Section 102 of the CGST Act and KGST Act permits rectification of an error apparent on the face of the record. An inadvertent typographical discrepancy may be corrected without a personal hearing where the correction does not alter the advance ruling, increase tax liability, or reduce admissible input tax credit. The hearing proviso is inapplicable in those circumstances. Rectification remains confined to the identified typographical error, leaving all other findings, discussion, and the ruling unchanged.

Section 107 of the CGST Act sets a three-month appeal period and permits the First Appellate Authority to condone delay only for one additional month on sufficient cause. As a statutory authority, it has no inherent power to extend that outer limit; equitable considerations or High Court directions confined to particular writ proceedings do not enlarge its jurisdiction. Where the Department has implemented an order restoring GST registration, enabled business continuation and return filing, estoppel and orderly administration prevent a later challenge seeking to reverse that position. Registration restoration consequently remains effective despite invalid condonation beyond the statutory limit.

Confiscation under Section 130(1)(ii) requires facts establishing deliberate tax evasion through unaccounted goods, not a short bona fide delay in recording genuine stock transactions. A pre-survey invoice, subsequent verification in regular books and statutory returns, and an accountant's temporary absence support the conclusion that delayed posting differs from non-accountal intended for clandestine removal. Physical-stock allegations based on visual approximation rather than standard weighment are also unreliable. Where assessment proceedings substantially accept the stock explanation and identify only minor discrepancies, treating the same transactions as both reconcilable and confiscable is legally inconsistent.

GST demands alleging wrongful input tax credit recredit must disclose the factual and legal basis of the charge in the show-cause notice, and adjudication must address the taxpayer's explanation through reasoned findings. Tax paid under the wrong IGST or intra-State tax head must follow the prescribed refund mechanism; unilateral recredit through GSTR-3B does not automatically create valid input tax credit. Payments actually made under the correct Central and State tax heads require recognition and reconciliation with the original payment and any recredit, preventing both double taxation and duplicate credit or refund. Interest requires findings of wrongful availment and utilisation, while penalty cannot stand independently where the underlying wrongful-credit charge fails.

GST exemption for municipal functions under Article 243W applies to services rendered by local authorities, not to an auction lessee commercially collecting weekly-market fees under tender conditions. Such collection arises from a contractual commercial right, and the contractor remains liable for applicable Central and State taxes. COVID-related lease waiver or refund of lease amounts and security deposit is not unconditional where GST and income-tax liabilities remain unpaid. Tender terms may permit adjustment of losses or expenditure against amounts payable to the licensee, requiring statutory dues to be cleared before lease-related relief or refunds are claimed.

Ex parte GST demand and rectification orders concerning alleged non-payment of compensation cess on outward cigarette supplies were set aside to permit a response to the show-cause notice. Compensation cess liability required determination after the taxpayer was afforded an opportunity to reply. Submission of the reply was conditional on payment of 25% of the balance tax amount, enabling the compensation cess issue to be considered after the taxpayer's response.

Ex parte confirmation of a GST demand without a reply from the taxable person is to be reconsidered through fresh adjudication on merits. A further opportunity to submit a reply and supporting documents is conditional on deposit of 25% of the disputed tax for each liability through the Electronic Cash Ledger. Amounts already paid or recovered beyond that deposit must be adjusted against the liability determined afresh. On compliance, notice must be issued and a fresh order passed expeditiously. Bank attachment must be vacated, subject to the stipulated deposit and absence of other tax arrears; non-compliance permits recovery in accordance with law.

Interest on wrongly availed IGST input tax credit must be determined by considering the aggregate electronic credit ledger balance available under the IGST, CGST and SGST heads. Under the combined-balance test, interest does not arise if the aggregate balance remains at or above the wrongly availed IGST credit from availment until reversal. If that aggregate balance falls below the wrongly availed credit, interest applies only to the extent of the shortfall. The interest liability requires fresh determination using this test after affording the assessee a personal hearing.

GST seizure and detention proceedings under Section 129 require consideration of a post-facto GST registration amendment and whether the e-way bill and tax invoice establish tax compliance rather than an attempt to evade tax. Reconsideration on merits is required in light of prior rulings addressing similar circumstances, with the affected taxpayer to receive an opportunity of hearing before a fresh determination. The central legal point is the evidentiary relevance of registration status and accompanying transport and invoice documents in detention proceedings.

Effective service of GST notices requires more than portal upload where a cancelled registration and repeated non-responses indicate that notice may not reach the registered person. Although portal upload is a valid service method, the proper officer should use other service modes available under section 169(1) to ensure an actual opportunity to respond. Section 75(4) requires an effective personal hearing. An ex parte assessment made without reasonable steps for effective notice and without such hearing breaches principles of natural justice and is unsustainable.

