https://www.taxtmi.com/caselaws?id=800154 Section 122(1A) of the CGST Act extends penalty exposure to any person, including non-taxable or unregistered persons, only where both conditions are established: retention of benefit from a specified Section 122(1) transaction and conduct of that transaction at the person's instance. Its penal consequences require prospective application, so it applies only to underlying acts or transactions occurring on or after 1 January 2021, not by reference to the show-cause notice date. Statutory appellate remedies do not prevent consideration of recurring pure legal questions, while transaction dates and proof of the twin conditions require evidentiary determination in the appellate process. en-us Tue, 29 Sep 2026 00:00:00 +0530 Thu, 01 Oct 2026 07:40:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800154 Section 122(1A) of the CGST Act extends penalty exposure to any person, including non-taxable or unregistered persons, only where both conditions are established: retention of benefit from a specified Section 122(1) transaction and conduct of that transaction at the person's instance. Its penal consequences require prospective application, so it applies only to underlying acts or transactions occurring on or after 1 January 2021, not by reference to the show-cause notice date. Statutory appellate remedies do not prevent consideration of recurring pure legal questions, while transaction dates and proof of the twin conditions require evidentiary determination in the appellate process. Case-Laws GST Tue, 29 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800154