GST paid on works performed after the GST regime began is reimbursable where the governing bill of quantities required bids to be quoted exclusive of taxes. Although the contract was executed under the VAT regime and contained general clauses requiring tax inclusion in bid rates, those clauses do not override the specific tax-exclusive BOQ basis. Section 15 of the CGST Act and applicable Finance Department circulars treat GST as payable in addition to contract value where tender rates exclude GST. Departmental recognition of reimbursement eligibility supports payment notwithstanding pending interdepartmental consideration.

GST registration may be cancelled only for prescribed contraventions, including failure to conduct business from a declared place. Form GST REG-01 and Rule 8 require documents supporting the principal place of business, but do not require a rent agreement for an additional place. Where the principal place is duly supported, non-submission of an additional-place rent agreement neither establishes a prescribed contravention nor proves non-conduct of business from a declared location. Cancellation on that ground is invalid, requiring restoration from the suspension date.

Consignees facing detained-goods proceedings arising from alleged undervaluation, underweight declaration, or tax evasion must receive a fresh show-cause notice where an earlier notice was issued only to the transporter. The notice must allow the consignee to submit a reply and relevant supporting records addressing the allegations. After considering the consignee's response and documents, the competent authority must determine the proceedings under the applicable GST enactments and rules. This ensures the consignee has an opportunity to be heard before the detained-goods matter is decided.

Effective notice is required to satisfy principles of natural justice in tax adjudication. Uploading a show-cause notice only under a portal's "Additional Notice and Orders" tab, without separate intimation, may prevent the affected person from becoming aware of the proceedings and submitting a reply. Adjudication undertaken without effective notice and a meaningful opportunity to respond is vitiated by breach of natural justice. The affected person must be allowed to file a response and receive a personal hearing before fresh adjudication.

GST assessment and recovery proceedings cannot rest on notices uploaded solely in the portal's Additional Notices and Orders section when the designated View Notices and Orders window is not used. Such placement fails to give the taxpayer effective notice and a meaningful opportunity to respond, contrary to principles of natural justice. The assessment order and consequential recovery proceedings were quashed, and fresh adjudication must permit a reply. Limitation of the show-cause notice remains for the adjudicating authority to determine.

Consignees of detained goods must receive a show-cause notice and a meaningful opportunity to respond before alleged undervaluation, underweight declaration or tax evasion is determined. Where the consignee can produce documents addressing the alleged discrepancies, fresh proceedings should permit a written reply and supporting material before a decision under applicable GST enactments and rules. The allegations remain open for determination through renewed notice and adjudication, rather than being conclusively decided without hearing the consignee.

GST registration cannot be cancelled solely because a rent agreement for an additional place of business was not produced where the prescribed registration application requires proof only of the principal place of business. Cancellation for contravention applies when statutory conditions, including non-conduct of business from the declared place, are established. Reliance exclusively on non-submission of documentation for an additional place of business conflicts with the statutory scheme and prescribed form. The cancellation and show-cause notice were quashed, and registration was restored from the suspension date.

Tax-exclusive bill of quantities rates prevail over general tender conditions stating that taxes are included in the bid price. GST, as an indirect tax, ultimately falls on the employer where the accepted BOQ expressly excludes taxes; a contractor cannot be denied reimbursement on the basis of inconsistent general clauses. Departmental communications and meeting decisions supported the reimbursement claim. Government circulars also permit revised administrative sanction where project-cost escalation results solely from revised GST rates. GST paid for hospital construction under the tax-exclusive BOQ was therefore required to be reimbursed within three months.

Section 16(5) of the CGST Act retrospectively permits input tax credit relating to FY 2017-18 to be claimed through a return filed up to 30 November 2021. A mismatch between GSTR-2A and GSTR-3B is a reconciliation issue and, by itself, does not require reversal where verifiable accounts, invoices and payment evidence establish genuine credit. Banking services received in furtherance of business are not within the blocked-credit categories under section 17(5) of the CGST/UPGST Act and may qualify for input tax credit.

Excess IGST paid on zero-rated cashew-kernel exports because of a clerical GSTR-3B classification error remains refundable where export turnover and tax were correctly declared in GSTR-1. Incorrect reporting in the domestic-supply column may block automated Customs processing, prompting a second correctly reported payment and refund of only that later payment. Reconciliation establishing the original payment as excess supports refund, as retaining tax paid twice lacks authority of law. Procedural difficulties in GST refund processing cannot justify withholding the unrecovered original IGST payment.

Input tax credit on joinery, carpentry and painting services used for shelves and display fixtures in rented retail shops is available where the services are used in furtherance of business and the GST component is not capitalised. The restriction for construction of immovable property applies only to the extent expenditure is capitalised. Although furnishing expenditure was capitalised as furniture and fixtures, the separately accounted GST was neither included in fixed-asset cost nor subjected to depreciation. The supplier-service classification, not disputed in the show-cause notice, could not be raised later to deny credit. Denial of the disputed credit was unsustainable and was set aside with consequential relief.

