In an unabated assessment, additions for unexplained cash credits under Section 153A require incriminating material found during search. Seized Tally data, bank-ledger entries and corroborative statements directly linked the taxpayer to unaccounted cash receipts, supporting the additions. Cash credits described as land advances remained unexplained because the taxpayer did not establish the payers' identities, provide confirmations or agreements, or otherwise substantiate their nature and source; book entries and audited accounts were insufficient. A consequential assessment pursuant to an operative revision order was not annulled. Telescoping was unavailable because no nexus was proved between the disputed credits and income considered in settlement proceedings.

Tax deduction at source on sales commission paid to foreign agents applies only where the remittance is income chargeable to tax in India. Commission paid to agents operating outside India, without a business connection or establishment in India, for services rendered abroad and received abroad through authorised banking channels, neither accrues nor arises in India and is not received in India. Such payments therefore do not trigger withholding obligations, and consequential liability for failure to deduct tax at source is unsustainable.

The non-quantifiable or uninvolved tax-effect exception under CBDT monetary-limit circulars does not permit a departmental appeal where reassessment has already determined a specific tax liability. Setting aside that assessment on a legal ground does not make the tax effect unquantifiable. The exception applies where tax consequences cannot presently be computed, including exemption-registration matters or revisional orders requiring fresh assessment. Where the quantified liability remains below the applicable threshold, the departmental appeal is not maintainable.

Further opportunity to furnish Forms 15G/15H is required where an appellate direction mandates their verification before recomputing interest-expenditure disallowance. Disallowance under the tax-deduction provisions must be recomputed only after the Assessing Authority examines all relevant forms, including outstanding forms the assessee undertakes to supply. The forms' genuineness may be verified before a fresh consequential order is issued in accordance with the appellate direction.

Direct authorisation to represent a company in GST refund proceedings, supported by a power of attorney, recorded appearances and fee correspondence, establishes professional engagement and agreed consideration. An alleged condition making fees payable only upon a successful refund cannot qualify the payment obligation unless agreed. An intermediary is not a necessary party where the client directly granted authority and engaged the professional. Recovery of the agreed fee follows from the established mandate and services rendered; pendente lite and future interest fall within the court's discretion under the Code of Civil Procedure, while litigation costs may be separately determined.

Supply, erection, testing and commissioning of a fire protection system constitute a composite supply where equipment and related services are naturally bundled with a principal supply. Permanent installation through site preparation, RCC platforms, wiring, pipework and commissioning creates immovable property where removal requires substantial dismantling. Transfer of goods in creating that immovable infrastructure falls within works contract and is treated as a supply of services, classifiable under SAC 9954. The claimed concessional 12% works-contract rate does not apply where earthwork is negligible and the statutory predominant-earthwork condition is not met.

Physical verification of goods may test whether quantities actually transported match the invoice, e-way bill, source records and documentary trail; those documents do not prevent such verification. Supplier-wise and aggregate weight discrepancies require cumulative assessment where they are unsupported by contemporaneous objections, independent weighment reports or technical evidence challenging departmental measurements. Repeated generation and cancellation of e-way bills by different entities for the same invoice number and quantity may reinforce unreconciled discrepancies and indicate an intent to evade tax. On these facts, setting aside tax and penalty under Section 129(3) was unsustainable, and restoration of the original tax and penalty order was warranted.

Goods in transit must carry contemporaneous documents and e-way bill details that match the physical consignment. Documents relating to different commodities, unsupported explanations of document exchange, and invoices produced only after detention do not establish compliance retrospectively. Where no valid documents identify a bona fide owner at interception, subsequent ownership claims do not displace the transporter's liability as a person other than the owner. For undocumented goods lacking matching invoices and traceable buyers, valuation based on product quality, specifications, and prevailing wholesale-market averages may provide a rational basis. Seizure-related penalty consequences remain sustainable on these grounds.

Portal downtime preventing contemporaneous e-invoice generation does not, by itself, justify a penalty under Section 129 where an e-way bill, commercial invoice and delivery note establish transparent movement of goods and no intent to evade tax exists. E-invoicing requirements must be applied consistently with Rule 55(4) and the principle that law does not compel impossibility; mens rea is necessary for the penalty. Payment through DRC-03 to secure release of detained goods under economic duress does not create estoppel against statutory appellate remedies, permitting refund with statutory interest where the penal demand fails.

Section 76(1) of the CGST Act requires every person who collects an amount representing tax to remit it to the Government, regardless of registration status, supply taxability, or whether the collection exceeds tax otherwise payable. Invoices, GSTR-1 disclosures, credit passed to recipients, and bank remittances may establish actual collection, creating an obligation to deposit the amount. Section 16(4) imposes a time limit for availing input tax credit; delayed GSTR-3B filing does not permit use of time-barred credit through the Electronic Credit Ledger to discharge tax liability. Non-remittance and invalid credit utilisation attract applicable fiscal consequences.

