Issues: Whether an adjudication order passed after the assessee filed a reply to the show-cause notice, without considering that reply or granting a hearing on it, could be sustained.

Analysis: The differing dates in the adjudication order and its annexure created a reasonable inference that the reply filed before the order was not considered. Since an adverse determination was contemplated after receipt of that reply, an opportunity of personal hearing was required under Section 75(4). The availability of a further appellate remedy did not preclude corrective writ relief where the adjudication suffered from denial of such opportunity.

Conclusion: The adjudication and appellate orders were unsustainable for breach of the requirement to consider the reply and afford a personal hearing, in favour of the assessee.

Issues: Whether a writ petition against a tax-determination order should be entertained despite a statutory appeal having been filed, where the order was passed without a hearing and without considering the assessee's reply.

Analysis: The availability of an appellate remedy does not require relegation to that remedy where the challenged order suffers from breach of the principles of natural justice. The order merely recorded the assessee's reply, stand and documents, without considering the contentions therein, and was made without affording an opportunity of hearing.

Conclusion: The determination order was vitiated by breach of the principles of natural justice; the statutory appeal did not bar writ relief. The issue was decided in favour of the assessee.

Issues: Whether blocking of input tax credit under Rule 86A could continue after expiry of one year from the date on which the restriction was imposed.

Analysis: Rule 86A(3) of the Tamil Nadu Goods and Services Tax Rules, 2017 provides that a restriction imposed under Rule 86A(1) ceases to have effect after one year. The restriction, imposed on 27.01.2023, had continued beyond that period. The statutory language requires the restriction to cease automatically; continued denial of debit from the credit ledger cannot be sustained indefinitely, particularly when it produces serious civil consequences. An internal departmental communication, without satisfaction of the requirements for invoking Rule 86A, cannot justify continued blocking. Recovery, where warranted after assessment, must proceed through the regular statutory mechanism.

Conclusion: The restriction on the petitioner's input tax credit ceased upon expiry of one year and the credit ledger must be unblocked. The conclusion is in favour of the assessee.

Issues: Whether the appellate order dismissing the appeal as time-barred could be set aside and the appeal restored for decision on merits where delay resulted from explained medical circumstances beyond the petitioner's control.

Analysis: Section 107 of the Rajasthan Goods and Services Tax Act, 2017 and the Central Goods and Services Tax Act, 2017 binds the Appellate Authority to the prescribed limitation. Extraordinary jurisdiction under Article 226 of the Constitution of India cannot ordinarily be used to circumvent that scheme, but may be exercised in exceptional circumstances. The medical reasons for the delayed appeal were beyond the petitioner's control, and refusal of adjudication on merits would cause grave prejudice.

Conclusion: The appellate order was set aside and the appeal was directed to be considered on merits, subject to payment of admissible late fees, penalty and statutory deposits.

Issues: Whether writ jurisdiction should be exercised to challenge the adjudication order despite an efficacious statutory appellate remedy where consideration of the taxpayers' replies and their alleged role requires factual examination.

Analysis: The challenge required examination of disputed factual matters, including whether the replies to the show-cause notice were considered and the precise role of each petitioner in the alleged transactions. Such matters were suitable for adjudication by the Appellate Authority. The reliance on principles requiring consideration of a taxpayer's response to a show-cause notice was distinguishable because the impugned adjudication was a consolidated order concerning numerous firms and individuals.

Conclusion: Writ jurisdiction ought not to be exercised to bypass the efficacious statutory appellate remedy where disputed factual issues require appellate examination.

Issues: Whether budgetary-support proceedings could be concluded by relying on an erroneous declaration despite a conflicting Chartered Accountant certificate, without affording the claimant an opportunity to explain the discrepancy.

