Condonation of delay in filing special leave petitions requires a justification establishing sufficient cause. Delays of 449 days and 427 days were treated as inordinate, and the explanations offered did not meet that standard. The special leave petitions were consequently dismissed solely on the ground of delay, with pending applications disposed of.

Outdoor playground equipment and eligible spare parts fall under sub-heading 95069990 and are treated as children's sports goods taxable at 5%. Outdoor gym equipment and eligible spare parts fall under sub-heading 95069190 as articles and equipment for general physical exercise, taxable at 18%. Parts solely or principally used with Chapter 95 equipment ordinarily follow the classification of that equipment. Bearings, however, are specifically described under heading 8482 and therefore take precedence over the general parts classification under the specific-description rule. Bearings are taxable at 18%, with the precise tariff item determined by their specifications.

Geomembrane made from woven HDPE strips below 5 mm in width, laminated on both sides with plastic and used for pond lining, falls within Heading 5911 as a textile product for technical use. Section XI treatment of the strips, Chapter 59 coverage of coated or laminated technical textiles, HSN notes and the functional-use test support classification rather than treatment as an article of plastics. This classification brings the product within the applicable GST entries for Heading 5911: GST applies at 12% until 21 September 2025 and at 5% from 22 September 2025.

Before 10 July 2024, credit of funds to the Electronic Cash Ledger did not constitute payment of self-assessed return tax; payment occurred only when the appropriate electronic ledger was debited. Interest on the cash component therefore continued until debit, despite receipt of funds through the Government banking channel. The Rule 88B(1) proviso excluding continuously retained cash-ledger balances applies prospectively because it contains no retrospective commencement provision. Notice validity requires demonstrated prejudice; detailed responses based on communicated interest calculations negate such prejudice. Although a requested personal hearing is required before an adverse decision, remand is unnecessary where facts and the sole statutory issue are undisputed and no further defence or evidence is identified. Reconciliation is required to prevent double recovery.

For periods before 10 July 2024, crediting funds to the Electronic Cash Ledger constituted a deposit rather than payment of a specific self-assessed return liability. Payment occurred only when the appropriate ledger was debited upon return filing; consequently, interest on the cash component continued until that debit. The 2024 Rule 88B(1) proviso excluding continuously available cash-ledger balances operated prospectively because it lacked express retrospective effect. Adequate disclosure and absence of prejudice preserved notice validity, while a requested personal hearing remained mandatory; where the record was complete and no further defence existed, remand was unnecessary. Demand-wise reconciliation remained necessary to prevent duplicate recovery of amounts paid, deposited, recovered, or adjusted.

The third proviso to Rule 138(3) of the CGST Rules permits Part B of an e-way bill to remain unfilled where goods move within the same State, up to 50 km, from the consignor's premises to the transporter's premises for further transportation. Explanation 2 preserves that exception, and the consignee's ultimate location does not change the character of the initial journey. Section 129 requires an actual contravention of the Act or Rules; a permitted omission cannot support penalty. Mens rea is not invariably necessary for this civil penalty, but absence of intent is immaterial where no underlying breach exists. Section 126 does not generally authorise reduction or waiver of the prescribed penalty.

Section 129 transit penalties require an established substantive contravention; mandatory invoice and e-way-bill requirements do not make every documentary discrepancy penal. Use of a consignee's former address may be a technical, bona fide error where invoices, e-way bills and transport records substantiate movement, physical verification confirms the goods, and no evidence shows a fictitious purchaser, diversion, duplicate documentation, value suppression, or intent to evade tax. Section 126(6) cannot reduce a valid percentage-based transit penalty, because liability under Section 129 must first arise. On these facts, the address mismatch did not attract the transit penalty.

Departmental GST appeals below the prescribed monetary threshold require compliance with litigation-control instructions issued under Section 120 of the Uttar Pradesh GST Act. Authorisation to file an appeal under Section 112(3) does not independently satisfy the monetary-limit policy. Where disputed tax falls below the threshold for GSTAT appeals, the Revenue must identify and substantiate a specified exception. Under the residual exception, it must produce a case-specific recorded opinion of the Commissioner. Without evidence of a recognised exception or such recorded opinion, the appeal is not maintainable for admission and cannot proceed on merits.

Incorrect selection of a respondent on the GSTAT portal may be rectified where the original appeal memorandum and impugned order correctly identify the proper State tax authority. Rule 26 of the GSTAT (Procedure) Rules, 2025 permits rectification of clerical and similar errors, while Rule 32(1) allows amendment of a defective appeal form upon sufficient cause. An erroneous portal entry is a curable, non-fatal procedural defect and does not prevent substitution of the correctly described respondent. Where the portal lacks a post-registration correction facility, corrected appeal documents must be re-uploaded and the Registry must correct the portal record and ensure service on the proper respondent.

