The vested right of appeal arises when the lis is instituted, and a later amendment imposing a fresh pre-deposit obligation does not apply to pending proceedings without clear legislative intent. Where a penalty-only appeal arose from a show-cause notice issued before the amended proviso took effect, the post-amendment pre-deposit requirement could not be imposed. The Registry's objection was set aside, the appeal was admitted without pre-deposit, and jurisdictional and merits issues remained open for final hearing.

Section 107(4) of the GST law fixes an outer limit on an appellate authority's power to condone delay in appeals against cancellation of registration. Extraordinary writ jurisdiction cannot enlarge that statutory appellate jurisdiction; condonation beyond the prescribed maximum is legally unsustainable. Where the Department has implemented appellate directions by restoring cancelled GST registrations, it cannot seek annulment without addressing the resulting alteration of the taxpayers' legal and commercial position. The departmental appeals consequently become infructuous where no effective or workable relief remains available.

Food supplied by an independent outsourced caterer to a hospital is a separate taxable supply, not a composite healthcare supply, because the caterer contracts only to supply food and cannot rely on the healthcare-provider clarification. Reliance on that clarification, although legally incorrect, does not by itself establish fraud, wilful misstatement, or suppression with intent to evade tax; the demand must therefore proceed under the ordinary tax-demand route. Where invoices did not separately identify or collect tax, the invoiced consideration is tax-inclusive and differential tax must be recomputed using cum-tax valuation after invoice verification.

Credit notes for returned or rejected processed-fabric supplies are excluded from outward taxable supply turnover when calculating an inverted-duty refund of accumulated input tax credit. The identical input-output supplies clarification is confined to accumulation caused by a rate reduction on the same goods over time; it does not apply where higher-taxed chemicals and dyes are used to process fabrics taxed at a lower rate without an output-rate reduction. Once refund eligibility and computational parameters are determined, consequential re-quantification is ministerial, does not reopen the merits, and does not constitute an appellate remand.

Refund of accumulated input tax credit under an inverted duty structure remains available where processed fabrics retain the same GST rate and credit accumulates from higher-taxed chemicals, dyes and consumables used in job-work processing. Circular No. 135/05/2020-GST concerns credit accumulation caused by a GST-rate reduction on the same goods and does not bar such refund claims. Once substantive refund eligibility is determined, an appellate direction for arithmetical recomputation merely implements that determination and is not a prohibited remand, provided the original authority cannot reconsider the merits. Refund orders allowing consequential recalculation were sustained.

Revocation of GST registration following cancellation for non-furnishing of returns requires filing outstanding returns and paying tax, interest, late fee and penalty. Verification limited to return filing and tax payment does not satisfy the proviso to Rule 23(1), which makes payment of these ancillary statutory liabilities a condition for revocation. The revocation order was modified to require recovery of unpaid interest and late fee and imposition of penalty under Rule 23.

GST detention penalties under section 129 require a pleaded and established contravention of the Act or Rules. A show-cause notice must identify the defective documents and the precise legal provision allegedly breached; a vague allegation of diversion or unloading at an undeclared destination is insufficient. Reliance on inculpatory statements requires their disclosure, and an offered personal hearing and cross-examination opportunity must be genuinely afforded before adjudication. Appellate review must address material natural-justice objections and identify the statutory contravention rather than rely on route or invoicing observations alone.

GST local-authority status is confined to bodies expressly enumerated in the CGST/KGST definition; a statutory body is not included merely because its constituting State law deems it a local authority. Accordingly, works contract services supplied to Kerala Water Authority attract GST at 18% from 1 January 2022 rather than the concessional local-authority rate. On delayed differential GST, interest applies only to the portion discharged through the electronic cash ledger, not to the portion paid through the electronic credit ledger.

Excess IGST paid twice on export supplies is refundable where export turnover and IGST liability were correctly reported in GSTR-1 but mistakenly classified under supplies other than zero-rated supplies in GSTR-3B. The mismatch prevented automated customs refund, leading to a second IGST payment through a corrected return; refund of that second payment did not extinguish the claim for the original excess payment. A clerical reporting error, supported by return reconciliation, does not constitute a substantive breach justifying denial. Retaining tax paid twice would lack authority of law, and refund cannot be denied on procedural grounds or the stated limitation objection.

Consignment value for goods returned by a job worker comprises the job-work charges and applicable tax, not the value of the principal's goods. Under section 15 read with Explanation 2 to Rule 138, the return movement represents the job-work service; where its taxable value is below the prescribed threshold, an e-way bill is not mandatory. Detention and penalty action cannot rest on allegations contradicted by departmental records, including the presence of a tax-paid job-work invoice, delivery challan and e-way bill. A detention or appellate order must remain within the show-cause notice's factual allegations and give reasons for treating an e-way bill as invalid; reliance on unalleged grounds breaches natural justice.

