Section 16(5) changed the statutory time limits for filing returns and availing input tax credit. Consequently, input tax credit cannot be rejected solely because the relevant returns were filed belatedly where the amended provision governs the claim. Rejection founded only on delayed return filing is unsustainable, and the input tax credit claim must be reconsidered in accordance with the revised statutory time limits.

Separation of audit and adjudication functions under the Karnataka GST framework requires that an officer conducting an audit under Section 65 should not also determine tax liability under Section 73(9). Where the same officer performed both roles, the adjudication order was quashed. Fresh adjudication must be undertaken by a different proper officer after allowing a further reply and providing an adequate opportunity of hearing.

Dismissal of a statutory GST appeal solely as time-barred, without adjudication on merits, does not merge the original registration-cancellation order or prevent constitutional writ review. Where non-response to a show-cause notice results from bona fide and unavoidable circumstances supported by sufficient cause, a justice-oriented approach may justify a further opportunity. GST registration may consequently be restored after setting aside cancellation, subject to filing pending returns and discharging outstanding tax liabilities. The central principle is that a limitation-only appellate rejection does not foreclose substantive writ relief.

Assignment or acquisition of leasehold rights in an industrial plot transfers benefits arising from immovable property and falls outside the GST scope of taxable supply. GST charged on that transfer lacks legal basis; consequently, tax, interest and reversed credit recovered on the assumption of taxability require restoration. The blocked-credit rule for construction of immovable property does not apply where only leasehold rights are acquired and no construction occurs. Fraud-based recovery proceedings are also unsustainable where the credit was disclosed in returns and accounts, reversed before notice, and no fraud, wilful misstatement or suppression with intent to evade tax is established.

Electronically authenticated GST adjudication orders operate as composite orders where a digitally signed portal order expressly incorporates an attached speaking annexure; authentication extends to the incorporated annexure. Section 161 permits correction of an apparent inconsistency between a portal recital and the incorporated determination where the corrigendum does not reopen merits, introduce fresh reasons, enlarge the original demand, or adversely alter the taxpayer's position requiring a further hearing. Adjudication summaries in FORM GST DRC-07 and rectification summaries in FORM GST DRC-08 remain mandatory for enforcement and statutory appeal. The substantive merits of the disputed input-tax-credit demand and any surviving limitation issue remain for appellate adjudication.

Composite GST show-cause notices covering multiple financial years or tax periods are impermissible because liability, returns, assessment, recovery and limitation operate independently for each period. Combining years with separate due dates and limitation periods conflicts with the statutory year-wise structure and restricts a taxpayer's ability to respond separately to each period. Dismissal in limine of a challenge to a contrary view does not trigger the doctrine of merger. Authorities within the relevant territorial jurisdiction must follow prior decisions rejecting such consolidation. Separate notices and determinations are therefore required for distinct financial years or tax periods.

Services fully supplied before GST commenced remain subject to the pre-GST service-tax regime, even where approval and invoicing occur after commencement. Under the time-of-supply and transitional framework, subsequent administrative approval or billing does not change the completed service's supply date or impose GST. Where contractual payment was withheld amid a genuine taxability dispute, delay was not wholly attributable to the payers; commercial interest was inappropriate, but interest at 8% per annum from bill submission until payment applied.

GST penalties for non-compliance cannot exceed the statutory maximum where returns have been filed and applicable late fees paid. The aggregate penalty exceeded the limit prescribed under the Uttar Pradesh Goods and Services Tax Act, 2017, despite regularisation of the filing default through returns and late fees. The show-cause notice and penalty order were set aside, relieving the assessee from the excessive penalty.

Omission of Rule 96(10) of the CGST/WBGST Rules without a saving clause means that proceedings or demands founded solely on that rule cannot be initiated or continued. Without a statutory saving provision or legal fiction preserving accrued proceedings, the omitted rule ceases to have operative effect. Departmental instructions aligned with this position by requiring field formations not to commence or pursue such matters. Consequently, Section 74 proceedings and consequential orders based exclusively on omitted Rule 96(10) were unsustainable and quashed.

An efficacious statutory appellate remedy under Section 107 must be pursued for challenging the impugned order. Deficiencies in the show cause notice and all other available contentions may be raised before the Appellate Authority. Four weeks were granted to file the statutory appeal, following disposal of the Special Leave Petition.