Analysis: The Chartered Accountant certificate, furnished at the respondents' direction, disclosed an input-tax-credit figure different from that stated in the declaration. The discrepancy was apparent on the record and formed the basis for determining the claimed benefit. Fairness and the principles of natural justice required that the claimant be given a reasonable opportunity to explain and substantiate the asserted mistake before the proceedings were concluded. The matter concerned a defect in the decision-making process rather than post-completion rectification of an otherwise valid determination.

Conclusion: The claimant was entitled to an opportunity to explain the discrepancy and support the claim with documents; the challenged determination could not stand to that extent. The issue was decided in favour of the claimant.

Issues: Whether rejection of the rectification application without effective communication of the rejection order, coupled with an unexplained discrepancy in its date, was legally sustainable.

Analysis: The record showed that the rejection could not be generated through the GST portal because of technical glitches, while the order-sheet recorded a different date from the date handwritten on the purported rejection order. The undisputed absence of communication deprived the assessee of an effective opportunity to challenge or pursue the rectification request. The rectification application was also required to be considered with the supporting records and explanation in circumstances where adequate opportunity had not been afforded in the original proceedings.

Conclusion: The rejection of the rectification application was legally untenable and was set aside; the competent authority must reconsider the application after affording the assessee an opportunity of hearing and communicating a reasoned order.

Issues: Whether extraordinary writ jurisdiction may be exercised to condone delay beyond the statutory appellate limitation where the assessee could not file the appeal because of delayed communication by its Chartered Accountant.

Analysis: The statutory appellate authority remains bound by the limitation scheme under Section 107 of the GST enactments. Nevertheless, Article 226 jurisdiction is available in exceptional circumstances and cannot be invoked routinely to bypass statutory limitation. Delayed communication by the assessee's Chartered Accountant was found to be beyond the assessee's control, and refusal of merits adjudication would cause grave prejudice.

Conclusion: The circumstances justified exceptional writ relief; the delayed statutory appeal is required to be entertained and decided on merits in accordance with law.

Issues: Whether a single composite assessment order imposing penalty could cover multiple tax periods.

Analysis: The statutory scheme governing assessment under Sections 73 and 74 was applied to require assessment proceedings to be confined to the relevant tax period. A composite order spanning more than one financial year or tax period would impair the registered person's entitlement to statutory benefits and the effective exercise of the appellate remedy. The applicable rule is that separate notices and assessment orders are required for distinct tax periods.

Conclusion: A single composite assessment order for multiple tax periods is impermissible and cannot be sustained.

Issues: Whether rejection of the rectification application without considering the assessee's substantive contentions and without affording sufficient opportunity was legally sustainable.

Analysis: The rectification application contained several specific objections to the tax demand and supporting material. The rejection order summarily dismissed the application without addressing those objections. Such non-consideration, coupled with the absence of sufficient and reasonable opportunity, violated the principles of natural justice.

Conclusion: The rejection of the rectification application was unsustainable for failure to consider the assessee's contentions and for breach of principles of natural justice.

Issues: Whether the blocking of input tax credit in the Electronic Credit Ledger without compliance with Rule 86A of the Central Goods and Services Tax Rules, 2017 was valid, notwithstanding subsequent reactivation of the ledger.

Analysis: Rule 86A(1), including clause (d), permits restriction on use of credit only by the competent officer upon reasons to believe and reasons recorded in writing. The respondents acknowledged that no proper reasoned order was passed and that no opportunity of hearing was afforded before the credit was blocked. The Electronic Credit Ledger had, however, become operational upon expiry of the statutory period.

Conclusion: The mandatory requirements of Rule 86A of the Central Goods and Services Tax Rules, 2017 were not complied with in blocking the input tax credit. In the exceptional circumstances, no further substantive relief was granted; future non-compliant blocking was cautioned to entail appropriate compensation to the aggrieved party.

Issues: Whether the applicant should be granted regular bail in connection with allegations of fraudulent availment and passing of input tax credit.

