Section 107 of the Central Goods and Services Tax Act, 2017 provides a statutory appellate remedy against an Order-in-Original, and writ jurisdiction is ordinarily not invoked where that remedy remains unexhausted. A delay of 99 days beyond the prescribed appeal period was treated as arising from circumstances beyond the petitioner's control, constituting sufficient cause to permit access to the appellate remedy. The Appellate Authority must entertain and decide the appeal on merits if it is filed within 30 days of uploading of the order.

Cancellation of GST registration under Rule 21(b) for alleged issuance of invoices without supply requires a reasoned order that considers the registered person's material reply. Where the reply asserts that an earlier show-cause notice on the same grounds was dropped and no fresh particulars or queries were supplied, the cancellation order must address those objections rather than merely repeat allegations of circular transactions. Failure to consider the reply and provide reasons renders the cancellation unsustainable, requiring fresh consideration after an opportunity of hearing.

Availability of a statutory appeal under the CGST Act is material to the discretionary exercise of writ jurisdiction, even though it does not absolutely bar recourse to Article 226. Challenges to rejection of GST registration cancellation that require factual inquiry and examination of records should ordinarily proceed through the appellate remedy under Section 107. Writ jurisdiction was not exercised, and the applicant was relegated to the statutory appeal without any view on the merits of the registration dispute.

Section 16(2)(c)'s constitutional validity was already settled by Supreme Court precedent, leaving no basis to entertain a writ challenge on that ground. A final tax order subject to the statutory appellate mechanism should be challenged through that remedy rather than by writ petition. The writ petitions were dismissed, while preserving the petitioners' liberty to pursue the available statutory appeal against the final tax order.

Dismissal of a statutory appeal solely on limitation, without examination on merits, warranted interference where the petitioner claimed no actual intimation of a show-cause notice uploaded on the portal and later knowledge of the adjudication order. The communication circumstances established a prima facie basis for ensuring an effective opportunity of hearing and reconsideration on merits. The appellate and adjudication orders were set aside, with fresh reasoned adjudication directed after hearing the petitioner.

Portal-only uploading of a GST show-cause notice and adjudication order under the "Additional Notice and Orders" tab, without separate intimation, may deny the taxpayer an effective opportunity to respond. Where the taxpayer cannot access or respond to the notice and is not afforded a personal hearing, the adjudication process breaches principles of natural justice. The adjudication order was set aside and the matter required fresh adjudication after a personal hearing.

Rejection of an appeal as time-barred requires consideration of the grounds advanced in the delay-condonation application and reasoned findings on those submissions. Treating acceptance of a delayed appeal as automatically defeating statutory limitation provisions does not address the explanation offered for delay. Where the authority fails to consider the petitioner's stated grounds for a nine-day delay, rejection of condonation is unsustainable. The limitation issue must be reconsidered through a reasoned order after hearing the petitioner.

Condonation of delay in a statutory appeal was warranted where serious illness of the person responsible for business affairs constituted sufficient cause and was supported by medical material. Compliance with the mandatory pre-deposit requirement before filing reinforced the availability of the appellate remedy. Dismissing the appeal solely as time-barred despite sufficient cause and pre-deposit compliance would be unduly technical and render the statutory remedy illusory. The delay was condoned, the appellate dismissal was quashed, and the appeal was directed to be admitted and decided on merits.

Availability of a statutory appeal against rejection of a GST registration-cancellation application does not bar writ jurisdiction under Article 226, but strongly informs its discretionary exercise. Where the challenge requires resolution of disputed facts and appraisal of the record, the statutory Appellate Authority is the appropriate forum. The writ petition was therefore not entertained, with liberty to pursue the statutory appeal; the Appellate Authority must decide it independently of observations made in the writ proceedings.

Retrospective extension of the input tax credit limitation under section 16(5) protects eligible registered persons whose belated claims were barred under section 16(4) but fall within the extended period. Input tax credit cannot be denied solely on limitation in such circumstances. The assessment disallowance was quashed to that extent, consequential recovery was restrained, and amounts already recovered were to be refunded or adjusted against future tax liabilities.

Defective service of a GST show-cause notice and adjudication order through an incorrect common-portal tab justified condonation of delay in filing the GST appeal. Uploading a notice on the portal alone was treated as insufficient service where there was no acknowledgement or reply, and belated recovery action supported the taxpayer's claim that the order appeared under "Additional Notices and Orders" rather than the designated tab. Although the Appellate Authority was bound by the statutory limitation period, refusal to hear the appeal would cause grave prejudice where the delay arose from circumstances beyond the taxpayer's control. The appeal was directed to be entertained and decided on merits if filed within the stipulated period.

