Proper officers must communicate show-cause notices and adjudication orders through physical mode in unregistered assessment proceedings under Section 63 of the OGST Act, 2017. Effective service must be verified to enable the noticee to participate, file objections or explanations, and produce relevant material before adjudication. Physical service is required to avoid ex parte assessment without a meaningful opportunity of hearing and disputes concerning non-service.

Transportation services for goods sent outside India have the foreign destination as their place of supply where both supplier and recipient are located in India. The supply is treated as an inter-State supply and is chargeable to IGST. The Indian recipient may claim input tax credit of the IGST charged, subject to applicable eligibility conditions, apportionment provisions and blocked-credit restrictions. The supplier must report the place of supply in FORM GSTR-1 using State code "96-Foreign Country".

Pre-CIRP GST dues of a corporate debtor are operational debt and cannot be pursued through coercive recovery; the proper officer may file the claim in insolvency proceedings. Where finalised insolvency proceedings reduce confirmed statutory dues, those proceedings are treated as other proceedings for recovery purposes. The jurisdictional Commissioner must issue FORM GST DRC-25 to communicate the reduced demand where FORM GST DRC-07 or DRC-07A was issued. Recovery may continue only for the reduced dues.

Capital-gains tax treatment is queried where land bequeathed to son X was sold after alleged manipulation of title documents. Although title was confirmed in X's favour, the earlier sale to buyer 1 was not declared null and void. Buyer 1 proposes a resale to buyer 2, with X joining as a consenting party and receiving part of the consideration. The issues concern long-term capital gains, partial consideration, application of section 78, and recording payment to X in the sale deed.

GST registration applications must be filed online using the form applicable to the applicant category, with complete and legible identity, business constitution, signatory, premises and other required particulars. Principal and additional business premises require accurate addresses and prescribed ownership, lease, consent, co-working or Special Economic Zone evidence. Aadhaar-authenticated applications generally follow the shorter processing timeline, while non-authenticated or risk-selected cases can require biometric checks or physical verification. Deficiencies must be addressed through the prescribed notice-and-reply process; unnecessary documents and subjective objections are excluded. Simplified registration provides automated processing for eligible small taxpayers subject to input tax credit restrictions.

Electronic GST refund processing requires applicants to submit FORM GST RFD-01, prescribed statements, undertakings and supporting invoices on the common portal, without physical submission. ARN generation marks filing, electronically transfers the claim, and starts the 15-day period for acknowledgement or deficiency memo. A deficient claim is not processed; ledger debits are automatically re-credited and a corrected claim must be filed afresh, subject to the statutory limitation. Claims require all due returns, subject to specified alternative returns for composition taxpayers, non-resident taxable persons and input service distributors.

GST recovery through WAMIS permits deduction of outstanding CGST, OGST and IGST liabilities from payments due to works contractors after a demand has crystallised, been served, become payable, and is not stayed. Circle Nodal Officers upload valid attachment orders and component-wise recovery details; active orders require departments to deduct available bill amounts after current statutory dues, using FIFO priority for multiple orders and prescribed tax-to-other-dues sequencing. Recovered sums are recorded in the recovery ledger, held under designated deduction heads, deposited through WAMIS and IFMS, and set off against the relevant demand. WAMIS supports partial recovery, monitoring, reconciliation, and audit trails.

Management fees supported by documented business purpose and commercial expediency are allowable business expenditure, and transfer-pricing observations do not determine allowability. Sales commission for marketing and support services paid to a United States entity is not Fees for Included Services under Article 12(4)(b) of the India-US tax treaty where it is not chargeable to tax in India; no withholding obligation or corresponding disallowance follows. Deduction for SEZ-unit profits requires verification of the accountant's Form 56F report and detailed workings, with expenses apportioned between STPI and SEZ units on an actual-expenditure basis.

Rule 96(10) restricted IGST refunds on exports where exporters had availed specified concessional or exemption benefits on procurement, to prevent double benefit. Its omission is applied retrospectively from 23 October 2017 because no saving or sunset clause preserved pending proceedings. The General Clauses Act does not preserve proceedings following omission of a rule without an express continuation mechanism. Pending matters involving rule 96(10) are to be handled on that basis, with the same approach applying mutatis mutandis to omitted rules 89(4A) and 89(4B).

GST export-of-services payment conditions are treated as fulfilled where consideration is received in convertible foreign exchange or through repatriable INR accounts, including SNRR, INR Nostro and NRE accounts, subject to applicable foreign-exchange requirements, foreign trade policy restrictions, RBI directions and other required permissions. Export receivables set off against import payables may satisfy the condition when undertaken in accordance with RBI directions. Net retention of an Indian reinsurance broker's commission may also satisfy the condition where foreign-exchange law extinguishes the obligation to realise and repatriate the relevant proceeds.

