Zoomcar INDIA Private Limited vs. Union Of INDIA

Held

The High Court disposed of the writ petitions by holding that the directions issued by the Supreme Court in SLP No.4240/2025, which is examining the challenge to the same circular notifications, shall govern the case of the petitioner. The Court acknowledged that the Supreme Court is already seized of the matter concerning the circular notifications dated 31.03.2023, 28.12.2023, 01.04.2023, and 01.01.2024. Therefore, instead of independently adjudicating the petitions, the High Court deferred to the ongoing Supreme Court proceedings. The ratio decidendi is that where a higher court is already examining an identical issue, a subordinate court should await the decision of the higher court to ensure consistency and avoid conflicting judgments. No specific issue was left undecided; rather, the entire matter was directed to be governed by the Supreme Court's decision.

Facts

The petitioner, Zoomcar India Private Limited, has filed writ petitions challenging certain circular notifications issued by the respondents. The specific circular notifications are dated 31.03.2023, 28.12.2023, 01.04.2023, and 01.01.2024. The respondents include the Union of India, the Goods and Services Tax Council, the State of Rajasthan, and various Deputy Commissioners of the State Goods and Services Tax Department. The petitions are connected and were heard together. The High Court noted that the Supreme Court is already examining the challenge to these circular notifications in a separate proceeding (SLP No.4240/2025).

Key Issues

1. Whether the circular notifications dated 31.03.2023, 28.12.2023, 01.04.2023, and 01.01.2024 are valid and binding on the petitioner, and if they are subject to judicial review by this Court, turning on the interpretation and application of relevant GST provisions and principles of administrative law. Petitioner's arguments: The petitioner is challenging the validity and applicability of the aforementioned circular notifications. While the specific grounds of challenge are not detailed in the provided excerpt, it is implied that the petitioner contends these notifications are detrimental to their business operations or are otherwise legally flawed. Respondents' arguments: The respondents, through their counsel, would likely defend the validity of the circular notifications and argue that they are issued in accordance with the powers vested in the GST authorities. They would also point to the ongoing proceedings before the Supreme Court concerning the same issue.