Analysis: The complaint against the applicant had been filed, although further investigation into the larger conspiracy continued. The applicant had remained in custody since 29.04.2026, a co-accused had been granted bail, and the trial was likely to take considerable time to conclude.

Outcome: Regular bail granted on furnishing personal bond and surety.

Issues: Whether a tax demand can be confirmed by applying a valuation rule different from that invoked in the show cause notice, without affording the assessee an opportunity to respond.

Analysis: The show cause notice invoked Rule 28(1)(a) of the Central Goods and Services Tax Rules, 2017, for determining the value of excavated soil. The adjudicating authority acknowledged that the invoked rule was inapplicable, but confirmed the demand by applying Rule 27(c), which adopted a distinct valuation basis. The assessee had no notice of, or opportunity to address, the applicability or valuation under Rule 27(c). The substitution of the valuation basis at adjudication caused grave prejudice and was inconsistent with the requirements of a valid show cause notice and principles of natural justice.

Conclusion: A demand cannot be sustained on the basis of Rule 27(c) when the show cause notice invoked Rule 28(1)(a) and no opportunity was given to meet the changed basis of valuation; the issue is decided in favour of the assessee.

Issues: Whether cancellation of GST registration and rejection of its revocation application could be sustained solely because the registered person reported nil turnover in GSTR-3B returns and did not respond to the subsequent show-cause notice.

Analysis: Section 29 of the Central Goods and Services Tax Act, 2017 permits cancellation only upon circumstances specified therein. The proper officer must independently reach satisfaction, founded on cogent and tangible material, that the statutory conditions exist. Nil turnover declarations, without verification of the evidence demonstrating continuing business activity from the registered premises, do not establish discontinuance of business or otherwise fall within the prescribed grounds for cancellation.

Conclusion: The cancellation proceedings and rejection of revocation were invalid, as nil turnover alone could not justify cancellation of registration under Section 29. The issue was decided in favour of the assessee.

Issues: Whether the accused should be enlarged on bail pending investigation into alleged fraudulent input tax credit claims.

Analysis: The material investigation concerning the accused was substantially complete; the accused had remained in custody since 16.06.2026; and certain co-accused had already been granted bail. Balancing these circumstances against the nature and gravity of the allegations, further custodial detention was not considered necessary for the investigation.

Outcome: Bail granted on furnishing the prescribed bond and surety and complying with the monthly appearance requirement before the investigating officer until submission of the charge sheet.

Issues: Whether an ex parte assessment order confirming demand for input tax credit mismatch could stand without compliance with the verification procedure prescribed by Circular No. 183/15/2022-GST.

Analysis: The prescribed procedure requires the proper officer to obtain invoice-related details from the registered person and verify fulfilment of the conditions for input tax credit under Section 16 before confirming a demand based on mismatch between FORM GSTR-3B and FORM GSTR-2A. The materials indicated that this exercise had not been undertaken before the ex parte adjudication order was issued. The matter required fresh consideration after allowing the petitioner to submit supporting documents and receive a reasonable opportunity of hearing.

Conclusion: The ex parte adjudication order was quashed, and the demand is to be reconsidered afresh in accordance with the circular and law.

Issues: Whether the accused was entitled to anticipatory bail in a case involving alleged creation of fake GST registrations and fraudulent use of personal credentials.

Analysis: The material collected during the ongoing investigation included technical links between the mobile numbers and email accounts used for GST filings and the accused, as well as allegations of his role in creating fake GST entities and receiving client payments. The accused had not joined investigation, the alleged fraud required further technical investigation, and custodial interrogation was considered justified. The seriousness of fraud involving misuse of PAN cards and related credentials, its wider economic ramifications, and the accused's alleged involvement in other financial-fraud cases weighed against pre-arrest protection.

Conclusion: Anticipatory bail was refused.

Issues: Whether adjudicating and quasi-judicial authorities may rely on unverified artificial-intelligence-generated case law while issuing orders; (ii) whether the impugned show-cause notice, cancellation order, revocation-rejection order and appellate order should be quashed and reconsidered afresh.