Delay of 89 days in filing a statutory appeal may be condoned where serious illness of the taxpayer's accountant genuinely prevented portal access and communication of the assessment order. Restoration of the appellate remedy is conditional on paying the balance needed to reach 25% of disputed tax, after crediting recovered amounts. On compliance, the appeal must be taken on record, heard personally, and decided on merits.

Section 16(5), retrospectively effective from 1 July 2017, allows registered persons to claim input tax credit for financial years 2017-18 through 2020-21 in returns filed up to 30 November 2021, despite the limitation in Section 16(4). Input tax credit falling within that extended statutory period cannot be reversed solely on limitation grounds. Recovery measures based on such reversals must be released, with amounts already recovered adjusted or refunded as applicable.

Input tax credit disallowed as time-barred under Section 16(4) is unsustainable where the limitation issue is covered by an earlier common order quashing a departmental order on the same point. For remaining GST assessment issues, portal upload is a valid mode of service, but repeated non-response requires use of other prescribed service methods, preferably registered post, to ensure effective notice. An ex parte assessment without that effort or a personal hearing breaches principles of natural justice. The limitation demand cannot stand, while the remaining issues require fresh determination after effective notice, reply and personal hearing.

Reasonable opportunity of personal hearing is required in tax adjudication. Where a notified hearing does not conclude proceedings, an ex parte determination based on a written reply cannot follow months later without a further hearing notice or date; it breaches natural justice and requires fresh adjudication. A belated jurisdictional challenge to a show-cause notice, raised after participation in proceedings and where a statutory remedy is available, need not be entertained in writ jurisdiction, leaving the objection for statutory adjudication.

Section 75(7) of the Uttar Pradesh GST Act and the CGST Act prohibits an adjudicating authority from confirming tax, interest or penalty exceeding the amount proposed in the show-cause notice. Where the adjudication order confirms a higher tax demand or penalty than the notice specified, it exceeds the authority's statutory jurisdiction. The confirmed liability must remain within the scope and amounts put to the taxpayer in the notice.

Effective service of GST notices requires more than portal upload where repeated non-response indicates that the taxpayer may not have received notice. In those circumstances, the officer must consider other permitted service modes, preferably RPAD, and provide a clear personal-hearing notice; otherwise, an ex parte assessment becomes an empty formality. The assessment on issues other than input tax credit limitation was set aside for fresh consideration after reply and hearing, subject to stipulated partial tax payment. The input tax credit component disallowed as time-barred under section 16(4) was separately quashed in accordance with an earlier common order.

Related-party financial creditors are excluded from representation, participation and voting in the Committee of Creditors where their contractual rights demonstrate participation in the corporate debtor's policy-making and business affairs. Such participation does not require the proactive control required for Section 29A; rights over board nomination, deadlock decisions, budgets, management, revenues and project execution can suffice. An uninvoked corporate guarantee may still give rise to financial debt for claim admission after CIRP begins. Individual homebuyers may challenge related-party inclusion despite the authorised representative's role. A post-CIRP assignment intended to evade related-party exclusion does not make the assignee eligible for CoC participation.

Section 16(5) of the CGST Act operates retrospectively notwithstanding section 16(4), permitting input tax credit for specified financial years where the section 39 return was filed by 30 November 2021. Input tax credit cannot be reversed solely for breach of the ordinary limitation provision when this retrospective exception applies. Recovery founded only on that limitation ground is correspondingly unsustainable, while proceedings concerning other substantive input tax credit eligibility conditions remain unaffected. Consequential relief includes de-freezing bank accounts and refunding or adjusting amounts recovered solely on the limitation ground.

Effective service of GST notices requires more than portal upload where repeated portal communications receive no response. After cancellation of registration, officers must consider other prescribed modes to secure effective notice; the absence of physical or registered-email communication, coupled with denial of a personal hearing, breaches principles of natural justice. The assessment was set aside and remitted for fresh consideration on merits, subject to the stipulated deposit and filing of a reply, with clear notice of personal hearing required.

Interest on wrongly availed IGST credit requires determination by considering the aggregate balance in the electronic credit ledger across IGST, CGST and SGST heads, as required by the clarificatory circular. The interest liability itself remained undecided on merits. The impugned orders were set aside and the matters remitted for fresh consideration after a personal hearing. The fresh enquiry is confined to applying the circular when determining interest on wrongly availed IGST credit.