Global Tech Fab Vs Government of NCT Delhi & Anr. (Delhi High Court)
Global Tech Fab filed a writ petition under Articles 226 and 227 of the Constitution of India before the Delhi High Court challenging a Show Cause Notice (SCN) dated 17th December 2023 and an assessment order dated 27th April 2024 for the financial year 2018-19. The assessment confirmed a total demand of ₹7,97,290, including interest of ₹3,66,166. The petition also challenged an order dated 11th September 2025, wherein the petitioner’s bank account at Union Bank of India, Delhi Cantt, was provisionally attached under Section 83 of the Central Goods and Services Tax Act, 2017 (CGST Act). In addition, the petitioner contested the vires of three notifications: No. 09/2023-Central Tax dated 31st March 2023, No. 56/2023-Central Tax dated 28th December 2023, and No. 56/2023-State Tax dated 11th July 2024.
The challenges were similar to a batch of petitions led by DJST Traders Pvt. Ltd. vs Union of India. In that matter, the Delhi High Court had observed that Notification No. 9/2023-Central Tax was issued following GST Council recommendation, while Notification No. 56/2023-Central Tax was issued without prior recommendation, contrary to Section 168A of the CGST Act. Notification No. 56/2023-State Tax was issued after the expiry of the limitation under Notification No. 13/2022-State Tax. Various High Courts across India have taken different views on these notifications: Allahabad and Patna High Courts upheld the validity of Notifications 9 and 56, whereas Guwahati High Court quashed Notification No. 56/2023-Central Tax. The Telangana High Court noted potential invalidity of Notification 56/2023-Central Tax, which is presently under consideration by the Supreme Court in SLP No. 4240/2025 (M/s HCC-SEW-MEIL-AAG JV v. Assistant Commissioner of State Tax & Ors). The Supreme Court had issued notices on the SLP and interim relief.
