Rule 86A blocking of an electronic credit ledger is a provisional measure that requires recorded reasons and cannot continue beyond one year. Filing a GST appeal with the prescribed pre-deposit creates a deemed stay of recovery for the balance demand, preventing appropriation from the electronic cash ledger or blocked credit ledger. That stay does not automatically lift a subsisting Rule 86A blocking order. Unblocking remains subject to the separate Rule 86A mechanism, under which the affected person may seek consideration of an unblocking request.

Regular bail was warranted under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, after weighing the allegations, the petitioner's willingness to provide a voice sample, and parity arising from bail granted to 34 of 37 accused. Although the allegations concerned an organised tax-evasion arrangement and forensic examination of voice samples remained pending, those considerations did not require continued custody on the stated facts. The petitioner therefore met the threshold for regular bail.

Ex parte GST demand orders issued under the Section 73 adjudication framework require an effective opportunity to submit a reply and supporting material where medically supported pregnancy prevented the proprietor from participating. Expiry of the statutory appellate remedy under Section 107 because of limitation may leave the affected person without recourse to challenge the demand. The demand cannot be sustained without permitting the proprietor to place relevant documents and submissions before the adjudicating authority.

Omission of Rule 96(10) without a savings or sunset clause prevents its continued application to pending refund proceedings. The governing principle for omitted subordinate legislation requires express transitional preservation before an omitted rule can sustain pending action. A recommendation that the omission operate prospectively was advisory and did not retain the refund restriction. Refund claims therefore cannot be denied by keeping Rule 96(10) alive after its omission.

Service of a GST show-cause notice under Section 73(1), read with Rule 142(1)(a), must comply with the recognised modes under Section 169. Where records do not establish service through the GST portal, registered post, or e-mail, an ex parte demand and consequential appellate order cannot be sustained because the registered person was denied the opportunity to file objections and be heard. The registered person must receive the notice and be afforded an opportunity of hearing before fresh adjudication.

Input tax credit supported prima facie by available GSTR-2A/2B portal data, GSTR-3B returns and the annual return requires verification before an assessment can be sustained for non-production of return copies. The assessment was set aside for fresh consideration after verifying the asserted recovery of part of the tax demand and providing a reasonable opportunity. Bank attachment was to be lifted consequentially upon verification of the asserted recovery.

Anticipatory-bail jurisdiction under the CGST Act may be invoked before any formal arrest authorisation where circumstances objectively establish a real and reasonable apprehension of arrest. A Section 70 summons, requiring evidence or production of material, neither itself establishes arrest nor makes a pre-arrest application premature; Section 69 separately governs arrest. Pre-arrest protection remains exceptional and requires balancing personal liberty against investigative needs. Alleged organised tax evasion, material obtained in searches, links to an arrested person, non-cooperation, and the need to trace operational, financial and electronic evidence may justify further interrogation and refusal of protection despite an undertaking to cooperate.

Failure to notice an adjudication order uploaded under the GST portal's "Additional Notice and Orders" tab prevented timely use of the statutory appellate remedy. Section 107 of the West Bengal GST Act and CGST Act prescribes the appeal process and limitation period. Where the taxpayer learned of the adjudication order only through a recovery notice, denial of an opportunity to pursue the appeal warranted intervention. The appellate order was quashed, and the appeal was directed to be entertained and decided on merits after an opportunity of hearing.

Challenges to a demand based on limitation, jurisdiction, and the clubbing of different financial years require adjudication through the statutory appellate remedy where they raise disputed questions of fact and law. Writ jurisdiction was not used to determine the merits, and all legal issues remained open for appellate consideration. Protection against coercive action continued until the statutory appeal attained finality.

Mechanical rejection of a request to condone delay in responding to an electronic show-cause notice is invalid where the explanation is not considered and reasons are absent. Adjudication also cannot proceed without the statutorily required personal hearing; fair procedure requires an effective opportunity to submit a reply and be heard. The rejection was set aside, and further adjudication must follow receipt of the reply, grant of a personal hearing, and issuance of a reasoned order.