Section 122 penalties may apply where taxpayers falsify financial records, create fake invoices or documents, furnish false returns with intent to evade tax, or avail or use input tax credit without actual receipt of goods. A voluntary, unretracted statement obtained in a statutory inquiry may establish fraudulent credit unless duress or coercion is shown. Credit eligibility requires proof of actual receipt of goods and supplier tax payment, with the taxpayer bearing the evidentiary burden. Unreliable movement records, invalid vehicle details and unproven supplies may defeat that claim. Appellate reliance on material not produced before the adjudicating authority requires justification under the applicable procedural rule.

Section 39(9) permits correction of omissions or incorrect particulars in the return for the period in which the error is noticed, including a later return within the same financial year, subject to the statutory deadline and provided the correction does not arise from scrutiny, audit, inspection or enforcement activity. B2B supplies mistakenly reported as B2C and subsequently re-reported as B2B can duplicate entries in Form GSTR-1, inflating reported turnover and tax liability where tax was already paid through Form GSTR-3B. A timely voluntary correction is revenue-neutral, and the resulting GSTR-1/GSTR-3B variance does not establish additional tax liability.

Job-work movements under section 143 permit a principal's goods to move for processing and return under delivery challans, while job-work charges may be separately invoiced. Under Rule 138, either the principal or, for inter-State job work, the registered job worker may generate the e-way bill; its generator and declared value do not alone establish a taxable supply. Where records show principal-owned goods were processed and returned, a return/e-way-bill mismatch requires independent evidence of undisclosed supply, consideration, or tax evasion. Without such evidence, GST, interest, and penalty cannot be sustained.

Input tax credit reversal for exempt cattle-feed supplies is limited to credit actually availed on common inputs, input services, or capital goods used for taxable and exempt supplies. Where no credit was taken on exempt traded goods, no reversal arises; any common input-services credit requires verification and proportionate computation under Rules 42 and 43. Annual-return figures may correct periodic-return declarations, so claimed clerical corrections and supporting records must be examined before differential tax is determined from a GSTR-1/GSTR-9 mismatch. Tax, interest, and penalty liability requires fresh merits determination after that verification and reconciliation, with an effective opportunity to submit evidence and be heard.

Section 107(11) requires the Appellate Authority to confirm, modify or annul the challenged decision or order. Dismissing a rectification appeal solely for multiplicity of litigation, without addressing its grounds or deciding the connected appeal against the original demand, fails to meet that requirement. The absence of a finding on the underlying demand also prevents determination of its merits. Both appeals require fresh, reasoned adjudication after a reasonable opportunity of hearing.

Statutory appellate remedy under the CGST Act ordinarily warrants restraint in writ jurisdiction, but does not bar relief where a recognised exception, including breach of natural justice, is established. Disputed allegations that personal-hearing notices were not served-concerning the registered email address, departmental communications and transmission of virtual-hearing details-require examination of the record. Challenges to consideration of the taxpayer's explanations and the merits of the demand may therefore be addressed by the appellate authority, with all service, hearing and demand-related contentions remaining open in accordance with law.

Section 122(1A) of the Central Goods and Services Tax Act, 2017 operates prospectively because it contains neither an express provision nor a necessary implication conferring retrospective effect. The governing principle is that statutory provisions apply prospectively unless their language clearly establishes retrospectivity. Consequently, penalties under Section 122(1A) cannot be imposed for conduct occurring before the provision came into force.

Regular bail in prosecutions alleging fraudulent GST input tax credit availment requires assessment of the accusation's gravity, punishment, risks of evidence tampering and abscondence, and public interest. Expiry of the statutory custody period, absence of any further recovery or discovery requirement, and the offence being triable by a magistrate weigh against prolonged custody. Ongoing investigation alone does not justify indefinite detention where triple-test concerns can be controlled through conditions. Continued incarceration before a potentially delayed trial would constitute pre-trial punishment and unjustifiably restrict personal liberty; regular bail is appropriate absent extraordinary circumstances.

Restrictions imposed on an electronic credit ledger under Rule 86A(3) of the Goods and Services Tax Rules, 2017 cease automatically upon expiry of one year from their imposition. Once that statutory period has expired, the restriction cannot continue, and the electronic credit ledger must no longer remain blocked on that basis.

Retrospective cancellation of GST registration does not, for statutory-audit purposes, preclude examination of records and compliance for the full notified period where registration existed during that period. Audit is record-based and does not itself determine tax liability, validate returns, or assume taxable supplies after cancellation. Although cancellation preserves pre-cancellation liabilities and obligations, audit authority arises from the statutory audit framework. Separate material non-disclosure of a known pending audit notice in cancellation proceedings defeats the clean-hands requirement and independently bars discretionary writ relief.