Input tax credit on purchases from an allegedly bogus supplier was allowed where the recipient produced purchase, transportation and goods-receipt records. Entitlement required examination of statutory conditions and transaction-specific evidence, rather than reliance solely on allegations against the supplier. Restoration of the supplier's registration also undermined the claim that it was bogus or non-existent. Documents submitted as additional evidence did not prejudice the adjudicating authority because they were forwarded for examination and its report was considered. The procedural objection was rejected, and the Revenue's appeal against allowance of input tax credit was dismissed.

Unaccounted goods found during a survey are deemed supplies under section 35(6), requiring determination of tax under sections 73 or 74. The proper officer may therefore pursue tax determination for excess or unaccounted stock at business premises, but may not directly invoke confiscation under section 130 or impose a penalty in lieu of confiscation. Confiscation proceedings under section 130 read with Rule 120, whether substituted for or added to tax-determination proceedings, are unsustainable. The confiscation-related fine and penalty were set aside, and the Revenue's appeal was dismissed.

Actual receipt of goods is an independent condition for input tax credit, requiring the claimant to establish eligibility through credible evidence. Supplier registration, tax invoices, portal reflection and banking payments do not conclusively prove receipt, while a supplier's later non-availability at its declared premises does not alone disprove an earlier supply. Input tax credit claims require cumulative evaluation of invoices, e-way bills, transport records and other corroborative material. Adequate adjudication requires verification of that evidence, reasoned findings, and an effective opportunity of hearing; failure to undertake this assessment warrants fresh adjudication without determining the claim on merits.

GST amnesty appeals should not be rejected solely because the prescribed cash component of a pre-deposit was debited through the electronic credit ledger rather than the electronic cash ledger, where portal glitches prevented the required cash-ledger debit. Such misallocation is a curable pre-deposit defect when the amount has otherwise been secured. The appellate authority must allow the taxpayer to rectify the cash-ledger component or rebalance the ledger debits, including re-credit of excess electronic credit ledger debit. Following rectification within the stipulated period, the first appeal must be admitted and decided on merits after hearing both sides.

Input tax credit on purchases from a supplier later reported non-existent must be assessed on the totality of evidence. Contemporaneous invoices, transport records, GST records and banking-channel payments require independent verification and cogent rebuttal; a supplier's later non-existence alone does not establish fictitious purchases or non-receipt of goods. Recovery of allegedly wrongful credit under Section 74 requires positive evidence of fraud, wilful misstatement or suppression with intent to evade tax. Non-appearance before authorities or delayed invoice payment followed by proportionate credit reversal with interest does not, by itself, establish those statutory ingredients or justify equal penalty.

GST transit penalties require evidence of an existing statutory contravention rather than presumptions based on a vehicle's route or anticipated delivery. A place-of-supply entry consistent with the invoice and e-way bill undermines an allegation that goods were diverted to an undeclared local supply. The GST framework does not require a selling dealer to disclose or follow a particular transportation route; route deviation alone, where accompanying documents are genuine, does not establish contravention. An uncorroborated driver statement referring to an unverified third party, coupled with interception before unloading, is insufficient to prove unauthorised delivery or tax evasion.

Refund of accumulated Compensation Cess input tax credit on coal used to manufacture leather products for domestic supplies requires independent satisfaction of statutory refund conditions for an inverted tax structure. Eligibility to avail such credit, and the absence of a blocked-credit restriction, do not by themselves establish entitlement to a cash refund. Inability to utilise the credit against other liabilities cannot independently create a refund right, and the refund formula or procedure cannot create substantive entitlement where statutory conditions are unmet. Clarifications concerning zero-rated supplies did not establish eligibility for the domestic supplies. The appellate order allowing the claims was set aside and the rejection orders were restored.

Road restoration charges paid to the PWD for cutting and restoring roads for a commercial gas-pipeline project constitute consideration for a taxable service, not compensatory damages or a non-supply arising from a sovereign function. The planned, request-based arrangement created bilateral reciprocity, and GST was payable by the business recipient under reverse charge because no evidence showed tax payment by the PWD under forward charge; the refund rejection stood. Electronic GST notices and adjudication through an authenticated portal remain valid despite no physical DIN where the notice states the factual and legal basis and the recipient suffers no surprise or prejudice; the procedural objections failed.

Reassessment proceedings concerning unsecured loans required an opportunity for the taxpayer to furnish confirmations from lenders and any further particulars needed to determine whether reassessment was warranted. Without that opportunity, the reassessment-initiation order, prior approval and consequential notice were quashed. Fresh consideration was directed after the taxpayer could provide the requisite clarifications and lender confirmations.