Issues: (i) Whether late fee for non-filing of the ST-3 return for the first half of the financial year was payable when the assessee was within the threshold exemption limit; (ii) Whether the penalty under Section 78 and the remaining late fee were liable to be interfered with.

Issue (i): Whether late fee for non-filing of the ST-3 return for the first half of the financial year was payable when the assessee was within the threshold exemption limit.

Analysis: The return under Section 70 of the Finance Act, 1994 read with Rule 7C of the Service Tax Rules, 1994 is required only from a person liable to pay service tax. Where the impugned order itself recognises entitlement to threshold exemption, and the receipts for the relevant first half-year remained below the exemption limit, the assessee was not required to file the ST-3 return for that period. In such circumstances, levy of late fee for that return could not be sustained.

Conclusion: The late fee for non-filing of the ST-3 return for the period 1 April 2016 to 30 September 2016 was set aside.

Issue (ii): Whether the penalty under Section 78 and the remaining late fee were liable to be interfered with.

Analysis: Penalty under Section 78 of the Finance Act, 1994 was treated as mandatory once the demand was confirmed by invoking the extended period of limitation. The remaining late fee relating to the later ST-3 return was also upheld, since the assessee remained registered and the return for that period was still required. The penalty under Section 77(1)(c) had already been set aside in the impugned order and was not revived.

Conclusion: The penalty under Section 78 and the remaining late fee were upheld.

Final Conclusion: The appeal succeeded only to the extent of relief against the late fee for the first return period, while the penalty under Section 78 and the balance late fee were sustained, resulting in a partial modification of the impugned order.

Issues: Whether painting and related end-to-end execution services were classifiable under Works Contract Service or under Management, Maintenance or Repair Service.

Analysis: The activity involved painting work for residential and commercial premises, along with material and manpower, and fell within the statutory description of completion and finishing services. The definition of commercial or industrial construction service and construction of complex service expressly included painting and similar finishing activities. On that basis, the services could not be treated as management, maintenance or repair of immovable property. The demand confirmed under the latter category was therefore unsustainable.

Conclusion: The classification adopted by the Revenue was rejected and the services were held to be correctly classifiable under Works Contract Service, in favour of the assessee.

Ratio Decidendi: Painting and similar completion and finishing services for buildings and complexes are not taxable as management, maintenance or repair merely because they relate to immovable property; they are to be classified under the specific construction-related service entry where the statute so provides.

Issues: Whether the adjudication order passed under Section 73(9) of the Karnataka Goods and Services Tax Act, 2017 deserved to be set aside and the matter remitted for fresh adjudication in view of the petitioner's explanation and the factual clarification required.

Analysis: The adjudication was based on the petitioner's communication regarding revised turnover, but the petitioner asserted that the communication required further explanation and that other material existed to show that it would not materially affect the case. The order of adjudication was found to rest on a factual matrix requiring clarification from the petitioner's side. In those circumstances, the matter warranted reconsideration rather than final determination on the existing record.

Conclusion: The adjudication order was set aside and the matter was remitted to the stage of reply to the show-cause notice for fresh adjudication.

Ratio Decidendi: Where an adjudication order rests on factual material requiring explanation from the noticee and the existing record does not permit a fair final determination, the proper course is to set aside the order and remit the matter for fresh consideration.

Issues: Whether the writ petition should be entertained in a matter alleging overlapping GST proceedings and whether the petitioner should be relegated to the statutory remedy of rectification and appeal.

Analysis: The petitioner did not participate in the second proceedings to bring the alleged overlap to the notice of the proper officer. The overlap principle was considered in the context of Section 6(2)(b) of the Central Goods and Services Tax Act, 2017, but the second requirement of identical demand or relief was not clearly shown on the facts. The Court also noted that Section 161 of the Central Goods and Services Tax Act, 2017 provides a statutory mechanism for rectification of an order or error apparent on the face of the record, and that the period for invoking that remedy had not expired. The Court therefore found it appropriate to leave the merits open and permit the petitioner to pursue rectification and the appellate remedy available in law.

Conclusion: The writ petition was not entertained on merits and the petitioner was left to pursue the available statutory remedies, including rectification and appeal.

Issues: (i) Whether the property sold by the assessee was a short-term capital asset or a long-term capital asset for capital gains purposes. (ii) Whether the registration charges of Rs. 20,68,000 formed part of the cost of acquisition and were eligible for indexation.

