Personal liberty under Article 21 was prima facie infringed when GST authorities arrested a petitioner who had appeared with records pursuant to a court direction in pending proceedings. The arrest authorisation omitted the direction and appearance, relied on routine grounds considered misplaced, and reflected a discrepancy between the summons time and later generation of its DIN, indicating possible manipulation. Interim release was directed, subject to passport surrender and travel conditions, while officers were required to explain their conduct before any disciplinary recommendation. The interim relief did not determine the merits of the pending proceedings.

Writ jurisdiction against a GST adjudication order is generally unavailable where an efficacious statutory appeal was not pursued within time and delay remains unexplained; a pending rectification application does not create a fresh period to challenge the original order. The statutory restriction on parallel GST proceedings applies only where proceedings concern the same subject matter, rather than merely the same assessee, period, transactions, or factual background. Proceedings based on incorrect tax liability and inadmissible input tax credit may continue independently from allegations of fraudulent credit without actual supply. The bar on duplicate penalties requires a prior penalty imposed on the person concerned for the same act or omission.

Section 93 of the CGST Act permits post-death determination of tax, interest or penalty through a legal representative, without requiring adjudication to have begun during the deceased's lifetime. Liability remains confined to estate assets and does not attribute the underlying contravention to the representative; effective hearing and appellate safeguards support its constitutional validity. Pure questions concerning Section 93 may be examined in writ jurisdiction despite an alternative remedy, but factual and merits disputes, including service, proof, representative-liability conditions and penalty computation, belong in statutory appeal. Retention or appropriation of investigation deposits requires a disclosed lawful basis and reasoned determination after hearing; any unsupported balance must be released with accrued fixed-deposit interest.

GST registration cancellation without deciding a registrant's request for time to submit transaction and input tax credit evidence breaches natural justice. The High Court quashed the show cause notice and cancellation order because the authority failed to consider material the registrant sought to produce, while permitting fresh proceedings on proper notice and opportunity. Registration-revocation proceedings cannot be combined with input tax credit disallowance or demands for tax, interest and penalty on grounds absent from the original notice. The rejection of revocation and appellate order were also quashed; fresh proceedings may be initiated in accordance with law, with merits left open.

GST law bars overlapping Central and State departmental proceedings when they assess or recover the same tax liability arising from the same contravention. The prohibition does not extend to distinct infractions solely because they produce similar liabilities or deficiencies. A consolidated GST demand that included FY 2017-18 and FY 2018-19, already covered by State proceedings, had to exclude those overlapping periods. The consolidated demand was quashed, and fresh determination was confined to periods not subject to the State proceedings.

Effective service of a rectification notice is required before adjudicating a refund of accumulated input tax credit under an inverted duty structure. Adjudication after the notice was returned undelivered breached principles of natural justice because the claimant was denied an opportunity of hearing. The refund rejection was set aside and remitted for fresh adjudication after granting a hearing, while leaving the merits of the refund claim open.

Recovery of an excess monetary refund of unutilised input tax credit under the inverted-duty scheme may proceed as an erroneous refund under section 73, even where the original refund sanction was not challenged by appeal or revision. The recovery mechanism is distinct from appellate or revisional review of the sanction order. Statutory interest applies under sections 73 and 50 until the principal is repaid; repayment through FORM GST DRC-03 does not close proceedings unless interest is also paid. Substituted Rule 89(5), operative before the refund claim and sanction, governs entitlement; later judicial validation and Rule 88B do not make interest impermissibly retrospective. Interest is computed for the period the erroneous refund remained with the recipient.

Section 132B's reference to a "person concerned" extends to a third-party claimant whose ownership of cash seized from another person's premises has been established in benami proceedings. Ownership establishes standing to seek release but does not itself satisfy the statutory conditions for release. The first proviso requires an application within the prescribed period explaining the nature and source of acquisition to the Assessing Officer's satisfaction; a bare release request is inadequate. Release was not accepted where the application was late and omitted that explanation, while source-related assessment proceedings remained pending or contemplated. Questions on the provisos' effect, including expiry of 120 days, were referred to a Larger Bench.

Reassessment of a section 80JJAA deduction cannot rest solely on a change of opinion where the deduction was specifically examined and accepted during the original scrutiny assessment. Employee, cost and supporting details had been furnished for the original assessment, while the reopening notice and the order under section 148A(d) identified no fresh tangible material indicating income escapement. The reassessment proceedings were therefore invalidated as a review of material already considered, and the section 148 notice and section 148A(d) order were quashed.

