Fixed "refurbish and rebate" credits issued to distributors at a uniform percentage, without any obligation to repair defective products or linkage to actual repair costs, are trade rebates rather than consideration for contractual work or professional services. They therefore do not attract tax-deduction obligations or consequential disallowance for non-deduction. The deductibility of employees' contributions depends on verification through challans and supporting records that remittances were made by the prescribed statutory due dates; timely deposits must be allowed in accordance with law.

Reassessment notices issued on or after 1 April 2021 for Assessment Year 2015-16 fell outside the period available for completion under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Consequently, the notice and consequential proceedings under the substituted reassessment framework, including the preliminary procedure and reassessment, could not continue and were required to be dropped.

Reassessment for AY 2022-23 based on an alleged Section 43B deduction for tax deducted at source was invalid where original scrutiny had examined the relevant expenses, TDS and statutory liabilities. The challenged amount represented TDS on salary and other payments, not expenditure claimed as a Section 43B deduction; leave encashment was separately reported as a smaller deduction. Because the material had been furnished and considered in the assessment under Section 143(3), the reopening rested on a misreading of records, non-application of mind and a change of opinion, without fresh tangible material showing escaped income. The show-cause notice and consequential order were quashed.

Limitation under Section 153B requires court-ordered stay periods to be excluded during the initial computation under its Explanation, before the resulting composite deadline is tested for eligibility under TOLA. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge limitation and conflict with strict construction of tax limitation provisions. On this approach, the calculated deadlines for stayed years fell outside TOLA's extension window, while assessments for other years were made after the extended deadline. The search assessments, connected notices and penalty orders were therefore time-barred and liable to be quashed.

Reassessment under section 147 cannot serve as a review of claims already examined in the original scrutiny assessment. A valid reason to believe income escaped assessment requires a live nexus with tangible material; a changed inference from existing assessment records is insufficient. Where queries on depreciation, expenditure disallowance and pre-production income were raised and answered, and recorded reasons identify no fresh material or failure of full and true disclosure, reopening lacks jurisdiction. The resulting reassessment order is invalid as founded on a mere change of opinion.

Advance-ruling jurisdiction does not extend to entitlement to refund of accumulated input tax credit under the inverted-duty proviso, as refund determination is not among the specified advance-ruling questions. Classification and rate questions remain admissible where no pending or concluded proceeding exists; a verbal doubt during refund scrutiny is not a statutory proceeding. Rubberised Cork Sheets and Agglomerated Cork Sheets fall under Tariff Item 45041010 because heading 4504 covers agglomerated cork with or without a binding substance. They qualify for 5% GST from 22 September 2025; binder content or absence of natural-cork status does not negate the benefit.

Preparatory coaching, learning resources and academic support do not qualify for the educational institution exemption because the provider neither conducts prescribed examinations nor awards the recognised qualification or degree. Examination, registration and related fees remitted for students remain taxable unless all pure-agent conditions, including recipient authorisation and separate invoicing, are met. Printed materials, recorded lectures and digital resources supplied for a consolidated coaching fee are naturally bundled with coaching as the principal supply and are taxable accordingly. Foreign-exchange fluctuations retained on remittance of foreign professional fees are outside taxable value where they are not consideration for a distinct supply. Training and infrastructure support supplied to universities is taxable as education services.

Psyllium seeds supplied after storage in dry, ventilated conditions are treated as dried goods rather than fresh or chilled goods, because their condition at the time of supply governs GST treatment. They therefore do not qualify for the exemption applicable to fresh or chilled Psyllium seeds, or for the alternative exemption for goods of seed quality. The seeds are classified under tariff item 1211 90 13 as dried plants and parts of plants used in pharmacy and attract GST at 5%. The fresh-or-chilled versus dried distinction determines exemption eligibility.

Full payment of the prescribed fee is required to maintain an advance-ruling application under the CGST and KGST framework. The requirement arises under section 97(1), read with rule 104 of the corresponding rules. Where an applicant neither remits the balance fee nor responds to communications and hearing opportunities to rectify the deficiency, the application cannot be entertained and is not maintainable.

Full payment of the prescribed fee under the relevant central and State enactments is a mandatory precondition for entertaining an advance-ruling application. An application not accompanied by the full fee remains defective, and failure to cure that defect despite repeated opportunities prevents consideration of the questions raised on merits. Non-appearance or continued non-compliance by the applicant reinforces that the application cannot proceed.

