GST assessment under Section 63 requires ascertainable turnover and a meaningful opportunity for the taxpayer to provide supporting material. An assessment made shortly after a final reminder while an adjournment request remained pending, despite acknowledgement that exact turnover was unascertainable, cannot support a demand exceeding documented work value without an allegation of additional works. Where portal access is unavailable under a temporary assessment identification and an electronic rectification attempt fails, a manual rectification application must be considered after hearing the taxpayer. Coercive recovery remains barred until that application is decided.

Section 7 admission turns on financial debt and default, determined summarily on a prima facie, preponderance-of-probabilities basis; exact claim quantification is reserved for CIRP verification. An authenticated Information Utility record has high evidentiary value, and unanswered authentication cannot later be met by bare denial; other contemporaneous documents may collectively prove default. Profitability or positive EBITDA does not displace default as the Code's trigger once statutory conditions are satisfied. A concluded determination validating an assignment may bar renewed challenge through issue estoppel, leaving the assignee able to apply as financial creditor. Section 62 appeals are confined to questions of law and cannot reweigh concurrent factual findings absent perversity, lack of evidence, ignored material evidence, or an erroneous legal standard.

Section 62(2) of the GST law provides for deemed withdrawal of a best-judgment assessment when the requisite GSTR-3B return is filed. Delayed filing does not prevent that statutory benefit where the applicable late fee is also paid, following the amendment permitting condonation of delay in return filing. Once the assessment is deemed withdrawn, the tax demand and related dues under that assessment cannot be recovered, and recovery proceedings cannot be initiated or continued on its basis.

GST liability on works contracts remains governed exclusively by the applicable GST enactments, notwithstanding contractual arrangements between contractors and employers. Claims for reimbursement of the incremental tax burden arising from the VAT-to-GST transition are contractual claims against the concerned employer, rather than grounds to modify statutory assessment, recovery, return-filing, interest, or penalty processes. Challenges to assessment orders and statutory representations concerning recovery must proceed through available statutory remedies.

Tax paid before adjudication cannot be recovered again through a demand where the Government had already received the short-paid amount; the tax demand was therefore set aside. For delayed GST payment, interest accrues only until cash is credited to the Government account and Electronic Cash Ledger through Form GST PMT-06, not until the later ledger debit on return filing. Interest paid on a residual tax shortfall cannot be set off against separate interest liabilities for delayed monthly payments. Penalty immunity applies only where tax and interest are paid within thirty days of the show-cause notice; payment after that period attracts the prescribed minimum penalty.

Retrospective operation of the substituted proviso to section 50(1) confines GST interest on delayed tax payment to the tax discharged through the electronic cash ledger, excluding the component paid by utilising input tax credit. Refund claims for interest paid on the credit-ledger component require verification of statutory conditions, payment and eligible quantum. Refund limitation cannot be introduced as a decisive appellate ground without notice and an effective opportunity to address the relevant date, computation and applicable exclusions. Limitation must be recomputed under section 54 after applying the notified exclusion of the specified COVID-19 period, followed by a hearing and consequential determination.

SEZ units may seek refund of eligible unutilised input tax credit distributed through an Input Service Distributor where the credit is attributable to their own zero-rated exports without payment of integrated tax. The supplier-specific procedure for direct SEZ supplies does not automatically bar such claims. Refund eligibility remains subject to verification, statutory conditions and quantification. A proposed exclusion for alleged prior supplier refund requires cogent documentary evidence, disclosure to the claimant and a reasonable opportunity to respond; supplier applications or unexplained back-office records alone do not establish double refund.

Section 171 requires suppliers of Rail Neer to pass GST rate-reduction benefits through commensurate reductions in transfer prices, even where maximum retail prices are railway-regulated and supplies are subsidised or complimentary. No exclusion applies to public-sector or governmental suppliers. Profiteering may be computed through a fair, case-specific comparison between pre-GST average base prices and post-GST transaction prices; no uniform formula or advance disclosure of the exact methodology is required where the supplier participated in the investigation. Investigation duration depends on circumstances rather than a one-year limit. Interest applies only prospectively from the interest provision's effective date, while penalty for continuing contraventions remains subject to statutory waiver upon timely deposit.

Bill-to/Ship-to transactions permit an intermediate purchaser to instruct the original supplier to dispatch goods directly to the ultimate recipient, provided the supplies are genuine, documented and properly accounted for. Rule 138(2) allows the consignor or consignee causing movement to generate the e-way bill. Where e-invoices and e-way bills are generated before interception by the party arranging transport, the supplier's separate non-generation does not justify detention of goods. Compliance with these requirements makes detention and penalty for e-way bill non-compliance unsustainable.

Road restoration charges paid by a business entity for permission to cut public roads for a pipeline constitute consideration for a taxable restoration service, not compensatory or liquidated damages. Targeted, request-driven restoration for commercial operations does not qualify for non-supply treatment or exemption available for governmental road functions, which concern community-wide maintenance. Where Government supplies that taxable service to a registered business entity, reverse charge applies to the recipient absent proof of tax paid under forward charge; revenue-neutrality claims do not override that liability. Electronically conducted GST adjudication remains valid where portal records authenticate the proceedings and the notice gives sufficient grounds without prejudice, despite no physical DIN.

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.