Section 129(3) requires a detention-penalty order to be passed within seven days of service of notice. The seven-day period is mandatory, not directory; an order made after that period, including one issued 28 days after notice, breaches the statutory requirement. Such delay vitiates the detention-penalty proceedings, renders the original order void ab initio and a nullity, and leaves no valid basis for an appellate order affirming the penalty.

Unutilised input tax credit accumulated from an inverted duty structure is refundable where manufacturing inputs are taxed at a higher rate than the outward supply and are distinct from the finished goods. For Agarbati manufacturing, perfumes, fragrances, chemicals, packaging materials and cardboard qualify as inputs whose higher tax rates may support refund eligibility. A CBIC clarification addressing situations where input and output supplies are the same goods does not restrict such claims. CBIC circulars bind central tax officers but not the Appellate Tribunal, although they may carry persuasive value.

Export quota premium is not equivalent to export-incentive receipts eligible for deduction under section 80HHC. Administrative circulars bind departmental authorities but cannot bind courts, override statutory language, or displace judicial interpretation. Equating premium from the transfer of export quota with receipts covered by the specified export-incentive provisions would create an impermissible legal fiction, particularly because such premium lacks characteristics of those receipts, including foreign-exchange realisation. Tax deductions must be construed strictly by reference to income derived and the statutory classification of eligible receipts; export quota premium therefore falls outside the claimed deduction.

Revisional jurisdiction over an assessment allowing deduction of export quota sale premium as business profits is limited to orders that are both erroneous and prejudicial to the interests of the Revenue. A permissible assessment view cannot be revised solely because the Commissioner takes a different view, unless the assessment position is unsustainable in law. The statutory treatment of export quota premium, administrative tax guidance, and the Tribunal's interpretation are relevant in determining whether the deduction is legally sustainable and whether revisional intervention is justified.

Book-entry conversion of compulsorily convertible debentures into compulsorily convertible preference shares did not constitute a sum received during the relevant previous year for the cash-credit provision. Share premium arising solely from that conversion therefore could not be treated as an unexplained cash credit, rendering the related addition unsustainable. Penalty founded solely on the deleted share-premium addition had no surviving basis. Penalty for non-reporting income also did not arise for principal additions that were set aside; for additions remanded for fresh consideration, penalty could be considered only if they were reiterated. The Revenue's appeals were dismissed for want of a substantial question of law.

Section 271AAB imposes penalty only where the amount falls within its exhaustive definition of undisclosed income; a surrender during search proceedings alone is insufficient. Diary entries recording advances indicate an outflow or application of funds, rather than unreported income, unless a corresponding undisclosed asset or source is established. Deeming rules for unexplained sums do not automatically apply to this self-contained penalty provision. The Assessing Officer must specifically establish that the amount was found in, or resulted from, the search as undisclosed income. Penalty on surrendered advances reflected in vague diary notings was therefore deleted.

Post-search reassessment for assessment years preceding a search initiated after 31 March 2021 must be commenced under the reassessment framework in sections 147 and 148. Explanation 2(i) to section 148 deems such a search to be information suggesting income escapement, while exemption from the preliminary procedure under section 148A in specified search cases does not remove the mandatory section 148 notice. Compulsory scrutiny selection and a notice under section 143(2) issued under administrative guidelines cannot confer reassessment jurisdiction. Later approval or taxpayer participation cannot cure a jurisdictional defect caused by failure to issue the required notice.

Genuineness of agricultural receipts requires evidence of actual cultivation, including land details, crops and plantations, irrigation facilities, labour, horticultural borrowings and supporting photographs. Where such material establishes extensive agricultural operations, the reasonableness of net agricultural income must be assessed after accounting for disclosed cultivation expenditure and the scale of activity. Treating full gross agricultural receipts as income without allowing cultivation costs disregards the distinction between gross receipts and net income. Absence of cash deposits or unexplained investments may further support the stated agricultural source.

Section 270A penalty for under-reporting was not leviable under the provision where a health and education cess deduction claim, made in reliance on judicial decisions, was withdrawn during assessment after a retrospective amendment. Coordinate Tribunal decisions on the identical issue supported the conclusion that withdrawal of the claim did not justify penalty. The penalty was consequently deleted.

Under the second proviso to section 153A(1), initiation of a search abates a scrutiny assessment that remains pending for an assessment year within the prescribed search period. Accordingly, once the pending assessment for AY 2013-14 abated, the Assessing Officer had no jurisdiction to complete the regular assessment under section 143(3). The resulting assessment was non-est, and proceedings consequential upon it were also non-est.