This compilation indexes twelve High Court writ petitions decided between December 2025 and August 2026 in which Section 16(2)(c) of the Central Goods and Services Tax Act, 2017 (and its State GST equivalents) was a central provision engaged. The cases span the Rajasthan, Telangana, Himachal Pradesh, Madhya Pradesh, Punjab-Haryana, Bombay, Tripura, and Karnataka High Courts, and cover a range of disputes: constitutional challenges to the validity of the provision, demands raised on account of alleged non-payment of tax by suppliers, registration cancellation matters, and interest-on-refund proceedings. The compilation is intended for in-house GST teams, Big-4 indirect-tax associates, and law-firm researchers who need a structured, court-by-court research index.

Research index only. This page is a structured case-law reference compiled for research and database purposes. Nothing on this page constitutes legal advice, tax advice, or any form of professional opinion. Readers must verify every ruling against the full judgment text and check for any subsequent stays, appeals, or reversals before relying on the information.

The statutory framework in one paragraph

Section 16(2)(c) of the Central Goods and Services Tax Act, 2017 prescribes one of the conditions that a registered person must satisfy in order to be eligible to avail input tax credit (ITC) in respect of a supply of goods or services: the tax charged in respect of such supply has actually been paid to the Government, either in cash or through utilisation of ITC admissible in respect of that supply. Read alongside the other conditions in Section 16(2) — receipt of goods or services, possession of a tax invoice or prescribed document, and filing of the return — this condition links a recipient's ITC entitlement to the upstream tax-payment compliance of its supplier. A separate time-limit condition for availing ITC is prescribed under Section 16(4) of the same Act.

The 12 rulings

1. M/S Nalwaya Construction vs Union Of India

Bench: Rajasthan High Court - Jodhpur
Date: 20 August 2026
Sections engaged: 16(2)(c), 16(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (D.B. Civil Writ Petition No. 6218/2026) was filed by the petitioner, a construction firm based in Udaipur, Rajasthan, before the Rajasthan High Court at Jodhpur. Per the source preview, the petitioner's counsel submitted that the matter was governed by a subsequent judgment of the Supreme Court in Bhandari Scrap Traders v. Union of India & Ors. (SLP(C) Nos. 23931/2026 etc., decided on 24.07.2026), wherein the challenge to the relevant provision was addressed; the full disposal terms are not captured in the available source preview.

2. M/S Shree Karni Electrovision vs Union Of India

Bench: Rajasthan High Court - Jodhpur
Date: 17 August 2026
Sections engaged: 155, 16(1), 16(2), 16(2)(c), 41(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (D.B. Civil Writ Petition No. 4266/2023) was filed by M/s Shree Karni Electrovision, a firm based in Bikaner, Rajasthan, against the Union of India and other respondents including a private supplier entity (Techno Kart India Limited). The source preview discloses the case number, bench composition, and appearance of counsel for multiple parties; the substantive grounds and disposal are not detailed in the available source preview.

3. M/S Synchrony International Services vs Assistant Commissioner (St)

Bench: Telangana High Court
Date: 30 July 2026
Sections engaged: 16(2)(c), 42(2), 56
Outcome: Outcome not specified in source
Procedural / substantive ground: The batch of writ petitions (W.P. Nos. 12047, 12052, 12127, 12128, 12130, 12132, 12133 and 12134 of 2026) related to the same petitioners and covered the period July 2018 to March 2021, concerning claims for interest over amounts already refunded to the petitioner company. Per the source preview, refunds were made partly by the Refund Sanctioning Authority and partly after orders of the appellate authority; since the refunds were delayed, the petitioner claimed interest, and such claims had been pending before the Proper Officer since 03.06.2025. The petitioner was compelled to approach the High Court upon the issuance of a third Deficiency Memo.

4. M/S Timco Steel Company vs Union Of India & Ors

Bench: Himachal Pradesh High Court
Date: 7 July 2026
Sections engaged: 16(2)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (CWP No. 9485 of 2024) was filed by M/s Timco Steel Company before the Himachal Pradesh High Court assailing notices dated 09.07.2024, 24.07.2024, and 01.08.2024. Per the source preview, the petitioner's counsel stated that replies to those notices had been submitted, though no such averment had been made in the writ petition itself nor had copies of the alleged replies been placed on record; the petitioner also stated it was not pressing certain reliefs at that stage, reserving the right to agitate them in an appropriate petition.

