Section 107 of the CGST Act confines condonation of delay in filing an appeal to the express statutory outer limit; equitable considerations and High Court jurisdiction under Article 226 cannot enlarge the First Appellate Authority's powers. Where registrations have been restored and taxpayers have resumed business, completed implementation may make departmental appellate relief ineffective because annulment could disrupt intervening transactions and input-tax-credit consequences. The appellate remedy against cancellation remains independent of revocation under Rule 23, although it must be pursued within the prescribed limitation period.

The right of appeal vests when the lis commences, so a later amendment imposing a new pre-deposit condition does not apply to pending proceedings unless retrospective operation is expressly stated or necessarily implied. For penalty-only GST appeals arising from show-cause notices issued before the proviso to Section 112(8) took effect, the earlier law did not require a penalty pre-deposit. The pre-deposit framework for first appeals under Section 107(6) supports the same treatment. Consequently, no 10% penalty pre-deposit is payable for appeals arising from pre-amendment proceedings.

Input tax credit eligibility under the CGST Act cannot be assessed solely from a GSTR-3B/GSTR-2A mismatch; the claimant retains the burden of proof, and eligibility requires category-wise and invoice-wise verification of underlying records. Supplier certificates for the disputed year must be considered despite later issuance, alongside reconciliation of reporting errors, reverse-charge credit, unclaimed credit and reversals. For renting of immovable property, the property's location determines place of supply; where the supplier and property are in the same State, CGST and SGST apply despite erroneous IGST reporting. Effective opportunity of hearing remains necessary under principles of natural justice.

E-way-bill validity may be extended in exceptional circumstances, including through a further eight-hour period after expiry. For goods in transit, a penalty for an expired e-way bill should account for otherwise valid accompanying documents, a short technical delay in obtaining extension, and absence of intent to evade tax. A rigid 200% penalty is disproportionate where interception follows shortly after the extension window; in such circumstances, a token fine and refund of the excess penalty are appropriate.

GST proceedings must identify the applicable tax period in each show cause notice and assessment order. Where annual returns have been filed, the relevant financial year is the tax period; before annual filing, proceedings may be based on monthly returns. A single notice or assessment order cannot combine multiple financial years. Proceedings that club separate financial years are jurisdictionally invalid. The consolidated assessment and consequential rectification-rejection orders were quashed, while permitting fresh separate proceedings for each financial year.

Biometric Aadhaar authentication for GST registration is required under interim directions as a nationwide safeguard against fraudulent registrations obtained through misuse of PAN and Aadhaar particulars. Restricting biometric verification to applications identified as risky through data analytics was considered insufficient in light of detected fraudulent registrations and tax evasion. The directions seek to protect revenue and prevent harassment of persons whose identity particulars are misused. Authorities may place practical implementation difficulties on record, and further consideration remains pending.

E-way bill rules permit validity extensions in exceptional circumstances and provide a further eight-hour window after expiry to seek extension. Transport after that period may justify detention and penalty, but a brief delay in renewing the e-way bill does not necessarily warrant a 200% penalty. Where interception occurred shortly after the additional extension window, comparable decisions supported relief while recognising that the lapse could still attract a nominal sanction. The 200% penalty orders were set aside, subject to payment of a token fine and refund of the balance penalty deposit.

Input tax credit claimed in GSTR-3B but not reflected in GSTR-2A requires category-wise and invoice-wise reconciliation; invoices alone or supplier default do not establish entitlement, while the entire mismatch cannot be disallowed without verification. Supplier certificates may be considered under the applicable circular but must be verified, and reverse-charge credit and tax-head or B2B-to-B2C reporting errors require independent examination. Effective opportunity of hearing is required before adjudication. Renting of immovable property is supplied where the property is located; where the supplier and property are in the same State, CGST and SGST credit remains available despite erroneous IGST reporting if tax is paid and no revenue loss arises.

The vested right of appeal arises when the lis is instituted, and a later amendment imposing a fresh pre-deposit obligation does not apply to pending proceedings without clear legislative intent. Where a penalty-only appeal arose from a show-cause notice issued before the amended proviso took effect, the post-amendment pre-deposit requirement could not be imposed. The Registry's objection was set aside, the appeal was admitted without pre-deposit, and jurisdictional and merits issues remained open for final hearing.

Section 107(4) of the GST law fixes an outer limit on an appellate authority's power to condone delay in appeals against cancellation of registration. Extraordinary writ jurisdiction cannot enlarge that statutory appellate jurisdiction; condonation beyond the prescribed maximum is legally unsustainable. Where the Department has implemented appellate directions by restoring cancelled GST registrations, it cannot seek annulment without addressing the resulting alteration of the taxpayers' legal and commercial position. The departmental appeals consequently become infructuous where no effective or workable relief remains available.

