Refund claims cannot be treated as time-barred through a deficiency memo under Rule 90(3). That provision applies only to rectifiable deficiencies and requires a fresh application after rectification; its limitation-related proviso does not authorise rejection on limitation grounds. Where a proper officer proposes to reject a refund claim wholly or partly, including for limitation, Rule 92(3) requires a show cause notice, consideration of the claimant's reply, and an opportunity of hearing. The prescribed refund-rejection procedure must therefore be followed.

GST penalty for delayed tax remittance may be avoided only where tax and interest are paid within 30 days of receiving the show-cause notice. A pandemic-period delay does not create a separate statutory ground for waiver. Consequently, a penalty capped at 10% of the tax demand remains legally sustainable where that payment condition is not met.

A deemed stay of recovery arising from appellate pre-deposit stays recovery of the balance demand but does not automatically require unblocking of an electronic credit ledger restricted for input tax credit. Blocking under Rule 86A is an independent provisional measure that requires recorded reasons and cannot continue beyond one year. The deemed stay prevents appropriation from the electronic cash ledger or blocked credit ledger, while the blocking order remains separately operative unless reconsidered. The affected person may seek unblocking, and refusal must be supported by a speaking order.

Service of Form GST DRC-01A intimation and Form GST DRC-01 show-cause notice under the section 73 process established procedural regularity in an ex parte GST assessment. Fresh adjudication was nevertheless made available conditionally: the taxpayer must deposit 25% of the disputed tax in cash and submit a reply with supporting documents within the prescribed period. On compliance, the assessment would be reconsidered de novo and the bank attachment lifted.

Ex parte GST assessment was quashed and remitted for de novo adjudication, conditional on the taxpayer depositing 25% of the disputed tax after verified adjustment of any cash recovery and filing a substantiated reply. The assessment was treated as an addendum to the show-cause notice, enabling fresh determination on merits. Failure to meet the deposit or reply conditions permits recovery proceedings in accordance with law.

Provisional attachments under Section 83 of the Central Goods and Services Tax Act cease to have effect upon expiry of the statutory one-year period. The statutory framework provides no authority to renew, reissue, or revive an attachment after that expiry. Where the attachments have lapsed and no interim protection preserves their operation, they no longer create enforceable restraint. A Revenue challenge relating solely to such expired attachments becomes infructuous because the attachments no longer survive.

Recovery under Form GST DRC-13 was initiated before a second appeal and the related statutory application. The petitioner was permitted to pursue that application before the competent authority, which was required to decide it and the pending request to withdraw recovery proceedings in accordance with law. Recovery was restrained until disposal of both applications, which were directed to be decided within fifteen days.

Pre-cut-off notice issued under section 87(b) to create a bank-account lien, which stated the outstanding service tax duty, constituted written quantification of duty payable under section 121(r) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. Quantification remained sufficient although the notice did not quantify interest and was addressed to the bank rather than the taxpayer. The service tax dues therefore stood quantified, making the taxpayer eligible for Scheme benefits; rejection of the declaration for lack of quantification was unsustainable, and writ relief followed.

Rule 86A blocking of an electronic credit ledger is a provisional measure that requires recorded reasons and cannot continue beyond one year. Filing an appeal with the prescribed pre-deposit creates a deemed stay of recovery for the remaining demand, preventing appropriation from the electronic cash ledger and the blocked credit ledger. That recovery stay does not automatically lift the separate Rule 86A blocking order. Unblocking must be sought independently, and any refusal should be issued through a speaking order after consideration of the request.

Provisional attachment of bank accounts under GST is a pre-emptive revenue-protection measure that ceases by operation of law one year after the attachment order. Continued freezing cannot rest on an expired attachment where no fresh provisional attachment order has been issued. Where account holders were not recipients of a later demand-cum-show cause notice, that notice did not provide a basis to maintain restrictions on their accounts. The lapsed attachments required the bank accounts to be defreezed and made operable upon production of a certified copy of the order.

Tax paid under the CGST and SGST heads through a clerical error may be appropriated towards the corresponding IGST liability where the entire liability was discharged within the prescribed period. Although Section 77 does not expressly address this payment error, its underlying principle avoids requiring the taxable person to make a duplicate payment and then pursue a refund. Interest should not apply where the required tax has already been remitted, albeit under incorrect GST heads. Appropriation may be made on application, with a refund application filed if required procedurally.

