Rule 164(6)'s deadline for filing a GST amnesty waiver application is an essential mandatory condition, not a directory procedural requirement. Section 128A relief remains subject to prescribed conditions, and the time-bound scheme's deemed-approval mechanism links key timelines to the waiver application. Separately, full payment of the tax demand under an ex parte original order safeguards revenue interests and supports setting aside that order for fresh determination. The taxpayer must receive a reasonable opportunity of hearing before the fresh determination, while the mandatory amnesty-application deadline remains unaffected.

Service of a GST show-cause notice exclusively through the portal after cancellation of registration does not provide an effective opportunity to respond, because the taxpayer is not obliged to continue monitoring that portal. For proceedings under Section 74, notice must be served through an alternative valid mode that enables a meaningful response and hearing. An order issued without valid service and opportunity of hearing is vitiated for breach of natural justice, although the Department may issue a properly served notice and proceed according to law.

Composite GST show-cause notices and assessment orders covering multiple tax periods are inconsistent with the period-specific scheme under Sections 73(3) and 74(3). Separate proceedings are required once the annual-return due date for each relevant year has arisen, because a combined proceeding impairs the registered person's statutory rights, including available relief under Section 128 and an effective appeal for each individual tax period. Accordingly, a composite notice and assessment order spanning 2021-22 to 2024-25 were unsustainable and set aside.

Exceptional Article 226 jurisdiction may permit consideration of a delayed GST appeal despite the statutory appellate limitation where circumstances are genuinely beyond the assessee's control. The appellate authority remains bound by the limitation framework under Section 107 and writ relief cannot routinely bypass that scheme. However, delayed communication by a Chartered Accountant, where it prevents timely filing and denial of merits adjudication would cause grave prejudice, may justify exceptional intervention. In such circumstances, the delayed appeal may be entertained and decided on merits in accordance with law.

Separate show cause notices are required for each distinct assessment year. Composite proceedings initiated through a single notice covering multiple financial years, and any consequential consolidated adjudication, are legally unsustainable under the applicable framework. The requirement preserves assessment-year-specific initiation of proceedings and invalidates a combined notice spanning several years.

GST regime replacement of VAT may impose a differential tax burden on works contracts during their currency. The recipient of the works contract service bears the differential tax attributable to GST, and a contractor that has discharged that liability obtains a corresponding right to reimbursement. State authorities must determine and reimburse the differential GST liability after verifying the relevant contractual records and calculations.

Blocking of input tax credit remained in place where the registered person had closed its business, its registration was cancelled, and it disclosed no intended use for the blocked credit. Statutory proceedings concerning input tax credit allegedly availed from non-existing taxpayers were also pending. These circumstances required the registered person to participate in those proceedings rather than seek interference with the credit-blocking action. The challenge to the blocked credit therefore failed.

Assessment orders confirming show-cause proposals without a taxpayer reply may be set aside for fresh adjudication even after the statutory GST appeal period expires, where the taxpayer undertakes the required cash pre-deposit, accounts for sums already recovered, and files a supported reply. De novo adjudication proceeds only on those conditions, while recovery remains subject to verification.

Section 16(5) changed the statutory time limits for filing returns and availing input tax credit. Consequently, input tax credit cannot be rejected solely because the relevant returns were filed belatedly where the amended provision governs the claim. Rejection founded only on delayed return filing is unsustainable, and the input tax credit claim must be reconsidered in accordance with the revised statutory time limits.

Separation of audit and adjudication functions under the Karnataka GST framework requires that an officer conducting an audit under Section 65 should not also determine tax liability under Section 73(9). Where the same officer performed both roles, the adjudication order was quashed. Fresh adjudication must be undertaken by a different proper officer after allowing a further reply and providing an adequate opportunity of hearing.

Dismissal of a statutory GST appeal solely as time-barred, without adjudication on merits, does not merge the original registration-cancellation order or prevent constitutional writ review. Where non-response to a show-cause notice results from bona fide and unavoidable circumstances supported by sufficient cause, a justice-oriented approach may justify a further opportunity. GST registration may consequently be restored after setting aside cancellation, subject to filing pending returns and discharging outstanding tax liabilities. The central principle is that a limitation-only appellate rejection does not foreclose substantive writ relief.

