Uploading show-cause notices solely in the portal's additional-notices window, where the recipient could not access them or respond, does not satisfy statutory service requirements. Such inaccessible communication denies a meaningful opportunity of hearing and breaches principles of natural justice. The assessment was set aside to the extent affected by invalid service, with an opportunity to submit a reply before fresh assessment proceedings.

Duplicate GST adjudication for identical issues and the same assessment period cannot continue where Central GST authorities had already issued the earlier order and that order remained pending in appeal. Subsequent State GST assessment and rectification proceedings on those issues were unsustainable because they duplicated the prior Central GST adjudication. The State GST orders were quashed in favour of the assessee.

GST adjudication under Sections 73 and 75 requires an effective opportunity to reply before a personal hearing where adverse consequences are contemplated. Scheduling the hearing before the expiry of the reply period denies that opportunity and violates principles of natural justice. Further, uploading a show-cause notice and adjudication order solely in the GST portal's "Additional Notices and Orders" tab does not constitute valid communication for Section 73 proceedings. Non-compliance with either the statutory hearing process or valid communication requirements invalidates the adjudication; the matter requires fresh determination after permitting a reply and scheduling a proper hearing.

Rule 96(10) of the Central Goods and Services Tax Rules, 2017 imposed restrictions on IGST refund claims beyond those contemplated by Section 16 of the Integrated Goods and Services Tax Act, 2017, rendering it ultra vires and manifestly arbitrary. Its omission without a saving clause makes the rule unavailable for pending matters that have not attained finality. Consequently, recovery or denial-of-refund proceedings based on Rule 96(10) cannot continue, and the earlier binding decision on the issue applies to similarly situated taxpayers.

GST show-cause notice service solely through the portal is ineffective where registration was cancelled before the notice was issued, because the taxpayer cannot be expected to monitor the portal thereafter. Section 169 permits multiple service modes but requires effective communication. Adjudication imposing tax and penalty also requires a personal hearing under Section 75(4) when requested. The tax and penalty order was quashed, with Revenue permitted to restart proceedings from the show-cause-notice stage and provide a hearing if sought.

Challenges concerning input tax credit restrictions under Section 17(5)(c) and (d) stand governed by the Supreme Court's resolution of their constitutional validity. Application of the functionality test and assessment of whether the impugned circular operates consistently with that ruling require factual determination by the Adjudicating Authority. Taxpayers may therefore pursue the relevant claims before that authority in accordance with law. Where proceedings were pursued bona fide before an incorrect forum, exclusion of that period may be sought under Section 14 of the Limitation Act, 1963.

GST registration cancelled for continuous non-filing of returns may be restored where the taxpayer clears all intimated statutory dues, penalties and fines within the prescribed period. The applicable approach permits revocation of cancellation to enable discharge of outstanding GST liabilities and resumption of compliance. Restoration is conditional upon timely payment of the amounts due.

Statutory GST appellate remedy remained the appropriate route because the State GST show-cause notice had been overtaken by subsequent Central GST adjudication proceedings. The interlocutory challenge to the Central GST adjudication order was unrelated to the original writ challenge, and no jurisdictional error or restraint on initiation of those proceedings was established. The show-cause notice challenge was therefore infructuous and the interlocutory challenge misconceived. Petitioners who had pursued writ proceedings on mistaken legal advice while interim protection operated were permitted to file a statutory appeal within 30 days, to be considered on merits without limitation objection.

Input tax credit mismatch demands require invoice-related verification and satisfaction of the statutory conditions for credit before confirmation. Circular No. 183/15/2022-GST prescribes that the proper officer obtain relevant invoice details and undertake this verification. Ex parte assessment and appellate orders issued without that procedure or an adequate hearing warranted fresh consideration. The tax demand and entitlement to input tax credit remained undecided, with the adjudicating authority required to reconsider the matter after receiving a comprehensive representation and providing a reasonable opportunity of hearing.

GST appeal limitation may not be triggered merely by uploading an order-in-original on the common portal where the taxpayer specifically asserts non-service and lacks acknowledged receipt or participation. Although the Appellate Authority is bound by the statutory limitation under Section 107 and cannot itself condone delay, merits adjudication may be required where delay arose from circumstances beyond the taxpayer's control. The appeal was restored for adjudication on merits after the delay was condoned, subject to compliance with the stipulated pre-deposit requirement.

