Electronic filing of audit reports in Form 3CLA on the income-tax portal by the due date for filing the return of income satisfies Rule 6(7A)(c). Where the prescribed authority is registered as an external agency on that portal and can access the uploaded reports, separate physical submission is not required by the stated rule. Reports uploaded before the applicable return-filing due dates, together with additional material supplied within the subsequently granted time, meet the prescribed timing requirement. Consequently, treating the applications as delayed on these facts is unsustainable.

Supreme Court condoned delay and dismissed the Special Leave Petition without interfering with the High Court order concerning a general insurance business. The matters identified included tax treatment of profit on sale of investments, disallowance for non-deduction of tax, depreciation on UPS as part of a computer system, application of minimum alternate tax to insurance companies, and consistency in departmental assessments. No Supreme Court ruling on the merits of those issues was stated.

Prior approval under Section 153D must not be mechanical and requires demonstrable application of mind. CBDT circulars and the Manual of Office Procedure are described as binding on the department, and the assessment order should record the grant of approval. Administrative orders that entail civil consequences must comply with the rules of natural justice. The text also refers to dismissal of a Special Leave Petition concerning the same respondent and confirmation of the High Court order, but the stated legal focus remains the validity and disclosure of prior approval in assessment proceedings.

Statutory printing of a manufacturer's corporate name, address and required particulars on unit containers for traceability, safety and regulatory compliance does not by itself constitute affixing a brand name for exemption purposes, where brand logos are absent and no commercial connection is intended to enhance product value. A corporate name or logo on tax invoices does not make otherwise unbranded goods branded. Packages supplied exclusively to institutional consumers, rather than for retail sale, fall outside the applicable concept of pre-packaged and labelled commodities. Accordingly, supplies meeting these conditions remain eligible for the relevant exemption, and related tax, interest and penalty demands are unsustainable.

Rule 24 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025 requires defective appeals to undergo scrutiny and permits escalation to the Registrar and the appropriate Bench where notified defects remain unrectified. After hearing the party, the Bench may direct registration or reject the appeal. Rule 10 preserves the Tribunal's inherent powers to make orders necessary to secure justice or prevent abuse of process, reflecting the principles that litigants must diligently pursue their rights and that litigation should reach finality. Failure to remove notified defects within sufficient time may result in dismissal for non-prosecution without examination of merits.

Section 171(1) requires suppliers receiving additional GST input tax credit to pass that benefit to eligible homebuyers through a commensurate reduction in prices. Free structural upgrades, fittings, additional works and other non-price benefits cannot substitute for a price reduction, regardless of their claimed value. Where the input tax credit benefit remains unpassed, the quantified profiteered amount includes GST collected on the additional realisation and remains payable to recipients. Rule 133(3)(b) requires interest at 18% per annum from collection of the higher amount until payment or recovery. Penalty may not be warranted where the relevant conduct substantially concluded before the penalty provision took effect.

GST registration cancellation requires the proper officer to record reasons to believe that cancellation is warranted before issuing a notice in Form GST REG-17 under Rule 22(1). Inspection material depicting an unrelated property or containing blank reports cannot adequately support cancellation proceedings. Cancellation orders and consequential registration suspension were quashed, and the proceedings were restored to the show-cause-notice stage. The registered persons may produce supporting business documents, after which the proper officer must reconsider the matter afresh.

Reimbursement of incremental GST under a contractual tax-variation clause cannot be made conditional on certification from GST authorities where the GST regime provides no such certification mechanism. Returns, challans and other relevant records evidencing actual incremental tax payment may support the claim. However, a quantified reimbursement cannot be granted without verifying that the amount represents tax paid beyond that embedded in the contract price. The contractor must substantiate the claim before the Commissioner, who must examine the supporting documents without requiring GST-authority certification; arbitration and other remedies remain available.

An assessing officer's signature is mandatory for a valid assessment order; curative provisions concerning procedural defects or service do not remedy its absence. An unsigned assessment order is therefore invalid and liable to be set aside. Under Rule 26(3), communication of an unsigned order does not constitute valid service, so delay in challenging it is immaterial. Any replacement assessment must be made through a fresh signed order preceded by notice, with the intervening period excluded in computing limitation.

