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Disputed GST Classification Must Be Raised in Appeal, Not Writ
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Madhya Pradesh High Courttax

Disputed GST Classification Must Be Raised in Appeal, Not Writ

October 14, 2026

The Madhya Pradesh High Court ruled that challenges to GST product classification must be addressed in appellate proceedings, not writ petitions, and such appeals are exempt from limitation periods.

MPHC Bars Writ Challenges to GST Classification

The Madhya Pradesh High Court dismissed a writ petition filed by Novus Animal Nutrition challenging the GST classification of its products, holding that classification disputes must be adjudicated in statutory appeals under the CGST Act. The Court emphasized that writ petitions are not maintainable for re-evaluating technical classification issues already subject to an appellate mechanism.

The Court clarified that appeals before the Appellate Authority under Section 107 of the CGST Act are not subject to any limitation period, rendering writ jurisdiction under Article 226 unnecessary. It reiterated that the statutory hierarchy under the GST regime must be followed, and disputed tax classifications involve factual and interpretative inquiries unsuitable for exercise through writ.

This decision reinforces the principle that statutory remedies must be exhausted before seeking extraordinary writ relief. Practitioners should advise clients to file timely appeals rather than resorting to writ petitions in classification disputes, ensuring compliance with the CGST Act’s dispute resolution framework.

Citations

  • CGST Act, 2017, Section 107
  • Article 226 of the Constitution
Practice Areas:tax

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