An assessment order for non-filing of returns, together with its summary, is deemed withdrawn when the taxpayer subsequently furnishes the relevant returns and pays the applicable tax, interest and late fee. Where the revenue authorities confirm filing of the returns and that no dues remain payable, recovery based on the earlier assessment is impermissible. Any consequential garnishee attachment founded on that recovery demand must therefore be set aside.

An unsigned GST summary assessment order in FORM GST DRC-07 is invalid because Rule 26(3) of the CGST Rules requires notices and orders to bear the assessing officer's signature. Sections 160 and 169 of the CGST Act do not cure the absence of a signature, and an unsigned proceeding is not duly served. As no effective service occurs, delay in challenging the unsigned order does not bar relief. The assessment summary cannot operate unless a fresh assessment follows notice and issuance of a duly signed order, with the intervening period excluded for limitation purposes.

A writ petition concerning an alternate statutory remedy under the CGST/KGST Act was disposed of at the petitioner's request, with liberty to file an appeal. The specified period was directed to be excluded in computing limitation under section 14 of the Limitation Act, provided the appeal is filed within six weeks. The direction preserves the petitioner's ability to pursue the statutory appellate remedy without the specified period counting towards limitation.

Revocation of cancelled GST registration was addressed where returns had not been filed and taxes remained unpaid. The text states that the petitioner was directed to apply for revocation, deposit the taxes due, and file the required returns. The registering authority was to consider the revocation request consequentially after those compliance steps.

Composite GST assessments under Sections 73 and 74 cannot validly cover more than one tax period where assessment occurs before the annual-return due date, or more than one financial year after that due date. A single show-cause notice or assessment order spanning two separate financial years is impermissibly composite and invalid. The assessment covering two financial years was therefore set aside in favour of the assessee.

Rectification of mistake cannot be used to reopen, review, recall or substantially modify a concluded order in appeal. The validity of the rectification proceedings was treated as governed by a binding coordinate-bench decision. Applying that principle, the rectification order and the concluded appellate order were quashed in favour of the assessee, confirming that rectification is not a mechanism for altering a final appellate determination beyond correction of a mistake.

Section 73(2), read with the outer limitation in Section 73(10), requires issuance of a show-cause notice sufficiently before the limitation deadline; it does not impose a fixed three-month interval between notice and adjudication. Reasonable time and opportunity to respond remain necessary under natural justice. Assessment orders for the same period cannot rest on inconsistent premises that supplies were respectively exempt and taxable. Such contradiction requires fresh consideration of the supplies' tax status through consistent adjudication after reasonable opportunity, subject to the stipulated tax-remittance condition.

VAT input tax credit was unavailable to a service provider with no taxable turnover or output tax liability under the VAT regime; credit entered in its VAT return could therefore not be carried forward as GST transitional credit through Form TRAN-1. The VAT credit disallowance remains operative. However, a VAT assessing officer cannot use VAT assessment proceedings to raise tax, interest or penalty on a transitional-credit claim made under GST. Any action concerning the Form TRAN-1 claim must be pursued by the competent GST authority under applicable GST Rules.

Excess input tax credit demands should rest on the factual basis stated in the show cause notice. The text explains that comparing GSTR-2A with GSTR-3B, after the notice relied on GSTR-3B and GSTR-9, denies the taxpayer an opportunity to respond and requires reconsideration consistent with natural justice. It further states that Section 77 of the CGST Act applies to tax paid under an erroneous inter-State characterisation of a supply, not to a mere mistaken remittance under the IGST head; such payment may instead be appropriated against CGST and SGST liability, subject to procedural requirements.

Provisional attachment of a bank account under the Central Goods and Services Tax Act, 2017 ceases to have effect after one year under section 83(2). As the attachment was continued beyond that statutory validity period, it could not lawfully remain in force. The continued attachment was invalid, the attachment proceedings were set aside, and the bank account was directed to be made operational.

