The Allahabad High Court stayed the operation of a GST demand order issued against Dell International Services India Private Limited, observing that the company had raised serious concerns regarding jurisdictional error and violation of principles of natural justice.

Taking note of the submission that “against proposed demand Rs. 9 crores the demand of tax Rs. 13 crores has been confirmed,” the Division Bench comprising Justice Saumitra Dayal Singh and Justice Indrajeet Shukla granted four weeks’ time to the State authorities to file a counter affidavit, with two weeks thereafter for the petitioner to file a rejoinder.

Dell International Services India Pvt. Ltd., the Indian services arm of US technology giant Dell, challenged the adjudication order on the ground that the final demand substantially exceeded the amount proposed in the original show cause notice (SCN).

According to the petition, the SCN had proposed a tax demand of ₹9,49,18,645, along with interest of ₹7,26,12,746 and penalty of ₹9,49,18,645. However, the impugned order dated January 19, 2026, confirmed a significantly higher liability — tax of ₹13,18,30,760, interest of ₹12,58,64,064 and penalty of ₹1,31,83,076 — taking the cumulative demand to ₹27,08,77,899.69.

Counsel appearing for the company argued that while the proposed tax demand was approximately ₹9 crore, the final order confirmed tax exceeding ₹13 crore without putting the petitioner on notice regarding the enhanced liability. It was contended that the adjudicating authority had travelled beyond the scope of the show cause notice, rendering the order legally unsustainable.

The petitioner further submitted that the proceedings suffered from a violation of natural justice and that a jurisdictional error had crept into the adjudication process.

Pending further hearing, the Court directed that the operation and effect of the impugned order dated January 19, 2026, passed by the concerned authority shall remain stayed until the next date of listing.

The matter will now be taken up after completion of pleadings.

Case Details

Case Title: M/S Dell International Services India Private Limited Versus State of U.P. and Another

Case No.: WRIT TAX No. – 801 of 2026

Date: 02/02/2026

Counsel For  Petitioner: Nishant Mishra, Vedika Nath

Counsel For Respondent: C.S.C.

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