GST writ jurisdiction is generally not exercised where effective statutory appellate remedies are available. A GST show-cause notice and demand order remained subject to appeal before the appellate authority and further recourse before the GST Tribunal. The portal record showed that the notice concerning mandatory personal hearing was visible to the taxpayer. All objections, including the alleged denial of a personal hearing, may be raised in the statutory appeal; the writ petition was therefore not entertained.

Assignment by sale or transfer of long-term leasehold rights in land and building transfers benefits arising from immovable property, with the assignee stepping into the original lessee's position. Such assignment falls outside the scope of taxable supply under Section 7(1)(a), read with Schedule II and Schedule III, and is therefore not chargeable to GST under Section 9. Input tax credit cannot arise for payment of GST on this non-taxable transaction. Consequently, a GST show-cause notice and demand founded on taxability of the leasehold-right assignment are unsustainable.

A binding High Court precedent governing a sanctioned refund required the appellate order to be quashed after the Supreme Court dismissed the challenge to that precedent. The appellate authority had proceeded on the incorrect basis that the governing ruling remained under challenge and acknowledged that the ruling had not been brought to its attention; it also took corrective action in a subsequent matter. The assessee was consequently permitted to utilise the refund amount.

Assignment by sale and transfer of long-term leasehold rights in land and buildings allotted by GIDC transfers the benefits arising from immovable property to the assignee, who steps into the lessee's position. Such assignment falls outside the scope of supply under Section 7(1)(a), read with Schedule II and Schedule III, and consequently does not attract GST under Section 9. Transfer of these leasehold rights is therefore not liable to GST.

Extended limitation for GST show-cause notices based on fraud, wilful misstatement or suppression of facts requires the notice itself to set out specific allegations and supporting material. Mere use of expressions such as "fraud or concealment of facts", without identifying the basis for that inference, does not justify recourse to the extended period. Deficiencies in the notice cannot be cured through a counter affidavit or other pleadings. Where the ordinary limitation period has expired, a notice lacking this substantiation is barred by limitation and cannot be sustained under the extended-limitation provision.

GST/TDS non-deposit arising from payments for Gram Sabha works falls primarily within the U.P. Goods and Services Tax Act, 2017, which provides a complete mechanism for determination of default, interest, penalty, prosecution and compounding. General penal provisions cannot be invoked unless allegations independently establish a distinct offence, such as dishonest misappropriation, forgery, cheating or wrongful gain. Substantive penal law applies prospectively: a penal provision introduced after the alleged 2017-18 default cannot create or alter the applicable offence. Proceedings based solely on Section 316(5) BNS were therefore unsustainable, while action under the GST Act remained available.

Extended limitation under Section 74 of the CGST Act for fraud, wilful misstatement or suppression of facts requires the show-cause notice itself to disclose specific allegations and the factual basis supporting that inference. A bare reference to "fraud or concealment of facts" does not establish a valid basis for invoking the extended period, and deficiencies in the notice cannot be cured through a counter affidavit. Where the ordinary limitation period has expired, including applicable exclusion of time, an unsupported invocation of extended limitation renders the notice unsustainable. Further proceedings based on such a notice cannot continue.

Assignment by sale or transfer of long-term leasehold rights in land and building to a third-party assignee constitutes transfer of benefits arising from immovable property. The assignee replaces the original allottee as lessee. Such assignment falls outside taxable supply under section 7(1)(a), clause 5(b) of Schedule II and clause 5 of Schedule III of the GST law, and is therefore not liable to GST. On this basis, the GST order concerning the assignment was quashed and the writ petition was allowed.

Assignment of long-term leasehold rights in land and building to a third-party assignee transfers benefits arising from immovable property. Where the assignee replaces the original allottee as lessee, the transaction falls outside the scope of supply and is not liable to GST. Applying the binding ruling on comparable assignments, upheld by dismissal of the SLP, the High Court quashed the show cause notice and assessment order levying GST and allowed the writ petition.

Executive Assistants are not entitled to inter-Commissionerate transfer where each Cadre Controlling Authority maintains a separate cadre and the applicable Recruitment Rules provide no absorption by transfer into another Commissionerate. The transfer policy therefore applies to this cadre, and appointment in the transferee Commissionerate cannot be secured through inter-Commissionerate transfer. Transfers treated as deemed loan arrangements may consequently result in repatriation. A request for relaxation on medical grounds may be made by representation for consideration on its merits.

Rule 138(1) requires prescribed information to be furnished and an e-way bill generated before taxable goods begin moving. Transport without an e-way bill at interception was treated as establishing intent to evade tax, because later online generation could not cure the failure of statutory monitoring or prevent potential account manipulation. A manually issued invoice was not regarded as an equivalent safeguard. The appellate authority's contrary reliance on precedent was distinguished, and the original tax and penalty order under the detention provisions was restored.

