M/s Nagaur Mukundgarh Highways Pvt. Ltd. filed a batch of writ petitions before the Rajasthan High Court (Jodhpur) challenging: (1) CBIC Circular No. 150/6/2021 dated 17.06.2021, which drew a distinction between services of 'access to a road on payment of annuity' (Heading 9967, exempt under Entry 23A of Notification No. 12/2017-Central Tax (Rate)) and 'construction of roads' (Heading 9954, taxable), thereby seeking to levy GST on annuity payments received by the petitioner; (2) a show cause notice dated 09.12.2022; and (3) a recovery order dated 07.07.2023. The petitioner contended that the circular could not override the statutory exemption under Section 11 of the CGST Act and that an advance ruling dated 12.02.2019 had specifically held Entry 23A to be applicable and binding on both the applicant and departmental authorities under Chapter XVII of the CGST/RGST Act. The court heard all connected petitions together, treating D.B. Civil Writ Petition No. 10055/2024 as the lead matter, and reserved judgment on 06.08.2026 before pronouncing it on 17.08.2026; however, the full operative outcome is not captured in the provided text excerpt.