A group of writ petitions was filed before the Gujarat High Court by companies (including Torrent Power Ltd) that had furnished corporate guarantees, challenging the constitutional validity of Rule 28(2) of the Central Goods and Service Tax Rules, 2017, Section 15(4) of the CGST Act, 2017, and CBIC Circulars dated 27.10.2023 and 11.07.2024. The petitioners argued that corporate guarantees furnished without any fee or commission do not constitute a 'supply' of goods or services under Section 7 of the CGST Act, and therefore cannot attract GST liability. They contended that the four essential conditions for a taxable supply — supply, services, related party, and course or furtherance of business — are not satisfied in the case of gratuitous corporate guarantees, and that a corporate guarantee is merely a contingent contract under Section 31 of the Indian Contract Act, 1872. The petitioners sought a declaration that Rule 28(2) of the CGST Rules and Section 15(4) of the CGST Act are ultra vires Articles 14, 19(1)(g), and 265 of the Constitution of India. The judgment text provided is a reserved judgment pronounced on 14 August 2026, but the final operative holding/order is not included in the extracted text.