GST demands founded on alleged fraudulent registration and identity theft should ordinarily be challenged through the statutory appellate remedy where impersonation, forgery and use of identity documents require assessment of disputed facts and evidence. Writ jurisdiction is unsuitable for re-evaluating findings already considered by the adjudicating authority, while the identity-theft investigation remains subject to the competent criminal court's supervision. The petitioners were directed to pursue the statutory appeal and could seek exclusion of time spent in writ proceedings for limitation purposes.

Under the Uttar Pradesh Goods and Services Tax Act, 2017, uploading a show-cause notice solely on the GST portal after cancellation of the taxpayer's registration does not provide effective service. Once registration is cancelled, the taxpayer is not obliged to monitor the portal, and an alternative mode of service is required to ensure a meaningful opportunity of hearing. Portal-only service in these circumstances breaches the principles of natural justice, rendering the resulting assessment order invalid and liable to be quashed.

Disputed denial of input tax credit, interest and penalty required factual verification of ERP software existence and use, and of the underlying transaction's genuineness. Because those matters had not been tested and a statutory appellate remedy was available, writ jurisdiction was not appropriate for resolving the controversy. The party was permitted to file a statutory appeal within 30 days without pre-deposit, and the appellate authority was directed to decide it on merits within three months.

Ex parte GST assessment and rejection of a delayed statutory appeal required reconsideration because the assessee asserted that the disputed tax had already been paid, but the payment was not reflected in the assessment. Verification of the asserted payment was necessary. Fresh adjudication was directed after the assessee deposits 15% of the disputed tax through the Electronic Credit Ledger and files a reply supported by relevant documents. The assessment and appeal-rejection orders were quashed and the matter remitted subject to those conditions.

A petitioner challenging a GST adjudication order was permitted to pursue the statutory appellate remedy. The writ petition was disposed of with liberty to file an appeal within two weeks, subject to making the statutory pre-deposit and submitting an application for condonation of delay.

Certification under Rule 89(2)(m) of the Central Goods and Services Tax Rules, 2017 is not required where a claim is limited to interest on principal refund amounts already sanctioned and disbursed. The rule's certificate concerning non-passing of the incidence of tax, interest or other amount does not apply in these circumstances. The Proper Officer must nevertheless scrutinise the refund particulars and determine the interest claim in accordance with law.

Section 107 prescribes a three-month period for filing a statutory appeal and permits a further one-month period on sufficient cause, creating an aggregate 120-day limit. Despite filing four days beyond that period, delay was condoned because the assessment order affected valuable rights of the assessee. The appellate dismissal was set aside and the appeal was restored for adjudication on merits.

An ex parte refund-rejection order issued without considering the reply to the show-cause notice or providing a hearing violates the principles of natural justice. The matter must be restored to the adjudicating authority from the stage of the reply, with fresh notice and a reasonable opportunity of hearing. A reasoned order must then be passed in accordance with law.

Payment of admitted tax liability in instalments falls within the statutory discretion of the Commissioner of State Tax. Where no instalment application has been made to that competent authority, the taxpayer must first seek relief through an application for consideration in accordance with law. The writ petition was disposed of with liberty to apply for instalment payment.

A consolidated demand-cum-show cause notice may cover multiple financial years under the CGST Act, as neither Section 73 nor Section 74 imposes a statutory bar on such consolidation. The applicable provision depends on whether fraud, wilful misstatement, or suppression of facts with intent to evade tax is established. That factual determination is for the Proper Officer, subject to statutory appellate review. Accordingly, an objection to jurisdiction based solely on consolidation of multiple financial years does not invalidate the notice.

GST demand challenges should ordinarily proceed through the statutory appellate mechanism rather than writ jurisdiction where an efficacious remedy before the GST Appellate Tribunal exists. Article 226 jurisdiction is discretionary and is generally unsuitable for disputes requiring detailed examination of evidence. An inspection-authorising officer's later appellate role does not by itself establish bias, because inspection authorisation is distinct from adjudicatory functions. Allegations concerning suppressed sales, estimated turnover, tax rates, and reconciliation of bank deposits, returns, and seized records require evidentiary assessment. Writ intervention is not warranted absent established denial of natural justice, jurisdictional error, bias, or other exceptional grounds.

