Interpretation of the saving provision under section 174(2)(e) of the Central Goods and Services Tax Act, 2017, is the issue raised in the writ petition. The High Court entertained the petition, directed affidavits, and listed the matter for final hearing. No final adjudication has been made on the scope or application of the saving provision.

Section 56(2)(x)(b) applies to immovable property received for inadequate consideration only where its temporal and valuation conditions are satisfied. A stamp-value difference alone does not establish taxability. Where consideration was fixed and substantial payments or contractual performance occurred before the charging provision commenced, later conveyance or registration does not by itself attract the later charge. Agreement-date valuation is available only for covered transactions where consideration was fixed and paid, wholly or partly, through prescribed banking or electronic modes on or before the agreement date. The tax authority must identify the correct statutory basis and provide a meaningful opportunity to respond.

GST seizure powers cannot be used to take cash as a general investigative measure or security for a possible tax demand. Currency is excluded from goods, and "things" is confined contextually to articles useful or relevant as evidence in GST proceedings. Valid seizure and retention require recorded statutory reasons, procedural compliance and observance of return timelines. Unauthorised retention engages property protections; later return does not cure the deprivation, and accrued interest is restitutionary rather than delayed-refund interest.

Under Section 37(1), salary expenditure is deductible only where it is actually incurred wholly and exclusively for business purposes and is supported by proof of genuine employment, services rendered, business nexus, and payment. Bank transfers and accounting entries alone are not conclusive. Where a third-party statement is central to an allegation of non-genuine salary, the taxpayer should receive disclosure and a meaningful opportunity to rebut it, including cross-examination where appropriate. A retracted and uncorroborated statement is vulnerable as the sole basis for disallowance.

Reassessment under the substituted Income-tax Act framework must comply with Sections 148, 148A, 149 and 151, with TOLA extending only qualifying statutory deadlines rather than preserving the repealed regime. Transitional notices issued between 1 April and 30 June 2021 and deemed Section 148A(b) notices leave only the time surviving to 30 June 2021, excluding deemed-stay and assessee-response periods; Section 148A(d) cannot enlarge Section 149 limitation. The first proviso to Section 149 prevents retrospective revival where the former limitation had expired, while valid approval remains jurisdictional. For Assessment Year 2015-16, post-1 April 2021 notices are time-barred and require determination before merits or other procedural objections.

Contractual GST reimbursement claims under Clause 2.14.A were treated as outside the scope of the arbitration clause. Availability of an arbitration agreement therefore did not justify refusing to entertain a writ petition seeking refund of the GST element. Competing interpretations of the contractual tax-reimbursement clause, together with all questions of law and fact concerning entitlement, remained open for merits determination. The High Court's dismissal orders were set aside, and the writ and review petitions were restored for adjudication in accordance with law.

Retrospective cancellation of GST registration cannot be imposed where the show-cause notice alleges non-operation from the declared place of business but does not propose cancellation for an earlier period. Such cancellation exceeds the scope of the notice. Where registration was previously restored for the relevant period after acceptance of the taxpayer's explanation, that circumstance further supports reconsideration. The cancellation was set aside, registration revived, and the notice remitted for fresh adjudication upon submission of a reply and supporting material, subject to costs.

Clause 42.1 requires the department to reimburse Central and State sales and other taxes paid by a works contractor upon proof of payment. Undisputed GSTR-3B forms establish payment of CGST and SGST for this purpose. Denial of reimbursement despite such proof is arbitrary, illegal and inconsistent with Article 14, since governmental authorities must act fairly and without arbitrariness in contractual dealings. Reimbursement of the documented CGST and SGST payments is required, with interest at 12% per annum from the respective tax-payment dates.

Delay in a statutory appeal against cancellation of GST registration was condoned where the appeal had been rejected solely as time-barred and the tax computation remained unadjudicated. Applying the cited precedent, the appellate remedy was restored to enable merits determination after hearing both sides. The appeal was revived, and the appellate authority was directed to decide the registration-cancellation dispute in accordance with law.

Anti-profiteering obligations in construction services require a commensurate price reduction only where implementation of GST yields an additional input tax credit benefit. Recalculation based on actual savings against total procurement showed that the post-GST input tax credit ratio had declined rather than increased. No additional credit benefit accrued to the construction-service supplier, so purchasers were not entitled to a corresponding price reduction. The re-investigation report was accepted, and no contravention of the statutory anti-profiteering obligation was established.

Rule 92(3) requires Form GST RFD-08 notice, consideration of the refund applicant's reply, and a pre-decisional hearing before accumulated input tax credit refunds may be wholly or partly rejected. These safeguards identify the alleged input tax credit mismatch and permit a specific response. An appellate hearing cannot replace those mandatory steps. Refund rejections issued without them are void from inception and require fresh processing, with substantive eligibility issues remaining open.

