Second-half dated-security borrowing will be completed through weekly auctions across maturities ranging from 3 years to 50 years, including Sovereign Green Bonds. Switching and buyback operations will continue to smooth the redemption profile, while a greenshoe option may permit retention of additional subscriptions. Treasury Bill borrowing will proceed through 91-day, 182-day and 364-day instruments. Auctions will offer non-competitive bidding for specified retail investors, and flexibility is retained to modify issuance terms or introduce non-standard maturity instruments, floating-rate bonds and inflation-indexed bonds.

From 1 October 2026, employer and employee contributions are payable under section 29 for establishments across Gujarat's 15 non-implemented and 16 partially implemented districts. Employees of these establishments are to receive Chapter IV benefits through the Employees' State Insurance Corporation. The territorial implementation operates under the third proviso to the First Schedule of the Code on Social Security, 2020, replacing the earlier arrangement while preserving prior acts and omissions.

Eligible registered persons with aggregate turnover not exceeding two crore rupees may elect not to furnish annual returns for financial years 2017-18 and 2018-19, with non-filing by the due date treated as deemed furnishing. Eligible composition taxpayers may file FORM GSTR-9A, and other eligible registered persons may file FORM GSTR-9, before the due date only. Taxpayers identifying short-paid tax or ineligible input tax credit during reconciliation may voluntarily pay the liability through FORM GST DRC-03.

GST refund claims may club successive tax periods across financial years, while specified claims continue to follow chronological filing except after a deficiency memo. Accumulated ITC refund is unavailable where inputs and outputs are the same goods taxed at different times. For tax refunds other than zero-rated supplies or deemed exports, cash and credit components must be paid in cash and re-credited, respectively, in the original payment proportion. Accumulated ITC claims are confined to supplier-uploaded invoices reflected in FORM GSTR-2A, with HSN/SAC reporting required where stated on inward invoices.

Defects capable of preventing admission include an illegible vakalatnama; appeal papers or supporting documents lacking digital signatures; an uncertified, unsigned, or illegible show-cause notice; omission of the order-in-original; and an impugned appellate order lacking its reference number or date. Failure to cure defects, upload supporting material, attend listed hearings, or seek adjournment despite repeated opportunities may result in rejection under Rule 24(4) of the GSTAT (Procedure) Rules, 2025.

GST exemption claims must be supported by cogent GSTIN-wise documentary evidence. GSTR-9C disclosure, entity-level audit records, or a non-speaking Chartered Accountant certificate cannot independently establish that unreconciled turnover is exempt interest income attributable to another registration. The taxpayer bears the burden of proving that the amount satisfies the exemption conditions and relates to the relevant period. Failure to produce available records at assessment and appellate stages may support an adverse inference that the withheld evidence would be unfavourable.

The amended Rule 89(5) formula is treated as curative and clarificatory because it corrects an earlier mismatch that could understate refunds of accumulated input tax credit under an inverted duty structure. Curative amendments may apply to earlier tax periods where refund or rectification claims remain within limitation and satisfy substantive requirements. A supplementary claim for an omitted differential amount is not barred merely because an earlier claim was filed, subject to eligibility, limitation, accurate quantification and prevention of duplicate refunds.

Section 107(12) of the CGST Act, 2017 requires first appellate authorities to issue written, reasoned orders identifying points for determination and recording decisions on each point. Dismissal of a GST appeal solely for absence or lack of prosecution, without considering the record and appeal grounds, is inconsistent with the statutory appellate duty. Appellate authorities must independently examine relevant facts and material grounds, provide an opportunity of personal hearing, and issue speaking orders supported by reasons.

Inverted-duty GST refund eligibility under Section 54(3)(ii) depends on accumulation of eligible input tax credit from higher-taxed inputs relative to output supplies, not on whether the claimant is termed a manufacturer or trader. Shared HSN classification of inputs and outputs is not an independent disqualification. All eligible inputs forming Net ITC, including chemicals, packaging and consumables, must be considered under Rule 89(5). The refund must be calculated using tax-period-specific data; annual figures may only corroborate business patterns or assist verification.

Section 147A, retrospectively inserted with effect from 1 April 2021, purports to validate reassessment notices issued by Jurisdictional Assessing Officers. Through a non-obstante clause, it overrides section 151A and judicial pronouncements, and treats the Assessing Officer for sections 148 and 148A as the jurisdictional officer rather than the National Faceless Assessment Centre. The central issue is whether prescribed faceless allocation is mandatory and whether retrospective validation can displace that procedure.

