M/s Nagaur Mukundgarh Highways Pvt. Ltd. filed a batch of writ petitions before the Rajasthan High Court (Jodhpur) challenging CBIC Circular No. 150/6/2021 dated 17.06.2021, a show cause notice dated 09.12.2022, and a recovery order dated 07.07.2023. The petitioner argued that Entry 23A of Notification No. 12/2017-Central Tax (Rate), issued under Section 11 of the CGST Act, grants a nil-rate GST exemption for 'service by way of access to a road or a bridge on payment of annuity' (Heading 9967), and that this statutory exemption cannot be overridden by a departmental circular. The petitioner further contended that an advance ruling dated 12.02.2019 had specifically held Entry 23A to be exempt from tax, and that this ruling was binding on both the applicant and the concerned departmental authorities under Chapter XVII of the CGST/RGST Act. The impugned circular sought to distinguish between services under Heading 9967 (access to road/bridge on annuity, exempt) and services under Heading 9954 (construction of road, taxable), which the petitioner contested. The court heard all connected petitions together, with the judgment reserved on 06.08.2026 and pronounced on 17.08.2026; however, the full operative findings and final order are not reproduced in the provided text.