Raj Jaggi
CHARTERED ACCOUNTANT, COMPANY SECRETARY AND COST ACCOUNTANT
Contact Info
CA. Raj Jaggi is a Chartered Accountant based in New Delhi, primarily practising in the field of Goods and Services Tax (GST) consultancy, litigation support, and advisory services. After being associated for nearly nineteen years, from June 2007 to March 2026, with the leading indirect tax firm A.K. Batra and Associates, he has now started his own independent professional practice with a focused specialization in GST consultancy and allied indirect tax matters.
Over the years, he has developed a strong inclination towards professional writing, research, and analytical commentary on evolving issues under GST and indirect taxation laws. During the past one year alone, more than 250 of his articles have been published on various reputed online tax and professional platforms such as CAclubIndia, VATINFOLINE, VILDirect, and TaxTMI. In addition, a few of his professional articles have been published in The Chartered Accountant Magazine and in the December 2025 issue of the NIRC Newsletter of ICAI.
His writing style combines legal analysis with practical insight, lucid narration, and motivational reflections, making complex GST provisions easier to understand for professionals, students, and industry readers alike. Besides writing on Indirect Taxes, he occasionally writes on a wide range of other topics such as motivational topics, topics related to famous personalities, etc.
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Showing 1 to 20 of 265 Results
GST confiscation challenges require established jurisdictional or natural justice defects before writ jurisdiction can displace the statutory appeal.
GST confiscation challenges ordinarily proceed through the statutory appeal. Direct writ intervention requires an established jurisdictional defect, genuine denial of natural justice, infringement of fundamental rights, or a challenge to the governing law. Allegations concerning document supply, hearing, evidentiary evaluation, findings or reasons must be tied to a specific defect; where they require examination of the record, they generally remain matters for appellate review. Compliance with filing conditions, including limitation and pre-deposit requirements, remains necessary. (AI Summary)
Goods and Services Tax - GST
Unconditional writ withdrawal bars renewed challenges to the same GST adjudication order despite new grounds or later procedural liberty.
Unconditional withdrawal of a writ petition without express liberty to file afresh ordinarily abandons the Article 226 remedy for the same cause of action. Changes in drafting, additional legal grounds, or challenges to related proceedings do not create a fresh cause where the substantive target remains the same GST adjudication order. Later liberty cannot retrospectively cure an earlier unconditional withdrawal. Article 226 also cannot ordinarily replace a statutory appeal that has lapsed without satisfactory explanation. The procedural restriction concerns maintainability and does not determine the substantive validity of the underlying tax demand. (AI Summary)
Goods and Services Tax - GST
Pre-deposit timing in GST appeals depends on final acknowledgement, allowing defects cured during Registry scrutiny before legal filing.
Rule 110 separates electronic presentation from legal filing. A Provisional Acknowledgement records receipt of Form GST APL-05 and permits Registry scrutiny; under the Explanation to Rule 110(4), an appeal is treated as filed only upon a Final Acknowledgement carrying an appeal number. A pre-deposit required during scrutiny, if paid within the permitted defect-removal period and before Final Acknowledgement, meets the timing requirement for final filing. This mechanism permits cure of a pre-deposit deficiency but does not waive the payment condition. (AI Summary)
Goods and Services Tax - GST
Urgent appellate listing may precede Registry scrutiny where continued GST cancellation threatens business continuity, without waiving statutory conditions.
Urgent listing of a GST appeal may precede ordinary Registry scrutiny where cancellation of registration causes continuing commercial prejudice and delay may make appellate recourse practically ineffective. Sufficient cause requires exceptional, supported circumstances showing ongoing harm, not merely a request for priority. Registry scrutiny remains applicable, but its sequence may be adjusted under procedural powers. Early listing concerns scheduling only and does not waive limitation, statutory pre-deposit, prescribed fee, maintainability, defects or other mandatory conditions governing the appeal. (AI Summary)
Goods and Services Tax - GST
Service-provider composition levy limits eligibility through PAN-level turnover, intra-State supplies, no input tax credit, and restricted platform services.
Section 10(2A) provides a residual composition levy for eligible service providers and mixed suppliers who cannot enter the conventional composition scheme. Eligibility depends on PAN-level aggregate turnover within the prescribed ceiling, collective election by all registrations under the PAN, and continuous compliance during the year. The combined 6% tax applies to turnover of supplies rather than profit, while composition taxpayers cannot collect tax separately or claim input tax credit. Inter-State outward supplies and platform-based services through specified electronic commerce operators remain restricted, and reverse-charge tax continues at regular rates. (AI Summary)
Goods and Services Tax - GST
Premature writ intervention in GST audit disputes requires taxpayers to first pursue statutory adjudication where factual issues remain unresolved.