5. M/S. Nahar Traders Through Its vs State Of M.P

Bench: Madhya Pradesh High Court
Date: 22 April 2026
Sections engaged: 2(91), 16(2)(c), 67(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two writ petitions (W.P. Nos. 2510/2026 and 2532/2026) involving similar controversies were heard analogously and disposed of by a common order of the Madhya Pradesh High Court at Indore. Per the source preview, the petitioner in W.P. No. 2510/2026 prayed for quashment of an order dated 30.12.2025 passed by respondent No. 4, whereby a total liability of Rs. 7,01,61,092/- was imposed on the petitioner; counsel for the petitioner contended that the said order had been passed on certain grounds that are not fully detailed in the available source preview.

6. Neelkanth Enterprises vs Union Of India And Another

Bench: Punjab-Haryana High Court
Date: 22 April 2026
Sections engaged: 29(2), 16(2)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (CWP-12072-2026) challenged an order dated 03.03.2026 by which the petitioner's GST registration was cancelled, following a show cause notice dated 03.02.2026. Per the source preview, the petitioner had filed a detailed written response to the show cause notice along with supporting documents, but the adjudication order rejected that response by merely stating that the petitioner's reply had been "examined," without providing substantive reasoning; the State counsel defended the order on the basis that the reply was duly considered by the Proper Officer.

7. Karan Agencies Through Partner Karan vs The State Of Maharashtra And Anr

Bench: Bombay High Court
Date: 2 April 2026
Sections engaged: 16(2)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter was heard as a batch of writ petitions filed before the Bombay High Court, involving multiple petitioners including Karan Agencies, Nevitad Distillers Pvt. Ltd., Karan Bottling Company Pvt. Ltd., Brihan Karan Sugar Syndicate Pvt. Ltd., and Dalmiya Bharat Sugar And Industries Ltd., all challenging matters connected to Section 16(2)(c) against the State of Maharashtra and others. The source preview discloses the case numbers and parties across the batch (including W.P. Nos. 7404 of 2021, 1502 of 2022, 34 of 2023, 7099 of 2021, 7102 of 2021, ST No. 93763 of 2020, and ST No. 94011 of 2020); the substantive grounds and disposal are not detailed in the available source preview.

8. Abnco Vie Win Ent Private Limited vs Union Of India

Bench: Bombay High Court
Date: 2 April 2026
Sections engaged: 16(2)(c), 16(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P. No. 4204 of 2024) was filed under Article 226 of the Constitution of India before the Bombay High Court praying, among other reliefs, for a declaration that Section 16(2)(c) of the CGST Act and the MGST Act is null, void, arbitrary, and violative of Article 14 of the Constitution of India, and further that it is null, void, and contrary to the provisions of Section 16(1) of the CGST and MGST Act. The petition thus raised a direct constitutional challenge to the validity of the provision.

9. M/S. Rythu Seva Kendram Bairanpally vs The Superintendent Of Central Tax

Bench: Telangana High Court
Date: 30 March 2026
Sections engaged: 107(8), 16(2)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P. No. 4967 of 2026) was preferred before the Telangana High Court seeking, inter alia, to set aside a demand confirmation order and Form DRC-07 issued on 20.02.2025, which confirmed demand under the CGST/TGST Act, 2017 on the ground of alleged violation of Section 16(2)(c); the petitioner also prayed for a declaration that the provisions of Section 16(2)(c) of the CGST Act, 2017 are unconstitutional, alleging violation of principles of natural justice and Articles 14, 19(1)(g), and 265 of the Constitution of India.

10. M/S Malaya Rub-Tech Industries vs The Union Of India Represented By Its

Bench: Tripura High Court
Date: 10 February 2026
Sections engaged: 73(1), 16(2)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP(C) No. 849 of 2022) was filed before the Tripura High Court at Agartala by a partnership firm registered under the Partnership Act, 1932, with its registered office in Kerala and a local office at Bodhjungnagar Industrial Estate, West Tripura. The petition was filed against, among others, the Union of India (through the Secretary, Department of Finance) and the State of Tripura (through the Commissioner & Secretary, Revenue Department); the substantive grounds and disposal are not detailed in the available source preview beyond the parties' identities and the sections cited.

11. Green Finch Team Management Private vs Bundl Technologies Private Limited

Bench: Karnataka High Court
Date: 10 February 2026
Sections engaged: 11, 16(2)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (COMAP No. 274 of 2025 c/w COMAP No. 326 of 2025) was filed before the Karnataka High Court at Bengaluru as a commercial appeal. Per the source preview, the matter involved monetary claims between Green Finch Team Management Private Limited (appellant, registered in Noida, Uttar Pradesh) and Bundl Technologies Private Limited (respondent, registered in Bengaluru), with claim amounts stated in the source preview relating to payments towards Temp DE charges, service charges, and related interest for periods up to and including 30.04.20 (year end not fully captured in preview); the substantive basis of the appeal under the sections engaged is not further detailed in the available source preview.