Issue (i): Whether the property sold by the assessee was a short-term capital asset or a long-term capital asset for capital gains purposes.

Analysis: The decisive facts were that the assessee had entered into an agreement to sell, paid the full agreed consideration during FY 2013-14, and obtained possession in that year. On those facts, the transfer was treated as complete in substance in FY 2013-14 for capital gains purposes, even though formal conveyance was registered later. The Tribunal accepted the finding that the assessee became entitled to enjoy the property as owner from the date of full payment and possession, making the holding period exceed 36 months.

Conclusion: The property was a long-term capital asset and the Revenue's challenge to deletion of the short-term capital gain addition failed.

Issue (ii): Whether the registration charges of Rs. 20,68,000 formed part of the cost of acquisition and were eligible for indexation.

Analysis: The assessee supported the claim with the demand draft, receipt, and related contemporaneous documents showing that the amount had been paid in FY 2013-14 in connection with acquisition of the property. The Tribunal found no contrary material from the Revenue to dislodge the factual finding that the payment was part of acquisition cost. On that basis, the amount was held to be includible in the cost of acquisition and eligible for indexation from the relevant year of payment.

Conclusion: The registration charges rightly formed part of the indexed cost of acquisition and the Revenue's objection was rejected.

Final Conclusion: The Revenue failed to dislodge the appellate findings on both the nature of the asset and the acquisition cost, so the assessee's capital gains treatment as sustained by the first appellate authority remained undisturbed.

Ratio Decidendi: For capital gains purposes, an agreement to sell coupled with full payment and delivery of possession can fix the effective transfer/acquisition date, and contemporaneously evidenced acquisition-related payments form part of the cost of acquisition for indexation.

Issues: Whether a consolidated satisfaction note recorded for multiple assessment years under section 153C of the Income-tax Act, 1961 validly sustained the assumption of jurisdiction and the consequential assessments.

Analysis: The satisfaction note was common for all the assessment years and did not separately identify year-wise material or bifurcate the amounts relatable to each assessment year. The decision turned on the requirement that the jurisdictional satisfaction under section 153C must be founded on material having a bearing on the determination of total income for the relevant year or years. The view taken was that where the material and reasons are not year-specific and the note is recorded in a consolidated manner without linking the seized material to individual assessment years, the statutory condition for invoking section 153C is not met.

Conclusion: The consolidated satisfaction note was held invalid, the jurisdiction assumed under section 153C was unsustainable, and the assessments were quashed in favour of the assessee.

Ratio Decidendi: For invoking section 153C, the Assessing Officer must record satisfaction linking the seized material to the relevant assessment year or years so that the material is shown to have a bearing on total income for those years; a consolidated note unsupported by year-wise linkage cannot validly confer jurisdiction.

Issues: Whether the penalty order passed under the Customs Act, 1962 could be set aside and the matter remitted for fresh consideration on the ground that the petitioner did not receive the show cause notice or the opportunity of personal hearing.

Analysis: The petitioner was a co-noticee against whom only penalty proceedings were pending. The order recorded that no reply had been filed to the show cause notice. In those circumstances, and in view of the grievance regarding non-service of notice and non-communication of the hearing opportunity, the appropriate course was to reopen the proceedings from the stage of reply to the show cause notice. The Court also noted that sustaining the penalty order without affording such opportunity would cause financial prejudice.

Conclusion: The penalty order was set aside insofar as the petitioner was concerned, and the matter was remitted for fresh consideration from the stage of reply to the show cause notice.

Ratio Decidendi: Where a penalty order is passed without a proper opportunity to respond to the show cause notice and to be heard, the order may be set aside and the proceedings remitted for fresh adjudication from the appropriate stage.

Issues: Whether the revenue could adjust income tax refunds against pre-CIRP tax demands after approval of the resolution plan extinguishing the corporate debtor's tax liabilities.

Analysis: On approval of a resolution plan under the Insolvency and Bankruptcy Code, the claims not forming part of the plan stand frozen and are binding on the corporate debtor and all stakeholders. The approved plan in the present matter expressly provided for waiver and extinguishment of outstanding tax liabilities, including assessed and unassessed dues. Once such liabilities stood discharged under the plan, the respondent had no legal basis to appropriate the petitioner's refunds towards past tax demands. The challenge was therefore confined to the legality of the refund adjustment, and the merits of the refund claim itself were not examined.

