The petitioner challenged a show cause notice proposing levy of GST at 28% instead of the prevailing rate of 18% on the ground of change in interpretation. The factual background showed that the petitioner sought writ intervention at the notice stage, alleging discrimination and non-reference to the GST Council.

The Court held that a show cause notice cannot ordinarily be challenged under writ jurisdiction when statutory remedies are available. Since the petitioner had an opportunity to file a reply and be heard before adjudication, interference at the notice stage was unwarranted. The writ petition was dismissed.