Valid service of service-tax show-cause notices is essential before ex parte adjudication can proceed. Postal delivery was not established, and emails sent to an address sourced from income-tax records were not shown to be accessible to the assessee or registered on the GST portal. As service was unproven, the ex parte adjudication and delayed appeal could not stand. The show-cause notices and consequential appellate orders were quashed, with remand for fresh notices and adjudication after providing an opportunity of hearing.

Article 289(1) exempts a State's property and income from Union taxation, restricting the Income-tax Act's taxing reach. A State-controlled conservation society may qualify for this immunity where it functions as an instrumentality and administrative vehicle of the State: it is controlled by State functionaries, performs public conservation obligations linked to Article 48A, and holds ring-fenced statutory receipts and corpus solely for those purposes. Incidental interest applied exclusively to conservation purposes retains that public character. Statutory conservation receipts and related funds meeting these conditions cannot be subjected to income tax.

Rule 20 requires the Tribunal to fix hearings with sufficient time to serve notice, enabling parties to appear and be heard. Where prior hearings were adjourned because the Tribunal did not function and no notice of the subsequently fixed hearing was issued to the assessee, an ex parte merits decision without verifying service breaches that requirement and causes a failure of justice. The ex parte appellate order was therefore set aside, and the appeal was restored for fresh adjudication after notice to both parties.

Bright Line Test is not a legally sanctioned method for determining transfer-pricing adjustments concerning advertising, marketing and promotion expenditure. Binding decisions support rejection of an adjustment computed through that test. The advertising, marketing and promotion adjustment was therefore rejected in favour of the assessee.

Hotel-booking costs recovered from end customers do not qualify as pure-agent reimbursements under Rule 33 where the supplier lacks customer authorisation to procure third-party booking services, receives invoices in its own name, obtains title to those services, and uses them for its own reservation supply. Rule 33 also requires separate recovery of actual expenditure and prohibits inclusion of unauthorised intermediary charges. Consequently, the full consideration collected for hotel reservation services, including recovered booking-agent costs, forms part of the taxable value and is subject to CGST and SGST.

Plastic twine (sutli) made from polypropylene or polyethylene granules is treated as an article of plastics under Chapter 39, not as textile twine, cordage, rope or cable under Heading 5607. Extrusion, slitting, orientation, twisting and winding do not by themselves make the product a textile material. Heading 3923 does not apply because the twine is neither a container nor an article for conveyance or packing of goods. In the absence of a more specific applicable heading within Chapter 39, plastic twine falls under sub-heading 39269099 as an other article of plastics and attracts GST at 18%.

Availability of an effective statutory appeal before the Appellate Tribunal precluded writ intervention where the extended limitation period for that appeal remained open. The contention that the adjudication exceeded the scope of the show-cause notice was left for determination in the appellate process. The writ petition was not entertained, and the petitioners were left to pursue the statutory appellate remedy.

Writ jurisdiction was not used to examine the jurisdictional challenge or validity of the assessment order because the statutory appellate remedy remained available. The petitioner received liberty to file the statutory appeal within two weeks, subject to the required pre-deposit and an application seeking condonation of delay. No determination was made on the merits of the assessment or the jurisdictional contention.

Building-plan scrutiny fees, ground rent and security deposits require express statutory authority; absent a State Government notification enabling municipal commissioner powers and a reasonable nexus between fee and services, such charges cannot be levied by a development authority. Labour welfare cess remains payable but cannot be recovered upfront before construction; collection must follow the timing and manner prescribed under the applicable cess rules. CGST and SGST do not apply to building-plan sanction because the sanction involves neither a supply of goods nor provision of services. The validity of relevant levies remains subject to a pending writ appeal.

Input tax credits availed under the erstwhile Haryana VAT regime cannot be adjudicated through proceedings under Sections 73 and 74 of the Punjab, Haryana and Central GST enactments. Those GST recovery and adjudication provisions do not extend to credits arising under the repealed VAT framework. Revenue may nevertheless pursue any remedy preserved under the applicable legal framework, subject to law. The stated position treats GST proceedings under those provisions as unavailable for determining liability relating to such legacy VAT credits.