Reassessment proceedings alleging fictitious mutual-fund losses and dividend income were quashed where the taxpayer was identically situated to one covered by a final earlier decision and the Revenue did not dispute its applicability. The order under section 148A(d) and the notice under section 148 were set aside because the earlier ruling had already quashed materially similar reassessment action on identical facts.

Section 119(2)(b) permits condonation of delay in a revised return seeking refund to prevent genuine hardship, subject to the prescribed six-year limit. The competent authority must independently determine whether the refund claim is correct and genuine and whether genuine hardship exists; this power cannot be exercised routinely. A rejection cannot rest on irrelevant considerations or an unreasoned denial of hardship, and recorded reasons cannot be supplemented in court. The sufficient-cause standard for delayed appeals under the Limitation Act does not impose a stand-alone requirement to explain delay under section 119(2)(b). The refusal to condone was quashed and remitted for a fresh reasoned decision, leaving the exemption claim open.

Tariff-related debit notes seeking reimbursement of income tax as an electricity-tariff component involve disputed questions requiring specialised adjudication before CERC. Writ jurisdiction did not extend to examining the merits of the debit notes or the claimed liability. The generating company was required to pursue the regulatory remedy before CERC, which was to decide the dispute expeditiously after hearing all parties. The writ petition was disposed of on that basis.

Unverified Insight Portal information cannot justify reassessment where it does not identify any transaction linking the taxpayer to alleged escaped income. Reassessment must rest on material demonstrating a taxpayer-specific nexus and application of mind; it cannot be used for a roving and fishing inquiry. Where the underlying material is not supplied, the alleged-beneficiary chart identifies no attributable transaction, and the Assessing Officer does not verify the information's genuineness, the reassessment notice and order under section 148A(3) lack a valid foundation. The reassessment proceedings were quashed and the writ petition was allowed.

Statutory transfer of an income-tax case gives the transferee Assessing Officer exclusive jurisdiction over pending, completed and future proceedings for every covered year. PAN database records do not determine or retain jurisdiction after transfer. Reassessment requires a notice issued by the jurisdictional Assessing Officer; a notice issued by the transferor officer is without jurisdiction and non-est. Consequently, the reassessment notice for the relevant assessment year and all resulting proceedings were quashed.

Deletion of a negative working-capital adjustment in rectification proceedings required implementation through a consequential appeal-effect order. The Assessing Officer was required to consider whether, after that deletion, the taxpayer's margin fell within the permissible arm's-length range and could reach a contrary conclusion only after giving a reasonable opportunity of hearing. The appeal-effect order was directed to be passed within 15 days, with liberty to seek revival if the consequential order caused grievance.

Valid adoption of the DCF method for valuing unquoted equity shares under Rule 11UA requires any assessment correction to remain within that method. Management projections, historical losses, or later financial results may justify scrutiny of assumptions, growth rates, discount factors, terminal value and market conditions, but do not alone permit substitution of the NAV method. Rejection requires identified arithmetical errors, internal inconsistencies, factual inaccuracies, or inputs demonstrably contrary to contemporaneous material or industry norms. Applying these principles, the addition under section 56(2)(viib) was deleted and the Revenue's appeal was dismissed.

Discounted cash flow valuation of equity shares and compulsorily convertible preference shares must be assessed as at the valuation date; subsequent actual cash flows, initial operating losses, or absence of positive cash flows do not alone invalidate projections. Substitution of the discounted cash flow method with net asset value valuation was therefore inappropriate, and the share-premium addition was deleted. Vendor-confirmation differences did not justify treating recorded business expenses as unexplained where audited books recorded the transactions, payments passed through banking channels, and business operations funded the expenditure; the unexplained-expenditure addition was deleted. Penalty-initiation challenges were premature because penalty proceedings remain separate from assessment proceedings.

Validity of a scrutiny assessment depends on issuance of a valid notice under section 143(2) within the prescribed limitation period; a notice issued after that period cannot support an assessment under section 143(3). Assessment jurisdiction following transfer of proceedings also requires a valid transfer order under section 127. Statutory powers must be exercised by the authority designated by law, and failure to produce a valid transfer order leaves the officer completing the assessment without jurisdiction. These defects render the assessment void ab initio.

Territorial jurisdiction over an income-tax appeal and a related cross-objection is ordinarily determined by the office location of the Assessing Officer who issued the assessment order, rather than the assessee's location or that of the appellate authority. Where the assessment order originated from the Chennai Assessing Officer, the Mumbai Bench lacked jurisdiction over both proceedings. The appeal and cross-objection were dismissed without examination on merits, with liberty to approach the appropriate Bench. Merits remained open, and time spent before the Mumbai Bench may be considered under delay-condonation law.

Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.