Contradictory auto-populated input tax credit figures and annual-return disclosures require examination by the adjudicating authority before an assessment is sustained. Where an asserted technical or clerical discrepancy creates a prima facie inconsistency in ITC records, the affected taxpayer must receive an opportunity of hearing in accordance with principles of natural justice. Fresh adjudication is required to reconcile the differing figures and issue a reasoned assessment order.

Rule 26(3) of the CGST Rules requires electronic notices and orders to be authenticated by a digital signature certificate, e-signature, or other notified verification method. Portal generation and a document reference number only identify or track a communication; they do not establish authentication, officer accountability, or application of mind. Unsigned electronic notices and orders therefore cannot sustain consequential demand or recovery proceedings. Placing unauthenticated communications in an additional-notices portal category without effective service may deny the taxpayer the mandatory personal hearing under Section 75(4) of the CGST Act. Breach of natural justice permits writ relief despite an available statutory appeal. Fresh proceedings require duly authenticated notice and an effective hearing.

GST assessment of Motor Spirit and High-Speed Diesel requires recognition that these petroleum products are treated as non-GST goods. Imposition of GST on invoices relating to such products creates a jurisdictional defect affecting the validity of the assessment. The assessment requires fresh determination based on the registration records, invoices, supporting documents and reply to the show-cause notice, after affording the taxpayer a personal hearing.

Condonation of delay in a statutory appeal under the limitation framework may be warranted where circumstances beyond the assessee's control prevent timely filing and refusal of merits adjudication would cause grave prejudice. A 95-day delay, calculated after the available statutory relaxation, was treated as fit for condonation, permitting a fresh appeal to be filed and adjudicated on merits in accordance with law.

Detention penalty applies under Section 129(1)(a) where goods are accompanied by a tax invoice establishing the taxpayer as their deemed owner. Suspension of registration during transit does not render the consignor or consignee bogus when cancellation proceedings are subsequently dropped and registration is restored. Section 129(1)(b), applicable where the owner does not come forward, is therefore inapplicable in these circumstances. The penalty must be determined under Section 129(1)(a), resulting in treatment favourable to the assessee.

Adequate opportunity to file objections and be heard is required before factual assertions underlying GST assessment and demand are determined. Where a taxpayer has not contested proceedings and seeks to raise factual objections, fresh proceedings permitting objections and participation are warranted. Whether reassignment of proceedings requires a fresh notice remains unresolved, and the merits of the assessment remain open.

GST demand proceedings confirmed after non-filing of a reply to the show-cause notice and rejection of the statutory appeal on limitation require a meaningful opportunity for the assessee to respond where bona fide reasons, unavoidable circumstances and sufficient cause are asserted. The assessee may submit a reply, documents and supporting material and receive a reasonable hearing before fresh adjudication, subject to payment of costs. This approach prioritises procedural fairness in contesting the GST demand.

Rejection of a rectification application without addressing specific objections to a tax demand and supporting material breaches principles of natural justice where sufficient and reasonable opportunity is not afforded. Meaningful consideration of the assessee's substantive contentions is required before rejecting rectification. A summary rejection that fails to engage with those objections is legally unsustainable.

Penalty adjudication founded on third-party statements requires a meaningful opportunity to cross-examine the persons whose statements are relied upon when the taxable person specifically requests it. Denial of that opportunity prevents an effective rebuttal of the evidentiary material and breaches principles of natural justice. Where the penalty rests on such statements, the adjudication is vitiated by the denial of requested cross-examination, operating in favour of the assessee.

GST registration cancellation for failure to respond to a show-cause notice sent by email may be set aside where the taxpayer establishes bona fide and unavoidable circumstances constituting sufficient cause for non-response. A justice-oriented approach supports granting a further opportunity to meet GST compliance obligations rather than sustaining cancellation solely on that omission. Restoration of registration is conditional on filing pending returns and paying outstanding tax, interest and penalty.