Input tax credit remains available for relevant tax periods where returns were filed by 30 November 2021, subject to other applicable requirements. Section 16(5) operates through a non obstante clause overriding the time restriction in Section 16(4). Accordingly, returns filed within the Section 16(5) cut-off are not barred by the Section 16(4) limitation, and the taxpayer may claim input tax credit if the remaining statutory conditions are satisfied.

Escaped assessment based on an audit objection must follow the procedure and safeguards, including the limitation period, prescribed for reassessment under Section 25(1). The five-year period runs from the last date of the year to which the assessment relates; an audit objection received or acted upon after that period cannot support lawful reassessment. Accordingly, a notice concerning 2009-10 returns issued in December 2020 was time-barred and was quashed.

Sections 73 and 74 of the GST Act require separate show-cause notices and assessment proceedings for each financial year once the annual-return due date has been reached. A single composite assessment order covering multiple tax periods is therefore invalid. The stated legal position permits fresh, year-specific proceedings for each relevant assessment year rather than consolidated action across financial years.

Revival of a cancelled GST registration requires filing all pending pre-cancellation returns and paying outstanding tax, interest, penalty, fine and late fee in cash. Input tax credit may be used only after scrutiny and approval by the competent authority. Returns and GST liabilities for the post-cancellation period must also be discharged in cash. Upon compliance with these conditions, cancellation may be set aside and the GST registration revived.

Input tax credit for returns filed from November 2018 to March 2019 cannot be denied solely for delayed filing where the returns were filed before the extended cut-off under Section 16(5). The stated analysis treats Section 16(5) as governing eligibility for the credit, subject to fulfilment of other applicable conditions. Accordingly, denial based on Section 16(4) is described as unsustainable, and the taxpayer's credit claim requires reconsideration and grant if otherwise eligible.

Section 62(2) provides that an assessment order for failure to furnish returns is deemed withdrawn when the registered person subsequently files the required returns within the applicable framework and pays the prescribed late fee for delayed filing. Where Form GSTR-3B for the relevant period is filed with the requisite late fee, the provision applies, including under the amended framework. The assessment order for non-filing of returns consequently stands deemed withdrawn.

Section 75(4) of the Central Goods and Services Tax Act, 2017 requires an opportunity of hearing before an adverse tax determination, regardless of whether the taxpayer specifically requests one. Failure to consider a reply to the show-cause notice and absence of proof that a hearing was granted breach mandatory natural justice requirements. An appellate remedy does not prevent writ relief where the foundational assessment is legally invalid for that breach. Consequently, an assessment order issued without considering the reply or providing a hearing, and the consequential appellate rejection, cannot be sustained.

Section 16(5) preserves input tax credit eligibility where returns for the relevant period were furnished by 30 November 2021. Returns filed for April 2018 to March 2019 within that cut-off must be assessed under Section 16(5), and input tax credit cannot be denied solely by applying Section 16(4) without giving effect to the extended time limit. Eligibility remains subject to satisfaction of other statutory conditions for claiming input tax credit.

Refund of unutilized input tax credit on zero-rated export services cannot be denied by classifying a supplier as an intermediary for an isolated period where identical services were treated as exports and refunds were granted in preceding and succeeding periods. In the absence of material showing that services during the disputed period differed or warranted intermediary classification, the inconsistent treatment is arbitrary and discriminatory. The supplier is entitled to the refund with applicable interest.

A rejected GST refund claim should be reconsidered only after completion of the ongoing investigation into the genuineness of suppliers, movement of goods, and underlying transactions. Verification of these matters may determine whether the transactions are legitimate and whether the related input tax credit is available. The refund claim is therefore to be decided afresh after the investigation is completed, with the merits of the claim and all contentions remaining open.

Input tax credit for March 2019 requires reconsideration where the relevant return was furnished before the cut-off recognised under Section 16(5). Section 16(5) permits credit where the return is furnished by 30 November 2021; a return filed on 13 December 2019 falls within that period. Consequently, denial solely for breach of the time limit under Section 16(4) cannot stand, subject to fulfilment of other input tax credit eligibility conditions.