Disclosure of relied-upon analytics reports is required where they form the basis of a customs classification dispute. Setting out the report's parameters, entries and core findings in a show-cause notice does not give the affected party an adequate opportunity to answer the case. Non-supply of the report and supporting documents breaches principles of natural justice and vitiates the adjudication order. Fresh adjudication must follow disclosure of all relied-upon material.

Manual filing of an appeal in FORM GST APL-01 with supporting documents is permitted where the rectification order being challenged is unavailable on the common portal under the amended appellate procedure. This enables the appeal to proceed despite the order's absence from the portal. The petitioner was allowed four weeks to file the appeal, with no limitation objection, for consideration on merits.

Section 75(4) mandates an opportunity of hearing where a show-cause notice contemplates an adverse decision. A taxpayer must be allowed to respond to the notice before the proper officer determines the matter through a reasoned order after hearing the taxpayer. An assessment made without that hearing does not comply with the mandatory statutory requirement and is unsustainable, requiring fresh adjudication in accordance with law.

GST treatment of actionable claims arising from betting and gambling extends to online gaming and fantasy sports played with stakes. Such actionable claims are treated as goods within the GST framework, and their supply is subject to prescribed valuation rules for betting, gambling and casino transactions. The 2023 amendments, including Rules 31B and 31C, are characterised as clarificatory and retrospective, requiring pending show-cause notices and proceedings to be determined on that basis. Casino-related valuation is to be recomputed under the specialised valuation rule applicable to casino transactions.

Proof of due service and receipt of summons is necessary before alleged non-compliance can support cognizance under the Bharatiya Nyaya Sanhita, 2023. For summons issued under the CGST Act, tracking records alone do not establish service or acknowledgment. Mere issuance therefore cannot demonstrate deliberate disobedience, evasion, or a prima facie case of wilful non-compliance. In the absence of evidence that the summons was duly served, refusal to take cognizance was sustained.

Anticipatory bail was unavailable where allegations prima facie indicated involvement in a conspiracy using forged invoices of non-existent firms, collecting tax without depositing it, and causing wrongful loss. Given the nascent investigation, custodial interrogation was considered necessary to establish the method of the alleged offences and the petitioner's connection with the fictitious firm. Pre-arrest bail remains an exceptional remedy requiring cautious exercise and exceptional circumstances, which were not established. The petitioner was therefore not entitled to anticipatory bail.

Section 75(4) of the CGST Act mandates a personal hearing whenever an adverse GST adjudication is contemplated. Show-cause notices that omit a hearing opportunity cannot support a valid adverse determination. Uploading notices and adjudication orders only under the portal's 'Additional Notice and Orders' tab may impede timely response and reinforce the procedural breach. An adjudication made without the mandatory hearing is invalid and requires fresh determination after considering the taxpayer's reply.

Restoration of Form GSTR-1 filing access on the GST common portal pending departmental proceedings depends on examination of the registered person's response and supporting material. No determination was made on the registration allegations or entitlement to portal access. The High Court required the registered person to submit a detailed representation to the issuing authority, which must decide it by a reasoned order after a personal hearing. Portal access must be activated only if the authority finds the person to be a bona fide registered proprietor.

Completion of the e-KYC process enabled the refund claim to be entertained and allowed. Administrative instructions were requested for similarly situated claimants, indicating that completed e-KYC should facilitate processing of comparable refund claims.

GST show-cause notices issued after cancellation of registration require physical service where the binding departmental circular so prescribes. Uploading notice solely on the common portal may not provide effective notice because a cancelled registrant may no longer operate or access the portal. Service only through the portal, more than four years after cancellation, was therefore insufficient and rendered the ex parte GST adjudication invalid.

GST registration cancelled for continuous non-furnishing of returns is to be revoked and restored where portal-based compliance became unavailable after expiry of the statutory revocation and return-filing periods. Restoration is conditional on the taxpayer intimating the authorities and clearing all statutory dues, penalties or fines within the prescribed time. The relief follows comparable restoration orders and was not opposed by the revenue authorities.

