GST appeal limitation may not be triggered merely by uploading an order-in-original on the common portal where the taxpayer specifically asserts non-service and lacks acknowledged receipt or participation. Although the Appellate Authority is bound by the statutory limitation under Section 107 and cannot itself condone delay, merits adjudication may be required where delay arose from circumstances beyond the taxpayer's control. The appeal was restored for adjudication on merits after the delay was condoned, subject to compliance with the stipulated pre-deposit requirement.

Section 107 of the Central Goods and Services Tax Act, 2017 requires an appeal to be filed within three months of communication of the adjudication order, with condonation available only for a further one month upon sufficient cause. The Appellate Authority has no jurisdiction to condone delay beyond that expressly limited period. Consequently, an appeal filed approximately two years after the original order cannot be entertained, particularly where the delay is not properly explained, and dismissal as time-barred stands upheld.

Transfer of a taxpayer's GST audit file from the Audit Wing to the Anti-Evasion Wing within the same Commissionerate is an administrative exercise. The Central Goods and Services Tax Act, 2017 contains no statutory prohibition on such transfer, so transfer alone does not warrant writ interference. Non-production of requested financial documents during audit was also recorded. Objections concerning the statutory period for completion of the audit may be raised before the Adjudicating Authority. The transfer therefore remains unaffected in writ jurisdiction.

GST registration restoration and time to pay late fee may be sought through a representation to the jurisdictional Superintendent where financial hardship and loss of portal access are asserted. The Superintendent has discretion to consider exceptional circumstances, so no mandatory direction for restoration or deferred payment follows. A request may be submitted within four weeks and must be considered and decided within one month of submission.

Challenges to a GST demand as time-barred under Section 74(10) require examination of the demand's nature, underlying proceedings and factual basis to identify the applicable limitation starting point. Where that inquiry involves debatable factual and legal issues, the statutory appellate remedy is the appropriate forum rather than writ jurisdiction. The taxpayer was therefore directed to pursue an appeal, with the Appellate Authority to pragmatically consider any request to exclude the period spent in writ proceedings under Section 14 of the Limitation Act, 1963.

GST Tribunal availability provides an efficacious statutory appellate remedy against cancellation of GST registration and rejection of a revocation application. Extraordinary writ jurisdiction should therefore not be exercised where the Tribunal can adjudicate the challenge on merits. All issues and contentions remain open before the Tribunal, and time spent bona fide pursuing the writ remedy is excluded for limitation if the Tribunal is approached within the stipulated period. The challenge must proceed before the GST Tribunal rather than through the writ petition.

Revocation of GST registration cancellation cannot be rejected without a proper and effective opportunity of hearing under the first proviso to Section 30(2). Effective hearing requires prior notice of the appointed date and time; a show-cause notice merely referring to a possible personal hearing is insufficient. Rejection based solely on failure to submit a reply, without specifying the hearing schedule, also lacks valid procedural basis where the order is cryptic and non-speaking. The revocation application must be reconsidered after due notification and an opportunity for personal hearing.

Principles of natural justice require effective notice and a meaningful opportunity to respond. Uploading a show-cause notice solely under the "Additional Notice and Orders" tab without separate intimation prevented the petitioners from responding within time, creating a prima facie procedural breach. Dismissal of the statutory appeal on limitation without examining merits was therefore set aside. The appeal was directed to be admitted and reconsidered on merits after hearing the petitioners.

GST refund cannot be withheld merely because a Revenue appeal is pending. Rule 90(3) permits deficiencies in a refund application to be communicated through Form GST RFD-03, but it does not substitute for the statutory withholding mechanism. Withholding under Section 54(11) requires the Commissioner to exercise that power through a specific, reasoned order after issuing notice and providing an opportunity of hearing. In the absence of such an order, pendency of an appeal does not justify withholding the claimed refund.

Service of a show cause notice under Section 73 of the CGST Act is not sufficiently established merely by uploading it on the common portal where the assessee neither acknowledges receipt nor files a reply. Ex parte adjudication on that basis denies an effective opportunity to respond and be heard. The ex parte order was set aside, proceedings were restored to the show cause notice stage, and the assessee was permitted to submit a reply. A fresh order must follow a hearing and be passed in accordance with law.

Effective statutory appellate remedy against a fresh GST adjudication order ordinarily requires the taxpayer to pursue objections before the appellate authority rather than invoke writ jurisdiction. Challenges to the maintainability of a subsequent show-cause notice and a claimed earlier dropping of proceedings may be raised in that appeal. The appellate authority may consider excluding the period spent pursuing writ proceedings when assessing limitation. The writ challenge was not entertained on merits, and the taxpayer was relegated to the statutory appeal mechanism.

