[2026:RJ-JP:26711-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 11802/2026 URN: CW / 26104U / 2026 Deepak Goyal S/o Sh. Satyanarayan Goyal, Aged About 45 Years, R/o E-33, E Block, Agrasen Nagar, Kishangarh, Ajmer, Rajasthan - 305801, Director Of M/s Mainawat Package Industry Pvt. Ltd. (Gstin 08Aabcm8087D1Zc), Having Its Registered Place Of Business At E-8, Riico Industrial Area, Madanganj-Kishangarh, Ajmer, Rajasthan - 305801. ----Petitioner Versus 1. The Joint Commissioner, , Central Goods And Services Tax And Central Excise Commissionerate, N.c.r. Building, Statue Circle, C-Scheme, Jaipur - 302005. 2. The Additional Director, Directorate General Of Goods And Services Tax Intelligence, Jaipur Zonal Unit, C-62, Sarojani Marg, C-Scheme, Jaipur - 302001. 3. The Union Of India, Ministry Of Finance, Department Of Revenue, Room No. 46, North Block, New Delhi - 110001, Through Its Revenue Secretary. 4. State Of Rajasthan, Through The Finance Secretary (Revenue), Finance Department, Government Of Rajasthan, 1St Floor, Main Building, Government Secretariat, Janpath, Jaipur 302005. ----Respondents For Petitioner(s) : Mr. Rahul Lakhwani Mr. Mihir Jhanwar, Advocates For Respondent(s) : Mr. Sachin Singh Rathore, Mr. Tanishq Aditya Parmar & Mr. Anshuman Singh, Advocates for Mr. S.S. Naruka, AAG HON'BLE MR. JUSTICE ARUN MONGA HON'BLE MR. JUSTICE MANEESH SHARMA Order 15/07/2026 1. The instant writ petition has been filed by the petitioner challenging the order in original dated 27.03.2026 (Annexure-1) passed [2026:RJ-JP:26711-DB] (2 of 3) [CW-11802/2026] by Joint Commissioner CGST, Statue Circle, C-scheme, Jaipur whereby GST demand of Rs.3,99,23,139/- for Financial Year 2019-20 and Financial Year 2018-2019 was raised on the account of wrongful availment and utilization of Input Tax Credit by the petitioner. 2. Heard and perused the case file. 3. At the outset, learned counsels for the respondents object to the maintainability of the writ petition herein stating that the alternative remedy as provided under Section 107 of the CGST Act, 2017, has not been availed. 4. Statutory remedy by way of an appeal under Section 107 of the CGST Act, 2017 before the Appellate Authority is provided against the impugned order dated 14.10.2025. Section 107 reads as under:- “Section 107. Appeals to Appellate Authority.- (1) Any person aggrieved by any decision or order passed under this Act or the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act by an adjudicating authority may appeal to such Appellate Authority as may be prescribed within three months from the date on which the said decision or order is communicated to such person. x-x-x-x-x“ 5. The instant writ petition was filed on 25.06.2026 against the impugned order, which was within the stipulated time period prescribed under Section 107 of the CGST Act, 2017 (factoring in the power to condone the delay of 120 days under Section 107 of the CGST Act, 2017). 6. In view of the aforesaid, we are not inclined to directly entertain the writ petition without the petitioner exhausting its alternate statutory remedy. 7. Accordingly, the writ petition is dismissed with liberty to the petitioner to raise all his grounds, legal and factual, before the appellate authority. [2026:RJ-JP:26711-DB] (3 of 3) [CW-11802/2026] 8. In the parting, in exercise of jurisdiction under Article 226 of Constitution of India, it is directed that time taken before this Court shall be excluded by the Appellate Authority while calculating limitation period to entertain the appeal under Section 107, ibid, if the appeal is filed within 30 days. 9. Disposed of accordingly. 10. All pending applications also stand disposed of. (MANEESH SHARMA),J (ARUN MONGA),J DEEPA/5