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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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