Conclusion: The adjustment of income tax refunds against extinguished pre-resolution tax dues was unlawful and was quashed. The issue is decided in favour of the assessee.

Final Conclusion: Approval of the resolution plan brought the prior tax claims to an end, and the revenue could not continue recovery by adjusting refunds against those extinguished dues.

Ratio Decidendi: Once a resolution plan is approved under the Insolvency and Bankruptcy Code and the relevant claims are not preserved in the plan, those claims stand extinguished and cannot be enforced by adjustment or continuation of recovery proceedings.

Issues: Whether the delay in filing the GST appeal deserved condonation and the appeal ought to be entertained and decided on merits.

Analysis: The statutory appellate remedy under the GST enactments is subject to limitation, but where the delay is shown to have arisen from circumstances beyond the control of the assessee, refusing consideration on merits would cause grave prejudice. The Court followed its consistent earlier view in similar matters and held that the explanation furnished was sufficient to justify interference.

Conclusion: The delay was condoned and the Appellate Authority was directed to entertain the appeal and adjudicate it on merits.

Issues: Whether the assessment order passed under the GST regime could be sustained when the notices and order were only uploaded on the portal and the petitioner was denied a meaningful opportunity to respond.

Analysis: The assessment was challenged on the ground of lack of effective service and violation of natural justice. The Court noted that while portal-based uploading had earlier been treated as sufficient service, the practical difficulty faced by assessees who are not technically equipped warranted a balancing approach. To protect revenue as well as procedural fairness, the Court held that the petitioner should be afforded a proper opportunity before fresh adjudication.

Conclusion: The impugned assessment order was set aside and the matter was remanded for fresh consideration after due opportunity to the petitioner, subject to payment of 20% of the disputed tax within the stipulated period.

Issues: Whether the writ petition challenging a GST demand order was maintainable despite the statutory appeal remedy, and whether the case fell within the exception of violation of principles of natural justice.

Analysis: The impugned order under the Goods and Services Tax Act, 2017 was appealable under Section 107, and the Court reiterated that writ jurisdiction under Article 226 ordinarily should not be invoked where an efficacious statutory remedy exists. The recognised exceptions to the rule of alternative remedy were noted, including violation of natural justice, lack of jurisdiction, fundamental rights, and challenge to vires. On the facts, the petitioner had participated in the proceedings and filed a detailed reply to the show cause notice, and there was no material to show denial of a requested personal hearing or any ex facie breach of natural justice. The Court therefore found no basis to bypass the statutory appellate remedy.

Conclusion: The writ petition was not maintainable and the petitioner was relegated to the statutory appeal remedy.

Issues: Whether the writ petition should be disposed of by directing the competent authority to reconsider the petitioner's objections to the show cause notice and pass a speaking order.

Analysis: The challenge to the input tax credit restriction was not pressed. The petitioner sought consideration of the replies and supporting documents already filed, and also indicated willingness to place fresh objections before the competent authority. The respondents did not oppose a fresh adjudication on the objections and documents. In these circumstances, the Court directed the competent authority to consider the objections, if filed, within the stipulated time and to pass a speaking and reasoned order thereafter.

Conclusion: The petition was disposed of with a direction for fresh consideration of the objections and supporting documents by the competent authority.

Issues: Whether the matter relating to the transactions covered under Form 'F' should be remanded for fresh consideration in light of the later Supreme Court exposition on the scope of reopening of assessments and the impact of the amendment to the Central Sales Tax Act.

Analysis: The earlier revisional order proceeded on the basis of the law as understood from the then-prevailing Supreme Court view. The later decision in Ashok Leyland-II substantially altered the understanding of the scope of reopening under the statutory scheme and clarified that, although an assessment order under the relevant provision carries conclusivity, it may still be reopened where the order is vitiated by fraud, collusion, misrepresentation, suppression of material facts, or furnishing of false particulars. The Court considered that the controversy also required examination of the amendment introducing Section 6(A)(3) and, more importantly, a fresh factual appraisal of the record by the final fact-finding authority.

Conclusion: The impugned order was set aside to the extent challenged and the matter was remanded to the Tribunal for fresh consideration in accordance with law.

Issues: Whether cancellation of charitable registration under section 12AB(4) could be sustained for alleged violations pertaining to periods prior to 01.04.2022, and whether the alleged specified violations on merits justified withdrawal of registration.

