GST refund claims are subject to a mandatory two-year limitation period, but writ jurisdiction may permit condonation where sufficient cause justifies departure from that period. A duplicate reversal of transitional credit, discovered only during a later review of records, may constitute sufficient cause for restoring a delayed refund application. Following restoration, the statutory authority must examine supporting documents and determine the claimant's substantive refund entitlement afresh.

The enhanced turnover threshold for composition levy under the CGST Act applied from 1 April 2019 through the implementing notification. It did not extend to the 2018-19 tax period because the earlier notification did not make the increased threshold available for that period. Taxpayers for 2018-19 therefore remained subject to the pre-enhancement composition-levy threshold.

Verification of the asserted completion of the Rule 88C process was necessary before adjudicating liability under Section 73. The response containing relevant details required examination to determine whether Rule 88C had concluded in the petitioner's favour and, if so, whether that conclusion affected the sustainability of the Section 73 proceedings. The adjudication order was quashed and remanded for reconsideration.

Parallel GST proceedings under Sections 73 and 74 for the same tax period cannot continue while an earlier proceeding remains unresolved, as this would create simultaneous adjudication. Later notices, adjudication orders and consequential recovery action were quashed. The earlier proceeding must be determined after allowing the taxpayer to submit documents supporting the exemption claim and granting a personal hearing. Its consideration cannot be denied on limitation where intervening parallel proceedings had been initiated.

Regular bail was granted in proceedings alleging wrongful availment and utilisation of input tax credit. Relevant considerations included the filing of the complaint, absence of criminal antecedents, continued custody, and the likelihood that trial would take time. The bail determination rested on custody status and personal circumstances in the pending GST-related offence.

Interim protection permits the petitioner to continue normal business activities and restrains coercive recovery or pressure to discharge an allegedly defaulting supplier's input tax credit liability until the next listing. The issue concerns whether search proceedings may continue after expiry of the stated authorisation validity where the search began within that period. The authorities' position supporting continuation was recorded, while allegations that the petitioner was pressured to pay the supplier's purported tax liability were to be addressed after obtaining instructions.

Operative appellate orders setting aside tax demands remain binding unless modified, stayed, or set aside through the prescribed process. Refund authorities cannot revisit the underlying input tax credit dispute when processing a consequential refund. Refund withholding requires the specified statutory conditions, including pending proceedings, the Commissioner's requisite opinion, and a hearing; a proposed challenge alone is insufficient. Writ jurisdiction may remain available despite an alternative appeal where action disregards a binding appellate order, is arbitrary, or breaches mandatory safeguards.

Article 226 writ jurisdiction ordinarily should not displace the statutory GST appellate remedy where alleged non-service of a show-cause notice or denial of personal hearing requires verification of service records, receipt, and related facts. Such fact-dependent and curable procedural objections should be examined in the statutory appeal rather than through writ proceedings. Lack of remand power does not curtail the Appellate Authority's jurisdiction to conduct a fresh, independent appraisal of the record and determine objections on merits. Notice-service and hearing objections therefore remain for adjudication in the statutory appellate process.

Personal hearing requirements under the Uttar Pradesh GST law require a fresh opportunity where no hearing occurs on the originally fixed date. Where no subsequent hearing date is intimated and an adjudication order is issued later without an adjournment sought by the assessee, the statutory requirement under section 75(4) and principles of natural justice are breached. Section 75(5) governs adjournments but does not dispense with a renewed hearing opportunity. Denial of a reasonable opportunity of personal hearing renders the adjudication invalid.

Binding GST appellate orders remain operative unless modified, stayed or set aside through statutory remedies; departmental review, an intended challenge, or a later appeal does not suspend them. Refund authorities must process a consequential refund arising from annulment of the underlying demand and cannot revisit adjudicated input tax credit entitlement during refund processing. Withholding pending proceedings requires compliance with statutory safeguards, including the prescribed opinion based on malfeasance or fraud and an opportunity of hearing; a proposed challenge to the appellate order is insufficient. Writ jurisdiction may be invoked despite an alternative appeal where refund rejection disregards a binding order and the appellate remedy is ineffective. The refund rejection was quashed and remanded for fresh consideration.

