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Author: Abhishek Jat, Advocate Introduction In a significant ruling dated April 22, 2025, the Delhi High Court quashed multiple service tax demands totaling several years’ worth of dues, issued through five Show Cause Notices (SCNs) spanning from 2007 to 2017. The Court held that the delay of six to eleven years in adjudicating these demands is constitutionally impermissible, reaffirming the principles of timely justice and natural justice in tax adjudication. This article analyzes the judgment in  Roots Education Pvt. Ltd. v. Commissioner of Central Tax GST Delhi East & Ors.  (W.P.(C) No. 4084/2025), highlighting the Court’s reasoning, statutory interpretation, and its reliance on precedent, including the pivotal  Vos Technologies India Pvt. Ltd. v. Director General  case. The judgment also critically examines the scope and limitations of Section 73(4B) of the Finance Act, 1994, which governs the timeline for service tax adjudication. Background and Fa...

  The Impermissibility of Supplementary Notices under Section 28(4) of the Customs Act By Abhishek Jat, Advocate The Delhi High Court recently delivered a significant judgment clarifying the legal boundaries surrounding the issuance of show cause notices (SCNs) under Section 28 of the Customs Act, 1962. The case,  Ismartu India Pvt. Ltd. v. Union of India , revolved around the contentious issue of whether a subsequent notice under Section 28(4) could supplement a prior notice issued under Section 28(1) of the Act. The Court’s ruling, delivered by a Division Bench comprising Justices Yashwant Varma and Harish Vaidyanathan Shankar, reaffirmed the distinct legal frameworks governing these provisions and emphasized the impermissibility of using one to supplement the other. Factual Background The petitioner, engaged in the import and sale of mobile phone components, was issued a show cause notice dated 25-07-2023 under Section 28(1) of the Customs Act. The notice alleged tha...