Withdrawal of a show-cause notice was permitted, with liberty to issue a fresh notice within two weeks. The jurisdictional objection, potential invocation of a different statutory sub-clause, and limitation issue were considered only prima facie; no final determination was made on the notice's validity, jurisdiction, or timeliness. The operative effect is that the impugned notice stands withdrawn without a conclusive ruling on those objections, while fresh proceedings may be initiated within the permitted period.

Service of a GST show-cause notice solely through the GST portal after cancellation of registration does not provide an effective opportunity of hearing, because the assessee has no obligation to continue monitoring that portal. Notice must be served through an alternative mode after cancellation to satisfy the principles of natural justice. Assessment proceedings initiated solely on portal-based service are therefore vitiated, and the assessment order was set aside for breach of natural justice.

Cancellation of GST registration requires fresh proceedings where no merits determination has been made. A fresh show-cause notice must be issued, the registered person must receive an effective opportunity to submit a timely reply, and that reply must be considered. A hearing must be provided where required before a reasoned decision is made in accordance with law. The competent authority may therefore initiate fresh proceedings and decide the registration-cancellation matter after following these requirements.

Contractual disputes concerning termination and forfeiture of security deposits, where an arbitration agreement applies, may be pursued through available commercial remedies rather than resolved in writ jurisdiction. Disbursement of an admitted amount may be sought without prejudice to those remedies, while the remaining dispute over termination and forfeiture proceeds through the applicable contractual mechanism.

A delayed statutory appeal against GST registration cancellation may be restored through writ jurisdiction where the appellate authority cannot condone delay beyond the statutory limit, but denial of a merits hearing would cause disproportionate hardship. Cancellation materially impairs the conduct of taxable business; where delay is plausibly explained and revenue suffers no serious prejudice, the statutory appellate forum should determine the cancellation dispute on merits. Questions relating to the show-cause notice, service, cancellation and compliance remain open for appellate adjudication. The appeal is to be restored without rejection on limitation.

Service of a show cause notice solely by upload on the common portal, without acknowledgement of receipt or a response from the assessee, is insufficient to sustain an ex parte adjudication. The matter requires restoration to the show cause notice stage, allowing the assessee an opportunity to submit a reply and be heard before fresh adjudication. The adjudicating authority may also consider the stated proceedings concerning alleged fraud during the renewed process.

Mandatory pre-deposit for a service-tax appeal under Section 35F may be paid by using validly transitioned CENVAT credit in the Electronic Credit Ledger where the provision does not require cash payment. Transition under Section 140(1) preserves vested credit, while Rule 142(3) recognises electronic payment of tax, interest and penalty. As pre-deposit represents an advance deposit of disputed dues, ledger debit and credit to the Government satisfy the requirement and protect revenue. An administrative instruction requiring payment through a designated portal cannot override the statutory scheme, judicial precedent, or the right to use validly transitioned credit.

Refund amounts previously re-credited as input tax credit may be paid in cash where the taxpayer has discontinued business and cannot use its Electronic Credit Ledger. No statutory prohibition prevents cash payment in these circumstances, while re-crediting unusable credit provides no effective benefit. The amount is therefore refundable in cash, together with applicable interest, if any, in accordance with law.

State tax officer jurisdiction for penalty proceedings depends on the applicable State statutory and administrative allocation framework. State circulars identify the Deputy Commissioner as competent where turnover exceeds the prescribed threshold, and a Central allocation circular does not displace that State framework. Participation in proceedings without a jurisdictional objection may also weigh against invoking writ jurisdiction. Where no prima facie jurisdictional defect exists and an effective statutory appeal is available, the doctrine of election supports recourse to the appellate mechanism. Time spent in writ proceedings may be excluded for limitation purposes if the applicable legal requirements are met.

Service of a GST show-cause notice solely through the portal after cancellation of registration is ineffective because portal communication is not the exclusive statutory mode of service and the taxpayer cannot be expected to continue monitoring the portal. Section 75(4) requires a personal hearing where an adverse decision is contemplated or requested in writing; ineffective notice deprives the taxpayer of that opportunity. Tax adjudication founded on such service is liable to be set aside, with fresh notice and adjudication permissible only after effective service and the required hearing.