1 CGHC010373822026 2026:CGHC:42183 NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR WPT No. 172 of 2026 1 - M/s. Best Security Services Through Its Proprietor Kuldeep Chaturvedi S/o Shri Rajkishore Chaturvedi Aged About 43, Years, Having Office At Flat No. 30, Third Floor Usha, Kiran Parisar Behind Jagriti School Bhatagaon, Raipur Chhattisgarh. ... Petitioner versus 1 - Union Of India Through - The Secretary Department Of Reuven Ministry Of Finance Government Of India North Block New Delhi. 2 - Central Board Of Indirect Taxes And Customs , Through- Its Chairman North Block New Delhi. 3 - Additional Director General Directorate General Of G S T Intelligence, Raipur Zonal Unit, 4th Floor R I O Complex, Lalpur Dhamtari Road Raipur Chhattisgarh. 4 - The Additional / Joint Commissoiner, (Adjudicationg Authority) Central G S T And Central Excise Commissionerate G S T Bhawan Old Dhamtari Road Tikrapara Raipur Chhattisgarh. ... Respondents For Petitioner : Mr. Shishir Dixit, Advocate For Respondents : Mr. Maneesh Sharma, Advocate Hon’ble Shri Justice Narendra Kumar Vyas Order on Board 28/09/2026 1. By way of the present petition, the petitioner has challenged Show Cause Notice (SCN) No. 16/RZU/JD/GST/2026-27 dated 31.08.2026 (Annexure P/1), issued under Sections 76 and 122 of the Central Goods and Services Tax Act, 2017, read with the corresponding provisions of the State Goods and Services Tax Act, 2017, and Section 20 of the Integrated Goods ARPAN SRIVASTAVA Digitally signed by ARPAN SRIVASTAVA Date: 2026.10.08 18:08:57 +0530 2 and Services Tax Act, 2017 for the tax period from April 2019 to March 2026. Demanding of GST amounting to Rs. 20,62,01,771/-, along with applicable interest and penalty. 2. Learned counsel for the petitioner submits that the impugned show cause notice dated 31.8.2026 has been issued by respondents authorities for expanding the financial year from 2019-20 to 2025-26 demanding GST amounting to Rs,20,62,01,771/-alongwith interest and penalty, for which it has no jurisdiction, therefore, aforesaid show-cause notice is liable to be quashed. 3. On the other hand, Mr. Sharma, learned counsel appearing for the respondents would submits that the objections raised by the petitioner in the present writ petition may be raised before the appropriate/competent authority, which shall be duly considered and decided by the authority concerned in accordance with the provisions of Section 76 of the Central Goods and Services Tax Act, 2017, as such the writ petition challenging the show cause notice is not maintainable. 4. I have heard learned counsel for the parties and perused the material available record. 5. Having considered the rival submissions made herein-above, this Court is of the considered view that the challenge raised by the petitioner primarily relates to the jurisdiction and competence of the respondent-authority to issue the impugned show cause notice dated 31.08.2026 to which the petitioner has an efficacious remedy for placing objections, including the objection regarding the jurisdiction of the authority and the validity of the proposed levy, before the competent authority, which has been raised in the instant petition. As such, the writ petition at this juncture is not maintainabhle. 3 6. Accordingly, the present petition is disposed of with liberty to the petitioner to submit its detailed reply/objections to the impugned show cause notice before the competent authority within the period of sixty days from the date of receipt of copy of the order and in turn, the competent authority shall consider and decide the objections, including the objection regarding jurisdiction, by passing a reasoned and speaking order in accordance with law expeditiously on its own merits as this Court has not decided anything on the merit of its contention raised by either of the party. 7. With the aforesaid observations and directions, the writ petition stands disposed off. Sd/- (Narendra Kumar Vyas) JUDGE Arpan