Goods and Service TaxArticle·6 January 2026
Limitation and not Sympathy defines GST Justice
By JustIDT
Executive Summary
J the App by JustIDT examines the adulthood of GST Jurisprudence
Courts are increasingly signalling that GST has entered its jurisprudential adulthood.
In a sharp reaffirmation of statutory discipline, the Gujarat High Court has drawn a clear line between equity and jurisdiction, holding that writ powers cannot be used to dilute legislatively fixed limitation periods.
The message is unambiguous, writ jurisdiction is not a parallel appellate forum for time-barred disputes, and fiscal statutes must operate as designed.
In doing so, the Court underscores a deeper principle for GST litigation, certainty and finality are not antithetical to justice, they are integral to it.
Harsh Deepak Shah v. Union of India & Ors; Special Civil Application No. 17382 of 2025 dated 24 December 2025before the High Court of Gujarat...
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