[2026:RJ-JP:15051-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 12924/2025 M/s Krn Heat Exchangers And Refrigeration Limited, (Formerly Known As M/s Krn Heat Exchangers And Refrigeration Pvt Ltd)Through Authorised Person Mr. Kamal Singh S/o Mr. Bane Singh, Aged 37 Years, R/o. Teehli, Madha, Alwar, Rajasthan 301405. ----Petitioner Versus 1. Union Of India, Through The Secretary, Department Of Revenue, Ministry Of Finance, Government Of India, North Block, New Delhi-110 001. 2. The Union Of India, Through The Secretary, Ministry Of Commerce And Industry Vanijya Bhawan, New Delhi 110011. 3. The Director (International Customs Division), Central Board Of Indirect Taxes And Customs, Department Of Revenue, Ministry Of Finance, Room No. 49, North Block, New Delhi 110001. 4. The Deputy Head Agency Of Foreign Trade, Import Export Management Office 12 Nguyen Thi Minh Khai Str., Dakai Ward, District 1, Hochiminh City Vietnam. 5. Principal Commissioner Of Customs, Jodhpur (Preventive), Jaipur, Ncr Building, Statue Circle, C Scheme, Jaipur -05. 6. Additional Commissioner Of Customs, Jaipur, Ncr Building, Statue Circle, C Scheme, Jaipur - 5. 7. Deputy Commissioner Of Customs, Concor, Khatuwas, Distt Alwar, Rajasthan, 301701. ----Respondents Connected With D.B. Civil Writ Petition No. 12927/2025 M/s Vaishali Metals Private Limited, Usha Papriwal Authorized Officer G-485, Road No. 9A, V.k.i. Area, Jaipur, Rajasthan 302013. ----Petitioner Versus 1. Union Of India, Through The Secretary, Department Of Revenue, Ministry Of Finance, Government Of India, North Block, New Delhi-110001. 2. The Union Of India, Through The Secretary, Ministry Of Commerce And Industry, Vanijya Bhawan, New Delhi- 110011. 3. The Director (International Customs Division), Central Board Of Indirect Taxes And Customs, Department Of Revenue, Ministry Of Finance, Room No. 49, North Block, [2026:RJ-JP:15051-DB] (2 of 6) [CW-12924/2025] New Delhi 110001. 4. The Deputy Head Agency Of Foreign Trade, Import Export Management Office, 12 Nguyen Thi Minh Khai Str., Dakai Ward, District 1, Hochiminh City Vietnam. 5. Principal Commissioner Of Customs, Jodhpur (Preventive), Jaipur, Ncr Building, Statue Circle, C Scheme, Jaipur -05. 6. Additional Commissioner Of Customs, Jaipur, Ncr Building, Statue Circle, C Scheme, Jaipur - 5. 7. Deputy Commissioner Of Customs, Ncr Building, Statue Circle, C Scheme, Jaipur - 5. ----Respondents D.B. Civil Writ Petition No. 12930/2025 M/s Kwality Tubes And Capillaries, Mr. Sandeep Papriwal Authorized Officer G-478, Road No. 9A, V.k.i. Area, Jaipur, Rajasthan 302013. ----Petitioner Versus 1. Union Of India, Through The Secretary, Department Of Revenue, Ministry Of Finance, Government Of India, North Block, New Delhi-110001. 2. The Union Of India, Through The Secretary, Ministry Of Commerce And Industry, Vanijya Bhawan, New Delhi- 110011. 3. The Director (International Customs Division), Central Board Of Indirect Taxes And Customs, Department Of Revenue, Ministry Of Finance, Room No. 49, North Block, New Delhi 110001. 4. The Deputy Head Agency Of Foreign Trade, Import Export Management Office, 12 Nguyen Thi Minh Khai Str., Dakai Ward, District 1, Hochiminh City Vietnam. 5. Principal Commissioner Of Customs, Jodhpur (Preventive), Jaipur, Ncr Building, Statue Circle, C Scheme, Jaipur -05. 6. Additional Commissioner Of Customs, Jaipur, Ncr Building, Statue Circle, C Scheme, Jaipur - 5. 