Uploading a show-cause notice and adjudication order solely on the GST Common Portal does not constitute valid service where the statutory framework does not expressly authorise the Portal to replace formal communication. The retrospective amendment on functions performed through the Common Portal and the CGST Rules limit its use to specified functions, without treating mere uploading as valid service of notices or orders. Portal-based communication that causes serious civil consequences without effective notice is impermissible. The assessee must receive an opportunity of hearing before adjudication.

A timely manual reply to a show-cause notice must be considered in adjudication even where electronic filing was required. Treating the reply as unfiled solely because it was not uploaded electronically, and deciding the matter due to the assessee's non-attendance at hearing, breaches principles of natural justice. Once the reply is on record, the adjudicating authority remains obligated to examine it; non-appearance does not remove that duty. An adjudication founded on non-consideration of the timely reply is invalid and requires fresh determination after considering the reply, with a personal hearing if requested.

Garnishee recovery action should not proceed without considering the taxpayer's reply, providing a personal hearing, and adjudicating disputed tax and input-tax-credit figures. Material discrepancies in outward supplies, tax liability, inward supplies, input tax credit, net tax payable and tax paid require reasoned determination before coercive recovery, given the serious civil consequences of a garnishee notice. The notice was required to remain in abeyance pending a fresh hearing and reasoned adjudication.

Ex parte tax assessments based on estimation cannot be sustained where the registered person was not given an adequate opportunity of hearing. Fresh assessment proceedings must be undertaken after providing that opportunity, with the consequential demand set aside. The applicable coordinate-bench approach requires the assessing authority to reassess the matter in accordance with procedural fairness.

Assessment orders may be quashed and remitted for fresh adjudication despite expiry of the statutory appellate limitation where the taxpayer claims GST exemption for paddy and rice supplies and undertakes the stipulated pre-deposit. Fresh adjudication was directed subject to deposit of 10% of the disputed tax in cash, filing a reply with supporting documents within 30 days, and issuance of notice before any fresh order. The assessment order was set aside conditionally, with the matter restored for de novo adjudication.

GST adjudication requires an effective opportunity of personal hearing before an adverse decision, including notice of the hearing date, time and venue. Selection of "No" in a hearing column does not remove the statutory requirement where the proposed determination is adverse. Adjudication orders must also record relevant facts and the basis for the decision; a brief unreasoned order that does not address material submitted in reply is non-speaking. Omission of these safeguards renders the determination vulnerable for breach of natural justice.

GST registration cancelled solely for continuous non-filing of returns may be restored conditionally where no allegation of a dubious tax-evasion process exists. Continued cancellation prevents the registered person from conducting business and issuing invoices, which may impair determination and recovery of tax liability. Restoration is contingent on filing all returns for the default period and paying the resulting tax, interest, fine and penalty within the stipulated period.

GST adjudication orders may be addressed through the statutory rectification mechanism where the taxpayer asserts that tax was discharged on the entire invoice amount. The taxpayer was required to submit a rectification application supported by relevant documents before pursuing the challenge. The proper officer was to entertain the application, provide one hearing opportunity, and decide it within the stipulated period. The writ petition was disposed of by directing recourse to rectification of the GST adjudication order.

Regular bail was granted in a prosecution alleging fraudulent availment and passing of input tax credit. Investigation had concluded and the final complaint was filed. As the prosecution relied on documentary and electronic material already held by the Department, further custodial detention was not considered necessary. Continued custody was also unwarranted because the applicant had been detained since January 2026 and trial was likely to take considerable time.

GST registration cancelled solely for continuous non-filing of returns may be restored where there is no allegation of a dubious tax-evasion process. The text states that continued cancellation prevents the taxpayer from conducting business and issuing invoices, which may also impair recovery of tax dues. It supports allowing the taxpayer to regularise the default by filing all pending returns and paying applicable tax, interest, fine and penalty within the stipulated period. On compliance with these conditions, the cancelled registration is to be restored.