Order date:  13 Aug 2025 
Parties: Abhinandan Sahoo v. Chief Commissioner of CT & GST, Odisha & Ors.

Facts -

• The petitioner assailed a demand order dated 21.08.2024 passed under Section 73 of the CGST/OGST Act for April 2019–March 2020, raising tax, interest, and penalty. 
• Alongside, he challenged Notifications 09/2023-CT and 56/2023-CT issued under Section 168A extending limitation periods, contending they were invalid. He argued that the order was time-barred and based on erroneous cross-references to Section 73(10) and Section 75(2).

Issue -

• Whether a writ petition is maintainable to challenge a Section 73 demand order and the validity of limitation-extension notifications under Section 168A.

Order -

• The Court held that the petitioner had an efficacious statutory appellate remedy under the GST Act; invoking writ jurisdiction under Article 226 was impermissible in the absence of extraordinary circumstances.
• It noted that the petition was also hit by delay and laches, since the impugned notifications were issued in 2023 but challenged only in August 2025.
• No exceptional grounds such as patent lack of jurisdiction or gross violation of natural justice were demonstrated to justify bypassing the appellate mechanism.
• The Court expressly refrained from ruling on the validity of the limitation-extension notifications under Section 168A, leaving the petitioner free to raise such issues before the appellate authority.