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) dated 28.06.2017, 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 exemption was confirmed by an advance ruling dated 12.02.2019 which was binding on the department. The petitioner contended that the impugned circular impermissibly drew a distinction between Heading 9967 (access to road on annuity, exempt) and Heading 9954 (construction of road, taxable), thereby seeking to override the statutory exemption and the binding advance ruling. The petitioner sought quashing of the recovery order and refund of amounts recovered. The judgment text as provided concludes mid-sentence before recording the court's final decision.