Sufficient cause supported condonation of delay in a GST appeal where the taxpayer lacked effective knowledge of the show-cause notice and adjudication order because they were uploaded under a non-designated portal tab. Although the Appellate Authority remained bound by the limitation prescribed under section 107 of the RGST/CGST Act, circumstances beyond the taxpayer's control and the risk of grave prejudice justified merits review. The delay was condoned, with a direction to entertain and decide the appeal on merits if filed within the stipulated period.

Fresh adjudication was permitted where the petitioner had not participated in the original proceedings and the statutory appellate limitation had expired. The impugned order was quashed, subject to an additional pre-deposit of 25% of the disputed tax and submission of a reply to the show-cause notice within the stipulated period. The earlier order was to operate as an addendum to the show-cause notice for the fresh proceedings. No further extension or concession was available; failure to comply allowed recovery proceedings to continue in accordance with law after due notice.

Retrospectively inserted section 16(5) extends the time for eligible registered persons to claim input tax credit for specified financial years where the section 39 return was filed by 30 November 2021. It overrides the limitation in section 16(4) for claims falling within that extended period, while preserving the requirement to satisfy all other statutory conditions. Input tax credit claimed through a March 2019 return filed within the extended deadline cannot be denied solely for delay. Limitation-based disallowance, consequential recovery, and related demands are to be removed, with recovered amounts refunded or adjusted against future tax.

Section 112(3) confines the prescribed limitation period to filing an appeal before the Tribunal and does not impose a separate six-month deadline on the Commissioner to review the first appellate order. A departmental appeal filed within the applicable extended filing period therefore remains maintainable even where the Commissioner's review occurred after six months. The maintainability objection was rejected, and the appeal was admitted for adjudication on merits.

Urgent listing of an appeal against GST registration cancellation may be granted without awaiting ordinary Registry scrutiny where sufficient cause and continuing prejudice are shown. Procedural rules permit exemption from procedural requirements and directions necessary for substantial justice, reflecting the principle that procedure should facilitate adjudication rather than defeat substantive rights through technicality. Cancellation preventing the appellant from conducting its sole business justified limited urgent listing, as delay could make appellate relief ineffective. The exemption applies only to listing and does not waive statutory requirements or determine maintainability or merits, which remain open.

Papad Khar, an alkaline manufactured mixture containing sodium chloride, sodium carbonate and sodium bicarbonate, is classified as an inorganic carbonate under tariff item 28362090. It is not covered by Heading 2501 because it is neither crude nor merely physically processed salt, and it does not possess the characteristics of yeast or prepared baking powder under Heading 2102. As a Chapter 28 inorganic chemical outside the relevant exclusions and alternative schedules, it attracts GST at 18%. Exemption for exempt papad does not extend automatically to Papad Khar used as an input; each input and finished product requires separate classification and rate determination.

E-invoicing applies to coaching-service supplies genuinely made to registered recipients where the supplier falls within the notified class and no exclusion applies. Recipient status depends on an enforceable contractual liability to pay consideration; the student may be the beneficiary, while a parent, guardian or sponsoring enterprise may be the recipient only if contractual terms establish that liability. Mere fee payment or provision of a GSTIN is insufficient. Proposed-supply questions may be raised, but recipient identity and place of supply cannot be determined through advance ruling where they require transaction-specific assessment. Supplier e-invoicing obligations operate independently of the recipient's input tax credit eligibility or business purpose.

Reassessment cannot revisit capital-gains and share-sale exemption issues already examined and accepted in a scrutiny assessment on the same facts, as doing so amounts to a change of opinion. Detailed inquiries into share valuation, purchaser identity and creditworthiness, transaction genuineness, and the consequential exemption claim establish formation of an opinion even where the assessment order does not address every query. The change-of-opinion principle applies under the revised reassessment procedure, in which a show-cause notice under section 148A(b) performs the function of recorded reopening reasons. The reassessment notices and related proceedings were quashed; the limitation challenge remained open.

Reassessment based on information linked to GST adjudication requires independent application of the Income-tax Act. Information suggesting escaped income may include material obtained through a CBDT risk-management strategy, but the record must establish that the relevant strategy covers the GST adjudication order. Income-tax authorities cannot rely solely on the GST proceeding or its appellate outcome when issuing or pursuing reassessment. The reassessment notice remained undisturbed, while any reassessment was required to proceed independently under the Income-tax Act and remain open to subsequent challenge.