Metallicz Media Private Limited Vs Union of India (Delhi High Court)
The petitioner, Metallicz Media Private Limited, filed a writ petition under Articles 226 and 227 of the Constitution challenging the Show Cause Notice (SCN) dated 8 May 2024 and the consequent ex-parte order dated 5 August 2024 for the financial year 2019–20, issued by the Sales Tax Officer, Delhi. The petitioner also questioned the vires of several Central and State notifications—Notification Nos. 9/2023 and 56/2023 (Central Tax) and Notification Nos. 9/2023 and 56/2023 (State Tax).
The Court observed that the challenge to these notifications mirrors issues raised in a batch of petitions led by DJST Traders Private Limited, where the question of whether the notifications complied with Section 168A of the CGST Act was examined. In those matters, different High Courts had delivered divergent rulings, and the Supreme Court was already seized of the issue in SLP No. 4240/2025. The Supreme Court noted the national-level split in judicial opinion and issued notice to decide whether the extended time limits for issuing orders under Section 73 for 2019-20 could be validly extended under Section 168A.
Since the Supreme Court’s decision will govern the controversy, the Delhi High Court recorded that the petitioner’s challenge to the impugned notifications must remain subject to the Supreme Court’s final ruling. The Court noted that challenges to parallel State notifications continue to be examined separately in another batch, led by Engineers India Limited.
