GST appeal rejection solely on limitation was treated as unsustainable where cancellation of registration seriously affected the taxpayer's business and non-compliance resulted from an accountant or local advocate failing to communicate return-filing requirements, the show-cause notice and ensuing proceedings. As the appeal had not been examined on merits, merits consideration was required in accordance with law, subject to payment of admissible late fees, penalty and statutory deposits.

GST on actionable claims arising from online gaming, fantasy sports, betting, gambling and casino transactions is treated as applicable where participants stake money on uncertain outcomes. Such participation is characterised as betting and gambling, with the resulting contingent beneficial interests treated as actionable claims and taxable supplies. The charging, valuation and machinery provisions are described as valid. The 2023 amendments, including valuation rules for online gaming and casino transactions, operate as clarificatory and retrospective measures. Pending show-cause notices and adjudication are to proceed under the applicable valuation framework.

GST on actionable claims arising from online gaming, fantasy sports, betting and gambling remains valid where pooled stakes are involved. The governing Supreme Court ruling upheld the relevant charging, supply and valuation provisions, including Rules 31A, 31B and 31C, and treated the 2023 amendments as clarificatory and retrospective. Challenges to the levy raise no independent issue where the substantive grounds are covered by that ruling. Pending show-cause-notice proceedings must therefore be pursued and determined under the applicable GST valuation framework.

Refund of unutilised input tax credit accumulated under an inverted duty structure cannot be rejected without proper consideration of the claimant's manufacturing status, business particulars, supporting documents and earlier refund claims. The rejection was characterised as palpably erroneous, legally infirm, irregular and perverse, warranting interference. The refund rejection was quashed and remitted for fresh consideration in accordance with law, after the claimant furnishes a comprehensive reply and relevant evidence and receives an opportunity of hearing.

Binding prior determinations prevent subordinate revenue authorities from issuing a fresh show-cause notice on identical allegations already conclusively resolved. The product had been treated as unmanufactured tobacco despite the use of machines and additives, and the requirements of fraud, wilful misstatement or suppression for invoking extended recovery provisions were found absent. Where the controversy and parties are identical, an earlier determination remains binding unless lawfully displaced; a pending review does not permit revival of settled allegations. The fresh notice was therefore without jurisdiction and unsustainable.

Provisional attachment of bank accounts under the Central Goods and Services Tax Act, 2017 ceases automatically on expiry of one year from its issuance under section 83(2). Once that period expires, no basis remains for continuing the account freeze unless a valid fresh attachment order is served. Attachment orders should specify their maximum one-year operation, and banks and financial institutions should de-freeze affected accounts upon expiry unless a fresh valid order is received. Regulatory communication should support compliance with this time limit.

Payment claimed under a work order must be verified by the concerned authority, which must take a reasoned decision on entitlement within two months. The petition was disposed of on those directions, without a direct determination requiring payment.

Omission of Rule 96(10) of the Central Goods and Services Tax Rules, 2017 applies to pending integrated tax refund proceedings because the omitted restriction was not preserved by a saving or sunset clause. The rule had restricted export refund claims where supplies were received after specified benefits were availed. As omission ordinarily removes a rule unless pending matters are expressly saved, pending refund claims must be assessed without applying the former restriction. An advisory recommendation favouring prospective operation does not bind the rule-making authority, and removal of unnecessary complications supports this result.

Criminal process cannot be used to coerce repayment of money where allegations arising from instalment payments and a proposed flat sale disclose an essentially civil dispute. Police enquiry and documentary material did not support the oral allegations, while earlier orders had treated the matter as civil; criminal cognizance was therefore unwarranted, and the refusal of cognizance and dismissal of the complaint stood restored. Setting aside a refusal of cognizance and remanding the matter necessarily prejudices the accused person; reopening cognizance without hearing that person was unsustainable.

CENVAT credit denial for alleged non-receipt of inputs requires cogent affirmative evidence where the recipient holds valid registered-dealer invoices, banking records, transport-tax records, statutory returns, stock records and purchase documentation. Investigation statements require statutory safeguards and reliable independent corroboration; inconsistent or allegedly coerced statements cannot alone support a demand. Isolated vehicle-registration discrepancies from the Vahan portal have limited probative value without examination of vehicle owners or evidence disproving transport. Extended limitation requires evidence of fraud, collusion, wilful misstatement or intentional suppression; disclosures in returns and audited records undermine its invocation. These principles support setting aside credit reversal, interest and penalties where evidentiary and limitation requirements remain unmet.

Central excise demand failed because the show cause notice used an indeterminate computation, without identifying actual freight or insurance amounts, the relevant movement of goods, or the basis for differing freight rates; such allegations did not permit an effective defence. Freight and insurance embedded in the all-inclusive sale price were not separately recoverable or includible again in assessable value, as the factory or depot from which goods were sold remained the place of removal rather than the buyer's premises. Extended limitation was also unavailable because freight treatment had been disclosed and no fraud, wilful misstatement, collusion, or suppression was established. Consequential interest and penalty could not survive.

