RPP Infra Projects Ltd. v. Union of India
In favour of the revenue
The ruling in brief
RPP Infra Projects Ltd. challenged DGGI Kanpur's investigation before the High Court of Delhi (W.P.(C) Nos. 10852, 10853, 10861 of 2025, decided 16 September 2026). The infrastructure company held GST registrations in multiple States, administratively assigned to respective state commissionerates, but DGGI issued a common show cause notice alleging cross-State invoice chains and bogus credits. The assessee objected that only state-assigned officers could act on its registrations. The court reasoned under Sections 3, 4, 5, 6, and 168 of the CGST Act that officers of the Directorate General possess all-India powers irrespective of tax administrative allocation. Investigation and notice by DGGI were valid. The jurisdictional challenge failed and the writ was dismissed in favour of the Union of India. Multi-state registrants cannot limit DGGI inquiry by administrative assignment alone.
For information only — not legal advice. Read the full judgment and applicable law before relying on this summary.
Provisions considered
- CGST S.5 — Levy and collection of CGST on intra-State supplies.
- CGST S.3 — Section 3 of the Central Goods and Services Tax Act, 2017.
- CGST S.4 — Section 4 of the Central Goods and Services Tax Act, 2017.
- CGST S.6 — Authorisation of officers and concurrent State tax jurisdiction.
- CGST S.168 — Power to issue instructions or directions by the Board.
Source documents
Similar rulings
In favour of the revenue
Siemens Healthcare (P). Ltd. v. Union of India
Siemens Healthcare (P) Ltd. approached the High Court of Delhi (W.P. (C) No. 16562 of 2024, decided 12 August 2026) to restrain transfer of its audit file from the Audit Wing to the Anti-Evasion Wing within the same commissionerate. The taxpayer cited lack of statutory authority and disruption of audit timelines under Section 65 of the CGST Act. The court treated the transfer as an internal administrative reallocation, not barred by statute, particularly where it followed repeated non-compliance by the petitioner in responding to audit requisitions. Judicial interference at the writ stage was unwarranted; the petitioner could raise jurisdictional and procedural objections before the adjudicating authority in the consequential proceedings. The petition was dismissed in favour of the revenue. Section 5 empowers reallocation of work among officers without invalidating subsequent enforcement.
In favour of the revenue
Nehkhohao Haokip v. Union of India
Nehkhohao Haokip and others petitioned the High Court of Gauhati (WP(C) No. 3871 of 2026, 27 July 2026) against repatriation from In-Charge Transfer (ICT) postings in the CBIC. The petitioners had been promoted as Executive Assistants and transferred on ICT after the 2015 Recruitment Rules, which provided separate cadres and no provision for absorption. CBIC policy restricted ICT except in limited cases. The issue was whether orders treating ICT as loan postings and directing repatriation were valid. The court upheld the department's position that ICT postings were impermissible under the rules and policy framework. No infirmity was found in the repatriation orders. The writ was dismissed in favour of the Union of India. This summary is for CA reference on service matters touching GST administration, not legal advice.
In favour of the revenue
Mohammed Kamran v. Senior Intelligence Officer Directorate General of Goods and Service Tax Intelligence
Mohammed Kamran, a scrap trader, challenged parallel GST investigations before the High Court of Karnataka (Writ Petition No. 38771 of 2025, decided 7 July 2026). State GST had initiated an inquiry into discrepancies in his transactions; during its pendency the Directorate General of GST Intelligence commenced a wider investigation into related supply chains, and the state inquiry was formally transferred to the central authority. The petitioner invoked Section 6 of the CGST Act to argue that dual proceedings were barred. The court examined Sections 6, 69, 132, and 168 and found no identical liability or overlapping adjudication on the same cause of action. The designated central authority was competent to proceed on its own investigative material. Parallel investigation was held permissible. The writ was dismissed in favour of the revenue. This summary is for professional reference on officer jurisdiction, not legal advice.
In favour of the assessee
Singapore Airlines Ltd. v. Union of India
Singapore Airlines Ltd. approached the High Court of Bombay in Writ Petition No. 2702 of 2026, decided on 29 June 2026, to challenge IGST demands framed on Computer Reservation System (CRS) services. The revenue treated the airline as the recipient liable under the CGST Act, including proceedings under section 74. The airline contended it neither received the services in question nor paid consideration, so the prior issue was whether it was a "recipient" at all—a question going to jurisdiction rather than mere tax quantification. The Court held the writ petition maintainable despite availability of a statutory appeal, because the dispute touched the competence of the adjudicating authority and warranted deeper examination of sections 5 and 6 read with section 74. The outcome at this stage favoured the assessee on maintainability, leaving substantive liability to be determined in appropriate proceedings. This editorial summary is for professional awareness among chartered accountants and is not legal advice.
In favour of the revenue
Jorabat Shillong Expressway Ltd. v. Union of India
Jorabat Shillong Expressway Ltd., a BOT annuity road concessionaire, challenged GST demand on post-COD annuity before the Meghalaya High Court (WP(C) No. 245 of 2024, 2 June 2026), raising classification, exemption, composite supply, and constitutional issues under Sections 3, 5, 9, 74 and 107 CGST. Thangkhiew and Bhattacharjee JJ found mixed questions of fact and law requiring adjudication, with no grave jurisdictional or natural justice breach, and declined Article 226 in favour of statutory appeal. Outcome favoured revenue on maintainability. Large infrastructure concessions should pursue Section 107/GSTAT for annuity tax characterisation. This note is published for Chartered Universe GST case-law research and does not constitute legal advice. Readers should consult the full order, confirm the decision date and citation, and assess whether later statutory changes affect reliance before advising clients or filing appeals.