GST appellate pre-deposit remains mandatory even where tax was paid during adjudication and only the penalty is disputed. The GST framework provides no exemption from the statutory deposit required to file an appeal. The correctness of tax and penalty liability, including the legal effect of tax paid during adjudication, must be examined on the merits by the appellate authority and cannot support waiver of the pre-deposit requirement. Exemption from statutory pre-deposit is therefore unavailable in these circumstances.

Challenge to a GST demand order in Form GST DRC-07 raised alleged statutory and natural-justice violations. The petitioner was granted liberty to pursue the statutory appellate remedy on making the prescribed pre-deposit and filing an application to condone delay. The appellate authority may assess whether delay should be condoned and, if satisfied, determine the appeal on its merits in accordance with law.

Challenge to a show cause notice and tax demand was raised in a writ petition. The writ petition was disposed of with liberty to pursue the statutory appeal. The statutory appellate route remained available for the petitioner to contest the show cause notice and tax demand through the prescribed appeal process, instead of obtaining substantive relief in the writ petition.

Challenge to a Form GST DRC-07 order alleging illegality, breach of the GST Act and denial of natural justice was disposed of with liberty to pursue the statutory appellate remedy. The petitioner may file an appeal on the prescribed pre-deposit and seek condonation of delay. The appellate authority may consider the delay application and, if satisfied, decide the appeal on merits in accordance with law.

Challenge to an assessment order despite an available appellate remedy was addressed through writ jurisdiction. The writ petition was disposed of with liberty to pursue the statutory appeal, subject to the prescribed pre-deposit and an application for condonation of delay. Coercive recovery under the garnishee notice was stayed for the period permitted to file the appeal.

GST appellate pre-deposit is not required where the disputed tax has already been paid under the IGST regime and the dispute concerns whether supplies are inter-State or intra-State, resulting in CGST and SGST liability. As the demand did not involve excess input tax credit, requiring a further 10% deposit under Section 112 would not be warranted for access to the appellate remedy. An appeal may be filed before the GST Appellate Tribunal within one week without that additional pre-deposit, while all merits issues remain open.

Section 73(2) of the Telangana Goods and Services Tax Act, 2017 governs the limitation period for proceedings concerning financial year 2020-21. A show-cause notice issued on 15 July 2025 and assessment orders passed on 9 September 2025 fell after the applicable cut-off date of 28 February 2025. Proceedings initiated or concluded beyond that limitation period are time-barred, involve a jurisdictional error, and cannot sustain consequential recovery action.

Failure to consider a taxpayer's reply to a show-cause notice and to provide a personal hearing before an adverse GST adjudication breaches the requirement under Section 75(4). Differing dates in the adjudication order and its annexure supported the inference that the reply, filed before the order, was not considered. Availability of an appellate remedy does not bar writ relief where adjudication denies this procedural opportunity. The adjudication and appellate orders were unsustainable, resulting in relief for the taxpayer.

Excess input tax credit confirmed without a reply was quashed where the disputed credit had subsequently been reversed and sufficient credit was available in the electronic credit ledger during the relevant period. The taxpayer must receive a fresh opportunity to file a reply and supporting evidence to substantiate the claim. The matter was remitted for de novo adjudication on merits.

Delay in filing a statutory GST appeal under Section 107 may be condoned where circumstances beyond the assessee's control prevented timely filing and refusal would deny an effective appellate remedy. Portal-only service of an order may not, in appropriate circumstances, justify rejection of the appeal solely on limitation grounds. The appellate authority must entertain and decide the appeal on merits if it is filed within 30 days of upload of the condonation order.

Condonation of delay in filing a GST appeal was granted in writ jurisdiction despite the Appellate Authority's statutory inability to extend the limitation under section 107 of the RGST/CGST Act. Delay attributable to circumstances beyond the petitioner's control, coupled with the grave prejudice arising from refusal of merits review, justified relief. The High Court directed the Appellate Authority to entertain and decide the appeal on merits, subject to filing within the stipulated period.

