Rule 86A of the CGST Rules permits temporary restriction only of input tax credit available in the Electronic Credit Ledger when the prescribed officer records reasons to believe that the credit was fraudulently availed or is ineligible. Credit availability at the time of invocation is a condition precedent. The rule does not authorise departmental debit entries, negative blocking, or restrictions exceeding the ledger balance. Although prior notice is unnecessary for an emergent restriction, recovery of wrongly availed or utilised credit must proceed under the statutory recovery mechanism. Restrictions beyond available credit are invalid.

Delayed GST appeals filed beyond the ordinary and condonable periods under Section 107 may, in peculiar circumstances involving factual questions requiring appellate examination, receive a further opportunity for merits adjudication. The delay was condoned, the dismissal and rectification orders concerning the appeal were quashed, and the appeal was restored for adjudication after adequate hearing.

Reliance on AI-generated legal authorities was questioned where the impugned tax order appeared to rest exclusively on cited decisions that may be nonexistent or inapplicable. Revenue authorities were required to obtain instructions confirming the existence and applicability of those authorities. Further consideration was retained, with potential directions for the issuing officer's presence and further action depending on verification. The matter remains listed for further hearing.

GST demand proceedings initiated against a deceased sole proprietor are invalid where show cause notices and the consequential demand order are issued in the deceased person's name. The proprietorship registration had been cancelled, while the legal heir was unconnected with the business and unaware of portal communications, leaving no effective opportunity to respond. The notices and demand order were quashed, without preventing lawful proceedings against the legal heir for any outstanding GST liability.

A timely rectification application under Section 161, decided by a reasoned order, governs computation of the limitation period for an appeal under Section 107 against a refund rejection. Limitation must run from the date of the rectification order rather than solely from the original adjudication order. Computing limitation only from the original refund-rejection order, without accounting for the rectification decision, improperly treats the appeal as time-barred. This principle applies where the statutory rectification application was filed within the prescribed period and was subsequently decided.

Input tax credit mismatch demands based on differences between FORM GSTR-3B and FORM GSTR-2A require verification under Circular No. 183/15/2022-GST. The proper officer must obtain invoice-related details from the registered person and verify compliance with the conditions for input tax credit under Section 16 before confirming a demand. Where an ex parte assessment is issued without that exercise, the demand requires fresh consideration after permitting supporting evidence and providing a reasonable opportunity of hearing. The ex parte adjudication order was quashed and the demand was remitted for reconsideration under the circular and applicable law.

Rejection of a GST rectification application without effective communication of the rejection order was legally untenable, particularly where technical portal glitches prevented generation of the order and the order-sheet date conflicted with the handwritten date. The lack of communication deprived the assessee of an effective opportunity to challenge or pursue rectification. The application must be reconsidered with the supporting records and explanation, especially as adequate opportunity was not afforded during the original proceedings. The rejection was set aside, and the competent authority must provide a hearing and communicate a reasoned order.

Portal-generated order discrepancies and non-communication rendered the rejection of a rectification application legally untenable. The order-sheet recorded that the rejection order could not be generated because of portal technical glitches, while the purported order carried a later handwritten signature date, creating an unresolved inconsistency. The High Court quashed the rejection and remanded the rectification application to the competent authority for fresh, reasoned disposal after giving the petitioner an adequate hearing and promptly communicating the order.

For input tax credit mismatches between FORM GSTR-3B and FORM GSTR-2A, the prescribed Circular requires the proper officer to obtain invoice details from the registered person and verify satisfaction of credit-availment conditions before confirming a demand. An ex parte demand was set aside because that verification had not occurred. Fresh consideration was directed on the taxpayer's representation, in compliance with the Circular and after a reasonable opportunity of hearing, without determination of the merits of the credit claim.

GST appeal limitation must be computed from a reasoned rectification order under section 161 where the rectification application was filed within the prescribed period and duly decided. The rectification proceedings directly affect the limitation period for challenging rejection of a refund claim; the Appellate Authority cannot calculate limitation solely from the original adjudication order. Rejection of the refund appeals as time-barred on that basis was impermissible. The appellate orders were quashed, and the matters were remanded for fresh adjudication on merits after hearing the petitioners.

GST show cause and demand proceedings initiated against a deceased sole proprietor, after death and cancellation of the proprietorship registration, cannot be sustained. The legal heir was unconnected with the business and unaware of proceedings conducted through the GST portal. The High Court quashed the notices and consequential demand order, while preserving the authority's right to commence proper proceedings in accordance with law against the legal heir for any outstanding demand.

