Article 226 may be invoked exceptionally to prevent grave prejudice where the statutory GST appellate limitation cannot ordinarily be bypassed. Explained medical circumstances beyond the appellant's control justified setting aside dismissal of a time-barred appeal and restoring it for decision on merits. Restoration remained subject to payment of admissible late fees, penalty and statutory deposits. The limitation framework under the Rajasthan and Central GST laws continues to bind the Appellate Authority, while writ jurisdiction remains available only in exceptional circumstances.

Rule 86A(3) of the Tamil Nadu GST Rules provides that a restriction on use of input tax credit imposed under Rule 86A(1) automatically ceases after one year. Continued blocking of the electronic credit ledger beyond that period cannot be sustained, particularly where the Rule 86A prerequisites are not independently satisfied. Internal departmental communication cannot justify an extended restriction. Where recovery is warranted following assessment, it must proceed through the regular statutory recovery mechanism. The credit ledger must be unblocked after the one-year restriction expires.

Breach of natural justice permits writ relief against a tax-determination order despite an available and already-filed statutory appeal. A determination order that merely records the assessee's reply, position and documents without considering the contentions, and is passed without an opportunity of hearing, is vitiated. The appellate remedy does not require the assessee to be relegated to appeal where the challenged order suffers from these procedural defects; writ jurisdiction remains available.

Input tax credit under Section 17(5)(d) is blocked only where immovable property is constructed on the taxable person's own account, subject to stated exceptions. Construction intended for sale, lease or licence is distinguished from personal use or premises from which the taxable person conducts business; ownership and capitalisation alone do not determine the restriction. Recovery through electronic cash or credit ledger debits requires prior electronic intimation in Form GST DRC-01D under Rule 142B and expiry of the prescribed seven-day period. Debits made without that procedure require restoration to the corresponding electronic ledger.

Omission of Rule 96(10) of the Central Goods and Services Tax Rules, 2017, effective from 8 October 2024, applies for the benefit of assessees in all proceedings pending on that date. The removal of the restrictive provision must be given effect when processing challenges to show-cause notices, orders-in-original and consequential refund claims. Pending matters are therefore to be dealt with without applying the omitted restriction.

Reasonable cause under section 80 of the Finance Act, 1994 may protect an assessee from penalty where a bona fide and reasonable belief supports non-payment of service tax. Contemporaneous departmental communications supporting the view that the services were non-taxable can establish that reasonable cause. A finding that there was no wilful suppression of facts or intent to evade tax, particularly where the extended limitation period is unavailable, materially reinforces the absence of culpable conduct. On these grounds, penalty under section 78 was unwarranted and set aside.

Uploading a show cause notice solely under the portal's 'Additional Notice and Orders' tab, without separately informing the taxpayer, denied a meaningful opportunity to respond before adjudication. This breached principles of natural justice because the taxpayer remained unaware of the notice and could not present a defence. The show cause notice and resulting adjudication order were quashed. Fresh adjudication may be initiated only after issuing a fresh notice and affording an opportunity of personal hearing.

GST adjudication based on a show-cause notice uploaded only in the portal's "Additional Notice and Orders" tab, without separate intimation, denied the assessee an effective opportunity to reply. Such portal-only service, where it leaves the assessee unaware of the proceedings, violates principles of natural justice. The show-cause notice, adjudication order and consequential notices were quashed, with fresh adjudication permitted after issuance of a fresh notice and an opportunity of hearing.

Bail conditions requiring a security bond equal to alleged tax and penalty dues are addressed as potentially onerous and incapable of enforcement where an accused stands on the same footing as co-accused subject to an identical condition. Declared family assets may provide adequate security for the alleged dues. The prescribed approach is that the bond equivalent to the full alleged tax and penalty amount need not be insisted upon when assets disclosed by the appellant's mother are accepted as security.

Bail conditions requiring a security bond equivalent to alleged tax and penalty liability may be modified where the accused stands on the same footing as a co-accused whose condition was found onerous and vague. Disclosed family assets, supported by affidavit, may constitute security instead of the stipulated bond. The impugned security-bond requirement was not to be enforced, and the declared family assets were treated as security for the alleged dues.

Reasonable cause under Section 80 of the Finance Act, 1994 can shield an assessee from penalty under Section 78 for non-payment of service tax where contemporaneous departmental communications supported a bona fide belief that consultancy services provided to Government institutions were non-taxable. Interpretational uncertainty, the Department's initial view, and the absence of fraud, wilful misstatement, suppression with intent to evade, or deliberate default support reasonable cause. Service tax for the normal limitation period and applicable interest remained payable, but the Section 78 penalty was set aside.

