Rule 68B's 2019 extension of the period for sale of attached immovable property applies to recovery claims still within the earlier limitation period but cannot revive claims already time-barred. Recovery-sale proceedings for the earlier assessment years were therefore barred, while those for later years remained timely because the amended period applied before expiry. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial; consequently, the Supreme Court's COVID-19 limitation exclusion applied. For unappealed demands, Rule 68B finality arises only after expiry of the demand-payment and ordinary appeal periods, preserving the later recovery proceedings and preventing release of the attachment.

A writ challenge to a Tribunal recall order does not remain maintainable once the Tribunal passes a final order pursuant to that recall. The recall order merges into, and no longer exists independently from, the final order. Where the final order is separately challenged through the statutory tax appeal remedy, the antecedent recall order cannot be challenged independently by writ petition. The challenge against the assessee therefore failed on maintainability.

Section 11(1)(d) exempts voluntary contributions only where a donor specifically directs in writing that they form part of the corpus. Interest earned on fixed deposits held in a charitable trust's own name arises from its investments and remains revenue income unless a donor expressly directs that such interest be treated as corpus. Donor permission to use refunded funds for self-help group or micro-credit programmes does not amount to a corpus direction for deposit interest. Earmarking funds for programme purposes constitutes application of income after accrual, not diversion at source. Claiming tax-deducted-at-source credit on the interest is inconsistent with excluding it from receipts.

Foreign investment was treated as duly explained where documentary evidence established the investors' registration and tax status, the investment-cum-collaboration agreement, restructuring, inward remittances, audited financial statements, and issuance of shares and compulsorily convertible debentures. The transfer-pricing report contained no adverse finding. Concurrent findings accepting the investors' identity, creditworthiness and the genuineness of the transactions cannot be disturbed without demonstrated perversity. Failure by the assessing authority to objectively address the assessee's supporting material also breached procedural fairness. Consequently, no addition for unexplained foreign investment under Section 68 was sustainable and no substantial question of law arose.

Actuarially backed ad hoc contributions made to remedy an established deficit in an approved superannuation fund are distinguished from ordinary annual contributions and initial contributions. Their legal character depends on their deficit-remedying purpose, including liabilities arising from earlier funding constraints, rather than the period over which the deficit arose. The annual ceiling under Rule 87 does not apply to such actuarially necessary funding, as applying it could impair fund solvency and conflict with the deduction available for contributions to approved funds under section 36(1)(iv). A reasoned application of governing precedents supports deletion of a disallowance and does not render that determination arbitrary or perverse.

Actuarially necessary contributions made to cure deficits in approved superannuation funds are distinguished from ordinary annual or initial contributions and are not subject to the Rule 87 ceiling. Applying that ceiling to deficit funding would impair fund solvency and conflict with the deduction available for approved superannuation-fund contributions. Contributions that bridge an actuarial shortfall in an approved gratuity fund are likewise not subject to the Rule 103 ceiling. Where approval of the gratuity fund remains in force, the Assessing Officer cannot revisit that approval or use Rule 103 to disallow actuarially required funding. Such deductions remain available where payments cure approved employee-benefit fund deficits.

Actuarially determined ad hoc contributions made to eliminate accumulated funding deficits in an approved superannuation fund are not ordinary annual contributions subject to the Rule 87 ceiling. Their character depends on the purpose of curing the gap between fund assets and actuarial liabilities, including deficits carried from earlier years, rather than on whether deficit funding recurs. Such payments are also distinct from initial contributions. Applying the annual ceiling to necessary actuarial-deficit funding would undermine fund solvency and conflict with the deduction framework for approved superannuation funds. A reasoned appellate determination based on applicable precedents is not arbitrary or perverse.

Composition eligibility lapses from the day aggregate turnover exceeds the prescribed threshold, requiring payment of tax under the regular scheme on subsequent supplies. Where turnover calculations have excluded accepted e-way bill errors, the remaining admitted turnover determines the lapse; input-tax credit remains unaddressed without a substantiated claim. Post-lapse invoice values must be treated as tax-inclusive where the composition taxpayer did not collect tax separately. Rule 35 requires extraction of the tax component from the total consideration, even if cum-tax treatment was not expressly claimed earlier. Tax, interest and penalty require redetermination on that cum-tax basis.

Rule 86A of the CGST Rules permits temporary restriction only of input tax credit available in the Electronic Credit Ledger when the prescribed officer records reasons to believe that the credit was fraudulently availed or is ineligible. Credit availability at the time of invocation is a condition precedent. The rule does not authorise departmental debit entries, negative blocking, or restrictions exceeding the ledger balance. Although prior notice is unnecessary for an emergent restriction, recovery of wrongly availed or utilised credit must proceed under the statutory recovery mechanism. Restrictions beyond available credit are invalid.

