The Court highlighted that the show cause notice (SCN) had been properly uploaded on the portal and no satisfactory reply was filed, leaving no ground for interference. In doing so, the Court relied on Supreme Court and Delhi High Court precedents that consistently bar writ jurisdiction in fraudulent ITC matters.

The Chhattisgarh High Court held that once the Department admits no service tax was payable, it cannot use limitation or procedural lapses to deny refund of the amount deposited during investigation

The Supreme Court also upheld the constitutional validity of Section 97 of the Finance Act, 2022, which retrospectively validated show cause notices issued under Section 28.