Advance ruling and jurisdictional objections secured interim protection, with partial deposit required for the remaining disputed tax heads.

The advance-ruling-based component of the assessment raised a statutory question under Section 103 of the CGST/SGST Act, 2017, and interim protection was granted against coercive recovery for six weeks in respect of that demand. The jurisdictional objection was treated as a debatable issue requiring further examination and a counter-affidavit. For the remaining disputed tax heads, coercive steps were restrained only on condition of deposit of 25% of the disputed tax within three weeks, preserving recovery rights pending further consideration.

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Issues: (i) Whether the assessing authority could rely on an advance ruling in view of Section 103 of the CGST/SGST Act, 2017; (ii) Whether the assessing authority lacked jurisdiction; and (iii) whether coercive recovery should be restrained pending further consideration.

Analysis: The plea that the assessment was founded on an advance ruling raised a statutory issue under Section 103 and was taken as a basis for interim protection in respect of the tax demand relatable to supply of flats under the joint development agreement. The jurisdictional objection was treated as a debatable issue requiring further examination and counter-affidavit. For the remaining disputed tax heads, interim protection was made conditional upon partial deposit.

Outcome: Interim protection was granted against coercive steps for six weeks in respect of the amount relating to the advance-ruling-based demand, and for the other disputed tax heads coercive steps were restrained subject to deposit of 25% of the disputed tax within three weeks.

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