12. Rajlaxmi Marketing vs The Assistant Commissioner

Bench: Karnataka High Court
Date: 10 December 2025
Sections engaged: 16(2)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 103035 of 2025) was filed before the Karnataka High Court at Dharwad under Articles 226 and 227 of the Constitution of India by Rajlaxmi Marketing, a sole proprietorship represented by its proprietor, with GSTIN 29ALOPJ8979L1ZU, against the Assistant Commissioner of Commercial Taxes (LGSTO-500), Hospet, and other respondents. Per the source preview, the writ petition specifically prayed to declare and strike down Section 16(2)(c) of the CGST Act, making this a direct constitutional challenge to the validity of the provision.

Patterns across these 12 rulings

Constitutional validity as a live issue across multiple courts. Cases 8 (Abnco Vie Win Ent, Bombay HC), 9 (Rythu Seva Kendram, Telangana HC), and 12 (Rajlaxmi Marketing, Karnataka HC) each contain explicit prayers to declare Section 16(2)(c) unconstitutional, void, arbitrary, or violative of Articles 14, 19(1)(g), and/or 265 of the Constitution. This demonstrates that the provision's constitutional validity was actively contested before at least three High Courts within a roughly five-month window (December 2025 – April 2026).
Supreme Court precedent cited as a pivot point. In Case 1 (Nalwaya Construction, Rajasthan HC – August 2026), petitioner's counsel expressly invoked a subsequent Supreme Court judgment (Bhandari Scrap Traders v. Union of India & Ors., decided 24.07.2026) as a basis for the relief claimed. This suggests that by mid-2026, a Supreme Court ruling had become a key reference point for Section 16(2)(c) litigation, with High Courts likely being asked to apply or distinguish it.
Batch/multi-petition consolidation is a recurrent procedural feature. Cases 3 (Synchrony International Services, 8 writ petitions), 5 (Nahar Traders, 2 writ petitions heard by common order), and 7 (Karan Agencies batch, 7 writ petitions across different petitioners) were all heard as consolidated batches. This pattern indicates that Section 16(2)(c) disputes often arise for multiple tax periods or related entities simultaneously, prompting courts to consolidate for efficiency.
Natural justice and adequacy of adjudication order reasoning as a recurring procedural grievance. Case 6 (Neelkanth Enterprises, Punjab-Haryana HC) explicitly raised the ground that the adjudication order failed to provide reasons for rejecting the petitioner's detailed reply. Case 9 (Rythu Seva Kendram, Telangana HC) similarly alleged violation of principles of natural justice. This signals that the manner of adjudication — not merely the substantive section — is frequently challenged alongside the Section 16(2)(c) demand.
Geographic spread reflects nationwide litigation. The twelve cases span eight different High Courts: Rajasthan (Jodhpur), Telangana, Himachal Pradesh, Madhya Pradesh, Punjab-Haryana, Bombay, Tripura, and Karnataka. This geographic breadth indicates that Section 16(2)(c) litigation is not concentrated in a single jurisdiction and that divergent approaches across High Courts are a genuine research risk that practitioners must track.

How to use this compilation

This index is a starting point for identifying relevant Section 16(2)(c) case law at the High Court level for the period December 2025 to August 2026. For each case listed, researchers should retrieve the full judgment text from indiankanoon.org, the official High Court website, or a licensed legal database before drawing any conclusions about holdings, ratio, or precedential value. The source previews reproduced here are excerpts only and do not capture the full reasoning, final operative order, or any directions issued by the court.

Before relying on any case in this compilation for a specific matter, practitioners should verify: (a) whether the case was stayed, reversed, or further appealed after the date shown; (b) whether a Supreme Court ruling (including Bhandari Scrap Traders v. Union of India & Ors., referenced in Case 1's source preview) has since settled or altered the legal position; and (c) whether any CBIC circular, notification, or Board instruction has been issued that addresses the point of law in question, since circulars and notifications can affect the live enforceability of a High Court view.

Researchers should also note that several cases in this compilation disclose "Outcome not specified in source" — meaning the final operative order is not captured in the available preview. These cases should be treated as procedurally noted rather than substantively decided for research purposes, and the full judgment must be retrieved to determine the actual relief granted or refused.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 16(2)(c) CGST: 12 High Court Writ Rulings (2025–2026)