GST appellate pre-deposit is cumulative, calculated against the tax still disputed in the Tribunal appeal, rather than requiring a separate fresh payment after the first appeal. A deposit already held against the same demand may be apportioned between both appellate stages, including amounts paid through FORM GST DRC-03, because pre-deposit forms part of disputed tax rather than an independent levy. Requiring refund and redeposit of the same sum would be anomalous. Deposits connected with separate proceedings cannot be double counted. Where the existing deposit meets the aggregate requirement, it may be appropriated and electronically mapped to the disputed demand, with no further deposit required.

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue and cannot merely replace one plausible view with another. Deduction for contributions to a Core Settlement Guarantee Fund required enquiry into whether payment created an accrued business liability or constituted a corpus for potential future defaults. Examination of genuineness and reasonableness alone was insufficient, given the fund's segregation, accumulated corpus and interest income. The ITAT sustained limited revision because the Assessing Officer had not undertaken requisite verification, directing fresh examination after hearing the assessee while leaving deductibility open.

Section 292BA cures defects only in an assessment or assessment order and does not extend to a TDS-default order under section 201(1)/(1A). Although such an order may be treated as assessment-like in another statutory context, its legislative character as an order cannot be converted into an assessment order for this curative provision. Mandatory Document Identification Number requirements under the CBDT Circular therefore governed validity. Issuance without a DIN was a substantive legal breach rather than a technical defect, rendering the TDS-default order invalid and requiring its quashing along with the appellate order.

GST assessment was unsustainable where actual turnover had not been ascertained, an adjournment request was declined, and the taxpayer could not electronically file rectification because departmental creation of a temporary identification prevented portal access. Although personal-hearing notices were issued, the assessment followed soon after the final reminder, and no other works during the relevant period were asserted. The High Court directed the assessing authority to consider a fresh manual rectification application after hearing the taxpayer and barred coercive recovery until that decision.

Section 129(3) requires a detention penalty order to be passed within seven days of service of the notice issued after detention. Penalty orders concerning vehicles carrying scrap, made after that mandatory period, were barred by limitation and without jurisdiction. Pending proceedings concerning the supplier's registration did not suspend the statutory period because no competent court had stayed the detention proceedings. The availability of a statutory appeal did not preclude writ jurisdiction against jurisdictionally invalid orders. The time-barred orders were quashed, the detained vehicles were directed to be released without payment of alleged duty, and otherwise permissible proceedings against the supplier or recipient remained unaffected.

Input tax credit for invoices from the covered period is regularised under section 16(5), retrospectively effective from 1 July 2017, where the relevant returns were filed by 30 November 2021. Credit relating to July 2018 through March 2020, including financial year 2019-20 invoices, cannot be denied solely because returns were filed after the original deadline. Orders denying the credit were quashed and remitted for re-adjudication under section 16(5) after hearing, including reconsideration of Electronic Credit Ledger blocking. Further coercive action was restrained pending re-adjudication.

Head office services supplied to separately registered branches or depots constitute supplies between distinct persons even without consideration. Where no invoices are issued for those services, CBIC clarifications and Rule 28 require their value to be treated as nil; common expenditure cannot instead be proportionately allocated to create taxable value. Extended limitation under Section 74 requires facts establishing fraud, wilful misstatement or suppression with intent to evade tax, rather than mechanical allegations. Recorded expenditure and recipient eligibility for input tax credit may demonstrate revenue neutrality and, without more, do not establish those conditions.

Anti-profiteering liability following a GST rate reduction may apply despite a business demerger and a post-reduction registration where transactional evidence establishes the supplier's nexus to affected supplies. Investigation may extend beyond the original complaint and continue after its withdrawal because the regime serves consumer welfare. For customised lump-sum supplies, invoice-wise base-price comparison is permissible if rational, evidence-based and reconciled; the computation was accepted. Wilful retention need not be proved, although non-passing of the benefit must be established. The supplier was found to have breached the pass-through obligation and was subject to restitution and deposit directions; no penalty applied because the penal provision operated only prospectively.

The scope of "any person" in GST penalty provisions for fraudulent invoice and input tax credit transactions, their prospective operation, and the availability of writ jurisdiction despite a statutory appeal were identified as questions apparently covered by earlier High Court rulings. The matter was listed for the CGST Department to examine those rulings and state whether it accepts or challenges them.

The interaction between the mandatory pre-deposit for a GST appeal and the IBC liquidation framework raises whether a corporate debtor in liquidation may be excused from making that deposit. The issue is whether using liquidation-estate funds for the pre-deposit conflicts with the statutory distribution waterfall governing creditors' claims. The High Court sought assistance on whether liquidation priorities affect the mandatory pre-deposit requirement for filing a GST appeal.