Transportation of motorcycles without an e-way bill at interception was treated as a procedural lapse where the e-way bill was generated shortly thereafter and the transaction was fully traceable through invoices, challans, accounts, bank records, and vehicle identification details. No discrepancy in quantity, value or classification, nor evidence of suppression, undervaluation, fake documents, unaccounted goods or intent to evade tax, was identified. The penalty was therefore set aside, and the deposited amount was refundable in accordance with law, subject to verification and statutory requirements.

Psyllium seeds (Isabgol) supplied in natural, raw and unprocessed form after procurement through APMC auctions are classified under Customs Tariff sub-heading 1211 90 13. The seeds are treated as dried rather than "fresh" or "chilled" plants or plant parts and therefore do not qualify for exemption under the relevant entry for fresh or chilled goods under HSN 1211. The stated conclusion treats the supply as taxable at 5%, notwithstanding a conflicting reference to exemption for goods of seed quality.

TDS refunds quantified under an assessment or appellate order under Section 201 constitute a crystallised entitlement carrying statutory interest. Form 26B, which concerns processing and adjustment of TDS statements under Section 200A and Rule 31A, cannot be required for such post-assessment refunds. Outstanding demands may justify withholding or adjustment only through a legally valid order under Section 245; demands linked to the assessee's PAN or sister TANs do not otherwise permit withholding. The quantified refunds were directed to be released with applicable interest, with additional interest for default.

Actuarial deficit contributions to approved superannuation and gratuity funds are distinguished from ordinary annual contributions subject to prescribed ceilings. Payments made to bridge actuarially determined shortfalls and preserve a fund's ability to meet obligations are treated as deductible gap-funding contributions. While approval of a gratuity fund continues, assessment proceedings cannot re-examine compliance with its approval conditions. Employees' PF and ESI contributions may be disallowed only where payment misses a due date prescribed by the applicable regime. Where no such date exists, an audit-report date generated solely for e-filing purposes cannot establish delay. The disallowances concerning all three categories of contributions were deleted.

Reassessment of a partner cannot rest on notional interest on capital or remuneration where the partnership deed merely enables, rather than mandates, those payments. Clauses subject to mutual agreement, including a subsequent amendment providing that no interest was payable, did not establish an enforceable entitlement or actual receipt by the partner. Without material showing that the partner received interest or remuneration, there was no basis to infer income escaping assessment. The High Court therefore quashed the reassessment notices issued to the partner.

Interest on delayed refunds arising from appellate-effect orders for Assessment Years 2014-15 to 2016-17 was directed to be computed under Section 244A(1A) from 1 December 2025 until payment, with additional Section 244A interest for September 2026 if payment was not made within the stipulated period. The Assessing Officer was required to secure consequential payment through the CPC. For Assessment Year 2014-15, the Assessing Officer was also required to verify the difference between tax deducted at source credit in the appellate-effect order and Form 26AS; if a short grant was established, interest under Section 244A(1) would run from 1 April 2014 until payment. No further direction applied to Assessment Year 2009-10.

Preliminary reassessment proceedings under Sections 148A(1) and 148A(3), followed by a notice under Section 148, are investigative steps that do not determine tax liability. Challenges concerning search-based information, applicability of Section 152(3), and sanction under Section 151 should ordinarily be examined during reassessment and through statutory appellate remedies. Writ intervention at this threshold is exceptional, limited to total absence of jurisdiction or a patent breach of a mandatory pre-condition; disputes requiring appraisal of material are not ordinarily examinable under Article 226. The challenge to reassessment initiation was therefore treated as premature, with recourse left to reassessment and appellate processes.

Deduction of cost of funds from deposit income of a primary agricultural credit co-operative society requires fresh consideration in light of Totagars Co-operative Sale Society. The claim for proportionate administrative and other expenditure remains open for adjudication. The impugned intimation, assessment orders and consequential penalty orders for the relevant assessment years were quashed, and the matter was remanded to the competent authorities. The society may submit objections and reply to the notice issued under section 142(1).

Agricultural-land status depends on the cumulative indicators applied in Sarifabibi, including land classification in registered deeds and revenue records, purchaser status and intended use, and the taxpayer's treatment of sale gains. Land described as industrial-purpose, recorded as fallow, sold for non-agricultural use and offered to tax as capital gain was treated as a capital asset rather than agricultural land. Relief for reinvestment in agricultural land requires fulfilment of the statutory conditions, including agricultural use of the transferred land during the prescribed period; industrial-purpose replacement land did not qualify. An unchallenged revisionary order cannot be contested through an appeal from the consequential assessment.