Writ challenges to licence notices and tender conditions became...

Writ challenges to licence notices and tender conditions became infructuous after the licence period expired, so no effective relief could be granted on those issues. GST demands raised under reverse charge on 99% of the licence fee were unsustainable because TASMAC is a distinct juristic entity and not the State Government, Union Territory or local authority for the relevant notifications; the reverse charge entry therefore did not apply. The assessment orders and show cause notice on that basis were quashed. The Court left open independent GST liability, if any, on the petitioners' own supplies and permitted fresh proceedings under the machinery for unregistered persons, subject to limitation.

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