GST treatment of medicines, consumables and medical devices supplied to in-patients depends on whether they are independently taxable supplies or integral components of exempt health services. Section 76 applies where an amount is collected as tax but is not paid to Government, irrespective of the taxability of the underlying supply. The inquiry requires invoices, procurement and tax-payment details, and the billing method, while distinguishing in-patient treatment supplies from standalone pharmacy sales on which GST is collected and remitted.

Rule 9(3) to 9(5) of the Security Interest (Enforcement) Rules, 2002 requires an auction purchaser to make the prescribed deposit immediately and pay the balance within the statutory period; any extension must rest on a written agreement. Acceptance of sale consideration 448 days after bid opening, without a written extension or permission to proceed despite an interim order, breached that mandatory procedure. Equitable considerations cannot override statutory requirements. Non-compliance vitiates the auction sale, acceptance of delayed consideration, and consequential sale certificate.

Availability of a civil remedy for a contractual dispute does not bar criminal-law recourse where allegations disclose theft or criminal misappropriation. Specific allegations of unauthorised scrap removal, unaccounted sale proceeds, and non-cooperation in providing accounts may warrant FIR registration and investigation where document verification and questioning are needed to establish the facts.

VAT classification of chewing gum turns on its common commercial understanding rather than its sugar content, food-standard specifications, tariff classification, or departmental commodity coding. Chewing gum or bubble gum is chewed as a mouth freshener and discarded; it is not consumed as an eatable sweetmeat and contains gum base and other ingredients in addition to sugar. Its treatment differs from toffee or chocolate, whose classification as sweetmeats does not determine the position of chewing gum. Chewing gum therefore falls under the residuary entry for unclassified goods rather than the entry for sweets and sweetmeats.

Trading became an exempted service under the CENVAT Credit Rules only from 1 April 2011. For the preceding period, the Rule 6 credit-reversal mechanism did not apply to common input services used for trading. From that date, proportionate common-input-service credit attributable to trading must be calculated using the prescribed trading value: trade margin, being the difference between sale price and cost of goods sold, or 10% of cost of goods sold, whichever is higher, rather than gross trading turnover. Where the calculated proportionate credit has been reversed, failure to intimate the Rule 6(3A) option does not justify a further demand, interest or penalties.

Free-of-cost materials supplied by a service recipient are not includible in the gross value charged for taxable services unless legislation specifically requires their inclusion. Service tax is levied on the taxable service, and valuation cannot be enlarged by adding recipient-supplied materials. Accordingly, the recipient's free supplies cannot justify denial of the 67% abatement otherwise available under the applicable service-tax valuation framework.

Scaffolding does not qualify as capital goods for CENVAT credit because it is neither covered as tubes, pipes or fittings nor included in any other prescribed capital-goods category under the CENVAT Credit Rules. Credit claimed on scaffolding is therefore inadmissible. Alleged excess CENVAT credit arising from carry-forward balances in ST-3 returns requires verification against revised return workings, audited accounts, CENVAT records and cash-payment challans. The excess-credit issue requires fresh adjudication, while the scaffolding-credit disallowance remains undisturbed.

Extended limitation for service-tax demands could not be invoked against a municipal corporation constituted under Article 243W and performing statutory functions where fraud, collusion, wilful misstatement, suppression of facts, and intent to evade tax were not established. Invocation of the extended period requires these essential elements and cannot rest merely on a delayed demand. The service-tax demand was consequently time-barred, and the associated penalties were unsustainable.

Extended limitation for service-tax recovery requires fraud, collusion, wilful misstatement or suppression with intent to evade tax; disclosure in income-tax records and a bona fide exemption claim do not establish that intent. Construction of public roads for general use is exempt, including qualifying subcontractor services. Service tax cannot be recovered twice on identical receipts for the same period through separate departmental proceedings. Deliberate suppression or wilful contravention is necessary for the penalty for tax evasion, whereas failure to obtain registration and file returns remains a strict-liability procedural default. Limitation, exemption and duplicate-demand grounds defeated the substantive demand and tax-evasion penalty, while the procedural penalty remained operative.

Principal-to-principal revenue sharing, where restaurant parties jointly operate and one receives a share of the kitchen operator's turnover, does not by itself constitute Business Support Service because no infrastructural support is provided to a service recipient. Similarly, stock and cash incentives tied to alcoholic-beverage sales are sales-linked receipts, not consideration for the sale of advertising space or time or for promotional activity. Neither category of receipt is taxable as Business Support Service or Advertisement Service, and related interest and penalties do not arise.