GST registration cancellation for admitted non-filing of returns under the CGST Act was annulled despite expiry of the statutory period for seeking revocation. Relief remains conditional on furnishing all outstanding returns within 30 days, while liability for tax, penalty, interest and late fees continues. Limitation periods for tax determination under Sections 73(10) and 74(10) run from the judgment, subject to the specified treatment for financial year 2025-26 under Section 44.

GST Common Portal procedures permit an assessment or adjudication order to be uploaded through DRC-07 on the date of passing or later. Delayed uploading may allow post-limitation publication and impair taxpayers' appellate rights. Disclosure of the actual upload date is therefore necessary to protect limitation and appeal periods. The High Court sought further GSTN instructions on compliance with upload-date disclosure directions within two weeks and listed the matter for further hearing, without final adjudication.

Anticipatory bail under the CGST Act is not maintainable merely because summons have been issued under section 70. Such summons do not designate the recipient as an accused or independently create a sustainable apprehension of arrest. Pre-arrest protection requires an arrest-authorisation order under section 69, based on reasons to believe and communicated to the affected person. Searches, continuing investigation, or the prospect of a future arrest do not replace that prerequisite; applications without it are premature.

Subsequent GST registration was directed to be restored where the taxpayer had neither carried on business under an earlier cancelled registration nor sought its revival. Maintaining cancellation of the later registration would have prevented the taxpayer from conducting business and discharging GST obligations. As no impediment to restoration was identified, the later registration could be restored without reviving the earlier registration.

GST adjudication was set aside and remitted for fresh consideration because relevant materials had not been produced before the adjudicating authority. The taxpayer must receive an adequate opportunity to submit its reply and supporting documents, enabling the authority to reconsider the matter on a complete factual record. The remand addresses the inability to place relevant material during the original adjudication rather than determining the substantive GST liability.

Delayed writ challenges to an assessment under Section 62 are examined through the explanation for inaction, the timing of GST-registration cancellation, and evidence of recovery action. The assessment preceded both the later writ petition and the registration cancellation. No satisfactory explanation addressed the period before cancellation, and no material established that the assessed demand was being recovered through further proceedings. Subsequent filing of a return and claimed discharge of tax liability formed part of the challenge.

Omission of Rule 96(10) of the Central Goods and Services Tax Rules, 2017, without a saving or sunset clause, prevents the omitted subordinate rule from being applied to pending refund proceedings. The governing principle is that subordinate legislation ceases to operate upon omission unless the rule-making authority expressly preserves its continuing effect. Refund claims cannot therefore be rejected solely by reference to Rule 96(10) after its omission, and proceedings founded exclusively on that rule are unsustainable.

Section 75(4) of the Uttarakhand Goods and Services Tax Act, 2017 requires a personal hearing whenever an adverse decision against a taxable person is contemplated, even if no separate request for hearing was made. An assessment order imposing tax and penalty without that opportunity is invalid. The assessment order was quashed, while the Department retained liberty to issue a fresh order after granting a hearing.

Statutory appellate remedies are the prescribed avenue for challenges to penalty proceedings involving alleged breaches of natural justice, insufficient time, the initiating officer's competence, and the applicable penalty provision. These grounds require examination of the adjudication record and statutory framework in appellate review. Writ intervention is not indicated absent an exceptional basis, while the appellate remedy remains available and the substantive challenges have not been finally examined.

GST assessment proceedings must be initiated against a living person; an assessment order issued in the name of a deceased sole proprietor has no legal effect unless the legal representative is brought into the proceedings. Section 93 permits recovery of the deceased person's GST dues from the business or estate, but does not validate an assessment made against the deceased. Such an assessment is invalid and liable to be set aside. Fresh assessment proceedings may be initiated only after notice to and an opportunity of hearing for the legal representative, with recovery confined to the deceased person's estate.

GST demand challenges involving alleged divergence between the show-cause notice and confirmed demand, tariff classification, applicable notifications, hearing rights, or cross-examination require factual scrutiny before the Appellate Authority. The statutory appellate remedy under the CGST Act provides for a hearing, prescribed pre-deposit, and consequential stay of recovery for the balance disputed amount. Writ jurisdiction under Article 226 should not be invoked where that efficacious remedy is available; such grievances must be pursued through the statutory appeal.