Show Cause Notice — Issue of Jurisdiction – The petitioner challenged issuance of SCN dated 18.01.2022, as the same is without jurisdiction. The counsel for the petitioner submitted that an issue of cross empowerment referring to provisions contained in Section 6  stating that in the absence of proper notification in that regard, the State authorities could not have issued SCN on the ground that once the assessment matter of the writ-petitioner was assigned to Central Taxation Authorities, the State Authority does not have jurisdiction to initiate proceedings under Section 73. The issuance of impugned notice under Section 73 is without compliance of mandatory provisions contained in Section 73. The court in respect of challenge to the circular and the SCN, observed that the circular merely works out the authorisation under Section 6(1). It is not appropriate for the Court, to consider the validity or otherwise of the show cause notice having regard to the fact that an alternative remedy by way of an appeal exists in favour of the petitioner. The petitioner instead of challenging the SCN at this stage should workout its remedy. At present, only show cause notice has been issued. The petitioner may raise various grounds, except the issue of jurisdiction, which has been raised in the writ petition and the same are required to be considered by the authority.

Held that:- The Hon’ble High Court dismissed the petition.