Introduction

This judgment deals with the scope of the High Court’s writ jurisdiction in matters involving search and seizure proceedings, validity of authorization issued under Section 67, summons under Section 70, and adjudication of stock discrepancies leading to penalty under Sections 122 and 130 of the GST Act.

The petitioner questioned both the legality of the search authorization and the methodology adopted by the department for determining stock discrepancies. The principal contention was that the search authorization was invalid because it did not bear a physical or digital signature and that the demand was based on an arbitrary estimation without conducting a proper physical inventory.