Section 148 permits the Government to notify classes of registered persons and prescribe special procedures for registration, returns, payment and administration. Notification No. 22/2024-Central Tax prescribes a six-month period for seeking rectification to claim the benefit of retrospective Section 16(5). The central issue is whether that limitation validly reflects the safeguards inherent in Section 148, particularly where no mechanism extends the period in extraordinary circumstances. The power to prescribe a special procedure was provisionally recognised, while the validity of the six-month limitation remains for further consideration.

Denial of a requested personal hearing in adjudication violates the principles of natural justice and renders the resulting order unsustainable. The adjudicating authority must independently consider the reply to the show-cause notice and give reasons for accepting or rejecting the explanation; treating the reply as a mere formality is impermissible. The adjudication order was set aside, and the assessee became entitled to fresh adjudication on merits after a reasonable opportunity of hearing.

GST registration cancellation requires strict compliance with Form GST REG-17 and Rules 22(1) and 25. A show-cause notice must state the grounds, allow a reply and specify the date and time for personal hearing; omission of hearing particulars breaches the prescribed procedure and natural justice. Physical-verification reports, supporting documents and photographs must also be uploaded in Form GST REG-30 within the stipulated period before cancellation. Availability of registration-revocation proceedings does not preclude writ jurisdiction where these procedural safeguards are violated. Non-compliance invalidates the cancellation notice and consequential registration-cancellation order.

Passport renewal for an accused on bail under the Central Goods and Services Tax Act should not be restricted below the regular ten-year term without a plausible justification, substantive harm, or reasonable apprehension of absconding. Continuing conditions requiring prior court permission for foreign travel and monitoring safeguards apply regardless of passport validity. Family ties, residence, business, and immovable property in India materially reduce absconding risk. Renewal was therefore directed for the regular ten-year period, subject to all existing conditions governing foreign travel and passport use.

Transitional SGST credit may support a refund claim only where it is carried forward through the prescribed TRAN-1 declaration and demonstrably credited as opening balance in the Electronic Credit Ledger on 1 July 2017. Without the declaration or satisfactory proof of ledger credit, refund of unutilised transitional credit is unavailable. Statutory appellate and revisional remedies must be pursued within prescribed limitation; Article 226 ordinarily cannot revive a time-barred challenge to an assessment order or bypass the legislative scheme of finality. The assessment denying the refund therefore remains undisturbed.

Adjudicatory and quasi-judicial authorities must independently verify all AI-generated legal material against primary sources, cite only accurate and relevant precedents, consider taxpayer authorities, and apply their own mind. Artificial intelligence may assist legal research but cannot replace authentic verification or reasoned decision-making; the issuing officer remains responsible for legal correctness. Reliance on non-existent or irrelevant AI-generated authorities renders the decision-making process defective and may breach applicable departmental instructions. The show-cause notice, cancellation, revocation-rejection and appellate orders were quashed for fresh proceedings, requiring a new notice, consideration of the taxpayer's reply and defence, and a reasoned determination according to law.

Anticipatory bail in alleged fake GST registration fraud may be refused where investigation yields technical links between GST filing credentials and the accused, alongside allegations of creating fictitious entities and receiving client payments. Non-cooperation with the investigation, the need for further technical inquiry, and the justification for custodial interrogation weigh against pre-arrest protection. Alleged misuse of PAN cards and personal credentials, wider economic repercussions, and involvement in other financial-fraud matters further support refusal of anticipatory bail.

Use of AI-generated legal material in quasi-judicial orders requires independent verification, human oversight, and the issuing officer's own application of mind. Reliance on non-existent or irrelevant AI-generated precedents prompted an unconditional apology, and non-compliance with departmental safeguards was directed to be treated as contempt of court. GST registration cancellation proceedings were quashed because the authorities proposed to revise the challenged orders and issue a fresh notice. Fresh adjudication must consider the taxpayer's reply and defence and result in a reasoned order in accordance with law; the merits remain open.

Transitional SGST input tax credit refund requires proof that the unutilised erstwhile-regime credit stood as an opening balance in the Electronic Credit Ledger on 1 July 2017. In the absence of the prescribed TRAN-1 declaration or other satisfactory evidence of that balance, the refund claim fails. Writ jurisdiction under Article 226 ordinarily cannot be used to revive a statutory challenge after the taxpayer's own default has allowed the appeal limitation to expire, particularly where the delay is inordinate. The writ petition was dismissed because the transitional credit was unsubstantiated and the statutory appellate remedy had become time-barred.