Best-judgment assessment for non-filing of a GST return could not be sustained where the taxpayer filed the return shortly after the condonable period and paid tax, interest and late fee. The belated return required scrutiny under the GST return-scrutiny procedure, and the assessment was quashed. Time from the order until completion of scrutiny was excluded from limitation for tax-demand proceedings.

GST registration cancelled for non-filing of returns was subject to a revocation application that the online portal would not accept after the prescribed period. Although the statutory appeal against cancellation had been rejected as time-barred and no merits determination on revocation occurred, the petitioner received liberty to file the revocation application online within two weeks, or physically where technical barriers persisted. The competent authority must entertain the application and decide it according to law within three weeks thereafter.

GST registration cancellation required reconsideration where the registered person asserted that its supplies were exempt and that returns had been regularly filed. Those assertions raised factual matters requiring examination after a reply to the show-cause notice and an opportunity of hearing. The cancellation order was quashed, and the matter was remitted for a fresh merits-based determination.

Rule 96(3) of the CGST Rules assigns processing of IGST refunds on exported goods to the Customs system or the proper officer of Customs once information on a valid GSTR-3B return is received. Where an export is regularised through a manual shipping bill due to an ICEGATE technical failure, the GST Department lacks statutory jurisdiction to sanction the export refund. Customs cannot reject the claim as a GST Department matter and must process and sanction any admissible refund, with applicable interest, in accordance with law.

GST assessment orders founded on notices and hearing intimations uploaded only under the portal's additional-notices tab may breach natural justice where registered-post service is required or advised alongside electronic communication. SMS and email reminders do not, by themselves, cure ineffective statutory service. Failure to ensure effective service deprives the assessee of a meaningful opportunity to submit objections and supporting records before assessment. An assessment completed in those circumstances is vitiated for breach of the principles of natural justice.

GST liabilities arising on works contracts during the transition from VAT to GST, including return filing, interest, penalties and limitation, remain governed exclusively by the applicable tax statutes. Contractual terms between contractors and employers cannot alter those obligations or support directions requiring tax authorities to permit revised returns, waive statutory consequences or depart from prescribed limits. Incremental GST burden arising from the transition is a contractual matter: contractors may seek adjustment or reimbursement from the relevant employer by computing pre-GST and post-GST work and submitting representations under the retained guidelines.

Duplicate GST assessments arising from the same mismatch between GST returns and the annual return for one assessment period cannot coexist. The erroneous duplicate assessment was quashed. The remaining assessment was set aside for fresh consideration, requiring verification of recovery of the SGST demand and a reasonable opportunity for the assessee to be heard, in accordance with the principles of natural justice.

Payment of the admitted differential 6% GST for civil construction works was due where the concerned authority accepted its liability and confirmed that payment would be made. The petitioner was entitled to receive the differential GST amount within three weeks, reflecting the admitted obligation to pay the tax component arising from the executed works.

Input tax credit limitation under Section 16(4) of the CGST Act could not survive because the issue was covered by an earlier common decision that had quashed the corresponding departmental determination. The Section 16(4) determination was therefore quashed. For the remaining assessment issues, uploading the show-cause notice and subsequent communications only on the common portal did not provide effective service where no response was received and statutory alternative modes were available. The remaining determinations were set aside for fresh adjudication after allowing objections and a personal hearing.

Delay in statutory GST appeals arising from a proprietor's need to care for a critically ill spouse and the spouse's subsequent death warranted condonation despite expiry of the statutory condonable period. The appellate time-bar orders were set aside, allowing the statutory appeals to be freshly adjudicated on merits. The underlying tax demands remained undecided, while costs were contemplated as compensation for the delay.

Challenges to GST notices and a summary order ordinarily require use of the prescribed statutory process where the notices are not ex facie without jurisdiction. The taxpayer must respond to the show-cause notice, place all defences before the competent authority, and use the appellate remedy if aggrieved. Extraordinary writ jurisdiction should not bypass alternative remedies in revenue matters unless exceptional circumstances justify intervention; merits-based contentions remain available within the statutory process.

