Deduction under section 80P(2)(d) was available to a co-operative society that was not a co-operative bank, despite cancellation of its licence. The High Court upheld that entitlement and quashed reassessment notices and related departmental orders. The Supreme Court found no ground to interfere, leaving the High Court's decision and the quashing of reassessment action undisturbed.

Section 263 revision requires an assessment order to be both erroneous and prejudicial to the Revenue; revenue loss or the Commissioner's disagreement with a legally sustainable view does not suffice. Export quota-sale premium accepted for deduction under Section 80HHC was treated as outside the specified export-incentive receipts under Sections 28(iiia) to 28(iiic) and therefore subject to the exclusion under Explanation (baa) to Section 80HHC. Although a CBDT Office Memorandum binds departmental officers, it cannot override statutory interpretation applied in judicial proceedings. As the Assessing Officer had not applied the relevant statutory criteria, the assessment satisfied both conditions for revision and the Commissioner's Section 263 action was justified.

Premium earned on a domestic transfer of export quota does not fall within the export-incentive receipts specified in Sections 28(iiia) to 28(iiic and therefore does not qualify for the Section 80HHC deduction. Departmental circulars and administrative instructions bind Revenue authorities but cannot bind constitutional courts or override statutory provisions and judicial interpretation. The CBDT Office Memorandum's treatment of export-quota premium as a specified incentive creates a legal fiction inconsistent with the statutory scheme, since such premium lacks the foreign-exchange character and other essential attributes of the enumerated receipts.

Refund of unutilised input tax credit under the inverted duty structure provision is available where inputs and outward supplies are commercially distinct and input GST rates exceed the output rate. Perfumes, fragrances, chemicals and packaging materials, compared with agarbati as the output supply, create a qualifying input-output rate differential. A circular addressing the same goods taxed at different rates over time does not bar such a claim. Departmental circulars bind tax officers but remain persuasive before the Tribunal and cannot expand statutory refund restrictions.

Section 129(3) requires the proper officer to issue a penalty order within seven days of serving notice. The statutory term "shall" makes that period mandatory, particularly because fiscal provisions require strict construction. Issuing the penalty order 28 days after service of notice breaches the prescribed time limit; the order is consequently void ab initio and a nullity in law.

Show-cause notices, detention orders and appellate orders founded on factual errors or grounds outside the notice violate principles of natural justice by denying an effective opportunity to respond and are unsustainable. For goods returned by a job worker to the principal, e-way-bill consignment value is limited to the transaction value of the taxable job-work service and excludes the value of the principal's original goods. Where job-work charges and applicable tax remain below the prescribed threshold, an e-way bill is not mandatory and penalty under Section 129 does not arise.

Excess IGST paid on zero-rated export supplies due to incorrect GSTR-3B reporting remains refundable where export details and tax liability were correctly reported in GSTR-1, but the automated Customs refund process failed because of a return mismatch. A subsequent duplicate IGST payment made to obtain the automated export refund does not extinguish the earlier payment, which remains excess tax. Clerical reconciliation errors and procedural discrepancies in GSTR-3B cannot justify retention of tax beyond the amount lawfully due, as such retention is impermissible under Article 265 of the Constitution.

Works-contract services supplied to Kerala Water Authority attract GST at 18% from 1 January 2022 because the Authority, although described as a local authority under State law, does not fall within the exhaustive CGST statutory definition of a local authority. Its GST registration classification does not change that position, and the concessional rate no longer applies to supplies made to governmental authorities. Interest on differential GST is confined to the portion discharged through the Electronic Cash Ledger; no interest is payable on the portion paid through the Electronic Credit Ledger.

Section 129 permits detention, seizure, and consequential tax and penalty only where goods in transit are transported or stored in contravention of the GST Act or Rules. Proceedings cannot rest on a vague allegation that omits the specific contravention or defective transport documents, because this prevents an effective response. Reliance on undisclosed inculpatory statements without cross-examination, issuing an adjudication order before the scheduled personal hearing, and failing to address material procedural objections breach natural justice. Tax and penalty orders initiated on that basis were unsustainable and set aside with consequential relief.

Revocation of GST registration cancelled for non-filing of returns requires furnishing all pending returns and paying tax, interest, penalty and late fee. Verification restricted to return filing and principal tax payment does not satisfy these statutory preconditions and leaves unpaid liabilities unaddressed. Interest and late fee remain recoverable through the prescribed recovery mechanism, while penalty liability arises under the revocation framework. Outstanding statutory dues must therefore be accounted for when restoring registration, including recovery of interest and late fee and imposition of penalty.

