A prima facie bona fide explanation for delay supported admission of the GST appeal for regular hearing. Payment of 20% of the stipulated pre-deposit triggered the statutory deemed stay of recovery proceedings for the unpaid balance while the appeal remains pending and has not been dismissed. The respondents were required to comply with the recovery stay, while the merits of the underlying demand remain undecided.

Writ jurisdiction over pending inspection and search proceedings was not exercised before issuance of a show-cause notice or final liability determination. Disputes over independent witnesses, the panchnama, and the voluntariness of tax payment required assessment of contemporaneous material by the competent authority. The writ petition was dismissed at that preliminary stage without deciding the merits, and all contentions remained open in statutory adjudication.

Service of a seizure order under Rule 139(2) is satisfied where Form GST INS-02 identifies the seized articles and bears the affected person's signature acknowledging physical receipt. Disputed factual claims about preparation or communication of the seizure order generally cannot be resolved in writ jurisdiction solely on affidavits. Accordingly, acknowledged physical service of Form GST INS-02 prevents search and seizure proceedings from being invalidated on an allegation of non-service.

Input tax credit eligibility under Section 155 remains the claimant's burden to prove, even where seized records are unavailable. The relevance of unavailable records, resulting prejudice, and supplied or reconstructed material requires evidentiary assessment in the statutory appeal. Challenges concerning tax demand, interest, penalties, documentary evidence and input tax credit are to proceed through the appellate remedy under Section 107 rather than the writ route. Duplicate GST DRC-07 demand summaries generated by a portal glitch require rectification so that they match the demand confirmed in the adjudication order, including for statutory pre-deposit computation.

Ex parte GST adjudication was unsustainable where the order was uploaded solely under the portal's "Additional Notice and Orders" tab, without separate intimation or a personal hearing. The absence of a hearing raised a prima facie breach of natural justice. The order was quashed, requiring fresh adjudication after consideration of the taxpayer's reply, a personal hearing, and issuance of a reasoned order in accordance with law.

Section 127 transfer power is a machinery provision requiring a demonstrated, legitimate need for coordinated investigation. Alleged accommodation entries alone do not establish the necessary nexus; the Revenue must show structural links with the searched group, interlacing of funds, or interconnected business activities. An isolated banking transaction and an opaque factual basis indicate inadequate application of mind and disproportionate operational prejudice, rendering an inter-State jurisdictional transfer legally untenable.

Demand adjudication cannot disregard a reply uploaded in Form GST DRC-06 and proceed ex parte on the incorrect basis that no reply was filed. Consideration of the response, an effective personal hearing, and a reasoned decision are required; the demand must therefore undergo fresh adjudication. Negative blocking of the Electronic Credit Ledger under Rule 86A(1) cannot be used as a recovery mechanism for allegedly wrongful or ineligible input tax credit. Questions concerning return filing, registration cancellation, and ledger operability must be determined through the applicable statutory process.

Statutory appellate remedy before the GST Appellate Tribunal becomes available once the Tribunal is functional, even where a writ petition was instituted during its non-constitution. A petitioner may pursue the statutory appeal within the permitted period, with the time spent in writ proceedings considered by the Tribunal, subject to statutory compliance. This enables transition from writ proceedings to the ordinary appellate mechanism after the appellate forum becomes operational.

Section 83 permits provisional attachment only after qualifying proceedings commence, against property belonging to a taxable person or person covered by Section 122(1-A), where tangible material establishes that attachment is necessary to protect revenue. The power requires a live nexus between the material and necessity, and must satisfy proportionality; vague suspicions involving third-party money laundering or online gaming do not suffice. Attachment reasons cannot be supplemented by affidavit. Merchant settlement funds held in escrow under a trust are not the payment aggregator's attachable property. As no GST liability, identified transactions, evasion mechanism, or statutory coverage was established, the attachment and remaining debit-freeze restrictions were set aside.

Provisional attachment of a payment aggregator's current and regulated escrow accounts requires an opinion based on tangible material showing that attachment is necessary to protect revenue. Vague suspicion of GST evasion by unidentified third-party online gaming merchants, without identifying the aggregator's tax liability, relevant transactions, evasion method, or statutory status, does not satisfy that threshold. Escrow funds reserved for merchant settlements are held in trust and are not the aggregator's attachable property. The High Court treated the attachment orders and continuing debit freezes as illegal and quashed them.

Inter-State transfer of assessment jurisdiction for coordinated investigation requires a demonstrated structural nexus between the taxpayer and the searched group; an isolated transaction is insufficient. Alleged incriminating material must establish interlacing of funds or interconnected business activities, rather than an unfounded or non-transparent conclusion. Absent a legitimate necessity for coordinated investigation, transfer may be arbitrary, show non-application of mind, and breach natural justice. Assessment jurisdiction remained at Kolkata, while material gathered at New Delhi was to be sent to the Kolkata Assessing Officer for lawful inquiry, preserving the Revenue's ability to investigate there.