Section 149's first proviso preserves the former reassessment limitation for assessment years beginning on or before 1 April 2021. Where the erstwhile six-year period had expired for Assessment Year 2014-15 on 31 March 2021, a notice issued later under the former Section 148, even if deemed a Section 148A notice under the substituted regime, could not revive reassessment jurisdiction. The reassessment notice and consequential reassessment were therefore time-barred and without jurisdiction.

Input tax credit on demo vehicles used for customer test drives is not blocked for authorised dealers under the dealer-agency model, although manufacturers directly supply new vehicles to customers. Demo vehicles in both dealer-agency and traditional dealership models are purchased under tax invoices and serve the equivalent purpose of promoting vehicle sales through test drives. The expression "such motor vehicles" covers vehicles used to further the supply of similar motor vehicles, rather than only the identical vehicle sold. The previous restriction denying credit to dealer-agents is withdrawn.

Interest on wrongly availed and reversed IGST credit is determined by the aggregate balance of IGST, CGST and SGST input tax credit in the electronic credit ledger. No interest arises if that combined balance never falls below the wrongly availed credit between availment and reversal, notwithstanding a lower IGST balance alone. If the aggregate balance falls below the wrongly availed amount, utilization and interest arise only to the extent of the shortfall. Compensation cess credit is excluded because it cannot be used for IGST, CGST or SGST liabilities or reversals.

Section 17(4) permits qualifying banking companies, financial institutions and non-banking financial companies to avail fifty per cent of eligible input tax credit instead of proportionate credit. A registration not engaged in deposit-taking, loans or advances cannot use the mechanism, while an election by one qualifying distinct-person registration requires all qualifying registrations of the same entity to comply. Same-PAN supplies receive the second-proviso relaxation only when both supplier and recipient have opted. Eligible credit must be reported, reversed, reclaimed and disclosed in FORM GSTR-3B through the prescribed non-IMS or IMS process.

Unregistered recipients may claim refund of GST borne on cancelled construction-service agreements or prematurely terminated long-term insurance policies only where the period for the supplier to issue a credit note has expired. The claimant must obtain temporary registration, complete Aadhaar authentication, provide a PAN-linked bank account, and file FORM GST RFD-01 with statement 8, the supplier's certificate, and supporting evidence. Separate claims are required for different suppliers. Refund cannot exceed invoice tax and is proportionately restricted where the supplier has returned only part of the amount paid.

Each registrant that receives input-service invoices for distinct persons and must distribute the related credit requires ISD registration. The ISD must distribute credit only to the recipient to whom it is attributable and must ascertain its prima facie eligibility before distributing it in the relevant month through FORM GSTR-6. Recipients remain responsible for credit eligibility and applicable reversals. Credit transferred by a same-PAN, same-State registrant to an ISD is a credit-transfer mechanism, not an outward supply, and is excluded from turnover and Net ITC refund computation.

No Claim Bonus does not represent consideration for a supply by an insured to an insurer because the insured has no contractual obligation to refrain from lodging a claim. It is an admissible discount in valuing insurance services where disclosed in the policy terms and recorded in the invoice, and GST applies to the premium payable after that deduction. Mandatory e-invoicing exemptions for specified entities or sectors apply entity-wide, rather than only to specified categories of supplies.

Expenditure disallowance linked to exempt income is not permissible where no exempt income was earned or receivable during the relevant year; rule 8D cannot produce a disallowance in the absence of such income. Unsecured-loan additions require consideration of additional appellate evidence relevant to the identity, creditworthiness and genuineness of loan credits. Where the first appellate authority has not addressed that evidence or recorded its admission under rule 46A, the loan-credit issue requires fresh determination on merits after both sides receive an opportunity to be heard.

GST appellate pre-deposit requirements require full payment of the admitted amount-tax, interest, fine, fee and penalty that the taxpayer accepts and does not challenge-before an appeal is filed. The contested balance is tax in dispute, and the statutory pre-deposit is calculated as ten per cent of that disputed tax. For an appeal before the Appellate Tribunal after modification of liability at the first appellate stage, the further pre-deposit is calculated on the disputed tax liability confirmed at that stage.

Where fraud, wilful misstatement, or suppression to evade tax is not established, a notice issued under section 74(1) is to be treated as a notice under section 73(1). The consequential order redetermining tax, interest, and penalty must be issued within two years from communication of the relevant direction. However, redetermination is limited to demands for which the original notice was issued within two years and nine months from the applicable annual-return due date or the date of erroneous refund. For multi-year notices, only timely noticed financial years may be redetermined.