SUV Compensation Cess classification requires cumulative satisfaction of the prescribed conditions. Ground clearance is measured in the vehicle's unladen delivery state; the later express definition of unladen clearance applies prospectively but confirms that the earlier entry did not require measurement in a laden condition. Manufacturer specifications are relevant evidence, while ARAI certification is relevant technical material but is neither conclusive nor wholly excludable for classification. Hyundai Creta, Alcazar and Tucson were classified under the higher Compensation Cess entry, sustaining differential cess. Suppression of facts with intent to evade tax was established, permitting extended recovery of short-paid cess with consequential interest and penalties.

Net input tax credit verification must consider reversals reported in GSTR-3B; gross differences between GSTR-3B and GSTR-2A alone do not establish excess credit. Output-tax variances between GSTR-9 and GSTR-9C require examination of the reconciliation statement, sales ledgers, invoices and financial records, rather than a portal-field comparison. For Rules 42 and 43, proportional reversal relating to exempt supplies requires segregation of actual common credit from specific credit and application of the exempt-to-taxable turnover ratio only to that common-credit pool. The demands were set aside and remanded for fresh verification and de novo adjudication.

Post-supply discounts under section 15(3) regulate exclusion from the supplier's taxable value; they do not automatically permit a recipient to reduce its own outward taxable turnover or output tax liability. Their treatment requires examination of credit notes, invoice linkage, prior agreement, the supplier's return treatment, and the recipient's input tax credit position. Mere disclosure in GSTR-9C cannot alone support an output-tax demand without proof of an actual reduction in outward turnover or tax liability. Appellate and adjudication orders were set aside for fresh inquiry, confined to allegations in the existing show cause notice; a new claim that incentives were consideration for promotional services could not be introduced at the appellate stage.

Unchallenged advance rulings bind the applicant and jurisdictional officer unless appealed, rectified, or declared void; a belated jurisdictional objection cannot be used in appellate proceedings to examine the ruling where statutory challenge mechanisms were not invoked. A departmental circular cannot impose GST or fix an 18% rate contrary to the applicable rate notification, nor retrospectively displace a subsisting ruling. Recovery of refunds as erroneous solely on that circular was unsustainable. Refund demands also cannot rest on grounds outside the show cause notice; where the recipient bore the tax incidence, submitted the prescribed certificate, and reversed input tax credit, objections based on supplier-only entitlement and unjust enrichment failed. Recovery, interest, and penalty were set aside.

AAAR appellate jurisdiction over a GST advance ruling is confined to the ruling challenged and the factual matrix examined by the original advance-ruling authority. A subsequently presented soap product, revised packaging and a fresh test report could not support appellate determination where they lacked a documented link to the original product and materially differed in appearance, description and packaging. Classification of the later product would require an original examination of its composition, specifications, labelling, intended use and commercial identity. The appeal was rejected without deciding the merits of the original classification ruling, leaving the later product's classification and tax treatment to available legal remedies.

Section 127 transfer of assessment following a search centralises proceedings involving entities connected with the investigation; it does not finally determine tax liability. Where an assessee's name emerges in search material, coordinated investigation and centralised assessment may justify transfer to a Central Circle. The assessee remains entitled to receive relevant material during assessment and to contest the matter on merits. Transfer is not arbitrary or prejudicial merely because assessment is moved where centralisation is required for coordinated investigation.

Reassessment initiation requires a show-cause notice issued within the applicable limitation period and accompanied by transaction-specific information suggesting income escapement. The information must identify the transaction, the basis of proposed escapement and sufficient particulars to enable an effective response; merely stating an alleged escaped amount is insufficient. Later disclosure cannot cure an initiation lacking those foundational particulars within time. For proportionate rights-share allotments, fresh shares are distinct from pre-existing shares transferred by another person. Where an existing shareholder's percentage holding remains unchanged and no disproportionate benefit arises, the difference between subscription price and fair market value alone does not establish receipt of property for inadequate consideration under Section 56(2)(x).

Reassessment based solely on transfer-pricing material already examined in scrutiny proceedings is impermissible where the earlier assessment lapsed because no final order followed the draft assessment order within the prescribed period. Without fresh material, reopening would circumvent the statutory time limit for completing assessment and allow the Revenue to benefit from its own omission. The reassessment notices and the order under section 148A(3) were quashed, and the writ petition was allowed.

Common appellate remand orders must address year-specific findings where the record contains a reasoned appellate decision on the same issues. Restoring Assessment Years 2012-13 and 2013-14 solely by applying the finding for the earlier year, without examining the detailed reasoning for 2013-14, amounted to non-application of mind. Because the material, appeal grounds and cross-objections were before the Tribunal, merits required adjudication rather than a mechanical remand. The common remand order was quashed, and both appeals were returned for fresh determination on merits after hearing the parties.