Interest on a GST refund may be claimed under Section 56 where a refund ordered under Section 54(5) is not issued within sixty days of receiving the refund application. The proviso also applies where a refund follows a final order of an adjudicating authority, appellate authority, appellate tribunal or court and the consequential refund application remains unprocessed beyond sixty days. A taxpayer may apply to the competent authority for such interest, and the application must be decided in accordance with law.

GST registration cancelled for non-existence at the declared principal place of business may be restored where the address discrepancy arose from a genuine mistake involving offices in the same building following redevelopment. As no GST dues were outstanding, restoration subject to payment of applicable charges, late fees and penalty permits lawful business operations while protecting revenue interests.

A petitioner may invoke the statutory rectification mechanism to correct an impugned assessment order before the Proper Officer. The writ petition was disposed of with liberty to pursue that rectification remedy.

A writ petition challenging an appealable GST adjudication order is not maintainable where an efficacious statutory appeal is available under the CGST Act. The asserted denial of relied-upon documents did not justify bypassing that remedy because no supporting particulars or prejudice were shown, while the record indicated electronic supply of the show-cause notice and relied-upon documents and a response to the hearing notice. No exceptional circumstance was established. The merits of the tax demand and the parties' substantive contentions were not examined, and the petitioner was required to pursue the statutory appeal within the permitted period.

Withdrawal of an authorisation letter removes the legal basis for an inspection and for seizure or retention of documents under Section 67. Where the department withdraws the authorisation during proceedings challenging its validity without reserving liberty to retain material obtained, it cannot retain files and documents taken in that inspection and must return them immediately. Principles governing admissibility of evidence obtained through an illegal search do not determine the separate issue of whether the department may retain the seized material.

Section 67 inspection, search and seizure require distinct, specific authorisation, recorded reasons to believe based on relevant material, and compliance with Document Identification Number safeguards, including disclosure of any subsequently generated DIN. Although the described search was procedurally defective, it could not be invalidated in the stated proceedings because release of the seized goods had previously been obtained on payment without setting aside the seizure. Tax recovery during search cannot be compelled before demand proceedings; payment under Section 74(5) requires written self-ascertainment, communication to the proper officer, Form GST DRC-4 acknowledgement, and written information on provisional release. Payment obtained without these safeguards is involuntary and may be refundable, subject to fresh assessment after notice and enquiry.

Representations on the computation of interest on self-assessed tax and the effect of Electronic Cash Ledger amounts must be decided before coercive recovery under garnishee notices. As divergent judicial views existed and the competent respondent had not adjudicated the representations, the substantive merits of the interest computation and garnishee proceedings were left open. The respondent must issue a reasoned decision within six weeks, and no precipitative recovery action may be taken under the impugned notices until that decision is communicated.

Disputed interest on self-assessed tax, including whether amounts available in the Electronic Cash Ledger should be adjusted or deducted, must be determined before garnishee recovery proceeds. Noting conflicting judicial views and that the taxpayer's representations remained undecided, the HC directed the competent respondent to issue a reasoned order in accordance with law and applicable precedents. No coercive action under the garnishee notices may be taken until the decision is communicated; if adverse, it will remain inoperative for a further three weeks. The petition was disposed of without deciding the merits of the interest liability.

GST inspection, search and seizure are distinct powers, and a search authorisation must identify the specific power exercised, be supported by recorded reasons to believe, and comply with Document Identification Number safeguards. Any exception to DIN generation requires a contemporaneous record of the technical difficulty, and a subsequently generated DIN must be communicated to the noticee. Tax recovery during search cannot precede adjudication unless payment is genuinely voluntary, based on the taxpayer's written self-ascertainment and prescribed acknowledgement. Taxpayers must also be informed of the option to obtain provisional release through bond and security. Where these safeguards are absent, payment may support a refund claim, subject to fresh assessment after notice and enquiry.