GST adjudication orders that expressly incorporate annexures must be read as composite instruments. A digitally signed portal-generated order can validly authenticate an accompanying annexure containing the reasons, input tax credit determination and consequential liability; an inconsistent portal recital that proceedings were dropped does not sever or invalidate the incorporated annexure. Rectification may correct an error apparent from the record to reflect the decision actually made, but cannot reopen merits or create a fresh adjudication. No further hearing is required where the correction does not adversely alter the taxpayer's original position. FORM GST DRC-07 is a statutory summary rather than the adjudication itself, but DRC-07 and corresponding DRC-08 must be made available within a reasonable time to permit appeal and demand enforcement.

Independent corroboration was required to sustain a penalty for alleged involvement in an attempted export of prohibited red sanders where the allegation rested solely on statements later retracted. Retraction placed on record required consideration, and an uncorroborated retracted statement could not alone establish liability. The setting aside of penalty against the person alleged to have introduced the employee to the purported mastermind also removed the factual basis for penalising the employee. The penalty was therefore unsustainable and the appeal succeeded.

PMLA search, seizure and arrest powers require recorded reasons to believe under sections 17 and 19, supported by material linking the person searched or arrested to proceeds of crime. In a land-compensation transaction involving a void unilateral cancellation of a registered gift deed, land vested in a local body and later acquired for a highway project. Contemporaneous cancellation and sale deeds, the circumstances of purchase, and receipt, partial refund and retention of compensation supported an active role and benefit from proceeds of crime. Communication of grounds of arrest and disclosure of supporting material satisfied the statutory conditions, rejecting the challenge to search, seizure and arrest.

Unconditional omission of Rule 96(10) of the CGST/WBGST Rules, 2017, without a saving clause, rendered the rule nonexistent for proceedings founded solely on it. Applying Supreme Court law on the effect of such omission, the High Court found that the impugned proceedings had no independent statutory basis. The show-cause notice and consequential orders concerning July 2017 to March 2021 were therefore quashed, and the writ petition was disposed of.

Redemption of confiscated goods remains available where the person seeking redemption timely requests quantification of applicable customs duty, but the authorities neither quantify it nor clarify that redemption fine and penalty may be paid independently. Failure to complete redemption within the stipulated period cannot then be attributed solely to the claimant, notwithstanding that expiry ordinarily makes confiscation absolute. The High Court directed communication of duty and release of the gold bars after payment of duty, redemption fine, penalty and stipulated interest.

Services rendered and completed before the GST appointed day remain subject, if taxable, to the erstwhile Service Tax regime even where work approval and billing occur after GST commenced. Post-facto approval and subsequent invoices do not alter the date of supply or bring an already completed manpower service within the WBGST Act. Payment cannot be withheld solely for non-compliance with GST formalities; the payable amount may be released after deduction of applicable pre-GST tax. Where a genuine taxability dispute and pending civil proceedings contribute to delayed payment, interest may be set at the prevailing banking rate; interest at 8% per annum was directed from bill submission until payment.

GST treats each financial year as a separate tax period for assessment, annual returns, demand limitation and recovery. A composite show cause notice covering multiple financial years improperly combines distinct periods with different due dates, limitation requirements, grounds and response obligations, and is therefore impermissible. Jurisdictional High Court precedent requiring year-wise notices remains binding on authorities notwithstanding a contrary High Court view and an in-limine dismissal of a special leave petition against that view, which does not trigger merger. The composite notice was quashed, with liberty to issue a fresh notice under the CGST Act if legally permissible.

Assignment or transfer of leasehold rights in a GIDC industrial plot is characterised as a transfer of benefits arising from immovable property, not a taxable GST supply. GST charged on that transfer therefore lacks legal basis, and input tax credit reversal and interest premised on the assumed levy cannot stand. The blocked-credit restriction for goods or services used in construction of immovable property does not apply where no construction activity occurred. As the underlying transaction is not taxable and the blocked-credit premise fails, allegations of wrongful credit, fraud, wilful misstatement or suppression for section 74 proceedings, including consequential penalty, cannot be sustained. The adjudication and appellate demands were quashed, with refund of tax and interest directed.

GST audit and adjudication should not be undertaken by the same officer where the adjudication order is issued under Section 73(9). The High Court, following a co-ordinate Bench ruling, quashed an order passed by the officer who had conducted the audit. Fresh adjudication was directed from the stage of the reply to the show-cause notice, to be undertaken by a proper officer other than the audit officer after providing an adequate hearing opportunity.

Differential GST arising from the replacement of VAT by GST during an ongoing works contract is to be borne by the recipient of the works contract service. Where the contractor has discharged that additional liability and the State has received the benefit of the completed work, the contractor is entitled to reimbursement of the verified differential amount. High Court directed the respondents to determine the GST differential attributable to the tax-regime change, verify the relevant records and calculations, and reimburse the amount in accordance with law within the stipulated period.