[2026:RJ-JP:3745-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 12405/2021 Adapt Infra Private Limited, Having Registered Office At 602, Apex Tower, Lal Kothi Scheme, Tonk Road Jaipur - 302015 Through Its Director Shri Gaurav Khandelwal S/o Shri Prakash Chand Khandelwal ----Petitioner Versus 1. Principal Commissioner, Central Goods And Services Tax, New Central Revenue Building, Statue Circle, C-Scheme, Jaipur, Rajasthan-302001. 2. Joint Commissioner, Anti Evasion, Central Goods And Services Tax, New Central Revenue Building, Statue Circle, C-Scheme, Jaipur Rajasthan-302001 3. Commissioner, Commercial Taxes Department, Rajasthan State Goods And Service Tax, Kar Bhawan, Ambedkar Circle, C-Scheme, Jaipur. 4. Deputy Commissioner, State Tax, Anti Evasion, Zone Iii, Rajasthan State Goods And Service Tax, Zonal Kar Bhawan, Jhalana Doongri Institutional Area, Jaipur, Rajasthan. 5. Assistant Commissioner, State Tax, Circle N, Rajasthan State Goods And Service Tax Zonal Kar Bhawan, Jhalana Doongri Institutional Area, Jaipur, Rajasthan. ----Respondents Connected With D.B. Civil Writ Petition No. 12365/2021 Gaurav Khandelwal S/o Shri Prakash Chand Khandelwal, Resident Of 802-803, Somdutt Landmark, Coral Block, Hawa Sadak, Civil Lines, Jaipur, Rajasthan - 302006 ----Petitioner Versus 1. Principal Commissioner, Central Goods And Services Tax, New Central Revenue Building, Statue Circle, C-Scheme, Jaipur, Rajasthan-302001. 2. Joint Commissioner, Anti Evasion, Central Goods And Services Tax, New Central Revenue Building, Statue [2026:RJ-JP:3745-DB] (2 of 5) [CW-12405/2021] Circle, C-Scheme, Jaipur Rajasthan-302001 3. Commissioner, Commercial Taxes Department, Rajasthan State Goods And Service Tax, Kar Bhawan, Ambedkar Circle, C-Scheme, Jaipur. 4. Deputy Commissioner, State Tax, Anti Evasion, Zone Iii, Rajasthan State Goods And Service Tax, Zonal Kar Bhawan, Jhalana Doongri Institutional Area, Jaipur, Rajasthan. 5. Assistant Commissioner, State Tax, Circle N, Rajasthan State Goods And Service Tax Zonal Kar Bhawan, Jhalana Doongri Institutional Area, Jaipur, Rajasthan. ----Respondents D.B. Civil Writ Petition No. 14623/2021 Hari Singh Choudhary S/o Shri Gaja Nand Choudhary, Resident Of 87, Mansinghpura, Tonk Road, Durgapur, Jaipur, Rajasthan - 302018. ----Petitioner Versus 1. Principal Commissioner, Central Goods And Services Tax, New Central Revenue Building, Statue Circle, C-Scheme, Jaipur, Rajasthan-302001. 2. Joint Commissioner, Anti Evasion, Central Goods And Services Tax, New Central Revenue Building, Statue Circle, C-Scheme, Jaipur Rajasthan-302001 3. Commissioner, Commercial Taxes Department, Rajasthan State Goods And Service Tax, Kar Bhawan, Ambedkar Circle, C-Scheme, Jaipur. 4. Deputy Commissioner, State Tax, Anti Evasion, Zone Iii, Rajasthan State Goods And Service Tax, Zonal Kar Bhawan, Jhalana Doongri Institutional Area, Jaipur, Rajasthan. 5. Assistant Commissioner, State Tax, Circle N, Rajasthan State Goods And Service Tax Zonal Kar Bhawan, Jhalana Doongri Institutional Area, Jaipur, Rajasthan. ----Respondents D.B. Civil Writ Petition No. 14625/2021 Rinkal Khandelwal W/o Gaurav Khandelwal, Resident Of 802- 803, Coral Block, Somdatt Landmark, Civil Line, Hawa Sadak, [2026:RJ-JP:3745-DB] (3 of 5) [CW-12405/2021] Jaipur, Rajasthan-302006. ----Petitioner Versus 1. Principal Commissioner, Central Goods And Services Tax, New Central Revenue Building, Statue Circle, C-Scheme, Jaipur, Rajasthan-302001. 