Food supplied by an independent outsourced caterer to a hospital is a separate taxable supply, not a composite healthcare supply, because the caterer contracts only to supply food and cannot rely on the healthcare-provider clarification. Reliance on that clarification, although legally incorrect, does not by itself establish fraud, wilful misstatement, or suppression with intent to evade tax; the demand must therefore proceed under the ordinary tax-demand route. Where invoices did not separately identify or collect tax, the invoiced consideration is tax-inclusive and differential tax must be recomputed using cum-tax valuation after invoice verification.

Credit notes for returned or rejected processed-fabric supplies are excluded from outward taxable supply turnover when calculating an inverted-duty refund of accumulated input tax credit. The identical input-output supplies clarification is confined to accumulation caused by a rate reduction on the same goods over time; it does not apply where higher-taxed chemicals and dyes are used to process fabrics taxed at a lower rate without an output-rate reduction. Once refund eligibility and computational parameters are determined, consequential re-quantification is ministerial, does not reopen the merits, and does not constitute an appellate remand.

Refund of accumulated input tax credit under an inverted duty structure remains available where processed fabrics retain the same GST rate and credit accumulates from higher-taxed chemicals, dyes and consumables used in job-work processing. Circular No. 135/05/2020-GST concerns credit accumulation caused by a GST-rate reduction on the same goods and does not bar such refund claims. Once substantive refund eligibility is determined, an appellate direction for arithmetical recomputation merely implements that determination and is not a prohibited remand, provided the original authority cannot reconsider the merits. Refund orders allowing consequential recalculation were sustained.

Revocation of GST registration following cancellation for non-furnishing of returns requires filing outstanding returns and paying tax, interest, late fee and penalty. Verification limited to return filing and tax payment does not satisfy the proviso to Rule 23(1), which makes payment of these ancillary statutory liabilities a condition for revocation. The revocation order was modified to require recovery of unpaid interest and late fee and imposition of penalty under Rule 23.

GST detention penalties under section 129 require a pleaded and established contravention of the Act or Rules. A show-cause notice must identify the defective documents and the precise legal provision allegedly breached; a vague allegation of diversion or unloading at an undeclared destination is insufficient. Reliance on inculpatory statements requires their disclosure, and an offered personal hearing and cross-examination opportunity must be genuinely afforded before adjudication. Appellate review must address material natural-justice objections and identify the statutory contravention rather than rely on route or invoicing observations alone.

GST local-authority status is confined to bodies expressly enumerated in the CGST/KGST definition; a statutory body is not included merely because its constituting State law deems it a local authority. Accordingly, works contract services supplied to Kerala Water Authority attract GST at 18% from 1 January 2022 rather than the concessional local-authority rate. On delayed differential GST, interest applies only to the portion discharged through the electronic cash ledger, not to the portion paid through the electronic credit ledger.

Excess IGST paid twice on export supplies is refundable where export turnover and IGST liability were correctly reported in GSTR-1 but mistakenly classified under supplies other than zero-rated supplies in GSTR-3B. The mismatch prevented automated customs refund, leading to a second IGST payment through a corrected return; refund of that second payment did not extinguish the claim for the original excess payment. A clerical reporting error, supported by return reconciliation, does not constitute a substantive breach justifying denial. Retaining tax paid twice would lack authority of law, and refund cannot be denied on procedural grounds or the stated limitation objection.

Consignment value for goods returned by a job worker comprises the job-work charges and applicable tax, not the value of the principal's goods. Under section 15 read with Explanation 2 to Rule 138, the return movement represents the job-work service; where its taxable value is below the prescribed threshold, an e-way bill is not mandatory. Detention and penalty action cannot rest on allegations contradicted by departmental records, including the presence of a tax-paid job-work invoice, delivery challan and e-way bill. A detention or appellate order must remain within the show-cause notice's factual allegations and give reasons for treating an e-way bill as invalid; reliance on unalleged grounds breaches natural justice.

Section 129(3) requires a detention-penalty order to be passed within seven days of service of notice. The seven-day period is mandatory, not directory; an order made after that period, including one issued 28 days after notice, breaches the statutory requirement. Such delay vitiates the detention-penalty proceedings, renders the original order void ab initio and a nullity, and leaves no valid basis for an appellate order affirming the penalty.

Unutilised input tax credit accumulated from an inverted duty structure is refundable where manufacturing inputs are taxed at a higher rate than the outward supply and are distinct from the finished goods. For Agarbati manufacturing, perfumes, fragrances, chemicals, packaging materials and cardboard qualify as inputs whose higher tax rates may support refund eligibility. A CBIC clarification addressing situations where input and output supplies are the same goods does not restrict such claims. CBIC circulars bind central tax officers but not the Appellate Tribunal, although they may carry persuasive value.