[2026:RJ-JP:28134-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 12933/2026 URN: CW / 28274U / 2026 Amit Singhal S/o Late Shri Purushottam Singhal, Aged About 37 Years, R/o 3, Keshav Nagar, Keshopura Bypass, Chungi Naka, Ajmer Road, Jaipur, Rajasthan -302024. ----Petitioner Versus 1. The Joint Commissioner, State Tax, Circle-C, Enforcement Wing-III, Rajasthan, Jaipur, Room No. 303, New Building, Kar Bhawan, Ambedkar Circle, Jaipur - 302005. 2. The Union Of India, Ministry Of Finance, Department Of Revenue, Room No. 46, North Block, New Delhi - 110001, Through Its Revenue Secretary. 3. State Of Rajasthan, Through The Principal Secretary, Finance (Revenue) Department, Government Of Rajasthan, 1st Floor, Main Building, Government Secretariat, Janpath, Jaipur, Rajasthan - 302005. ----Respondents For Petitioner(s) : Mr. Rahul Lakhwani Mr. Mihir Jhanwar For Respondent(s) : Ms. Mahi Yadav, AAG with Ms. Chelsi Agarwal HON'BLE MR. JUSTICE ARUN MONGA HON'BLE MR. JUSTICE ASHUTOSH KUMAR Order (Oral) 22/07/2026 Per: Arun Monga, J. 1. The petitioner seeks quashing of the Show Cause Notice dated 21.04.2026 issued by respondent No. 1 under Section 122(1A) of the Rajasthan Goods and Services Tax Act, 2017 (for short "the RGST Act"), proposing a penalty of ₹47,64,95,447/- upon the petitioner, as also of [2026:RJ-JP:28134-DB] (2 of 4) [CW-12933/2026] the reply-cum-communication dated 15.06.2026, whereby the petitioner's preliminary objections were rejected in limine. 2. Briefly, the facts as stated in the petition are that the petitioner is an accountant and tax-return preparer practicing under the name "Tax Agility", whose professional work is stated to be confined to assisting clients in obtaining GST registration and filing GST returns on the basis of the information and documents furnished by them. It is averred that the petitioner has no proprietary, managerial or beneficial interest in any of the firms referred to in the impugned Show Cause Notice. Respondent No. 1 initiated an investigation into the alleged creation of fake firms for wrongful availment and passing on of input tax credit (ITC), in the course of which searches were conducted at the premises of several entities and statements of their proprietors were recorded under Section 70 of the RGST Act. The petitioner contends that these statements were recorded in his absence and are now sought to be relied upon to brand him the "mastermind" behind twenty-three firms, without his being afforded any opportunity to cross-examine the persons whose statements are so relied upon. 2.1 A search was conducted at the petitioner's premises on 13.12.2024 under Section 67 of the RGST Act, during which certain articles, including rubber seals, cheque books, mobile phones and a laptop, were seized; the seized electronic devices were subsequently subjected to forensic examination. The petition further states that the petitioner was arrested on 26.11.2024 under Section 69 of the RGST Act in connection with alleged offences under Section 132, and that criminal proceedings arising out of the same transactions are pending before the competent criminal court. It is also averred that, following an ex parte audit of the seized material, respondent No. 1 issued the impugned Show Cause Notice under Section 122(1A) of the RGST Act [2026:RJ-JP:28134-DB] (3 of 4) [CW-12933/2026] proposing a penalty of ₹47,64,95,447/- for the financial years 2019-20 to 2024-25, said to represent the aggregate of the ITC allegedly wrongly availed and passed on. 2.2 The petitioner submitted preliminary objections in Form GST DRC- 06 challenging, inter alia, the jurisdiction of respondent No. 1, the denial of cross-examination, the non-supply of the relied-upon documents, the absence of a valid Document Identification Number, limitation, and the very applicability of Section 122(1A), while also seeking an opportunity of personal hearing. According to the petitioner, respondent No. 1, the very officer who conducted the investigation and issued the impugned Show Cause Notice, rejected the preliminary objections by the communication dated 15.06.2026, fixed the matter for hearing on merits, and proceeded further without furnishing the relied- upon documents or granting cross-examination. 2.3 Hence this writ petition. 3. We have heard learned counsel for the parties and perused the case file. 4. We find no ground to interfere at this stage. The proceedings before the competent authority are at a nascent stage, and the petitioner, as it transpires, has already joined those proceedings by submitting a reply to the impugned Show Cause Notice, which reply (Annexure-3) we have also perused. 5. We would, however, observe in parting that we expect the competent authority to supply to the petitioner the material relied upon by it, as sought in the reply, before taking a final decision on the Show Cause Notice. 6. With these observations, the writ petition stands disposed of. 7. It further transpires that the petitioner has, in the course of the proceedings, filed an application seeking cross-examination of the [2026:RJ-JP:28134-DB] (4 of 4) [CW-12933/2026] witnesses whose statements are relied upon. Appropriate orders shall also be passed, either way, on the pending application(s) in accordance with law. 8. All pending application(s) also stand disposed of. (ASHUTOSH KUMAR),J (ARUN MONGA),J 3/MOHITA/PARSHANT