Analysis: The statutory regime of section 12AB(4) introducing cancellation on account of "specified violation" came into force with effect from 01.04.2022. In the absence of an express legislative mandate, the provision could not be applied to alleged defaults relating to earlier assessment years. The principle that a provision imposing a new burden operates prospectively, unless the statute clearly provides otherwise, governed the matter. The cancellation order also rested on section 12AA even though that provision had ceased to operate in the relevant regime. On merits, the alleged discrepancies in valuation, maintenance of accounts, donor details, and foreign receipts in the hands of individuals were not shown to establish misapplication of the society's funds, non-genuine activities, or false information in the registration application.

Conclusion: The invocation of section 12AB(4) for pre-01.04.2022 periods was invalid, and the alleged specified violations were not made out. Cancellation of registration was not sustainable.

Final Conclusion: The assessee succeeded, the cancellation of registration was set aside, and the registration stood restored.

Ratio Decidendi: Section 12AB(4), being a provision creating a new cancellation regime on account of specified violation, applies prospectively from its effective date and cannot be used to cancel registration retrospectively for earlier years in the absence of express statutory authority.

Issues: Whether interest was payable on the amount deposited pursuant to the Supreme Court's interim order directing deposit of the disputed amount with a stipulation of refund forthwith with applicable interest if the appeal succeeded, or whether the refund and interest were governed by Sections 27 and 27A of the Customs Act, 1962.

Analysis: The amount was deposited not as duty paid under the refund machinery of the Customs Act, 1962, but pursuant to a specific judicial direction issued in the pending civil appeal. The interim order itself governed the consequences of the deposit and required refund forthwith with applicable interest on success of the appeal. In such a situation, the department could not re-characterise the payment as duty or compel the assessee to seek refund under Section 27 of the Customs Act, 1962. The interest condition in the judicial order was binding and could not be diluted by invoking the time limit under Section 27A of the Customs Act, 1962. The amount deposited during the pendency of the appeal was also not liable to be treated as duty merely because it was described in the refund correspondence as differential duty. The governing principle is that a deposit made under a court's order is controlled by that order and not by the ordinary statutory refund route, unless the order itself leaves the matter to the statute.

Conclusion: The amount deposited pursuant to the Supreme Court's interim order was refundable with interest, and the assessee was entitled to interest at 6% per annum from the date of deposit till payment.

Final Conclusion: The denial of interest on the Supreme Court-directed deposit was unsustainable, and the assessee succeeded in obtaining interest on the refunded amount.

Ratio Decidendi: A deposit made in obedience to a court's conditional order is governed by the terms of that order, and when the order directs refund with applicable interest upon success of the appeal, the statutory refund provisions for duty cannot be used to deny that interest.

Issues: Whether reduction of the MEIS customs duty benefit from 3% to 2% by subsequent cancellation or modification of the scrips could be applied to imports made by the appellant during the period when the scrips were valid.

Analysis: The Tribunal applied the settled principle that a licence or scrip obtained by fraud is not void ab initio but only voidable, and that cancellation made after import does not affect imports already completed on the strength of a valid scrip. Once the DGFT had issued the MEIS scrips and they were presented and utilized during their validity, the benefit available at that time could not be denied merely because the scrips were later reduced from 3% to 2% or cancelled thereafter. The Tribunal also held that it made no difference whether the scrip was used by the original holder or a transferee, and the allegation of deliberate misclassification was not relevant to the issue in appeal.

Conclusion: The subsequent reduction of MEIS benefit could not be applied retrospectively to the appellant's imports, and the duty demand, interest, and penalty were unsustainable.

Ratio Decidendi: A validly issued scrip or licence remains effective for imports made during its currency, and later cancellation or reduction does not retrospectively extinguish the benefit already availed.

Issues: (i) Whether customs duty and interest could be demanded under section 28(4) of the Customs Act, 1962 on the imported marble blocks, (ii) Whether penalty under section 114A of the Customs Act, 1962 could be imposed on the importer, and (iii) Whether penalties under section 114AA of the Customs Act, 1962 could be sustained against the other appellants.

Issue (i): Whether customs duty and interest could be demanded under section 28(4) of the Customs Act, 1962 on the imported marble blocks.

