The petitioner challenged a show cause notice alleging misclassification of two-wheeler seats and short payment of GST for the period from 2017 onwards. The factual background showed that the petitioner had already paid differential tax under protest owing to prevailing classification disputes.

The Court held that the issues raised involved disputed questions of fact and classification which require adjudication. Since the petitioner had an opportunity to respond to the notice, interference at the show cause notice stage was not warranted. The writ petition was dismissed.