7. Deputy Commissioner Of Customs, Ncr Building, Statue Circle, C Scheme, Jaipur - 5. ----Respondents D.B. Civil Writ Petition No. 14936/2025 M/s. Daikin Air Conditioning India Private Limited, Having Its Registered Office At Sp2-12 To Sp2-15, Sp2-24 To Sp, New Indl Complex (Majrakath), Neemrana, Kotputli-Behror, Rajasthan - 301 705 Through Its Authorized Signatory Mr. Anurag Misra S/o Late Shri. R.n. Misra, Aged 50 Years, R/o Tower B-1, Flat No. 1204, Palm Grove Heights, Ardee City, Sector-52, Gurgaon, Haryana - 1220111, Working As Avp-Legal And Compliance [2026:RJ-JP:15051-DB] (3 of 6) [CW-12924/2025] ----Petitioner Versus 1. Union Of India, Through Secretary, Department Of Revenue, Ministry Of Finance, North Block, New Delhi- 110001 2. Central Board Of Indirect Taxes And Customs, Through The Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi- 110001 3. The Principal Commissioner Of Customs, Jodhpur (Preventive), N.c.r. Building, Statue, C Scheme, Jaipur - 302 005 4. The Director (International Customs Division), Central Board Of Indirect Taxes And Customs Room No. 19A, 4Th Floor, Jeevan Deep Building, Sansad Marg, New Delhi- 110001 ----Respondents D.B. Civil Writ Petition No. 16495/2025 M/s. Carrier Midea India Private Limited, Having Its Registered Office At First Floor, Pearl Tower, Plot No. - 51, Sector-32, Gurugram, Haryana- 122001 Through Its Authorized Signatory Mr. Sumit Prashant S/o Shri S.k. Paswan, Aged 39 Years, R/o 169, Secor A, Pocket B And C, Vasant Kunj, New Delhi- 110070, Working As The Senior Manager- Legal. ----Petitioner Versus 1. Union Of India, Through Secretary, Department Of Revenue, Ministry Of Finance, North Block, New Delhi- 110001. 2. Central Board Of Indirect Taxes And Customs Through The Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi- 110001. 3. The Commissioner Of Customs, Icd Patparganj And Other Icds, Near Ghazipur Village, New Delhi- 1100 96. 4. The Director (International Customs Division), Central Board Of Indirect Taxes And Customs, Room No. 19A, 4Th Floor, Jeevan Deep Building, Sansad Marg, New Delhi- 110001. ----Respondents For Petitioner(s) : Mr. Pradeep Rajpurohit on behalf of Mr. Chirag Shetty, through V.C. Ms. Ayushi Agrawal, through V.C. For Respondent(s) : Mr. Bharat Vyas, (Sr. Adv.) ASG assisted by Ms. Anushka Khandelwal & Ms. Anima Chaturvedi Mr. Bhuwnesh Sharma, AAG with [2026:RJ-JP:15051-DB] (4 of 6) [CW-12924/2025] Mr. Sunita Meena Mr. Vishnu Dutt Ms. Epsa Nangalia Mr. Ram Singh Bhati Mr. Kinshuk Jain, Sr. Standing Counsel assisted by Mr. Sourabh Jain Mr. Parth Khandal Ms. Mahi Yadav, AAG with Mr. Kuldeep Singh Rathore, AAAG Mr. Ayush Jain HON'BLE MR. JUSTICE INDERJEET SINGH HON'BLE MR. JUSTICE ASHOK KUMAR JAIN Order 10/04/2026 Since, the controversy involved in these writ petitions is similar in nature and the same are being decided by this common order. The facts of the case are taken from D.B. Civil Writ Petition No. 12924/2025, wherein the following prayer has been made as under:-:- “It is, therefore, most respectfully prayed that this Hon'ble Court may - graciously be pleased to ‘issue an appropriate writ of Mandamus or Certiorari or any other appropriate writ/ order/ direction: a. That this Hon’ble Court be pleased to issue a writ of mandamus, or any other appropriate writ, order, or direction restraining the Respondents to take any action contrary to the AIFTA against the Petitioner. b. That this Hon'ble Court be pleased to issue a writ of prohibition restraining the Respondent No. 5 from proceeding with the Impugned SCN No. GEN/ADT/PCA/332/2022/1449 dated 