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.

Service-tax liability on turnover from trading in farm products requires examination of whether that turnover is exigible to service tax before liability can be sustained. Where the adjudicating order proceeded on the basis that no response was filed and no personal hearing was attended, reconsideration is required after allowing the taxpayer to respond and submit relevant material. The service-tax order was quashed and the proceedings restored for fresh consideration, with the taxpayer's response to be considered without rejection solely for delay. The writ petition was partly allowed.

Cancellation of GST registration based solely on a list identifying an enterprise as fake requires prior physical verification of its registered business premises, particularly where the registrant has responded to the show-cause notice with documents relating to State Authority proceedings. Treating the enterprise as non-operational without that verification was improper. The show-cause notice and cancellation order were quashed, while preserving the proper officer's ability to verify the premises under the GST Rules and take further action in accordance with law.

Effective opportunity of hearing in GST adjudication was denied where electronic notices were sent to e-mail credentials registered with an erstwhile auditor, leaving the taxpayer without effective knowledge of the proceedings. The High Court treated the explanation of loss of contact with the auditor as plausible and bona fide, and found that the resulting inability to respond justified intervention against the ex parte adjudication. The adjudication order and summary were quashed, with fresh consideration directed after a 10% deposit of the tax demand and filing of a response and supporting documents. The authority must issue a reasoned order after affording an opportunity to respond.

Re-credit of excess tax to an electronic credit ledger requires examination of the taxpayer's entitlement under the applicable refund framework and CBIC circulars. Relief cannot be granted without recorded reasons; the direction permitting re-credit was therefore set aside and remanded for a fresh speaking order. Recomputation of GST liability also requires a disclosed and reasoned basis, with reference to self-assessed and auto-generated returns and audit reports on record. The unexplained reduction of assessed liability was set aside and remanded for fresh determination after hearing both sides.

Valid e-way bill compliance requires Part B to identify the vehicle actually transporting goods. Where a vehicle breaks down and goods are transferred, the movement must be supported by contemporaneous evidence and the e-way bill must be updated or freshly generated before transit. A later e-way bill issued by the purchaser does not cure a vehicle mismatch where the driver holds the supplier's invoice and no contemporaneous material establishes purchaser-led transport. Such discrepancies are not merely technical and can support an inference of intent to evade tax. Penalty proceedings under Section 129 for transport without a valid e-way bill were confirmed.

Tax withholding under Section 195 arises only where a payment to a non-resident is chargeable to tax in India. Where consistent Tribunal findings, upheld by the High Court for earlier years, establish that the recipient has no permanent establishment in India and its relevant income is not taxable, the Assessing Officer cannot take a contrary position on identical facts. Section 195(2) applies only when the payer accepts that part of a remittance is taxable but requires determination of the taxable portion or deductible tax. It does not require an application where the entire payment is not chargeable. Consequently, no tax deduction obligation or Section 201 default arises for such payments, and the Section 201 order was quashed.

Third-party search material forming the foundation for assessment of a person other than the searched person requires use of the special assessment procedure under section 153C. Its overriding clause displaces general reassessment under sections 147 and 148, even where the Revenue subsequently analyses or corroborates the seized material and treats it as information indicating escaped income. Because the alleged transactions, taxpayer identification and inference of unaccounted income originated in seized material, the section 148A(d) order and consequential section 148 notice lacked jurisdiction and were quashed.

Consequential assessment orders giving effect to appellate directions that require verification and an opportunity to the assessee must be completed within the limitation period applicable under section 153(3), as extended by TOLA where relevant. Where the appellate order was received during FY 2019-20, the consequential order had to be made by 31 March 2022. An order issued after that date is time-barred and cannot support a demand notice. In the absence of a valid fresh assessment, the returned income must be accepted, and amounts deposited against the invalid demand are refundable with interest.