Introduction of additional departmental documents or inputs at the appellate stage requires consideration of an assessee's objection to their admission. Where the assessee objects, the appellate authority must provide an opportunity of hearing before deciding the appeal. Deciding the appeal shortly after receiving the objection, without hearing the assessee on the newly introduced material, violates principles of natural justice and vitiates the appellate order.

GST writ challenges to orders alleging input tax credit availment on fake or bogus invoices should ordinarily be pursued through the statutory appellate remedy where disputed questions of fact require adjudication. The appellate authority may consider an application to condone delay in filing the statutory appeal liberally, enabling consideration of the appeal on its merits.

Full disclosure in discretionary bail proceedings requires parties to reveal parallel remedies and all prior bail or release orders. Pursuing concurrent remedies while withholding rejected bail or refused ad-interim relief constitutes forum shopping, suppression of material facts and abuse of process, requiring the bail application to be reconsidered on a fully informed merits assessment; interim bail may continue on existing terms pending further orders. A direction to list a matter "two weeks hence" ordinarily excludes a court vacation when the period expires during vacation, unless a specific vacation date or Vacation Bench listing is directed, subject to applicable High Court rules.

Forum shopping and suppression of material facts undermine the good faith required for discretionary bail jurisdiction. Pursuing parallel bail or release remedies while withholding rejection orders and refusal of interim release constitutes abuse of process. Urgent vacation listing of a pending bail petition, without a returnable date, Vacation Bench direction, or adequate notice to the opposing party, improperly seeks to steal a march and mislead the Court. The bail petition was revived for fresh consideration on merits, while the existing bail continued as interim bail pending further orders.

Serious illness and death of a proprietor's spouse, disrupting the firm's affairs, justified condonation of delay in statutory GST appeals. The High Court set aside appellate orders rejecting the appeals as time-barred and remitted them for determination on merits, based on the parties' concession and subject to payment of costs. Failure to pay costs forfeited the benefit of restoration, while all merits remained open before the appellate authority.

Input tax credit denied as time-barred under section 16(4) of the CGST Act was quashed because the issue was covered by a common order that had quashed the departmental determination. On the remaining adjudication issues, portal uploads of notices and reminders, without any response, did not provide an effective opportunity of hearing where statutory alternative service modes were available. The balance of the adjudication was set aside and remanded for fresh consideration, conditional on agreed pre-deposit, reply filing and effective notice of personal hearing.

Effective service of GST notices requires more than uploading statutory notices and hearing intimations under an additional-notices portal tab when the taxpayer receives no physical service through RPAD. SMS and email reminders do not cure the resulting lack of a meaningful opportunity to file explanations and supporting records, which breaches principles of natural justice. GST adjudication and the consequential Form GST DRC-07 may therefore be set aside for fresh consideration, subject to a 10% deposit of disputed tax. The taxpayer must be allowed to submit objections and documents, followed by a clear 14-day personal-hearing notice and a merits-based order.

Rule 96(3) assigns processing of IGST refunds on exported goods, including goods covered by manual shipping bills, to the Customs system or the proper Customs officer after receipt of information on a valid Form GSTR-3B return. Where the GST Department disclaims jurisdiction to sanction the refund, Customs cannot reject the claim by asserting that it falls within the GST Department's jurisdiction. Customs must process the claim and sanction any admissible IGST refund with applicable interest in accordance with law.

Excess output tax paid beyond monthly liability may be set off against ineligible input tax credit where no overall tax short payment arises, avoiding an unnecessary payment-and-refund cycle. Refund of such excess output tax falls within the stated statutory exception and is not subject to unjust-enrichment scrutiny. Sales-return claims supported by valid credit and debit notes cannot be rejected solely for non-uploading on the GST portal where no mandatory upload requirement applied. Reasoned appellate orders must address material submissions, and demands cannot rest on grounds beyond the show cause notice. Interest for delayed return filing requires a notice identifying the relevant defaults, tax base and computation.