21.02.2025 (Annexure - P8). c. That this Hon'ble Court be pleased to issue a writ of certiorari or order or directions in the nature of certiorari or any other writ, order or direction of like nature, to quash and set aside the Impugned SCN No. GEN/ADT/PCA/332/2022/1449 dated 21.02.2025 issued by the Respondent No. 5 (Annexure — P8). [2026:RJ-JP:15051-DB] (5 of 6) [CW-12924/2025] d. That this Hon'ble Court be pleased to issue a writ of mandamus or 2 writ in the nature of mandamus or any other appropriate writ order or direction ordering and directing the Respondent No. 5 to withdraw the SCN No. GEN/ADT/PCA/332/2022/1449 dated 21.02.2025 (Annexure — P8). e. That this Hon’ble Court be pleased to issue a writ of certiorari or in the nature of certiorari or any other appropriate writ, order or direction to set aside the Letter dated 05.07.2623 issued by Respondent no. 6 (Annexure — P/7) f. That this Hon'ble Court be pleased, to issue a. writ of mandamus or a writ in the nature of mandamus or any other appropriate writ: order or direction ordering and directing the Respondent N 9.7 to release the future consignments of Petitioner without furnishing the bank guarantee and bond and by allowing the benefit of notification no. 46 of 2011 réad with notification no. 189 of 2009. g. That this Hon'ble Court be pleased to issue a writ of mandamus or a writ -in the nature of mandamus or any other appropriate writ order or direction ordering and directing the Respondent No.7 to cancel the bank - guarantee already given by the Petitioner and finalise the Bills of entry. after allowing the benefit of notification no. 46 of 2011 read with notification no. 189 of 2009. h. That this Hon’ble court during the pendency of this petition direct the Respondent no. 7 to release the impugned goods without furnishing of bank guarantee and bond. i. For any ad-interim relief. j. For costs of the Petition and orders thereon; and k. To provide any other:‘relief as this Hon’ble Court may deem -fit and proper. in facts, circumstances. and legal position of the case and in law to the Petitioner.” Learned Additional Solicitor General appearing on behalf of the respondents submits that these writ petitions filed against the show-cause-notices are not maintainable. He further relied upon the judgment passed by the Hon’ble Supreme Court in the matter [2026:RJ-JP:15051-DB] (6 of 6) [CW-12924/2025] of M/s Trillion Lead Factory Private Ltd. Vs. Superintendent of Central Tax (Special Leave to Appeal (C) No(s).7101/2026) decided on 27.02.2026, wherein, para No.4, it was held as under:- “4. It is trite law that no writ lies against an issuance of show cause notice and such writ petition would not be maintainable. This position has been explained to by this Court in the case of Secretary, Ministry of Defence and Others V. Prabhash Chandra Mirdha, (2012) 11 SCC 565 and in the judgment of Commr. Of Central Excise Commissionerate Vs. M/s. Krishna Wax (P) Ltd, Civil Appeal No.8609/2019 disposed of on 14.11.2019 vide paragraph 12.” Having perused the record, it is an admitted position that the present writ petitions have been filed challenging the show-cause notices. Accordingly, in view of the judgment rendered by the Hon’ble Supreme Court in the matter of M/s Trillion Lead Factory Private Ltd. (supra), the writ petitions stand dismissed. The petitioners are at liberty to raise all the legal issues before the concerned Authority. (ASHOK KUMAR JAIN),J (INDERJEET SINGH),J Upendra Pratap/37-41