Advance-ruling applications require full payment of the prescribed fee under section 97(1) of the CGST and KGST Acts read with rule 104. They must also identify the applicable statutory category of questions under section 97(2). Non-payment of the balance fee despite opportunities, failure to comply with hearing notices, and omission of the required question category constitute fundamental filing defects. These mandatory requirements determine maintainability, and non-compliance renders an advance-ruling application not maintainable.

Leasing a projector, server, UPS and VSAT for a single rental is treated as a mixed supply where the equipment is not naturally bundled in the ordinary course of business. Independent usability of each item, absence of customary industry bundling, lack of consumer expectation, and no ancillary or integral relationship prevent composite-supply treatment. A mixed supply is taxable at the rate applicable to its highest-rated constituent supply. As the projector attracts the highest rate, the lease is subject to 28% GST until 21 September 2025 and 18% GST thereafter.

Reasoned and speaking appellate orders must address material grounds, evidence and authorities relied on by the parties; cryptic affirmances that merely state inadequate evidence do not reflect proper exercise of appellate jurisdiction. Where original adjudication was ex parte and objections concerning show-cause notice adequacy, relied-upon documents, reconciliation and effective hearing remain unresolved, merits should not be determined at the second appellate stage because that would deny an effective appellate tier. Fresh adjudication should follow identification and disclosure of relied-upon material, opportunity to reply and reconcile, personal hearing, and reasoned findings.

Service tax paid under the pre-GST regime on advances for flat bookings that are later cancelled is not input tax or input tax credit under the CGST Act, because those concepts cover specified GST levies charged on supplies to a registered person. Where services are not ultimately provided after the appointed day, section 142(5) requires the service-tax refund claim to be dealt with under the existing law and paid in cash. Such a refund cannot be adjusted unilaterally through the electronic credit ledger without statutory authority.

Rule 89(5) requires turnover of inverted rated supplies and adjusted total turnover to be correctly determined when computing a refund of accumulated input tax credit under the inverted duty structure. The effect of alleged outward supplies taxable at 18% could not be determined because the underlying invoices and supporting material were unavailable, and the appellate determination had not addressed those supplies. Refund eligibility therefore required fresh verification and a reasoned determination after both parties were afforded an opportunity of hearing.

Transport of goods with an expired e-way bill that records a wholly different vehicle fails the requirement for prescribed transit documents. Part B must contain correct vehicle particulars, and the limited relaxation for minor one- or two-character errors does not cover substitution of an entirely different vehicle. An incomplete or incorrect e-way bill creates a rebuttable presumption of intent to evade tax, assessed from surrounding circumstances. Where alleged diversion and delay lack a timely explanation or credible supporting material, that presumption remains unrebutted and penalty is sustainable.

Rule 138's compulsory e-way bill requirement for inter-State movement became operational nationwide from 1 April 2018, rather than on 24 November 2017. Non-production of an e-way bill before that mandatory commencement could not, by itself, constitute a breach supporting detention, seizure, or penal action. Where goods matched the tax invoice and transport documents, and no discrepancy, tax evasion, or intent to evade tax was established, proceedings for goods movement could not rest solely on the absence of an e-way bill.

Parallel State GST assessment and rectification proceedings concerning the same issues and assessment period as an earlier Central GST adjudication cannot be sustained where the Central GST order remains pending in appeal. Duplicate adjudication arises when State GST authorities proceed after Central GST authorities have investigated and issued an order on identical matters for the identical period. The overlap makes the State GST assessment and rectification orders unsustainable.

Section 77 addresses tax paid as CGST and SGST for a supply later treated as inter-State, permitting refund of wrongly paid tax without interest. Its underlying principle supports correcting a clerical selection of tax heads where the full liability was timely discharged. Amounts inadvertently paid under CGST and SGST may be appropriated against the corresponding IGST liability on application, rather than requiring duplicate payment under IGST followed by a refund claim. The earlier deposit may then be refunded in accordance with applicable directions.

Provisional attachment of bank accounts under the CGST Act ceases automatically one year after the attachment order. Rule 159 requires an attachment order in Form GST DRC-22, and no later provisional attachment can extend an original order where no fresh order has been issued. As a temporary revenue-protection measure, provisional attachment cannot continue after statutory expiry or operate as a recovery mechanism. Bank accounts subject only to expired attachment orders must therefore be de-frozen and restored to operation. No demand-cum-show-cause notice had been issued to the affected persons.