Assessment proceedings under Sections 73 and 74 must correspond to the relevant tax period and cannot be combined into a single show-cause notice or assessment order for multiple financial years once the annual-return filing due date has been reached. A composite assessment order covering two financial years was therefore impermissible and invalid. The order was set aside in favour of the assessee.

Composite GST assessment orders under Sections 73 and 74 cannot cover more than one tax period where assessment precedes the annual-return due date, or more than one year after that due date. A single assessment covering April 2019 to March 2024 was therefore inconsistent with these period-wise limits. The order was set aside, with fresh proceedings permitted separately for each assessment year.

A best-judgment assessment for non-furnishing of returns is deemed withdrawn when the registered person furnishes a valid return within the statutory period under Section 62(2). The registered person must still pay applicable interest and late fee. Filing the valid return for the relevant tax period with those payments removes the best-judgment assessment while preserving liability for interest and late fee.

Availability of a further statutory appeal required the petitioner to pursue that remedy rather than seek adjudication of the writ claims. The non-availability of the appellate tribunal did not justify bypassing the statutory appellate framework where the appeal remained available. The petitioner was relegated to the appellate remedy, and the intervening period was directed to be excluded for limitation purposes.

Rule 97A of the Central Goods and Services Tax Rules, 2017 permits manual filing in addition to electronic filing; it does not replace an online refund application acknowledged within the prescribed period. A refund claim electronically filed and acknowledged on time must therefore be treated as the relevant application, notwithstanding that its manual copy was submitted later. Rejecting the claim as time-barred solely by reference to the later manual filing was described as illegal and arbitrary, requiring reconsideration based on the timely online application.

Section 62(2) treats an assessment for failure to furnish returns as deemed withdrawn when the registered person subsequently files the prescribed returns within the stipulated framework and pays the applicable late fee. Where returns for the relevant periods, including GSTR-3B, are filed with the prescribed late fee, the amended provision's benefit applies to condone the delay. The assessment orders for non-filing of returns consequently stand deemed withdrawn.

Statutorily recognised IGST refund claims cannot be denied solely because the online customs system generates technical mismatches or does not permit electronic processing. Portal-related limitations do not curtail the entitlement to refund under the applicable GST enactments. Refund claims must therefore be processed manually on the basis of physical documents, with appropriate refund orders passed in accordance with the GST framework.

Best-judgment assessments for failure to furnish GSTR-3B are deemed withdrawn under Section 62(2) when the registered person subsequently furnishes a valid return within the prescribed period and pays applicable interest and late fee. Furnishing the return after the assessment order, together with the additional late fee and interest, satisfies this condition where the amended provision applies. The assessment consequently ceases to operate, while liability for interest and late fee remains.

A consequential-refund direction does not prevent the adjudicating authority from examining independent statutory impediments, including restrictions under a relevant notification or unjust enrichment; the Tribunal's finding that claims were maintainable and within time did not mandate automatic payment. However, rejection based on alleged impermissibility of CENVAT credit where tax was paid on an abated value was procedurally unsustainable because that ground was not disclosed through a show cause notice. The refund claim requires fresh, reasoned adjudication after notice and an opportunity of hearing.

A legal representative may be liable for a deceased sole proprietor's tax, interest and penalty only from the deceased's estate, where the business is discontinued and liability is determined before or after death. That statutory liability does not remove procedural safeguards: an adverse assessment requires independent notice and an opportunity of hearing for the legal representative, and the order must state relevant facts and reasons. Assessment orders issued without these safeguards are vitiated. Tax dues may therefore be pursued against the legal representative only through fresh proceedings that comply with notice, hearing and reasoned-order requirements, within the limits of the estate.

Rectification of bona fide GST return-reporting errors is permissible where invoices were mistakenly reported under a GST TDS GSTIN instead of the regular GSTIN. Sections 37(3) and 39(9) of the CGST Act require a purposive approach allowing correction of Form GSTR-1 and Form GSTR-3B to ensure accurate return data, provided there is no revenue loss. Technical limitations of the GST portal should not prevent rectification. The retrospective relaxation under Section 16(5) covers the relevant period for availing input tax credit. The invoices may be corrected through online or manual means.

Section 75(7) prohibits an adjudication order from confirming tax, interest or penalty exceeding the amount specified in the show-cause notice or on grounds not stated there. Where the notice proposed a composite demand but the final order imposed a substantially higher tax, interest and penalty liability, the demand exceeded the notice on its face. Such a demand contravenes Section 75(7) and is invalid; the demand order was set aside.

GST registration cannot be cancelled through an unreasoned order without demonstrating application of mind or giving the registered person an opportunity of hearing. Such cancellation is arbitrary and inconsistent with Article 14 where the order does not disclose the grounds supporting the action. The cancellation order was therefore unsustainable and was set aside, with fresh adjudication to occur after considering the petitioner's reply and providing a hearing.

Substantial vacancies in the Uttar Pradesh Benches of the Goods and Services Tax Appellate Tribunal were recorded, while the process for filling sanctioned posts remained pending approval by the Department of Revenue, Ministry of Finance. The High Court directed the responsible Department of Revenue officer to file an affidavit on the status of the vacancies and appointments. The matter was listed for further hearing, and the interim order was continued.

GST appeal delay may be condoned where portal upload does not effectively communicate the order in the circumstances and the taxpayer was denied a personal hearing. Although the Appellate Authority remains bound by the prescribed appeal limitation, circumstances beyond the taxpayer's control, material prejudice from denial of hearing, and the risk of grave injury from refusing merits review supported condonation. The appeal was permitted to be entertained and decided on merits if filed within the stipulated period.

Assignment by sale and transfer of long-term leasehold rights in land and building transfers the benefits arising from immovable property from the existing lessee to the assignee, who replaces the original lessee. Such assignment falls outside taxable supply under the GST framework, including Section 7(1)(a), Schedule II and Schedule III, and does not attract GST under Section 9. The stated position follows an earlier binding decision whose challenge before the Supreme Court was dismissed. Consequently, GST proceedings initiated under Section 73 were quashed.

Bail pending trial in allegations of fraudulent input tax credit and allied forgery was supported by the period of alleged claims, delay in lodging the FIR, suo motu cancellation of GST registration with a pending appeal, and the accused's incarceration. The prosecution case on merits remained unexamined. The text states that these factors warranted release on bail pending trial.

Bail in alleged fraudulent input tax credit availment, passing of credit, and wrongful export refunds was supported because the offences carried a maximum five-year sentence, were triable by a Magistrate, and investigation had concluded with the complaint filed. As no charge had been framed and trial completion was unlikely within a reasonable time, continued pre-conviction detention was not justified. Personal liberty, the presumption of innocence, and the right to a speedy trial favoured release, particularly as the applicant had no criminal antecedents and no material showed flight risk, repeat offending, witness intimidation, or tampering with documentary or electronic evidence. Release on bail was warranted subject to appropriate safeguards.

Cancellation of GST registration must satisfy Article 14's requirement of non-arbitrariness because it adversely affects the right to carry on business. An order cancelling registration must disclose reasons and demonstrate application of mind; a registrant must also receive an effective opportunity to reply to the show-cause notice and be heard. The text states that cancellation and the consequential appellate order, having lacked these requirements, were unsustainable and set aside. Fresh adjudication is to occur after the registrant's reply is received and its defence is considered at a hearing.

Where an assessment order was already under challenge in pending proceedings, the Supreme Court declined to interfere with the High Court order and dismissed the special leave petition. The petitioner was permitted to continue pursuing the pending proceedings, and pending applications were closed. The operative point is that the existing challenge to the assessment order remained available for adjudication in those proceedings.