Delayed GST appeals filed beyond the ordinary and condonable periods under Section 107 may, in peculiar circumstances involving factual questions requiring appellate examination, receive a further opportunity for merits adjudication. The delay was condoned, the dismissal and rectification orders concerning the appeal were quashed, and the appeal was restored for adjudication after adequate hearing.

Reliance on AI-generated legal authorities was questioned where the impugned tax order appeared to rest exclusively on cited decisions that may be nonexistent or inapplicable. Revenue authorities were required to obtain instructions confirming the existence and applicability of those authorities. Further consideration was retained, with potential directions for the issuing officer's presence and further action depending on verification. The matter remains listed for further hearing.

GST demand proceedings initiated against a deceased sole proprietor are invalid where show cause notices and the consequential demand order are issued in the deceased person's name. The proprietorship registration had been cancelled, while the legal heir was unconnected with the business and unaware of portal communications, leaving no effective opportunity to respond. The notices and demand order were quashed, without preventing lawful proceedings against the legal heir for any outstanding GST liability.

A timely rectification application under Section 161, decided by a reasoned order, governs computation of the limitation period for an appeal under Section 107 against a refund rejection. Limitation must run from the date of the rectification order rather than solely from the original adjudication order. Computing limitation only from the original refund-rejection order, without accounting for the rectification decision, improperly treats the appeal as time-barred. This principle applies where the statutory rectification application was filed within the prescribed period and was subsequently decided.

Input tax credit mismatch demands based on differences between FORM GSTR-3B and FORM GSTR-2A require verification under Circular No. 183/15/2022-GST. The proper officer must obtain invoice-related details from the registered person and verify compliance with the conditions for input tax credit under Section 16 before confirming a demand. Where an ex parte assessment is issued without that exercise, the demand requires fresh consideration after permitting supporting evidence and providing a reasonable opportunity of hearing. The ex parte adjudication order was quashed and the demand was remitted for reconsideration under the circular and applicable law.

Rejection of a GST rectification application without effective communication of the rejection order was legally untenable, particularly where technical portal glitches prevented generation of the order and the order-sheet date conflicted with the handwritten date. The lack of communication deprived the assessee of an effective opportunity to challenge or pursue rectification. The application must be reconsidered with the supporting records and explanation, especially as adequate opportunity was not afforded during the original proceedings. The rejection was set aside, and the competent authority must provide a hearing and communicate a reasoned order.

Portal-generated order discrepancies and non-communication rendered the rejection of a rectification application legally untenable. The order-sheet recorded that the rejection order could not be generated because of portal technical glitches, while the purported order carried a later handwritten signature date, creating an unresolved inconsistency. The High Court quashed the rejection and remanded the rectification application to the competent authority for fresh, reasoned disposal after giving the petitioner an adequate hearing and promptly communicating the order.

For input tax credit mismatches between FORM GSTR-3B and FORM GSTR-2A, the prescribed Circular requires the proper officer to obtain invoice details from the registered person and verify satisfaction of credit-availment conditions before confirming a demand. An ex parte demand was set aside because that verification had not occurred. Fresh consideration was directed on the taxpayer's representation, in compliance with the Circular and after a reasonable opportunity of hearing, without determination of the merits of the credit claim.

GST appeal limitation must be computed from a reasoned rectification order under section 161 where the rectification application was filed within the prescribed period and duly decided. The rectification proceedings directly affect the limitation period for challenging rejection of a refund claim; the Appellate Authority cannot calculate limitation solely from the original adjudication order. Rejection of the refund appeals as time-barred on that basis was impermissible. The appellate orders were quashed, and the matters were remanded for fresh adjudication on merits after hearing the petitioners.

GST show cause and demand proceedings initiated against a deceased sole proprietor, after death and cancellation of the proprietorship registration, cannot be sustained. The legal heir was unconnected with the business and unaware of proceedings conducted through the GST portal. The High Court quashed the notices and consequential demand order, while preserving the authority's right to commence proper proceedings in accordance with law against the legal heir for any outstanding demand.

Reliance exclusively on AI-generated case laws in a State Tax Officer's order prompted High Court scrutiny. The AGP was directed to obtain instructions on whether the cited authorities exist and are relevant to the issue. Failing such instructions, the High Court indicated it would require the officer's personal presence. If the cited case laws are non-existent or do not remotely apply, the High Court indicated that appropriate action against the officer may follow. Instructions were required by the next hearing date.