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 was binding on the department under Chapter XVII of the CGST/RGST Act. The respondents sought to distinguish between services under Heading 9967 (access to road on annuity, exempt) and services under Heading 9954 (construction of road, taxable), relying on the 2021 circular. The judgment text provided concludes before the court's final holding is recorded, so the ultimate decision is not fully captured in the excerpt.