Reliance exclusively on AI-generated case laws in a State Tax Officer's order prompted High Court scrutiny. The AGP was directed to obtain instructions on whether the cited authorities exist and are relevant to the issue. Failing such instructions, the High Court indicated it would require the officer's personal presence. If the cited case laws are non-existent or do not remotely apply, the High Court indicated that appropriate action against the officer may follow. Instructions were required by the next hearing date.

Condonation of delay in a GST appeal was granted despite filing beyond the period under section 107 because factual questions required appellate adjudication. Applying the approach in Simplex Infrastructures Ltd. in the peculiar circumstances, the High Court held that the taxpayer should receive a further opportunity to pursue the statutory appeal. The time-bar dismissal and consequential rectification order were quashed, and the appeal was restored for decision on merits after a proper hearing. All substantive contentions remained open.

Rule 86A permits only a temporary restriction on debiting input tax credit that is available in the electronic credit ledger when the rule is invoked and its conditions are met. Availability of credit is a condition precedent; the provision does not authorise authorities to create debit entries or impose a negative ledger balance. Blocking was therefore invalid to the extent it exceeded the credit then available. Wrongly availed or utilised credit must instead be recovered through the statutory remedies available under law.

Composition-scheme eligibility lapses automatically on the day aggregate turnover exceeds the prescribed threshold. Supplies made thereafter are taxable under the regular scheme, with adjustment for composition tax paid on post-lapse turnover; the cessation of composition eligibility was sustained. For post-lapse supplies where tax was not separately collected, invoice values must be treated as tax-inclusive because a composition taxpayer cannot collect tax separately and no additional collection was alleged. Rule 35 requires extraction of the tax component from the cum-tax value. Differential tax, and consequential interest and penalty, must therefore be recomputed on that basis.

Actuarial deficit contributions to an approved superannuation fund are characterised by their purpose. Contributions made to bridge actuarially determined deficits, including prior-year deficiencies, are ad hoc gap-filling payments rather than ordinary annual contributions subject to the Rule 87 ceiling or initial contributions. Recurrence of deficits does not alter that character. Applying the ceiling to contributions necessary to meet actuarial liabilities could impair the fund's solvency and conflict with the deduction scheme for approved superannuation funds. On that basis, disallowance of the actuarial deficit contributions was deleted and the revenue's appeal failed.

Actuarial deficit contributions made to an approved superannuation fund to align fund assets with actuarial liabilities are distinguished from ordinary annual or initial contributions. Because their purpose is to remedy an actuarial shortfall, they are not subject to the Rule 87 ceiling on annual contributions, preserving the fund's solvency. Similarly, contributions bridging actuarial liability and available assets in an approved gratuity fund are not ordinary annual contributions subject to the Rule 103 ceiling. Unless approval is formally withdrawn, the assessing authority must accept the fund's approved status and cannot, during assessment, question compliance with the Rules to restrict the deduction.

Actuarial-deficit contributions to an approved superannuation fund are distinguished from ordinary annual and initial contributions by their purpose. Ad hoc payments required to align fund assets with actuarial liabilities and cure accumulated funding deficiencies fall outside the Rule 87 ceiling for ordinary annual contributions; applying that ceiling could undermine the fund's solvency and the deduction framework for approved funds. A reasoned appellate determination based on jurisdictional precedent is not perverse or arbitrary merely because the revenue disputes its application. The disallowance of actuarially determined deficit contributions was deleted, and the revenue's challenge failed.

Interest on bank fixed deposits held in a trust's name constitutes the trust's income, even where the funds are intended for Self-Help Groups. Corpus exemption requires a specific written direction from the donor; correspondence allowing distribution of refunded funds did not direct that deposit interest form part of the corpus. A later obligation to allocate funds to Self-Help Groups is application of income, not diversion at source. The trust cannot claim tax deducted at source credit while excluding the interest from revenue receipts. The interest was taxable as revenue income, and its addition was affirmed.

The doctrine of merger applies where the Appellate Tribunal has passed a final order in an appeal: prior interlocutory orders, including a recall order, merge into the final appellate order and cease to have independent existence. A writ petition challenging the recall order therefore cannot survive once the final order is challenged through the available statutory tax appeal. The challenge to the final order must be pursued in that statutory appellate remedy, and the writ petition was dismissed.