Audit findings may identify discrepancies and support further action, but they do not create an enforceable tax liability. A show-cause notice initiates statutory adjudication, in which the taxpayer may contest the proposed demand through records, evidence and legal submissions. Rule 101(4) requires genuine consideration of the audit reply, though a brief response does not by itself establish complete non-consideration. The Adjudicating Authority must independently examine limitation, computation, audit scope, the legal basis of the demand, and whether a Form GST DRC-03 payment was voluntary or lawfully appropriable. (AI Summary)
Goods and Services Tax - GST
Alternative statutory remedy governs GST classification disputes where jurisdiction and natural-justice objections require factual and evidentiary examination.
GST classification disputes involving tariff treatment, exemption eligibility and alleged excess beyond a show-cause notice ordinarily engage the statutory appellate remedy rather than direct writ review when the asserted jurisdictional defect cannot be separated from contested facts. Section 75(7) confines a final tax demand to the amount and grounds specified in the show-cause notice. Classification of animal-feed supplements between Heading 2309 and Heading 3004 depends on evidence such as product composition, principal use, labels, dosage, trade understanding and technical material. (AI Summary)
Goods and Services Tax - GST
Personal GST penalty requires retained benefit and proof that the individual caused the transaction, with prospective application.
Section 122(1A) reaches an unregistered individual who retains the benefit of specified invoice or input-tax-credit contraventions and causes the transaction to be conducted. Personal liability requires proof of both retained benefit and control, direction, or causation; designation or managerial participation alone is insufficient. The mechanism does not create automatic vicarious liability for directors or employees. Effective from 01.01.2021, it applies prospectively according to the date of each underlying transaction, not the date of the show-cause notice or adjudication. (AI Summary)
Goods and Services Tax - GST
Input tax credit reversals require transaction-specific inquiry, purchaser evidence, disclosure, and reasoned findings; supplier default alone is insufficient.
GST input tax credit is conditioned on the tax charged on a supply having been paid to the Government. A recipient's full payment of the invoice, including GST, settles the recipient-supplier obligation but does not by itself establish Government payment. Supplier non-payment, a retrospective registration cancellation, or an alert may justify inquiry, but cannot alone establish that the recipient's credit is inadmissible. The recipient must substantiate commercial reality through invoices, proof of receipt, transport and stock records, banking evidence, and other contemporaneous material, while the officer must evaluate that evidence through a transaction-specific and reasoned process. (AI Summary)
Goods and Services Tax - GST
Additional court-fee compliance in GST appeals remains distinct from statutory pre-deposit and may be cured to secure merits review.
Additional court-fee liability on a State GST appeal may operate separately from the statutory pre-deposit required under Section 107. The fee must be supported by the applicable State legislation and notification in force when the appeal was filed; a later notification cannot ordinarily impose a new liability retrospectively. Non-payment of a lawful court fee is a curable procedural defect and should be addressed before merits review. Where the first appellate authority has not considered the tax dispute, substantive issues should ordinarily remain for first-appellate determination after payment and a proper hearing. (AI Summary)
Goods and Services Tax - GST
GST taxability of leasehold assignments must be determined before input tax credit restrictions and fraud-based recovery provisions apply.
Taxability must be determined before input tax credit eligibility. A blocked-credit inquiry presupposes a taxable inward supply on which tax has been lawfully charged. Where an assignment is outside the charge of GST, denial or reversal of input tax credit cannot retain the economic burden of an invalid levy. The restriction on credit for construction of immovable property applies only where expenditure has a clear nexus with construction-related activity on the taxable person's own account. Acquisition of existing leasehold rights without construction does not satisfy that requirement merely because the rights concern land. (AI Summary)
Goods and Services Tax - GST
E-way bill vehicle mismatches and unexplained expiry can turn a technical lapse into serious transit documentation non-compliance.
An expired e-way bill does not by itself establish tax evasion, but expiry coupled with a vehicle wholly different from that recorded in Part B, unexplained delay or route deviation, and absent contemporaneous evidence may constitute substantive transit-documentation non-compliance. Part B must identify the vehicle actually transporting the goods and must be updated after transshipment. Minor-error relaxation does not automatically cover a complete vehicle mismatch. Credible records are required to rebut the presumption arising from movement without a complete and valid e-way bill. (AI Summary)
Goods and Services Tax - GST
GST appellate pre-deposit requirements are satisfied where earlier deposits exceed the tax surviving after first appellate relief.
