The High Court of Rajasthan dismissed multiple connected writ petitions challenging show-cause notices issued under AIFTA. Relying on a recent Supreme Court judgment, the Court held that no writ lies against the issuance of a show-cause notice and held all petitions to be non-maintainable.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
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HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR
D.B. Civil Writ Petition No. 12924/2025
M/s Krn Heat Exchangers And Refrigeration Limited, (Formerly Known As M/s Krn Heat Exchangers And Refrigeration Pvt Ltd)Through Authorised Person Mr. Kamal Singh S/o Mr. Bane Singh, Aged 37 Years, R/o. Teehli, Madha, Alwar, Rajasthan 301405.
----Petitioner
Versus
----Respondents
Connected With
D.B. Civil Writ Petition No. 12927/2025
M/s Vaishali Metals Private Limited, Usha Papriwal Authorized Officer G-485, Road No. 9A, V.k.i. Area, Jaipur, Rajasthan 302013.
----Petitioner
Versus
(2 of 6)
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[CW-12924/2025]
New Delhi 110001.
----Respondents
D.B. Civil Writ Petition No. 12930/2025
M/s Kwality Tubes And Capillaries, Mr. Sandeep Papriwal Authorized Officer G-478, Road No. 9A, V.k.i. Area, Jaipur, Rajasthan 302013.
----Petitioner
Versus
D.B. Civil Writ Petition No. 14936/2025
M/s. Daikin Air Conditioning India Private Limited, Having Its Registered Office At Sp2-12 To Sp2-15, Sp2-24 To Sp, New Indl Complex (Majrakath), Neemrana, Kotputli-Behror, Rajasthan - 301 705 Through Its Authorized Signatory Mr. Anurag Misra S/o Late Shri. R.n. Misra, Aged 50 Years, R/o Tower B-1, Flat No. 1204, Palm Grove Heights, Ardee City, Sector-52, Gurgaon, Haryana - 1220111, Working As Avp-Legal And Compliance
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[CW-12924/2025]
(3 of 6)
----Petitioner
Versus
----Respondents
D.B. Civil Writ Petition No. 16495/2025
M/s. Carrier Midea India Private Limited, Having Its Registered Office At First Floor, Pearl Tower, Plot No. - 51, Sector-32, Gurugram, Haryana- 122001 Through Its Authorized Signatory Mr. Sumit Prashant S/o Shri S.k. Paswan, Aged 39 Years, R/o 169, Secor A, Pocket B And C, Vasant Kunj, New Delhi- 110070, Working As The Senior Manager- Legal.
----Petitioner
Versus
----Respondents
| For Petitioner(s) | : Mr. Pradeep Rajpurohit on behalf of Mr. Chirag Shetty, through V.C. Ms. Ayushi Agrawal,through V.C. |
|---|---|
| For Respondent(s) | : Mr. Bharat Vyas, (Sr. Adv.) ASG assisted by Ms. Anushka Khandelwal |
| & Ms. Anima Chaturvedi | |
| Mr. Bhuwnesh Sharma,AAG with |
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Mr. Sunita Meena Mr. Vishnu Dutt Ms. Epsa Nangalia Mr. Ram Singh Bhati Mr. Kinshuk Jain, Sr. Standing Counsel assisted by Mr. Sourabh Jain Mr. Parth Khandal Ms. Mahi Yadav, AAG with Mr. Kuldeep Singh Rathore, AAAG Mr. Ayush Jain
HON'BLE MR. JUSTICE INDERJEET SINGH HON'BLE MR. JUSTICE ASHOK KUMAR JAIN Order
10/04/2026
Since, the controversy involved in these writ petitions is similar in nature and the same are being decided by this common order. The facts of the case are taken from D.B. Civil Writ Petition No. 12924/2025, wherein the following prayer has been made as under:-:-
“It is, therefore, most respectfully prayed that this Hon'ble Court may - graciously be pleased to ‘issue an appropriate writ of Mandamus or Certiorari or any other appropriate writ/ order/ direction:
a. That this Hon’ble Court be pleased to issue a writ of mandamus, or any other appropriate writ, order, or direction restraining the Respondents to take any action contrary to the AIFTA against the Petitioner. b. That this Hon'ble Court be pleased to issue a writ of prohibition restraining the Respondent No. 5 from proceeding with the Impugned SCN No. GEN/ADT/PCA/332/2022/1449 dated 21.02.2025 (Annexure - P8).
c. That this Hon'ble Court be pleased to issue a writ of certiorari or order or directions in the nature of certiorari or any other writ, order or direction of like nature, to quash and set aside the Impugned SCN No. GEN/ADT/PCA/332/2022/1449 dated 21.02.2025 issued by the Respondent No. 5 (Annexure — P8).