Section 161 of the CGST Act and Clause 4 of Notification No. 22/2024-CT treat the period for deciding a timely rectification application as directory, because the requirement to decide it within three months operates only "as far as possible". The competent authority must endeavour to meet that period, but its expiry neither makes it functus officio nor extinguishes jurisdiction to determine the application on merits. A rectification application filed within the prescribed time therefore cannot be rejected solely because the decision period has elapsed and must be considered on merits.

Service of a GST show-cause notice solely through the portal after cancellation of the registered person's registration is inadequate, because the person is no longer obliged to monitor that portal. Alternative service is required to provide a meaningful opportunity to respond. Failure to use an alternative mode denies natural justice and renders the resulting assessment unsustainable. The assessment order was quashed, while fresh proceedings were permitted upon service of a proper notice in accordance with law.

GST registration revocation cannot be rejected through a non-speaking order. An order determining civil rights must record intelligible reasons, and a rejection unsupported by any accompanying order disclosing its basis is unsustainable. The revocation application therefore requires fresh determination in accordance with law.

A timely filed rectification application remains capable of decision on merits after the three-month disposal timeline expires. The requirement that the competent authority decide the application "as far as possible" within that period is directory: it requires an endeavour to comply but neither makes the authority functus officio nor removes its jurisdiction after three months. Rejection solely on the ground that the disposal period had expired was quashed, and the application was remitted for a merits-based decision within three months.

Restoration of blocked GST portal access for furnishing Form GSTR-1 requires effective consideration of the taxpayer's supporting material. The taxpayer must submit a comprehensive representation in response to the information notice, and the competent authority must decide it through a reasoned and speaking order after granting a personal hearing. Where the material establishes that the taxpayer is a bona fide registered proprietor, the GST portal must be activated within 48 hours to enable Form GSTR-1 filing. The merits of the restoration request remain subject to fresh independent determination by the competent authority.

Anticipatory bail was refused where allegations of cheating and forgery involved inducing purchases through fictitious firms and using forged invoices to evade deposit of collected tax. The accusations prima facie indicated the accused's involvement, while the investigation remained at an early stage. Custodial interrogation was considered necessary to establish the manner of the alleged offences and obtain material linking the accused to the fictitious firm. As pre-arrest bail requires extraordinary and exceptional circumstances, and none were established, the petition was dismissed without addressing the trial merits.

Proof of service and acknowledgment of statutory summons are necessary to support an allegation of deliberate or wilful non-compliance during an investigation. Mere issuance of summons, without material establishing that the person concerned received and acknowledged them, does not establish intentional disobedience or evasion of appearance. On those facts, declining cognizance of the complaint was treated as free from jurisdictional error. Fresh summons may be issued where legally permissible, provided they are duly served and proof of service is maintained. No conclusion follows on the merits of the investigation or on any underlying liability or offence.

GST on actionable claims arising from betting and gambling, including online gaming and fantasy sports played with stakes, remains payable under the GST framework. The Supreme Court sustained the levy and the validity of the relevant provisions, Rule 31A, Rules 31B and 31C; the 2023 amendments and Rules 31B and 31C operate clarificatorily and retrospectively. Pending show-cause proceedings must be decided on that basis, with casino valuation recomputed under Rule 31C. Following an undertaking to adjudicate accordingly, the petitioner withdrew the petition without pressing reliefs.

GST adjudication involving penalty or other adverse liability requires an opportunity of personal hearing. A show-cause notice stating that personal hearing is inapplicable, followed by an adjudication order without a hearing, breaches the statutory hearing requirement and principles of natural justice; a hearing in an unrelated earlier matter does not cure that defect. Section 74A(8)(ii) allows payment of tax and applicable interest within 60 days of the show-cause notice without penalty, with proceedings deemed concluded. Adjudication before expiry of that payment period contravenes the provision. Orders issued in breach of either requirement are unsustainable.