GST appellate pre-deposit must be assessed against the tax actually remaining in dispute after first appellate relief. Although deposits at the first appellate and Tribunal stages ordinarily operate cumulatively, they do not create unrelated liabilities arising from the same tax dispute. Where the reduced demand is accepted and an earlier deposit exceeds the aggregate prescribed requirement for the surviving tax, the revenue stands sufficiently secured and no duplicate deposit is required. Tribunal fee compliance remains an independent condition, and further deposit is necessary where the earlier payment is insufficient. (AI Summary)
Goods and Services Tax - GST
Unaccounted stock requires tax determination before confiscation, while fines cannot survive without valid confiscation proceedings.
Unaccounted goods must ordinarily be addressed through tax determination under Section 35(6), read with Sections 73 or 74, rather than through automatic confiscation. The proper officer must determine quantity, value, tax period, taxability, applicable rate, and the taxpayer's explanation through a notice-based adjudicatory process. Confiscation under Section 130 requires independent proof of its statutory conditions and cannot replace tax assessment. A fine in lieu of confiscation depends upon valid confiscation proceedings and cannot survive independently where that foundation is absent. (AI Summary)
Goods and Services Tax - GST
GST appellate pre-deposit requires separate satisfaction of admitted tax payment and percentage deposit on genuinely disputed tax.
GST appellate pre-deposit conditions require separate satisfaction of two cumulative obligations: full payment of admitted tax and related dues, and deposit of the prescribed percentage of remaining disputed tax. A voluntary payment through a belated Form GSTR-3B return, without protest and accompanied by acceptance of related interest, retains the character of admitted self-assessed tax even if later appropriated against a confirmed demand. Payment during investigation may be considered towards disputed-tax deposit only where contemporaneous evidence establishes that it was made under protest for a liability that remained contested. (AI Summary)
Goods and Services Tax - GST
Workplace humour supports leadership trust, emotional resilience, and respectful relationships when it remains inclusive, proportionate, and free from humiliation.
Appropriate workplace humour can coexist with serious professional purpose, enabling proportionate responses to mistakes, pressure and disagreement without reducing responsibility. In leadership, self-aware and respectful humour may reduce psychological distance, encourage candid feedback and timely disclosure of problems, and strengthen trust and psychological safety. It must not become sarcasm, ridicule, personal insult or humour directed at characteristics or mistakes of persons with less power. Its value depends on context, restraint, authenticity and whether it preserves every participant's dignity. Professional achievement is strengthened by humility, emotional accessibility, gratitude and the ability to remain connected to colleagues and family. (AI Summary)
Other Topics
Inverted-duty GST refunds depend on higher-taxed processing inputs, while appellate re-quantification may implement final eligibility without fresh adjudication.
Inverted-duty GST refund eligibility under Section 54(3)(ii) depends on whether unutilised input tax credit arises because eligible inputs bear higher tax rates than outward supplies. Higher-taxed chemicals, dyes, reagents and consumables used in processing lower-taxed fabric must be considered; a common HSN classification or the status of an input as non-principal does not negate rate inversion. Circular No. 135/05/2020-GST concerns identical goods sold at lower rates after a rate reduction, not multi-input processing. Once appellate eligibility is finally decided, verification and calculation under Rule 89(5) are consequential, not a remand. (AI Summary)
Goods and Services Tax - GST
Input tax credit adjudication must precede refund exclusion, preserving notice-based due process and preventing collateral credit disallowance.
Refund authorities may verify entitlement, computation and formula-based exclusions under Section 54 and Rule 89(5), but cannot determine that already availed input tax credit is substantively ineligible through refund adjudication. Allegedly wrongly availed credit requires separate determination under Sections 73 or 74. A notice proposing rejection must identify disputed transactions, statutory grounds and computation; a vague allegation of "wrong ITC" is insufficient. Appellate examination cannot introduce a new factual basis absent from the original notice. (AI Summary)
Goods and Services Tax - GST
Period-specific ITC reversals affect zero-rated export refunds only when reversed credit formed part of current-period Net ITC.
Refunds of accumulated Compensation Cess credit on zero-rated exports must be calculated from Net ITC actually availed during the relevant period. A reversal recorded in Form GSTR-3B within that period affects the formula only where the reversed credit was availed and included in that period's Net ITC. Historical credit reversed during the period, but never included in the current computation, cannot be deducted merely because of the timing of the entry. Administrative clarification and income-tax accounting cannot add conditions absent from the statutory formula. (AI Summary)
Goods and Services Tax - GST
Curative GST refund formula supports retrospective differential claims when applications meet limitation and substantive eligibility requirements.
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. (AI Summary)
Goods and Services Tax - GST
TaxTMI 
TaxTMI 
10 Oct 2026 
3 Replies 
