Request-specific road restoration performed by a government authority after business-directed road cutting is treated as a taxable supply for consideration, rather than a sovereign public-road function, liquidated damages, or unilateral compensation. Public-function exemptions and non-supply treatment do not extend to customised commercial restoration services, requiring the business recipient to discharge GST under reverse charge. Refund sanctions issued in other jurisdictions neither create binding precedent nor res judicata. An unsubstantiated claim that the supplier previously paid tax does not displace reverse-charge liability. Electronic proceedings remain valid where the notice provides adequate particulars and the portal record establishes procedural integrity without prejudice.

Refund of unutilised Compensation Cess credit under the inverted tax structure mechanism requires accumulation because the tax rate on inputs exceeds the rate on output supplies under section 54(3)(ii). Eligibility to take such credit and the absence of blocked-credit restrictions do not independently establish a cash-refund entitlement. Compensation Cess credit is ordinarily restricted to payment of Compensation Cess, and inability to offset it against other liabilities does not itself justify refund. Rule 89(5) cannot create substantive eligibility. Circulars concerning qualifying zero-rated supplies do not extend unconditional refund treatment to domestic supplies that do not attract Compensation Cess; accumulated credit attributable to such supplies is inadmissible unless statutory refund conditions are met.

Place of supply under GST is determined by the location where movement of goods terminates for delivery to the recipient. Where statutory records, including the invoice and e-way bill, identify a stated destination, an allegation of diversion to another State is undermined by inconsistent records. GST law does not require a supplier to declare or use a particular transport route; route deviation alone does not constitute a contravention when valid transit documents are undisputed. Detention penalties require evidence of an existing contravention and intent to evade tax, not an uncorroborated driver statement or a presumed future diversion before unloading.

Input tax credit cannot be denied and extended recovery proceedings cannot rest solely on a supplier's later non-existence where contemporaneous invoices, e-way bills, transport records, accounts, GST records and banking-channel payments support actual receipt and eligibility, absent cogent rebuttal or proof of fraud, wilful misstatement or intentional suppression. The claimant bears the burden of proving ITC eligibility, including actual receipt of goods. Where supplier invoices remain unpaid beyond the prescribed period, proportionate ITC reversal with applicable interest applies, and credit may be re-availed after payment subject to statutory conditions. Voluntary reversal alone does not establish grounds for extended recovery proceedings.

Debit of the prescribed pre-deposit from the electronic credit ledger, rather than the electronic cash ledger, under the delayed-appeal amnesty scheme is a curable procedural defect where the entire amount was secured and a portal glitch caused the payment mode. Technical failures on the official portal should not prejudice the statutory appellate remedy. The taxpayer should receive a reasonable opportunity to make good the stipulated cash component before rejection of the delayed first appeal. Substantial compliance with the pre-deposit condition supports adjudication of the first appeal on merits after the deficiency is cured, rather than rejection as time-barred solely because of the ledger used.

Input tax credit eligibility requires cumulative satisfaction of statutory conditions, including actual receipt of goods and tax payment, with the claimant bearing the burden of proof. Supplier registration, invoices, portal reflection and banking payments are relevant but not conclusive where the supply is disputed; nor does a supplier's later absence conclusively negate an earlier supply. Verification of invoices, e-way bills, transport records and related material must support reasoned findings. Monetary-limit rules may permit a departmental appeal on a recurring interpretive issue where the requisite approval exists. Disputed credit claims require fresh adjudication after documentary verification and an effective opportunity to the claimant.

Unaccounted or excess goods found during a survey of business premises must be addressed through the GST tax-determination mechanism. Section 35 requires registered persons to maintain true and correct accounts, and Section 35(6) treats unaccounted goods or services as supplied for determining tax liability. Sections 73 and 74 therefore govern assessment and recovery of tax on such goods. Direct confiscation and penalty proceedings under Section 130(2) read with Section 122 are unsustainable where the allegation is limited to excess or unaccounted stock discovered at the premises.

Input tax credit must be determined by statutory eligibility conditions and evidence of the recipient's transaction, rather than solely by allegations that the supplier is bogus. Purchase orders, tax invoices, e-way bills, banking records, books of account, stock registers, consignment documents, vehicle details, supplier returns and tax-payment records supported actual purchase, transportation and receipt of goods. The supplier's restored registration and the departmental opportunity to examine the material also negated any breach of natural justice. Input tax credit was therefore allowed on the available evidence.

Input tax credit on joinery, carpentry and painting services used to furnish rented retail shops is available where the services directly support taxable retail activity and meet the business-use requirement. The construction-related credit restriction applies only where the tax component is capitalised to fixed-asset cost. Separate accounting of CGST and SGST as input tax credit, without capitalisation or depreciation, supports admissibility. A supplier-service classification objection not raised in the show-cause notice cannot be introduced at the recipient-credit stage. Credit on the relevant furnishing invoices is therefore not barred.

