The petitioner contested a show cause notice dated April 5, 2024, arguing that it relied heavily on statements recorded during the Pre-GST regime in 2018-19. The petitioner’s counsel, Mr. Hidayatullah, contended that these statements, not taken during any formal inquiry, should not serve as a basis for the notice. Citing a prior decision from the same court, he asserted that such statements were essentially non-evidence and that the show cause notice lacked sufficient legal grounding.

Mr. Hidayatullah argued that the notice should be quashed as it was not supported by significant evidence beyond the disputed statements. He emphasized that without these statements, the notice could not stand. The petitioner sought an injunction preventing the authorities from proceeding further based on the notice.

Conversely, Mr. Mishra, representing the respondents, countered that the notice was based on more than just the contested statements. He suggested that other relevant materials from the investigation supported the notice, and that any questions regarding the admissibility of the statements could be addressed during the adjudication process once a response was submitted by the petitioner.

The court carefully examined the arguments from both parties. It established that unless the show cause notice was evidently issued without jurisdiction, it typically would not intervene at this preliminary stage. Drawing on precedents from the Supreme Court, the court reiterated that it should not entertain writ petitions solely contesting show cause notices unless they involved fundamental rights violations, breaches of natural justice, or clear jurisdictional failures.

The court referenced previous rulings, highlighting the established principle that litigants should first respond to show cause notices and raise their defenses within the adjudicatory framework. It asserted that unless the petitioner could demonstrate a complete lack of jurisdiction on the part of the authority issuing the notice, the matter should be resolved through the normal procedural channels.

Ultimately, the court declined to interfere with the show cause notice, asserting that the petitioner had not shown adequate grounds for such intervention. However, it granted the petitioner an extension of eight weeks to respond to the notice, ensuring that the time taken to address this matter would not count against any statutory limits for resolution.

The court emphasized that the petitioner’s defenses remain open for consideration in the ongoing proceedings. This ruling underscores the judiciary's commitment to procedural integrity while allowing for thorough examination of administrative actions.

In summary, while the petition was dismissed, the court's decision reinforced the importance of adhering to established legal processes in administrative disputes, highlighting the balance between challenging authority and maintaining procedural norms.