CENVAT credit on inputs and related GTA services cannot be denied solely because VAHAN portal data shows vehicle discrepancies or because limited, unverified third-party communications raise doubts. Denial requires positive, cogent evidence of non-receipt, particularly where statutory and commercial records support receipt and consumption, finished goods were manufactured and cleared on payment of duty, and no stock discrepancy, diversion, fabricated record, or alternative raw-material source is established. Procedural defects in consignment notes are insufficient without independent corroboration of fictitious transactions. Extended limitation is unavailable where credit was disclosed in statutory returns and fraud, collusion, wilful misstatement, or suppression with intent to evade duty is not proved; the demand, interest, and penalties consequently fail.

Delayed filing of monthly duty-paid statements under an area-based exemption scheme is a procedural lapse and does not defeat the substantive exemption benefit where eligibility is otherwise undisputed. Delayed compliance with the stipulated filing date cannot justify recovery of a sanctioned refund or denial of self-credit, because the prescribed statements do not determine the underlying entitlement to exemption. The benefit remains available where the assessee otherwise satisfies the conditions of the area-based exemption scheme.

Extended limitation for recovery of inadmissible CENVAT credit applies where material facts affecting credit eligibility were deliberately concealed. Input-service credit related to services received while manufactured goods enjoyed area-based exemption, but the disclosure of intended post-exemption credit availment did not identify those pre-cut-off invoices. Spreading the credit across ER-1 returns rather than fully disclosing it in the relevant return, despite invoice availability, supported concealment rather than bona fide error. The statutory conditions for the extended period were therefore met, and recovery was not time-barred.

Maximum retail price declaration under the Standards of Weights and Measures (Packaged Commodities) Rules depends on whether packaged commodities are sold to industrial or institutional consumers within the Explanation to Rule 2A(b). Such sales are excluded from Chapter II requirements, including MRP declaration. Where the exclusion does not apply, valuation under section 4A of the Central Excise Act is based on the declared MRP after allowing the applicable abatement.

Reverse-charge service tax does not apply to road freight where no consignment note is issued, because goods transport agency service requires both road transport and a consignment note; mere carriage of goods falls outside that category. Directors' remuneration is not taxable where tax treatment, salary disclosure and provident-fund contributions establish an employer-employee relationship, since employment services are excluded from taxable service. Contract-manufacturing arrangements do not amount to manpower supply where contractors retain responsibility for labour, wages, statutory compliance, safety and supervision, and the recipient lacks control over the workforce. The disputed activities therefore attract no corresponding service-tax liability, interest or penalties.

Refund of accumulated CENVAT credit attributable to exported output services cannot be denied for lack of nexus between input and exported services where availment of the underlying credit was never challenged through recovery proceedings under Rule 14 read with Section 73. Rule 5 permits refund of accumulated credit relating to exported output services where its prescribed conditions and procedure are met. The absence of the service provider's PAN-based registration number on invoices also does not sustain denial in these circumstances. The disputed refund was therefore allowable.

Rejection of a VCES declaration is appealable; a departmental circular cannot override High Court decisions recognising maintainability. Pre-declaration payments must be reckoned towards VCES declared tax dues where they relate to the tax dispute covered by the declaration. Entitlement to settlement therefore requires factual verification of the nexus between earlier deposits and the declared dispute, and rejection solely on non-maintainability cannot stand.

Business Auxiliary Service does not arise merely because dealership incentives, reimbursements, miscellaneous receipts, accounting regroupings or receivable entries appear in ledgers. Incentives under a principal-to-principal dealership arrangement may constitute trade discounts, and Rule 3 of the Point of Taxation Rules, 2011 does not permit double taxation of already invoiced transactions. Goods Transport Agency reverse charge requires evidence that freight was paid or payable to a qualifying GTA, including statutory indicia such as a consignment note. Reverse charge for manpower supply and security services depends on suppliers meeting the specified non-corporate status. Extended limitation requires identified fraud, collusion, wilful misstatement or suppression with intent to evade; disclosed audited records and interpretative disputes are insufficient. Consequently, unsupported tax demands, interest and penalties cannot survive.

Service of an Order-in-Original by speed post requires proof of delivery to the intended recipient or an authorised agent; dispatch alone does not establish valid service. In the absence of delivery evidence for the order allegedly dispatched in December 2022, receipt was treated as occurring when a copy was supplied to the assessee on 03.02.2025. The appeal filed on 31.03.2025 therefore fell within the applicable two-month limitation period, making the contrary limitation finding unsustainable.