The petitioners, Union of India and another, filed a Special Leave Petition before the Supreme Court challenging the judgment and order dated 12 March 2025 passed by the Delhi High Court in W.P.(C) No. 114/2025. The matter relates to the interpretation and application of Section 25(4) of the Central Goods and Services Tax (CGST) Act, 2017, which stipulates that each registration obtained under the Act shall be treated as a distinct person for all purposes of the statute.

During the hearing, the petitioners, represented by the learned Additional Solicitor General, contended that the Delhi High Court’s decision had failed to give due effect to this statutory provision. It was argued that the High Court’s view disregarded the legislative intent that separate registrations must be considered as distinct taxable entities, which directly impacts the manner in which tax liabilities and compliance are to be determined under the CGST framework.

After hearing the petitioner’s counsel, the Supreme Court issued notice to the respondents, returnable within six weeks, thereby seeking their response to the issues raised in the petition.