Omission of Rule 96(10) without a saving or sunset clause prevented its continued application to pending export refund proceedings. Proceedings initiated under an omitted rule can continue only where an express saving provision or statutory legal fiction preserves them. Applying this principle, the High Court treated the Supreme Court precedent as applicable and quashed the adjudication notices and orders founded on Rule 96(10), allowing the writ petitions.

Intermediary-service classification turns on whether a supplier arranges or facilitates an identifiable main supply between other parties; a subcontractor supplying contracted services on its own account is excluded. Marketing, promotion, business-support and IT-enabled services provided independently on a principal-to-principal basis, without authority to bind the foreign principal or participate in third-party arrangements, qualify as export of services rather than intermediary services, supporting refund of unutilised input tax credit. Section 107(11) bars the first appellate authority from effectively remanding a refund matter after annulling the original order, while preserving the Tribunal's separate remand power.

Departmental appeals disputing only a penalty are governed by the disputed penalty for monetary-limit purposes. Where the amount is below the prescribed limit, the Revenue must specifically identify and establish a recognised exception. Reliance on a residual exception requires material that the Commissioner considered the particular matter and recorded the requisite opinion; bare approval or authorisation to appeal is insufficient. Maintainability must be determined before merits, resulting in threshold dismissal where policy compliance is not shown.

Departmental GST appeals involving disputed tax below the prescribed monetary limit require the Revenue to specifically plead and establish a recognised exception to the litigation-control policy. The threshold is calculated on aggregate disputed tax, excluding interest and penalty. Mere Commissioner authorisation does not establish the residual exception; the record must show a case-specific exercise of that power and its supporting basis. Where no applicable exception is proved, the appeal is not maintainable, may be dismissed at the threshold, and the underlying tax merits remain unexamined.

Road restoration charges paid by a business entity for PWD-authorised road cutting and request-driven restoration constitute consideration for a taxable service because payment is directly linked to identified work and bilateral reciprocity. Such work is not a non-supply or exempt public-function service merely because routine road maintenance is governmental; it is performed for the entity's commercial activity. Government services supplied to registered business entities attract reverse charge where forward-charge payment is unproven, so refund of GST paid under reverse charge is unavailable. Electronic GST proceedings authenticated through the portal remain valid without a physical DIN where notice particulars enable a meaningful response and no prejudice arises.

Road restoration charges paid for request-driven repair after excavation for commercial pipeline laying constitute consideration for a taxable service rather than compensatory damages. Routine public-road maintenance differs from targeted restoration supplied to a business entity; consequently, non-supply treatment and the governmental-services exemption do not apply, and tax under reverse charge remains payable. Prior refund sanctions in other jurisdictions and unsubstantiated double-taxation claims do not displace that mechanism. Electronic GST proceedings remain valid where portal records authenticate the application, notice, replies and orders, and the notice gave adequate factual and legal particulars without prejudice despite no physical DIN. The refund rejection and reverse-charge payment were sustained.

Road restoration charges paid for restoring public roads excavated for a commercial gas pipeline constitute consideration for a taxable service because the payment directly corresponds to requested restoration work. Targeted, fee-based restoration for a business entity differs from routine public road maintenance and does not qualify as non-supply or for public-function exemption treatment. GST is payable by the recipient under reverse charge, resulting in rejection of the refund claim. Electronically issued GST notices and orders authenticated through the official portal remain valid without a physical DIN where they clearly state the factual and legal basis and cause no prejudice.

Road restoration charges paid to the PWD for restoring public roads cut for a business pipeline project constitute consideration for a taxable service, rather than compensatory payment or liquidated damages, because they arise from a requested and reciprocal restoration arrangement. Targeted restoration for a business entity is not treated as a general governmental or public-utility function eligible for non-supply treatment or exemption; the recipient remains liable under the reverse-charge mechanism and cannot obtain a related refund. Electronic GST proceedings remain valid without a physical Document Identification Number where portal authentication establishes the notice's source and integrity and the recipient suffers no prejudice. The refund claim was rejected.

Section 260A(7) imports CPC appellate procedure into High Court income-tax appeals to the extent compatible with Section 260A. Because such appeals resemble second appeals and Order XLII applies Order XLI to them, Order XLI Rule 22 can permit cross-objections despite no express provision in Section 260A. A cross-objection remains limited to the adverse part of the Tribunal's order and must raise a substantial question of law. It cannot expand jurisdiction to factual issues or matters outside that order. Maintainability therefore depends on satisfying the statutory substantial-question-of-law requirement.

Section 132B provides statutory simple interest on cash requisitioned under section 132A from the day after expiry of 120 days following requisition until completion of assessment. Where no tax liability is determined, the requisitioned cash must be released, with interest at one-half per cent for every month or part thereof during that pre-assessment period. Following assessment and discharge of any liability, seized cash must be released forthwith. Continued retention contrary to that requirement warrants restitutionary compensation for loss of use of money, irrespective of whether the tax department earned interest on the retained cash. Interest at six per cent per annum applies until actual release.