GST demand proceedings confirmed without a response to the show-cause notice were restored for fresh determination after the taxpayer established bona fide reasons, unavoidable circumstances and sufficient cause for non-participation. The time-barred appellate rejection was also set aside, enabling submission of replies and supporting documents and a reasonable hearing before fresh adjudication.

Section 110(5) limits provisional attachment of a bank account to six months, with a further extension of up to six months only where reasons are recorded and the extension is intimated. Once the investigation had concluded, the show-cause notice was adjudicated, and the assessee had made the statutory pre-deposit and filed an appeal, no statutory basis supported continuing a debit freeze beyond one year. Continued freezing in those circumstances was coercive and lacked legal sanction. The bank account was therefore required to be defreezed.

Section 107 of the GST Act provides a statutory appellate remedy before the appropriate authority. The writ petition was withdrawn with liberty to pursue that remedy, subject to payment of the stipulated statutory deposit within the time granted.

Personal hearing must be effectively afforded where the show-cause notice provides for it and the taxpayer specifically requests it. Failure to communicate the date and time of the requested hearing breaches the principles of natural justice; consideration of a written reply alone does not cure that defect. The adjudication order was therefore invalid and quashed, with fresh adjudication required after giving the taxpayer an opportunity of hearing.

Rejection of a KARA SAMADHANA scheme application for waiver of penalty and interest without disclosing material particulars or reasons was treated as illegal and arbitrary. A non-speaking notice under Section 128A of the CGST/KGST Act failed to provide the basis for denial. The rejection was quashed, and the reconsideration request must be decided in accordance with law after granting the assessee a sufficient and reasonable opportunity of hearing.

Communication of GST audit findings in FORM GST ADT-02 under Rule 101(5) read with Section 65(6) is administrative and informs the registered person of the audit findings. It does not itself constitute an adjudication or recovery action. Recovery cannot be initiated solely on the basis of ADT-02; any further proceedings must be undertaken under the applicable provisions of the Central Goods and Services Tax Act, 2017, in accordance with law.

Fresh hearing in ex parte tax determination proceedings was required because the petitioners' pleaded material facts were undisputed and the respondents had not filed an affidavit-in-opposition. The tax demand's merits were not examined. Respondent authorities were directed to provide a renewed opportunity to raise objections and to issue a reasoned order within four weeks, ensuring that the determination follows a proper hearing process.

Availability of an efficacious statutory appeal ordinarily bars writ intervention against GST adjudication unless fundamental rights, natural justice, patent lack of jurisdiction, or vires are implicated. Challenges to the invocation of Section 74, audit proceedings, evidentiary assessment, input tax credit, reverse-charge liability, export material, and demand computation require factual appraisal by the appellate authority; participation in adjudication and disagreement over evidence do not establish denial of hearing. A consolidated show cause notice spanning multiple financial years is not inherently without jurisdiction, since statutory language permits notices for periods and separate order-limitation calculations do not require separate notices. Year-specific limitation objections remain for statutory appeal.

Cross-examination of persons whose statements are relied upon in GST penalty proceedings is necessary to satisfy principles of natural justice where the affected party specifically requests it. Denial of that opportunity before imposing penalty constitutes a serious procedural defect. The penalty order and consequential notices were set aside, with fresh consideration required after supplying relevant documents, granting a personal hearing, permitting cross-examination of relied-upon persons, and allowing a fresh reply. The merits of the underlying allegations remained open for independent reconsideration.

GST adjudication challenges involving the extended-demand provision, audit objections, input tax credit, reverse-charge liability, export transactions and factual demand heads require statutory appellate review where the taxpayer participated in proceedings and had an opportunity to present its defence. A disagreement over the evaluation of replies, documents or evidence differs from a denial of natural justice and does not by itself justify writ jurisdiction. A consolidated show cause notice may cover multiple financial years because the statutory language permits notices for periods, while limitation for the order is calculated by financial year. Limitation for an individual year remains available for determination in appeal. Writ interference is unavailable absent patent lack of jurisdiction or manifest breach of natural justice.