The Hon’ble Patna High Court in the case of Manju Devi Agarwal v. Central Board of Indirect Taxes and Customs & Ors. [Civil Writ Jurisdiction Case No. 862 of 2026, order dated April 27, 2026] held that where the taxpayer voluntarily discharged substantial tax liability after audit but failed to contest allegations of wilful suppression and also admitted liability towards interest and penalty during adjudication, such taxpayer is estopped from subsequently challenging invocation of Section 74 of the CGST Act in writ jurisdiction.
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