The Hon’ble Delhi High Court in Armour Security India Limited v. Union of India & Anr. [W.P.(C) No. 10738 of 2026 dated August 03, 2026] declined to exercise writ jurisdiction against the Show Cause Notice issued under Sections 76 and 74 of the Central Goods and Services Tax Act, 2017 (“the CGST Act”) and the consequent Order-in-Original, and relegated the assessee to the alternative remedy of appeal under Section 107 of the CGST Act, holding that the question as to what constitutes a “reasonable period” for issuance of a Show Cause Notice under Section 76 of the CGST Act is required to be adjudicated upon on the basis of the facts of each case, and such power is very much available with the Appellate Authority. The comprehensive appellate remedy cannot be narrowly construed so as to exclude examination of this question.
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