Parallel GST proceedings for the same tax period cannot continue while earlier proceedings on alleged nil or exempt turnover remain pending. The later show-cause notices, adjudication orders and consequential recovery action were quashed as duplicative proceedings. The exemption claim remains for examination in the earlier proceedings upon production of documents and after a personal hearing. Those earlier proceedings must be reconsidered afresh without limitation impeding consideration because the now-quashed parallel proceedings had been initiated.

Section 73 adjudication requires consideration of the taxpayer's claim that its Rule 88C(2) explanation was accepted and that the mismatch proceedings concluded in its favour. Where that claim remains unexamined, the taxpayer must receive an opportunity to provide the relevant details and response. The adjudication was quashed and restored for fresh consideration of whether the Rule 88C proceedings had concluded in the taxpayer's favour and whether that conclusion affected the sustainability of the Section 73 proceedings.

GST refund applications remain subject to a mandatory two-year limitation period, but writ jurisdiction may be available to condone delay. An asserted double reversal of TRAN-I credit, discovered only on examining records, can constitute just cause for such condonation. The time-bar rejection was set aside, and the refund claim was restored for fresh examination by the statutory authority upon production of supporting documents.

Government recipients of works-contract services must bear and reimburse the differential GST liability caused by the VAT-to-GST transition during contract execution. Reimbursement is limited to the incremental tax attributable to GST, rather than the full tax burden, and depends on verification of the contractor's records and calculations. A writ of mandamus required consideration of the contractor's representation, determination of the verified differential amount, and reimbursement within the stipulated period.

GST advance ruling jurisdiction is confined to questions concerning supplies undertaken or proposed to be undertaken by the applicant. Questions concerning consultancy services allegedly supplied by a consultancy in-charge or faculty member to the applicant, including that person's GST registration and tax-invoice obligations, fall outside that scope. The advance ruling application was therefore not admitted because it did not concern any supply made or proposed to be made by the applicant.

Under GST, a comprehensive transfer of an entire proprietorship business to an LLP without consideration, including assets, liabilities, employees and business rights, constitutes a supply even if not made in the ordinary course of business. Transfer of a business as a going concern is classified as a supply of services because it is excluded from treatment as a supply of goods. The going-concern exemption applies only where the business is established as a going concern under applicable standards. If that status is not established, transferred stock and other business assets are treated as taxable supplies of goods at the applicable rates.

Electrically operated E-Rickshaws, E-Carts, Ecovat Hydraulic vehicles and E-Scooters retain that classification when supplied without batteries if their traction derives solely from electrical energy and the fitted motor, inverter, control module and drivetrain enable passenger or goods transport. The three-wheeled vehicles fall under heading 8703 and E-Scooters under heading 8711; each attracts GST at 5 per cent whether supplied with or without batteries. Refund claims for accumulated input tax credit arising from an inverted duty structure fall outside the specified scope of advance-ruling questions and remain undecided on merits.

Imported IT support services from a related foreign entity constitute imports of services liable to integrated tax under reverse charge. For such supplies, the recipient's self-invoice qualifies as the invoice contemplated by the second proviso to Rule 28(1) and the reverse-charge self-invoicing requirement. Where the recipient is eligible for full input tax credit, the value declared in that self-invoice is deemed to be the open market value. This treatment applies only subject to full input tax credit eligibility on the reverse-charge tax payable.

Water-pipeline construction involving transfer of goods incorporated into immovable property is a works contract. New main-pipeline installation falls under SAC 995422 as construction of water mains and lines, while distribution-network revamping falls under SAC 995429 as repair and maintenance of civil engineering works. The water-supply exemption is confined to direct water-supply services and does not cover related construction, repair, or ancillary infrastructure works. Supplies to a statutory governmental authority also fail the relevant exemption conditions where they are neither pure services nor qualifying composite supplies. Both services are taxable as works contracts at 9 per cent CGST and 9 per cent SGST.

Final settlement orders under section 245D(4) cover statutory deductions disclosed in the settlement application, including a section 80IB(10) housing-project deduction. Chapter XIX-A permits departure from that finality only when the Settlement Commission declares its order void for fraud or misrepresentation. It does not preserve a parallel power for the Assessing Officer to reopen, under sections 147 and 148, deduction issues already covered by the final settlement. Where the prescribed recourse to challenge the settlement order has been rejected and attained finality, reassessment of that deduction is unsustainable.