Parallel Central and State GST proceedings concerning identical issues for the same assessment period require avoidance of duplicate adjudication. Where Central GST authorities issue an earlier adjudication order and an appeal against it remains pending, subsequent State GST assessment and rectification orders addressing the same issues and period cannot be sustained. The overlap between the two proceedings makes the later State GST action duplicative of the prior Central GST adjudication.

Mandatory nationwide e-way bill compliance for inter-State movement of goods took effect only from 1 April 2018, despite rule 138 having provided the operational mechanism earlier. Non-production of an e-way bill for goods intercepted before that date therefore did not justify detention or penalty. Correspondence between the goods, invoice and transport documents, coupled with the absence of discrepancies or material indicating intent to evade tax, supported deletion of the detention proceedings and penalty. The Revenue's challenge against that deletion failed.

E-way bill validity requires Part B to state the actual vehicle used for movement; a concession for minor clerical errors does not cover entirely different vehicle particulars. Transport under an expired e-way bill bearing a wholly different vehicle number may support a rebuttable presumption of intent to evade tax. Mens rea is not required for a civil fiscal penalty unless the governing enactment makes it essential. The presumption remains rebuttable through surrounding facts, but failure to provide a satisfactory rebuttal supports penalty under the CGST/UPGST transport-of-goods provisions. On the stated facts, the penalty was sustained and the second appeal dismissed.

Inverted duty structure refund computation requires accurate determination of turnover of inverted-rated supplies and adjusted total turnover. The treatment of outward supplies allegedly taxable at a higher rate must be verified before deciding whether they form part of the relevant turnover figures. Where supporting invoices or other documents are unavailable and the relevant issue has not been examined, the admissible accumulated input tax credit refund cannot be correctly quantified. Refund computation requires fresh examination after production of relevant records and a reasonable opportunity for both sides to address the turnover treatment.

Pre-GST service tax paid on advances for flat bookings later cancelled after the appointed day does not qualify as input tax under the CGST/SGST Acts and cannot be carried as GST input tax credit. Where services are ultimately unprovided, the transitional provision requires the service-tax refund claim to be processed under the existing law and paid in cash. Taxpayers cannot adjust that claim through an electronic credit ledger without specific statutory authority. The claimed GST credit was therefore inadmissible.

Reasoned appellate orders are required by natural justice: common GST appellate orders confirming demands were invalid because they gave only a general conclusion without addressing material appeal grounds, cited judicial authorities, or each appellant's distinct contentions. The failure to give cogent reasons constituted a failure to exercise appellate jurisdiction. Objections concerning show cause notices, availability of relied-upon documents, and effective personal hearing in original proceedings also required consideration. The Tribunal set aside the appellate and original orders and remitted the matters for fresh adjudication after providing relied-upon documents, allowing replies and effective hearings, and issuing reasoned orders.

Leasing digital cinema equipment comprising a projector, server, UPS and VSAT for a single rental is classified as a mixed supply where the items are not naturally bundled in the ordinary course of business and can be supplied independently. The bundled lease therefore does not meet the requirements of a composite supply. GST is payable at the highest rate applicable to any constituent supply, which is the rate applicable to the projector: 28% up to 21 September 2025 and 18% thereafter. The bundled-lease treatment as a mixed supply is accordingly correct.

Psyllium seeds (Isabgol) are classified under tariff sub-heading 1211 9013, supported by the express tariff description and HSN coverage of Plantago psyllium herbs and seeds. GST exemption as fresh or chilled plant parts under Entry 87 was denied for supplies stored in godowns before onward sale. Eligibility depends on the goods' condition when supplied by the applicant, and godown storage was treated as giving the seeds a dried character. The supplies were consequently taxable at 5% under Entry 71 of Schedule I. The alternative exemption for goods of seed quality under Entry 77 was also denied.

Professional coaching supplied by an entity that does not itself deliver a recognised qualifying curriculum, conduct examinations or award qualifications is not exempt as education by an educational institution and is taxable. Examination, registration and related student fees remain within taxable value unless all pure-agent conditions, including student authorisation and separate invoice disclosure, are met. Coaching bundled for a single fee with study materials and digital resources is a composite supply whose principal supply is commercial training. Retained foreign-exchange differences unconnected with separate consideration are outside GST. Training-partner services to universities are taxable where no exempt service or educational-institution status is established; insufficient contractual material prevents precise six-digit classification.