Analysis: The demand could not be sustained on the quantities admittedly found in stock at the unit, since the goods were shown to be lying within the 100% EOU and were not diverted. As to the remaining quantity, the demand rested on an inference that imported marble had been diverted and that slabs exported through third parties were of Indian-origin material. The inference was drawn largely from internet material and statements of third parties. The Court held that internet material by itself could not establish exclusive availability of the relevant marble in India, and that the statements could not be relied upon without compliance with section 138B of the Customs Act, 1962. In the absence of admissible evidence proving diversion, the duty demand failed.

Conclusion: The demand of customs duty and interest under section 28(4) of the Customs Act, 1962 was not sustainable and was set aside in favour of the assessee.

Issue (ii): Whether penalty under section 114A of the Customs Act, 1962 could be imposed on the importer.

Analysis: Penalty under section 114A requires non-levy or short-levy of duty by reason of collusion, wilful misstatement, or suppression of facts. The import was made under a valid exemption regime applicable to a 100% EOU, with the necessary bond and permission in place. The case, at its highest, alleged failure to satisfy a post-import condition, not a false declaration or suppression at the time of import. That did not meet the statutory threshold for invoking section 114A.

Conclusion: Penalty under section 114A of the Customs Act, 1962 was unsustainable and was set aside in favour of the assessee.

Issue (iii): Whether penalties under section 114AA of the Customs Act, 1962 could be sustained against the other appellants.

Analysis: Section 114AA applies only where a person knowingly or intentionally makes or uses a false or incorrect declaration, statement, or document in the transaction of business under the Act. Since the imports were made under an exemption notification and there was no proved false declaration at the time of import, the subsequent allegation of non-compliance with post-import conditions did not establish the requisite mens rea or falsity for section 114AA. Accordingly, the personal penalties could not stand.

Conclusion: The penalties under section 114AA of the Customs Act, 1962 were not sustainable and were set aside in favour of the appellants.

Final Conclusion: The impugned order was set aside in its entirety, and all appeals succeeded.

Ratio Decidendi: A duty demand based on alleged diversion of imported goods cannot be sustained on uncorroborated inference or inadmissible statements, and penalties under sections 114A and 114AA require the specific statutory ingredients of suppression, wilful misstatement, or knowing use of false material to be independently proved.

Issues: (i) Whether the Equity Pledge Agreement and the share transfer arrangement established that Danyang ILT remained related to the Essilor Group and under its control; (ii) whether the non-filing of annual reports of Danyang ILT and the non-disclosure of certain related entities justified treating the Essilor Group as non-cooperative and resorting to facts available; (iii) whether information concerning Danyang ILT and the three non-exporting related entities was relevant for determination of dumping margin; and (iv) whether exports of subject goods produced by Danyang ILT could be used against the Essilor Group for determination of dumping margin.

Issue (i): Whether the Equity Pledge Agreement and the share transfer arrangement established that Danyang ILT remained related to the Essilor Group and under its control.

Analysis: A pledge is only a bailment of goods or security for debt and does not, by itself, confer ownership or operational control over the pledged property. The equity pledge arrangement showed only a security interest and did not transfer ownership or control back to the Essilor Group. The record also showed that the shareholding had been transferred and stood with DYSS, so the earlier relationship could not, on that basis, continue to be treated as subsisting control for the purpose of the investigation.

Conclusion: Danyang ILT was not shown to be a related party of the Essilor Group, and no control of the Essilor Group over Danyang ILT was established.

Issue (ii): Whether the non-filing of annual reports of Danyang ILT and the non-disclosure of certain related entities justified treating the Essilor Group as non-cooperative and resorting to facts available.

Analysis: The duty to furnish information extends only to material information that is relevant and within the party's ability to produce. The annual reports of Danyang ILT were not shown to be within the possession or control of the Essilor Group. Further, the three related entities in China were non-exporting producers, and in a non-market economy investigation the normal value was not affected by their non-participation. The investigation record already contained the relevant export and production data needed to assess normal value and export price. On that basis, the use of adverse inference and facts available was unwarranted.

Conclusion: The Essilor Group could not be treated as non-cooperative on these grounds, and resort to facts available was unjustified.

Issue (iii): Whether information concerning Danyang ILT and the three non-exporting related entities was relevant for determination of dumping margin.

Analysis: Dumping margin is determined on the basis of relevant facts relating to normal value and export price during the period of investigation. Information about a non-exporting producer, or about entities whose products were not exported to India during the period of investigation, did not affect the computation of normal value in the present non-market economy context. Accordingly, such information could not be treated as essential for calculating the dumping margin of the Essilor Group.

