittal, for

Ms. Mahi Yadav, AAG

HON'BLE MR. JUSTICE INDERJEET SINGH HON'BLE MR. JUSTICE RAVI CHIRANIA

Order

27/03/2026

1. Learned counsel for the petitioner submits that the issue involved in the present writ petition has already been considered and decided by a Co-ordinate Bench of this Court in the matter of ‘M/s. Kota Metals & Anr. vs. The Additional Commissioner (Adjudication) & Ors.’, (D.B. Civil Writ Petition No.19707/2025) vide order dated 16.12.2025, wherein the

following order was passed:

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“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 Agarwal 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.”

2. Issue notice to the respondents, returnable within a period of

four weeks.

3. List the matter after four weeks, along with D.B. Civil Writ

Petition No.19707/2025.

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4. Meanwhile, effect and operation of the impugned order dated 30.12.2025 (Annex.4) passed by the respondent No.2 shall

remain stayed.

(RAVI CHIRANIA),J ( INDERJEET SINGH),J

4 - RAVI KHANDELWAL

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