Section 107 of the Central Goods and Services Tax Act, 2017 requires an appeal to be filed within three months of communication of the adjudication order, with condonation available only for a further one month upon sufficient cause. The Appellate Authority has no jurisdiction to condone delay beyond that expressly limited period. Consequently, an appeal filed approximately two years after the original order cannot be entertained, particularly where the delay is not properly explained, and dismissal as time-barred stands upheld.

Transfer of a taxpayer's GST audit file from the Audit Wing to the Anti-Evasion Wing within the same Commissionerate is an administrative exercise. The Central Goods and Services Tax Act, 2017 contains no statutory prohibition on such transfer, so transfer alone does not warrant writ interference. Non-production of requested financial documents during audit was also recorded. Objections concerning the statutory period for completion of the audit may be raised before the Adjudicating Authority. The transfer therefore remains unaffected in writ jurisdiction.

GST registration restoration and time to pay late fee may be sought through a representation to the jurisdictional Superintendent where financial hardship and loss of portal access are asserted. The Superintendent has discretion to consider exceptional circumstances, so no mandatory direction for restoration or deferred payment follows. A request may be submitted within four weeks and must be considered and decided within one month of submission.

Challenges to a GST demand as time-barred under Section 74(10) require examination of the demand's nature, underlying proceedings and factual basis to identify the applicable limitation starting point. Where that inquiry involves debatable factual and legal issues, the statutory appellate remedy is the appropriate forum rather than writ jurisdiction. The taxpayer was therefore directed to pursue an appeal, with the Appellate Authority to pragmatically consider any request to exclude the period spent in writ proceedings under Section 14 of the Limitation Act, 1963.

GST Tribunal availability provides an efficacious statutory appellate remedy against cancellation of GST registration and rejection of a revocation application. Extraordinary writ jurisdiction should therefore not be exercised where the Tribunal can adjudicate the challenge on merits. All issues and contentions remain open before the Tribunal, and time spent bona fide pursuing the writ remedy is excluded for limitation if the Tribunal is approached within the stipulated period. The challenge must proceed before the GST Tribunal rather than through the writ petition.

Revocation of GST registration cancellation cannot be rejected without a proper and effective opportunity of hearing under the first proviso to Section 30(2). Effective hearing requires prior notice of the appointed date and time; a show-cause notice merely referring to a possible personal hearing is insufficient. Rejection based solely on failure to submit a reply, without specifying the hearing schedule, also lacks valid procedural basis where the order is cryptic and non-speaking. The revocation application must be reconsidered after due notification and an opportunity for personal hearing.

Principles of natural justice require effective notice and a meaningful opportunity to respond. Uploading a show-cause notice solely under the "Additional Notice and Orders" tab without separate intimation prevented the petitioners from responding within time, creating a prima facie procedural breach. Dismissal of the statutory appeal on limitation without examining merits was therefore set aside. The appeal was directed to be admitted and reconsidered on merits after hearing the petitioners.

GST refund cannot be withheld merely because a Revenue appeal is pending. Rule 90(3) permits deficiencies in a refund application to be communicated through Form GST RFD-03, but it does not substitute for the statutory withholding mechanism. Withholding under Section 54(11) requires the Commissioner to exercise that power through a specific, reasoned order after issuing notice and providing an opportunity of hearing. In the absence of such an order, pendency of an appeal does not justify withholding the claimed refund.

Service of a show cause notice under Section 73 of the CGST Act is not sufficiently established merely by uploading it on the common portal where the assessee neither acknowledges receipt nor files a reply. Ex parte adjudication on that basis denies an effective opportunity to respond and be heard. The ex parte order was set aside, proceedings were restored to the show cause notice stage, and the assessee was permitted to submit a reply. A fresh order must follow a hearing and be passed in accordance with law.

Effective statutory appellate remedy against a fresh GST adjudication order ordinarily requires the taxpayer to pursue objections before the appellate authority rather than invoke writ jurisdiction. Challenges to the maintainability of a subsequent show-cause notice and a claimed earlier dropping of proceedings may be raised in that appeal. The appellate authority may consider excluding the period spent pursuing writ proceedings when assessing limitation. The writ challenge was not entertained on merits, and the taxpayer was relegated to the statutory appeal mechanism.