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Delhi High Court rules on CGST Section 107 pre-deposit laws

The Delhi High Court has ruled on the applicability of pre-deposit laws under Section 107 of the Central Goods and Services Tax (CGST) Act, 2017. In a judgment involving multiple writ petitions, the court determined that amended pre-deposit requirements introduced via Notification No. 16/2025-Central Tax are not applicable to appeals arising from adjudicatory proceedings initiated before October 1, 2025.

The legal proceedings involved investigations into the alleged issuance of invoices without the actual supply of goods and the wrongful availment of Input Tax Credit. Petitioners challenged the evidentiary materials used, including electronic records and handwritten documents, while also contesting the multiplication of penalties and the procedures used for adjudication.

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Delhi High Court · Director General of Analytics and Risk Management · Shiv Overseas