Omission of Rule 96(10) of the CGST Rules, effective from 8 October 2024, applies to all pending proceedings and extends its benefit to affected assessees. The Supreme Court upheld this position, settling challenges concerning the deleted provision. Pending matters involving notices, orders-in-original, consequential refund claims and remittances must therefore be processed in accordance with the omission and applicable law. Challenges pending before High Courts are to be placed before the appropriate roster courts for orders consistent with the settled position.

Input tax credit claims for construction intended to be leased or licensed require consideration of the principle that such construction is not undertaken on the taxable person's own account. Assessment findings rejecting a leasing-based claim without applying the Supreme Court ruling in Safari Retreats required fresh consideration; the assessment and consequential DRC-07 orders were set aside without deciding ITC entitlement on merits. Recovery by debiting electronic cash or credit ledgers also required prior electronic intimation in Form GST DRC-01D and seven days to pay under Rule 142B. Non-compliant recoveries were to be re-credited or refunded after the underlying assessments were set aside.

Section 16(5) of the CGST Act, inserted retrospectively, grants input tax credit to taxpayers who furnished returns by its prescribed cut-off date, notwithstanding the time limit in Section 16(4). A circular cannot restrict that statutory entitlement. A notification requiring a rectification application within a specified period does not govern a taxpayer who had already filed an appeal against the assessment order before the amendment. Denial of March 2020 input tax credit and consequential demands therefore require reconsideration under Section 16(5), subject to other eligibility conditions.

Section 171 permits GST rate-reduction benefits to be passed through electronic gift vouchers where e-wallet credits carry monetary value, are unconditional, have no expiry or usage restrictions, and are traceable to identified customers, invoices and supplies. System-generated labels such as "Offers and cashback" do not negate the documented link to the benefit. Benefits not traceable to identifiable recipients remain unpassed; after accounting for cancelled or returned supplies, the residual amount must be deposited in the Central Consumer Welfare Fund with applicable interest. The anti-profiteering penalty provision does not apply to conduct occurring before it came into force, so no penalty is leviable for that earlier period.

GST treatment of school-affiliation, annual registration and late-registration charges turns on whether services directly relate to admission to or conduct of examinations. Affiliation and related administrative charges are treated as independent taxable supplies, with the examination-services exemption construed strictly; affiliation regularisation remains limited to its specified period. A consolidated show cause notice may cover multiple tax periods absent prejudice or jurisdictional defect. GST Council-based circulars on affiliation remain binding on departmental authorities. Amounts collected without separately charging GST require cum-tax valuation. Extended limitation requires affirmative proof of fraud, wilful misstatement or delibe.....

Finality of tax liability was central to the closure of criminal prosecution. The liability dispute had not become final when the Trial Court closed the prosecution; the tax demand was determined, accepted and complied with only afterwards. Closure on the premise that the liability had already been fully satisfied therefore failed to account for material subsequent developments. The closure order was set aside, and the matter was remanded to the Trial Court for fresh consideration in accordance with law, without any view on the merits of the criminal prosecution.

Work Contract Tax actually paid during the relevant previous year is deductible for an assessee consistently following the cash system of accounting, even where the statutory liability relates to earlier financial years. Once the books and accounting method are accepted, mercantile principles cannot be selectively applied to deny the deduction without material showing a mercantile method, manipulation, or accounting defects warranting intervention. Interest paid solely for delayed payment of Work Contract Tax is compensatory rather than penal in nature. As it compensates the State for delayed use of funds and relates to statutory business liability, the interest is allowable as a business deduction.

Expenditure on an abandoned towel-manufacturing expansion within an existing textile business was deductible as revenue expenditure because no completed capital asset or enduring advantage arose. Its initial classification as capital work-in-progress did not determine its character, which depended on its purpose and business context. The matching principle could not restrict a statutory deduction or compel spreading of expenditure; it applies only where the taxpayer elects to spread costs and the relevant conditions are met. The write-off was allowable in the relevant year, and the disallowance was deleted.

Buy-back of a company's own shares followed by mandatory extinguishment does not entail receipt of "property" for section 56(2)(x), because the shares cannot be held, enjoyed or transferred by the company as an asset. Interest-free advances do not justify interest disallowance under section 36(1)(iii) where interest-free own funds exceed those advances and no specific borrowing is traceable to them; proportionate disallowance from a mixed pool of funds is unwarranted. Principal loans and inter-corporate deposits written off in an organised money-lending business qualify as bad debts where actual write-off occurs. A lending licence, tax-audit description and the proportion of interest income are not determinative of that business character.