GST registration cancellation cannot be sustained where the registered person's acknowledged reply to the show-cause notice is not considered. Proceeding on the erroneous basis that no reply was filed demonstrates non-application of mind and renders both the notice and cancellation decision defective. Restoration of registration must be reconsidered by the competent authority after hearing the registered person. The fresh decision must be a speaking, reasoned determination that addresses the reply and the merits of restoration.

Reasoned GST adjudication under section 73(9) requires meaningful consideration of the show-cause notice and the taxpayer's detailed reply, supported by cogent reasons. A cryptic order that fails to address those submissions reflects non-application of mind and is unsustainable without examination of the underlying tax demand. Fresh determination requires consideration of the reply and an adequate personal hearing, without expressing any view on the merits.

Effective notice and a meaningful opportunity to reply to a GST show-cause notice are required under the principles of natural justice. Uploading a notice solely in the portal's Additional Notice and Orders tab, without separate intimation, may prevent the assessee from responding and deny that opportunity. The ex parte adjudication order and consequential notices were set aside, with fresh adjudication required after receipt of the reply and an opportunity of hearing.

GST portal service of a show-cause notice solely through the "Additional Notice and Orders" tab, without separate intimation, deprived the taxpayer of an effective opportunity to respond and breached natural justice. Dismissal of the statutory appeal solely on limitation, without examining the merits, did not cure that procedural defect. The show-cause notice, adjudication order, and appellate order were set aside, requiring fresh notice, a hearing opportunity, and a reasoned adjudication in accordance with law.

Regular bail pending trial for alleged fraudulent availment and utilisation of input tax credit involves consideration of charge-sheet filing, the period of custody, and the applicant's criminal antecedents. Offences involving fraudulent input tax credit under Sections 132(1)(b) and 132(1)(c) of the CGST Act are non-bailable but compoundable. Bail consideration proceeded without expressing any view on the merits of the prosecution allegations.

Writ petitions challenging Orders-in-Original under the CGST Act raise the issue whether the statutory appellate remedy bars recourse to writ jurisdiction. The Supreme Court dismissed the Special Leave Petitions and declined to interfere with the High Court judgments and orders. The reported position leaves those rulings on the availability of writ jurisdiction, despite an alternative statutory remedy, undisturbed.

GST adjudication challenges through writ jurisdiction involve the availability of an alternative statutory appellate remedy, exceptional circumstances permitting judicial intervention, and alleged breach of principles of natural justice. The Supreme Court dismissed the special leave petition challenging the High Court judgment, finding no grounds to interfere and leaving that judgment undisturbed.

Uploading a GST show cause notice solely under the portal's "Additional Notice and Orders" tab, without separate intimation, denied the taxpayer an effective opportunity to reply and breached the principles of natural justice. As the statutory appeal was dismissed solely on limitation without consideration on merits, the show cause notice, adjudication order and appellate order were quashed. Fresh proceedings were directed through a fresh show cause notice, an opportunity of hearing, and a reasoned adjudication.

Input Tax Credit reconciliation through GSTR-2A/2B, GSTR-3B and the annual return may provide prima facie evidence of available credit. A tax demand alleging excess utilisation of Input Tax Credit requires reconsideration where those material records were not duly examined, with an opportunity to establish the credit claimed. Verification of asserted recovery of part of the demand is also required before releasing a bank attachment. The tax demand was set aside for fresh consideration, and the attachment was to be lifted subject to verification of recovery.

Statutory appellate jurisdiction does not permit the First Appellate Authority to condone delay beyond the enactment's prescribed outer limit; equitable relief available in writ jurisdiction cannot enlarge that power. Condonation beyond that limit renders consequential appellate orders legally unsustainable. Where the Department has implemented those orders by restoring cancelled registrations, altering the registrants' legal and commercial position and permitting business continuation, it cannot seek annulment without addressing the consequences of restoration. The absence of effective, workable relief makes the Department's challenge infructuous and not maintainable.