Belated refund claims may be admitted within the prescribed six-year period where the claim is correct and genuine and refusal would cause genuine hardship. The authority must assess those criteria independently, may verify the claim, and give a reasoned decision based on recorded grounds. A separate sufficient-cause explanation for delay, analogous to the Limitation Act standard, is not an independent requirement under this framework. Factors relevant to hardship include employment loss, the refund sought and final comparable decisions. The framework calls for fresh consideration of condonation without deciding the underlying exemption claim.

Reassessment of an investor cannot rest solely on allegations that a mutual fund manager manipulated accounting methodology. The Assessing Officer must possess information establishing a rational nexus or live link between those allegations and the investor's own escaped income, including material connecting the investor to a sham arrangement or fictitious loss. Where no material showed the investor's knowing participation and binding coordinate precedent governed the identical issue, the reassessment notice under Section 148 and the order under Section 148A(d) were quashed.

Reassessment of the section 80JJAA deduction was impermissible because the original scrutiny assessment had specifically examined eligible additional employees and related costs, received supporting material, and accepted the claim under section 143(3). Reopening under sections 148A and 148 raised the same issue without fresh tangible material unavailable during scrutiny, amounting only to a change of opinion. The section 148 notice and section 148A(d) order were therefore quashed in favour of the assessee.

Ownership established under Benami law does not itself justify release of cash seized in an income-tax search. The first proviso to section 132B(1)(i) permits a third-party claimant to seek release even where assets were seized from another person, subject where necessary to indemnity for competing claims. Release requires an application within the stipulated period and a satisfactory explanation to the Assessing Officer of the nature and source of acquisition. Benami findings that cash is not benami establish ownership only for those proceedings and do not displace the income-tax inquiry into its source. Questions concerning the statutory time limit, non-decision of an application, and deficient applications remain for Larger Bench determination.

Tax deduction on external development charges was in issue: whether the payments constituted rent subject to deduction under section 194-I or contractual payments under section 194C. The Special Leave Petition was not entertained because a 328-day filing delay was not condoned; the reasons offered were found unsatisfactory and insufficient in law. The petition was consequently dismissed without resolving the TDS classification of the charges.

Monetary refunds of unutilised input tax credit exceeding entitlement under the refund formula may be treated as erroneous refunds recoverable under Section 73. Recovery jurisdiction does not require prior reversal of the original refund sanction through departmental appeal or revision, although it does not permit disregard of a subsisting appellate determination. Sections 73 and 50 impose compensatory interest on erroneous refunds, irrespective of fraud, taxpayer fault, or departmental error in granting the refund. The substituted refund formula applied from its stated effective date, while the later interest-computation rule neither created nor removed the underlying statutory interest liability.

Effective service of a rectification notice under Section 161 of the Central Goods and Services Tax Act, 2017 is necessary before rejecting a refund claim. Where the notice is returned undelivered, the affected person lacks a meaningful opportunity to respond to the proposed rectification and participate in the hearing. An earlier written reply and the statutory deadline for passing an order do not replace effective notice or an opportunity to be heard. Adjudication in these circumstances violates the principles of natural justice.

Section 6(2)(b) of the CGST Act applies when central and state departmental proceedings concern the same tax liability, deficiency or obligation arising from a particular contravention; similar liabilities arising from distinct infractions do not trigger the bar. State GST proceedings had already covered FYs 2017-18 and 2018-19, while the central authority confirmed a consolidated demand extending from July 2017 to November 2022 and including those years. The consolidated demand could not cover the overlapping financial years. The impugned order was quashed and remitted for fresh determination excluding FYs 2017-18 and 2018-19.

GST registration cancellation requires a clear show cause notice and a meaningful opportunity to furnish supporting evidence before retrospective cancellation. A registrant's request for reasonable time to produce purchase and sale records, e-way bills and transport evidence must be addressed. Revocation or appellate action cannot rely on allegations absent from the original notice, including unnotified input tax credit concerns. Registration-cancellation proceedings and separate tax-demand proceedings for fraudulent input tax credit availment or suppression operate in distinct statutory domains and cannot be conflated. Fresh action requires an appropriate notice, proper hearing and opportunity to produce evidence.

Condonation of delay in seeking revocation of cancelled GST registration requires examination of the justification for delay and a meaningful opportunity of personal hearing. Rejecting the condonation application before the scheduled hearing, while deciding the merits of the underlying revocation request, exceeded the scope of the proceeding. Appellate review of the delay-condonation issue likewise could not determine the revocation application on merits. The rejection order, appellate order and show-cause notice were quashed, with fresh proceedings required in accordance with law.

Statutory appellate remedies generally preclude GST writ jurisdiction where challenges to an adjudication order require examination of disputed facts. Allegations that replies were not considered and that no role was attributed to particular persons required assessment of replies, transaction roles, accounts, invoices and allegedly ineligible input tax credit by the Appellate Authority. Writ intervention was therefore inappropriate. The speaking-order principle did not require a different result because the adjudication was a common, extensive order involving multiple firms and individuals, unlike a decision concerning an individual assessee.

GST adjudication under Section 73 requires observance of natural justice, including effective intimation of the adjudication order, a meaningful opportunity of hearing, consideration of the taxpayer's reply, and a reasoned determination. Uploading an order only in the portal's "Additional Notice and Orders" tab, without separate intimation, may not provide an effective hearing. Where these safeguards are absent, fresh adjudication is required after properly considering the reply and affording a hearing.

Section 93 of the CGST Act permits tax, interest and penalty to be determined against a legal representative after the alleged contravener's death, without requiring prior notice or commenced adjudication during that person's lifetime. Liability depends on proof of the underlying contravention and satisfaction of the statutory conditions for representative liability. Recovery under Section 93(1)(b) is limited to the deceased's estate and its ability to satisfy the charge; the representative is not treated as the wrongdoer. Fair-hearing protections, including the opportunity to contest the contravention, statutory basis and quantum, and appellate review, remain available. Section 93(1)(b) is constitutionally valid under Article 14.

Unavailed statutory appellate remedies and unexplained delay ordinarily preclude extraordinary writ jurisdiction where jurisdictional and factual issues can be addressed on appeal. The GST bar on parallel proceedings under Section 6(2)(b) applies only to identical subject matter; overlapping transactions, periods, or factual background do not suffice where Section 73 tax-liability and input-tax-credit eligibility proceedings differ materially from Section 74 allegations of fraudulent credit availment. Conclusion of separate proceedings against co-noticees does not bar an independently determined liability. Section 75(13) requires a prior penalty on the same person for the same act or omission.

Arrest of a person appearing before GST authorities under a pending court direction raised prima facie concerns over personal liberty and interference with the judicial process. The person attended at the stipulated time with records, while the arrest authorisation did not disclose that the appearance followed the court-directed proceedings. The stated grounds for arrest appeared inconsistent with the person's presence and willingness to cooperate, and the subsequent summons and recorded arrest timing indicated possible procedural irregularity. The High Court directed interim release and sought an explanation from the concerned officers.

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.