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d. That this Hon'ble Court be pleased to issue a writ of mandamus or 2 writ in the nature of mandamus or any other appropriate writ order or direction ordering and directing the Respondent No. 5 to withdraw the SCN No. GEN/ADT/PCA/332/2022/1449 dated 21.02.2025 (Annexure — P8).
e. That this Hon’ble Court be pleased to issue a writ of certiorari or in the nature of certiorari or any other appropriate writ, order or direction to set aside the Letter dated 05.07.2623 issued by Respondent no. 6 (Annexure — P/7)
f. That this Hon'ble Court be pleased, to issue a. writ of mandamus or a writ in the nature of mandamus or any other appropriate writ: order or direction ordering and directing the Respondent N 9.7 to release the future consignments of Petitioner without furnishing the bank guarantee and bond and by allowing the benefit of notification no. 46 of 2011 réad with notification no. 189 of 2009.
g. That this Hon'ble Court be pleased to issue a writ of mandamus or a writ -in the nature of mandamus or any other appropriate writ order or direction ordering and directing the Respondent No.7 to cancel the bank - guarantee already given by the Petitioner and finalise the Bills of entry. after allowing the benefit of notification no. 46 of 2011 read with notification no. 189 of 2009.
h. That this Hon’ble court during the pendency of this petition direct the Respondent no. 7 to release the impugned goods without furnishing of bank guarantee and bond.
i. For any ad-interim relief.
j. For costs of the Petition and orders thereon; and
k. To provide any other:‘relief as this Hon’ble Court may deem -fit and proper. in facts, circumstances. and legal position of the case and in law to the Petitioner.”
Learned Additional Solicitor General appearing on behalf of
the respondents submits that these writ petitions filed against the show-cause-notices are not maintainable. He further relied upon the judgment passed by the Hon’ble Supreme Court in the matter
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of M/s Trillion Lead Factory Private Ltd. Vs. Superintendent of Central Tax (Special Leave to Appeal (C) No(s).7101/2026) decided on 27.02.2026 , wherein, para No.4, it was held as under:-
Having perused the record, it is an admitted position that the present writ petitions have been filed challenging the show-cause notices. Accordingly, in view of the judgment rendered by the Hon’ble Supreme Court in the matter of M/s Trillion Lead Factory Private Ltd. (supra) , the writ petitions stand dismissed.
The petitioners are at liberty to raise all the legal issues before the concerned Authority.
(ASHOK KUMAR JAIN),J
(INDERJEET SINGH),J
Upendra Pratap/37-41
2 issues framed by the court
Whether writ petitions challenging show-cause notices are maintainable in view of Supreme Court precedent holding no writ lies against issuance of such notices
Whether the writ petitions seeking quashing, withdrawal, and release of goods based on AIFTA provisions are sustainable
Colour shows how this judgement treated each authority
M/s Trillion Lead Factory Private Ltd. Vs. Superintendent of Central TaxRelied on¶88
M/s Trillion Lead Factory Private Ltd. Vs. Superintendent of Central Tax (Special Leave to Appeal (C) No(s).7101/2026)
Secretary, Ministry of Defence and Others V. Prabhash Chandra MirdhaRelied on¶92
Secretary, Ministry of Defence and Others V. Prabhash Chandra Mirdha, (2012) 11 SCC 565 · Who else cites this
Commr. Of Central Excise Commissionerate Vs. M/s. Krishna Wax (P) LtdRelied on¶92
Commr. Of Central Excise Commissionerate Vs. M/s. Krishna Wax (P) Ltd, Civil Appeal No.8609/2019
1 provisions across 1 enactments
M/s Krn Heat Exchangers And Refrigeration Limited
M/s Vaishali Metals Private Limited
M/s Kwality Tubes And Capillaries
M/s. Daikin Air Conditioning India Private Limited
M/s. Carrier Midea India Private Limited
Union Of India
Inderjeet Singh
Ashok Kumar Jain
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