Refund of accumulated input tax credit under an inverted duty structure is available where higher-taxed chemicals, dyes and consumables are used for fabric processing and the output supply has not undergone a GST rate reduction. The clarification concerning identical input and output goods applies to the same goods being taxed at different rates following a rate reduction, not to processing activities using distinct higher-taxed inputs. Once refund eligibility is determined, a direction to arithmetically re-compute the refundable amount merely implements that determination. Such consequential computation does not reopen adjudication and is not a prohibited remand.

Credit-note values reversing supplies must be deducted from outward taxable turnover when calculating an inverted-duty refund under the statutory refund formula. The circular-based exclusion for identical input and output supplies does not apply where no output-rate reduction occurred and higher-taxed chemicals, dyes and consumables were used to process fabric; the refund claim remains governed by the statutory formula. Consequential re-computation by the original authority, after eligibility and parameters are conclusively determined, is a ministerial exercise and not a prohibited remand because it does not reopen merits or permit fresh adjudication.

Outsourced caterers supplying food independently to hospitals make a separately taxable food supply, not a composite healthcare supply, even where the food is consumed by in-patients. Composite-supply treatment may apply to the hospital's healthcare package but does not extend to an independent supplier. Fraud, wilful misstatement, or suppression with intent to evade tax must be established before the extended-demand mechanism applies; mistaken reliance on a circular without mala fides requires ordinary-demand treatment. Where invoices contain no separately identifiable tax and no tax was collected additionally, invoice values are treated as tax-inclusive and tax is recomputed under Rule 35 after verification.

Section 107 of the CGST Act confines condonation of delay in filing an appeal to the express statutory outer limit; equitable considerations and High Court jurisdiction under Article 226 cannot enlarge the First Appellate Authority's powers. Where registrations have been restored and taxpayers have resumed business, completed implementation may make departmental appellate relief ineffective because annulment could disrupt intervening transactions and input-tax-credit consequences. The appellate remedy against cancellation remains independent of revocation under Rule 23, although it must be pursued within the prescribed limitation period.

The right of appeal vests when the lis commences, so a later amendment imposing a new pre-deposit condition does not apply to pending proceedings unless retrospective operation is expressly stated or necessarily implied. For penalty-only GST appeals arising from show-cause notices issued before the proviso to Section 112(8) took effect, the earlier law did not require a penalty pre-deposit. The pre-deposit framework for first appeals under Section 107(6) supports the same treatment. Consequently, no 10% penalty pre-deposit is payable for appeals arising from pre-amendment proceedings.

Input tax credit eligibility under the CGST Act cannot be assessed solely from a GSTR-3B/GSTR-2A mismatch; the claimant retains the burden of proof, and eligibility requires category-wise and invoice-wise verification of underlying records. Supplier certificates for the disputed year must be considered despite later issuance, alongside reconciliation of reporting errors, reverse-charge credit, unclaimed credit and reversals. For renting of immovable property, the property's location determines place of supply; where the supplier and property are in the same State, CGST and SGST apply despite erroneous IGST reporting. Effective opportunity of hearing remains necessary under principles of natural justice.

E-way-bill validity may be extended in exceptional circumstances, including through a further eight-hour period after expiry. For goods in transit, a penalty for an expired e-way bill should account for otherwise valid accompanying documents, a short technical delay in obtaining extension, and absence of intent to evade tax. A rigid 200% penalty is disproportionate where interception follows shortly after the extension window; in such circumstances, a token fine and refund of the excess penalty are appropriate.

GST proceedings must identify the applicable tax period in each show cause notice and assessment order. Where annual returns have been filed, the relevant financial year is the tax period; before annual filing, proceedings may be based on monthly returns. A single notice or assessment order cannot combine multiple financial years. Proceedings that club separate financial years are jurisdictionally invalid. The consolidated assessment and consequential rectification-rejection orders were quashed, while permitting fresh separate proceedings for each financial year.

Biometric Aadhaar authentication for GST registration is required under interim directions as a nationwide safeguard against fraudulent registrations obtained through misuse of PAN and Aadhaar particulars. Restricting biometric verification to applications identified as risky through data analytics was considered insufficient in light of detected fraudulent registrations and tax evasion. The directions seek to protect revenue and prevent harassment of persons whose identity particulars are misused. Authorities may place practical implementation difficulties on record, and further consideration remains pending.

E-way bill rules permit validity extensions in exceptional circumstances and provide a further eight-hour window after expiry to seek extension. Transport after that period may justify detention and penalty, but a brief delay in renewing the e-way bill does not necessarily warrant a 200% penalty. Where interception occurred shortly after the additional extension window, comparable decisions supported relief while recognising that the lapse could still attract a nominal sanction. The 200% penalty orders were set aside, subject to payment of a token fine and refund of the balance penalty deposit.