Excess input tax credit demand required reconsideration because the disputed credit had been reversed and surplus credit remained in the Electronic Credit Ledger. The High Court quashed the demand order, which had confirmed the show-cause notice without a reply, and remitted the matter for fresh adjudication on merits. The taxpayer must file a reply to the show-cause notice with supporting documents within the stipulated period; otherwise, recovery may proceed in accordance with law.

GST adjudication requires consideration of the taxpayer's reply to the show-cause notice and a further opportunity of personal hearing before an adverse order is made on that reply. Inconsistent dates in the adjudication order and its annexure supported the inference that the subsequently filed reply had not been considered. The High Court set aside the adjudication and appellate orders and remitted the matter for fresh adjudication after personal hearing, subject to the stipulated further deposit. The original adjudication order would revive if the taxpayer failed to cooperate.

Statutory limitation under Section 73(2) of the Telangana GST Act governed the validity of the show-cause notice and assessment orders for financial year 2020-21. Issuance of the notice after the prescribed deadline, followed by assessment orders beyond the applicable cut-off, constituted a jurisdictional error. The time-barred proceedings, including the consequential recovery notice, were therefore set aside.

GST appellate remedy requires the statutory pre-deposit even where tax dues were paid during adjudication proceedings. Payment of the disputed tax, or a challenge to the correctness of tax or penalty, does not dispense with this filing condition; those issues must be determined on the appeal's merits. The petitioner could pursue the statutory appeal only after making the prescribed deposit and filing a delay-condonation application. The appellate authority was directed to consider the delay application sympathetically and, if satisfied, decide the appeal on merits.

Voluntary reversal of excess input tax credit, with applicable interest, before issuance of a demand-cum-show-cause notice eliminates further interest liability under section 73 of the CGST Act where revenue records verify the claim. The taxpayer's reversal was accepted as genuine, resulting in the first appellate order being set aside and the appeal being allowed. Any necessary demand appropriation must be issued by the proper officer within one month of communication.

Political contribution deductions supported by banking payment and a receipt from a registered unrecognised political party cannot be disallowed merely on general search material suggesting that the recipient operated a cash-back arrangement. Such material may warrant inquiry, but cash repayment to a particular donor requires assessee-specific evidence establishing a transactional nexus. Search presumptions do not establish cash receipt by a person from whose possession or control the material was not found, particularly where third-party material is not supplied and cross-examination is unavailable. An unexplained-money addition also requires proof that the assessee owned unrecorded money; inferred cash receipt based on alleged commission, without foundational evidence, is conjectural.

Interest on borrowed capital extends to service fees and other charges connected with money borrowed, debt incurred or a credit facility. Protection insurance, processing fees and annual maintenance charges paid in connection with a bank loan used to acquire a let-out property fall within this broader meaning where their genuineness and nexus with the borrowing are undisputed. Such charges are deductible as interest on borrowed capital in computing income from house property, and the related disallowance is not sustainable.

Reassessment beyond three years requires escaped income to meet the statutory threshold; where unaccounted purchases had corresponding sales and the embedded profit was separately assessed, only that profit constituted escaped income. Reassessment notices for AY 2014-15 to AY 2018-19 were therefore quashed. Material seized during a third-party search required notice under section 148 before assessment, rendering the direct AY 2022-23 assessment void. No cross-examination breach arose without a specific request, and the pre-amendment reassessment regime permitted a 30-day return period. Where corresponding sales were accepted, tax applied only to embedded profit, not the full unaccounted purchase value.

Surrendered excess stock and cash identified during a survey were characterised as business income where the taxpayer consistently offered them as miscellaneous business income, dealt regularly in the excess stock, and had no independent undisclosed asset or non-business income source. Such income was therefore taxable at normal rates. The enhanced rate introduced under section 115BBE applied prospectively from Financial Year 2017-18, corresponding to AY 2018-19, and did not apply to AY 2017-18. Disallowance of investment-related expenditure under section 14A was sustained as statutorily computed, and ad hoc disallowances of specified business expenses were also sustained where ledger extracts and cash payments did not justify interference.