Service of a seizure order in Form GST INS-02 was satisfied where the order identified the seized articles and bore the petitioner's signatures acknowledging physical delivery. The High Court declined to resolve conflicting factual claims on affidavits in writ jurisdiction, rejected the non-service challenge to the search and seizure proceedings, and dismissed the writ petition. The merits of the statutory proceedings remained open before the competent authority.

Input tax credit may remain available to a bona fide purchasing dealer where contemporaneous records, including tax invoices, e-way bills, consignment notes, banking payment evidence and proof of material consumption, establish actual receipt and use of goods. A supplier's later non-existence or retrospective registration cancellation does not by itself defeat credit if the supplier was registered when the supply occurred and transaction evidence remains unrebutted. Penalty for wrongful credit requires proof of fraud, wilful misstatement, suppression or collusion attributable to the recipient; a purchaser is not a guarantor of the supplier's subsequent non-compliance.

E-way bill rules require an e-way bill for internal stock transfers exceeding the prescribed value, even where goods move under a delivery challan otherwise than by supply; the challan does not replace that obligation. Transfer of tax-paid goods between a dealer's own premises, without another person or consideration, does not constitute supply and attracts no tax. Although failure to carry an e-way bill was a technical procedural breach, penalty under Section 129 was unsustainable because the goods were traceable and a bona fide misunderstanding of distance-based rules negated intent to evade tax. The penalty and related orders were set aside, with refund of the deposited penalty plus applicable interest.

Ghamella/Tasla is classified as a taxable article under the specific Chapter 73 tariff description rather than as an exempt agricultural hand tool. Its concave, load-bearing container design lacks the active working attributes of a hand tool, so the specific entry prevails over the general exemption entry. The later exclusion from the agricultural-tools exemption is clarificatory and does not create retrospective tax liability. Internal audit clearance or pre-notice administrative closure is not a quasi-judicial adjudication and does not bar a subsequent show cause notice on res judicata grounds. Describing the unchanged product as an exempt implement supports penalty for deliberate misstatement and suppression of taxable supplies.

Penalty under Section 129(3) for alleged diversion of goods requires reliable evidence that the actual movement or delivery contravened GST law, even where valid invoices and e-way bills accompany the consignment. Vehicle proximity to another factory, discrepancies in a transport bilty, and the driver's statement do not, without corroboration, establish delivery to an undeclared recipient where the goods' description and quantity match the accompanying documents. Failure to provide GPS-camera footage relied on adversely may deny a fair opportunity to contest the allegation. The penalty orders were set aside and the penalty quashed.

Refund of accumulated Compensation Cess ITC for domestic leather-product supplies under the inverted-duty structure requires more than lawful availment of credit. Section 54(3) limits refunds of unutilised ITC to statutory categories; credit usable only for Compensation Cess does not itself establish a cash-refund right. The claimant must meet the inverted-duty test and show that the exclusion for nil-rated or exempt outward supplies does not apply. A clarification on qualifying zero-rated supplies does not create an unconditional domestic-supply refund. As statutory entitlement was not established, the refund-granting order was set aside and rejection orders restored.

Customs and food-safety legislation operate concurrently: border control, tariff classification, valuation and anti-fraud enforcement remain within Customs powers, while food-safety compliance is regulated separately. A Customs Proper Officer may draw samples of imported food before Bill of Entry routing through FICS for Customs examination and investigation; routine FSSAI sampling does not create exclusive jurisdiction. Executive instructions cannot restrict statutory Customs powers. Challenges to sampling, testing methods, chain of custody and laboratory-report admissibility should be resolved in show-cause adjudication. Judicial review should not prematurely quash those processes or impose fresh-sampling, testing, cargo-release, or charge-waiver directions beyond the writ relief sought.

Delayed production of invoices and bilties did not establish that intercepted makeup accessories were documented, where the driver initially produced all documents available and the later material was uncorroborated. Unidentified buyers and sellers, unverified business credentials, unexplained discrepancies, and no reliable link between the documents and goods supported treating the consignment as undeclared. Transit-State action was not excluded by the asserted inter-State movement because the claimed out-of-State destination was not established. The documented-consignment precedent was distinguishable, and the penalty for transporting undeclared goods was sustained.

Refund of accumulated Compensation Cess input tax credit on coal used to manufacture leather products for domestic supply under an inverted tax structure depends independently on the conditions in Section 54(3); credit standing in the electronic credit ledger does not itself create a cash-refund right. Availability of credit, including the absence of a blocked-credit restriction, concerns credit availment rather than refund eligibility. Inability to use cess credit against other liabilities and the absence of cess on domestic output supplies do not establish inverted tax structure eligibility. Clarifications and export-related decisions concerning zero-rated supplies do not support the domestic refund claim. The refund-granting appellate order was set aside, restoring the original rejections.