Issue (i): Whether adjudicating and quasi-judicial authorities may rely on unverified artificial-intelligence-generated case law while issuing orders.

Analysis: The impugned order relied upon non-existent and irrelevant authorities generated through artificial intelligence. The departmental instructions required independent verification of AI-generated legal material through primary sources, accurate and relevant citation of judgments, consideration of taxpayer authorities, human oversight, and the officer's independent application of mind. The issuing authority remains responsible for the correctness and legal sustainability of the order.

Conclusion: Unverified AI-generated content cannot be relied upon for adjudicatory orders; the prescribed instructions must be scrupulously followed, and their breach would amount to contempt of court.

Issue (ii): Whether the impugned show-cause notice, cancellation order, revocation-rejection order and appellate order should be quashed and reconsidered afresh.

Analysis: The respondents accepted that the impugned orders required revision and agreed to issue a fresh notice. In view of the defective reliance on AI-generated authorities, fresh proceedings were required, with due consideration of the petitioner's reply and defence and a reasoned decision in accordance with law.

Conclusion: The impugned notice and orders are quashed; fresh notice and fresh adjudication shall follow, with all rights and contentions kept open.

Final Conclusion: The dispute is restored to the adjudicatory stage for a lawful, independently reasoned determination after fresh notice.

Ratio Decidendi: Adjudicatory authorities must independently verify legal material and apply their own mind; artificial intelligence may assist research but cannot substitute authentic legal verification or reasoned quasi-judicial decision-making.

Issues: (i) Whether refund of unutilised SGST input tax credit could be granted by treating transitional credit as credit available for the relevant refund period; (ii) Whether writ jurisdiction could be invoked after expiry of the statutory limitation for appeal against the assessment order.

Issue (i): Whether refund of unutilised SGST input tax credit could be granted by treating transitional credit as credit available for the relevant refund period.

Analysis: Section 140 and Rule 117 require transitional credit to be carried forward on filing the prescribed TRAN-1 declaration. The claimed amount could be considered for refund only upon satisfactory proof that it stood credited in the Electronic Credit Ledger as opening credit on 01.07.2017. The petitioner did not produce the TRAN-1 declaration or satisfactory material establishing such credit.

Conclusion: Refund of the disputed transitional SGST credit was not allowable. The issue was decided against the assessee.

Issue (ii): Whether writ jurisdiction could be invoked after expiry of the statutory limitation for appeal against the assessment order.

Analysis: Statutory appellate and revisional remedies were available under Sections 107 and 108. A party which allows the appellate limitation to expire cannot ordinarily invoke Article 226 to revive an unenforceable cause of action. The discretionary writ remedy cannot defeat the legislative scheme of limitation or disturb finality in litigation.

Conclusion: The belated writ petition was not maintainable for challenging the assessment order after the appellate limitation had expired. The issue was decided against the assessee.

Final Conclusion: The assessment order denying refund of the disputed transitional credit remains undisturbed, and the challenge was barred by the petitioner's failure to pursue the statutory remedy within time.

Ratio Decidendi: A writ court ordinarily cannot revive a time-barred statutory challenge where the assessee neither establishes entitlement to the claimed transitional credit nor pursues the prescribed appellate remedy within limitation.

Issues: Whether the passport renewal of an accused on bail in proceedings under the Central Goods and Services Tax Act, 2017 could be restricted to three years rather than the regular ten-year term.

Analysis: The continuing conditions requiring prior court permission for foreign travel, coupled with monitoring safeguards, applied irrespective of the passport's validity period. The petitioner's family, residence, business and immovable properties in India materially reduced the apprehension of absconding. No plausible reason, substantive harm or reasonable apprehension justified limiting renewal to three years.

Conclusion: The passport was directed to be renewed for the regular term of ten years, while all other conditions governing foreign travel and passport use remained binding.