2. Joint Commissioner, Anti Evasion, Central Goods And Services Tax, New Central Revenue Building, Statue Circle, C-Scheme, Jaipur Rajasthan-302001 3. Commissioner, Commercial Taxes Department, Rajasthan State Goods And Service Tax, Kar Bhawan, Ambedkar Circle, C-Scheme, Jaipur. 4. Deputy Commissioner, State Tax, Anti Evasion, Zone Iii, Rajasthan State Goods And Service Tax, Zonal Kar Bhawan, Jhalana Doongri Institutional Area, Jaipur, Rajasthan. 5. Assistant Commissioner, State Tax, Circle N, Rajasthan State Goods And Service Tax Zonal Kar Bhawan, Jhalana Doongri Institutional Area, Jaipur, Rajasthan. ----Respondents For Petitioner(s) : Mr. Ravindra Pal Singh, Adv. Mr. Ranjan Mehta, Adv. For Respondent(s) : Ms. Mahi Yadav, AAG with Ms. Harshita Verma, Adv. Mr. Rohan Mittal, Adv. Mr. Kinshuk Jain, with Mr. Parth Khandal, Adv. Mr. Sourabh Jain, Adv. Mr. Sunil Yadav, Adv. Mr. Siddharth Ranka, Adv. HON'BLE DR. JUSTICE PUSHPENDRA SINGH BHATI HON'BLE MRS. JUSTICE SANGEETA SHARMA Order 28/01/2026 [2026:RJ-JP:3745-DB] (4 of 5) [CW-12405/2021] 1. Learned counsel for the petitioner submits that the issue of leviability of GST on royalty is the core issue and requires adjudication by this Court. 2. Mr. Kinshuk Jain, learned counsel appearing for the respondent, submits that the issue stands squarely covered by the judgment rendered by a coordinate Bench of this Court in the case of Sudershan Lal Gupta Contractor v. Union of India & Ors. (D.B. Civil Writ Petition No. 8109/2022), decided on 27.09.2022, along with other connected matters. He further submits that the coordinate Bench of this Court, while deciding the matter, relied upon the judgments rendered in the cases of Udaipur Chambers of Commerce and Industry & Ors. v. Union of India & Anr. (D.B. Civil Writ Petition No. 14578/2016, decided on 26.07.2021); M/s Mateshwari Minerals & Anr. v. Union of India & Anr. (D.B. Civil Writ Petition No. 7650/2021, decided on 17.12.2021); M/s Shivalik Silica v. Union of India & Ors. (D.B. Civil Writ Petition No. 14849/2021); and Rajasthan Small Mines (Cheja Patthar) Lease Holders Association & Ors. v. State of Rajasthan & Ors. (D.B. Civil Writ Petition No. 5199/2022). 3. Learned counsel for the petitioner tried to distinguish this case by saying that the broader issue of leviability of GST on royalty is still open. 4. This Court, upon perusing the judgment rendered in the case of Sudershah Lal Gupta (supra), finds that all issues pertaining to the same prayer have been duly dealt with, and is thus not persuaded to take any other different view. [2026:RJ-JP:3745-DB] (5 of 5) [CW-12405/2021] 5. In view of the decision rendered in the case of Sudershah Lal Gupta (supra), the present petitions are dismissed. However, the petitioners shall be at liberty to take up any other issue(s) other than the issue of leviability of GST on royalty, if the need arises. (SANGEETA SHARMA),J (DR. PUSHPENDRA SINGH BHATI),J Sudheer/Heena/58-61