Excess IGST paid on export supplies remains refundable where the original payment was incorrectly reported against non-zero-rated supplies in GSTR-3B, despite correct disclosure of export turnover and IGST liability in GSTR-1. The reporting mismatch may prevent automated export-refund processing, leading to a second IGST payment and refund of that later payment through the Customs system. Where the original payment remains unrefunded, retaining tax paid twice is impermissible because a clerical or procedural error cannot justify collection of tax not legally due under Article 265 of the Constitution.

Section 16(5) retrospectively permits input tax credit for FY 2017-18 through FY 2020-21 in returns filed up to 30 November 2021, overriding the earlier time limit in Section 16(4). Credit supported by returns, accounts, tax invoices and payment evidence remains available even if claimed in a later return. A GSTR-2A and GSTR-3B mismatch is only a reconciliation discrepancy and cannot alone justify reversal when the underlying supply and tax payment are verifiable. Banking services used in furtherance of business do not fall within the blocked-credit categories under Section 17(5); related credit is therefore admissible.

GST paid on works performed after the GST regime began is reimbursable where the governing bill of quantities required bids to be quoted exclusive of taxes. Although the contract was executed under the VAT regime and contained general clauses requiring tax inclusion in bid rates, those clauses do not override the specific tax-exclusive BOQ basis. Section 15 of the CGST Act and applicable Finance Department circulars treat GST as payable in addition to contract value where tender rates exclude GST. Departmental recognition of reimbursement eligibility supports payment notwithstanding pending interdepartmental consideration.

GST registration may be cancelled only for prescribed contraventions, including failure to conduct business from a declared place. Form GST REG-01 and Rule 8 require documents supporting the principal place of business, but do not require a rent agreement for an additional place. Where the principal place is duly supported, non-submission of an additional-place rent agreement neither establishes a prescribed contravention nor proves non-conduct of business from a declared location. Cancellation on that ground is invalid, requiring restoration from the suspension date.

Consignees facing detained-goods proceedings arising from alleged undervaluation, underweight declaration, or tax evasion must receive a fresh show-cause notice where an earlier notice was issued only to the transporter. The notice must allow the consignee to submit a reply and relevant supporting records addressing the allegations. After considering the consignee's response and documents, the competent authority must determine the proceedings under the applicable GST enactments and rules. This ensures the consignee has an opportunity to be heard before the detained-goods matter is decided.

Effective notice is required to satisfy principles of natural justice in tax adjudication. Uploading a show-cause notice only under a portal's "Additional Notice and Orders" tab, without separate intimation, may prevent the affected person from becoming aware of the proceedings and submitting a reply. Adjudication undertaken without effective notice and a meaningful opportunity to respond is vitiated by breach of natural justice. The affected person must be allowed to file a response and receive a personal hearing before fresh adjudication.

GST assessment and recovery proceedings cannot rest on notices uploaded solely in the portal's Additional Notices and Orders section when the designated View Notices and Orders window is not used. Such placement fails to give the taxpayer effective notice and a meaningful opportunity to respond, contrary to principles of natural justice. The assessment order and consequential recovery proceedings were quashed, and fresh adjudication must permit a reply. Limitation of the show-cause notice remains for the adjudicating authority to determine.

Consignees of detained goods must receive a show-cause notice and a meaningful opportunity to respond before alleged undervaluation, underweight declaration or tax evasion is determined. Where the consignee can produce documents addressing the alleged discrepancies, fresh proceedings should permit a written reply and supporting material before a decision under applicable GST enactments and rules. The allegations remain open for determination through renewed notice and adjudication, rather than being conclusively decided without hearing the consignee.

GST registration cannot be cancelled solely because a rent agreement for an additional place of business was not produced where the prescribed registration application requires proof only of the principal place of business. Cancellation for contravention applies when statutory conditions, including non-conduct of business from the declared place, are established. Reliance exclusively on non-submission of documentation for an additional place of business conflicts with the statutory scheme and prescribed form. The cancellation and show-cause notice were quashed, and registration was restored from the suspension date.

Tax-exclusive bill of quantities rates prevail over general tender conditions stating that taxes are included in the bid price. GST, as an indirect tax, ultimately falls on the employer where the accepted BOQ expressly excludes taxes; a contractor cannot be denied reimbursement on the basis of inconsistent general clauses. Departmental communications and meeting decisions supported the reimbursement claim. Government circulars also permit revised administrative sanction where project-cost escalation results solely from revised GST rates. GST paid for hospital construction under the tax-exclusive BOQ was therefore required to be reimbursed within three months.

Section 16(5) of the CGST Act retrospectively permits input tax credit relating to FY 2017-18 to be claimed through a return filed up to 30 November 2021. A mismatch between GSTR-2A and GSTR-3B is a reconciliation issue and, by itself, does not require reversal where verifiable accounts, invoices and payment evidence establish genuine credit. Banking services received in furtherance of business are not within the blocked-credit categories under section 17(5) of the CGST/UPGST Act and may qualify for input tax credit.