Assignment or acquisition of leasehold rights in an industrial plot transfers benefits arising from immovable property and falls outside the GST scope of taxable supply. GST charged on that transfer lacks legal basis; consequently, tax, interest and reversed credit recovered on the assumption of taxability require restoration. The blocked-credit rule for construction of immovable property does not apply where only leasehold rights are acquired and no construction occurs. Fraud-based recovery proceedings are also unsustainable where the credit was disclosed in returns and accounts, reversed before notice, and no fraud, wilful misstatement or suppression with intent to evade tax is established.

Electronically authenticated GST adjudication orders operate as composite orders where a digitally signed portal order expressly incorporates an attached speaking annexure; authentication extends to the incorporated annexure. Section 161 permits correction of an apparent inconsistency between a portal recital and the incorporated determination where the corrigendum does not reopen merits, introduce fresh reasons, enlarge the original demand, or adversely alter the taxpayer's position requiring a further hearing. Adjudication summaries in FORM GST DRC-07 and rectification summaries in FORM GST DRC-08 remain mandatory for enforcement and statutory appeal. The substantive merits of the disputed input-tax-credit demand and any surviving limitation issue remain for appellate adjudication.

Composite GST show-cause notices covering multiple financial years or tax periods are impermissible because liability, returns, assessment, recovery and limitation operate independently for each period. Combining years with separate due dates and limitation periods conflicts with the statutory year-wise structure and restricts a taxpayer's ability to respond separately to each period. Dismissal in limine of a challenge to a contrary view does not trigger the doctrine of merger. Authorities within the relevant territorial jurisdiction must follow prior decisions rejecting such consolidation. Separate notices and determinations are therefore required for distinct financial years or tax periods.

Services fully supplied before GST commenced remain subject to the pre-GST service-tax regime, even where approval and invoicing occur after commencement. Under the time-of-supply and transitional framework, subsequent administrative approval or billing does not change the completed service's supply date or impose GST. Where contractual payment was withheld amid a genuine taxability dispute, delay was not wholly attributable to the payers; commercial interest was inappropriate, but interest at 8% per annum from bill submission until payment applied.

GST penalties for non-compliance cannot exceed the statutory maximum where returns have been filed and applicable late fees paid. The aggregate penalty exceeded the limit prescribed under the Uttar Pradesh Goods and Services Tax Act, 2017, despite regularisation of the filing default through returns and late fees. The show-cause notice and penalty order were set aside, relieving the assessee from the excessive penalty.

Omission of Rule 96(10) of the CGST/WBGST Rules without a saving clause means that proceedings or demands founded solely on that rule cannot be initiated or continued. Without a statutory saving provision or legal fiction preserving accrued proceedings, the omitted rule ceases to have operative effect. Departmental instructions aligned with this position by requiring field formations not to commence or pursue such matters. Consequently, Section 74 proceedings and consequential orders based exclusively on omitted Rule 96(10) were unsustainable and quashed.

An efficacious statutory appellate remedy under Section 107 must be pursued for challenging the impugned order. Deficiencies in the show cause notice and all other available contentions may be raised before the Appellate Authority. Four weeks were granted to file the statutory appeal, following disposal of the Special Leave Petition.

GST adjudication orders that expressly incorporate annexures must be read as composite instruments. A digitally signed portal-generated order can validly authenticate an accompanying annexure containing the reasons, input tax credit determination and consequential liability; an inconsistent portal recital that proceedings were dropped does not sever or invalidate the incorporated annexure. Rectification may correct an error apparent from the record to reflect the decision actually made, but cannot reopen merits or create a fresh adjudication. No further hearing is required where the correction does not adversely alter the taxpayer's original position. FORM GST DRC-07 is a statutory summary rather than the adjudication itself, but DRC-07 and corresponding DRC-08 must be made available within a reasonable time to permit appeal and demand enforcement.

Independent corroboration was required to sustain a penalty for alleged involvement in an attempted export of prohibited red sanders where the allegation rested solely on statements later retracted. Retraction placed on record required consideration, and an uncorroborated retracted statement could not alone establish liability. The setting aside of penalty against the person alleged to have introduced the employee to the purported mastermind also removed the factual basis for penalising the employee. The penalty was therefore unsustainable and the appeal succeeded.