Conclusion: The information concerning Danyang ILT and the three non-exporting entities was irrelevant for determining the dumping margin.

Issue (iv): Whether exports of subject goods produced by Danyang ILT could be used against the Essilor Group for determination of dumping margin.

Analysis: Once Danyang ILT was found not to be related to the Essilor Group, the price and volume of goods produced by Danyang ILT and exported by the Essilor Group could not be treated as material for fixing the dumping margin of the Essilor Group. The investigation had sufficient material from the cooperating exporting producers and related entities for a proper determination.

Conclusion: Goods produced by Danyang ILT and exported by the Essilor Group could not be used for determining the Essilor Group's dumping margin.

Final Conclusion: The finding of non-cooperation and the resulting recommendation of anti-dumping duty against the Essilor Group were unsustainable and were set aside, with a direction for fresh consideration without treating the Essilor Group as non-cooperative.

Ratio Decidendi: In an anti-dumping investigation, a party cannot be treated as non-cooperative on the basis of information that is irrelevant to the determination of normal value and export price, and a pledge arrangement does not by itself establish ownership or control so as to create related-party status.

Issues: Whether a claim filed after the last date for submission and after approval of the resolution plan could be directed to be admitted and verified, and whether the rejection of such belated claim was justified.

Analysis: The claim was filed long after the public announcement and after the committee of creditors had approved the resolution plan. The record also showed a prior written stand by the society that its claim against the developer had already been fully and finally settled, and the claim was not reflected in the corporate debtor's books. In a time-bound insolvency process, belated claims cannot be allowed to unsettle an approved plan or reopen the CIRP, particularly when the claimant was already aware of the proceedings and did not act within the prescribed timeline.

Conclusion: The rejection of the belated claim was upheld and the appellant was denied relief.

Final Conclusion: The appellate challenge failed because the delayed claim could not be entertained after approval of the resolution plan, and no ground was shown to interfere with the rejection order.

Ratio Decidendi: In insolvency resolution, claims must be lodged and decided within the prescribed timeline, and a claim filed after approval of the resolution plan cannot ordinarily be revived to disturb the finality of the approved resolution.

Issues: (i) whether mere deposit of tax amounts in the electronic credit ledger under the reverse charge mechanism amounted to payment of GST, and whether interest was payable for delayed appropriation to the Government; (ii) whether input tax credit availed before appropriation to the Government could be recovered and penalised; (iii) whether a composite assessment and penalty order covering two tax periods could be sustained.

Issue (i): whether mere deposit of tax amounts in the electronic credit ledger under the reverse charge mechanism amounted to payment of GST, and whether interest was payable for delayed appropriation to the Government

Analysis: Deposit of cash into the electronic credit ledger does not, by itself, amount to discharge of tax. Payment is completed only when the amount is appropriated to the Government exchequer. On the admitted facts, the tax amounts were eventually debited to the Government account, but only after the stipulated time. The delay in appropriation therefore attracted liability to interest for the period of delay.

Conclusion: The tax was not treated as paid in time, and interest for delayed payment was payable against the assessee.

Issue (ii): whether input tax credit availed before appropriation to the Government could be recovered and penalised

Analysis: Input tax credit could be availed only after the underlying tax payment stood properly appropriated. The assessee's earlier availment of credit was therefore not correct. However, once the tax liability was later discharged by debit entries, the order directing independent recovery of the credit, apart from appropriation of the tax already paid, was not sustainable on the facts found. The question whether the conduct amounted to suppression of facts or was merely an inadvertent omission required factual reconsideration by the primary authority.

Conclusion: The finding of wrongful availment was accepted only to the extent of the legal infirmity, but the recovery and penalty treatment required reconsideration and were not finally sustained as framed.

Issue (iii): whether a composite assessment and penalty order covering two tax periods could be sustained

Analysis: The impugned order covered two distinct tax periods in a single composite exercise. Such a composite determination was not permissible and necessitated separate consideration for each period.

Conclusion: The composite order was unsustainable and had to be set aside.

Final Conclusion: The matter was sent back for fresh, separate orders for the two tax periods, while the legal position on delayed appropriation and consequential interest remained against the assessee.

Ratio Decidendi: Deposit in an electronic credit ledger does not amount to payment of GST unless and until the amount is appropriated to the Government, and a composite order covering distinct tax periods cannot be sustained.