HIGH COURT OF JUDICATURE AT ALLAHABAD WRIT TAX No. - 2421 of 2026 Court No. - 3 HON'BLE SAUMITRA DAYAL SINGH, J. HON'BLE SWARUPAMA CHATURVEDI, J. 1. Heard Shri Adarsh Srivastava, learned counsel for the petitioner and Shri Arimardan Singh Rajpoot, learned counsel for the revenue. 2. Challenge has been raised to the Adjudication Order dated 03.03.2026 passed by Superintendent, CGST, Ghaziabad for tax period 2019-2020 to 2021-2022. 3. Two grounds have been pressed. First, it has been submitted that the impugned order has been passed arising from a composite notice issued by the adjudicating authority dated 29.09.2025 for the Financial Year 2019- 2020, 2020-2021 and 2021-2022. 4. Submission is, such composite notice is impermissible in law. It is without jurisdiction. 5. Second, the impugned order has been passed solely on the strength of audit conducted by the CAG. No independent satisfaction may have been recorded by the adjudicating authority. 6. On the other hand, learned counsel for the revenue would contend, the issue of composite notice has been decided against the assessee and in favour of the revenue by a coordinate bench in M/S SA Aromatics Pvt. Ltd. and another Vs. Union of India and 5 others, 2026:AHC:14559-DB. 7. On the second issue, it has been submitted, fact dispute exists. While the Versus Counsel for Petitioner(s) : Adarsh Srivastava, Reena Pal Counsel for Respondent(s) : Dhananjay Awasthi M/S Pit Zone Through Its Proprietor Anubhav Jain .....Petitioner(s) Superintendent, Central Gst .....Respondent(s) proceedings may have been initiated on the satisfaction recorded on the strength of information received from the CAG, impugned order has been passed after affording due opportunity of hearing. 8. Thus, preliminary objection has been raised that petitioner has statutory remedy of appeal available to him under section 107 of the CGST Act, 2017. 9. Having heard the learned counsel for the parties and having perused the record, on the first issue described as jurisdictional issue, in M/S SA Aromatics Pvt. Ltd. (supra), challenge raised to composite notice has been repelled. Such notice has been found to be valid. In view of that decision with which we are in agreement, there exists no scope to offer interference on that issue. 10. On the second issue, preliminary objection is sustained. Clearly fact disputes are involved as may require detailed consideration to be offered on facts. In face of statutory remedy of appeal available, we recognize the principle that in tax matters, writ jurisdiction may not be easily or readily invoked as may bye-pass the statutory remedy of appeal. 11. To the extent, such remedy of appeal is equally efficacious, interference claimed in the present writ petition is declined. 12. Accordingly, the writ petition is dismissed, leaving it open to the petitioner to avail statutory remedy in accordance with law. It is made clear, the said appeal, if preferred may dealt with on its own merit without being prejudiced by any observation made in this order. May 6, 2026 Bhanu WTAX No. 2421 of 2026 2 (Swarupama Chaturvedi,J.) (Saumitra Dayal Singh,J.) Digitally signed by :- BHANU PRATAP KUSHWAHA High Court of Judicature at Allahabad