GST-related tax-default allegations already subject to proceedings under the special GST enactments must be investigated and addressed through the procedure prescribed by those enactments. The Bharatiya Nagarik Suraksha Sanhita requires offences governed by a special law to be dealt with under that law, giving the GST statutory framework priority over general criminal-law recourse. On that basis, Bharatiya Nyaya Sanhita proceedings for the same alleged GST default were impermissible against the applicant, and the charge sheet and cognizance order were set aside to that extent.

Section 74 CGST adjudication requires an effective opportunity to respond where GST registration has been cancelled and a revised correspondence address has been communicated. Adjudication founded solely on the absence of a reply cannot be sustained without procedural fairness and a meaningful right to be heard. Voluntary reversal of allegedly excess input tax credit before initiation of proceedings also requires an opportunity to contest the continuation and characterisation of proceedings. The merits of the show-cause proceedings, including whether Section 74 or Section 73 applies, remain unresolved.

Differential GST liability arising from the transition from VAT to GST under works contracts depends on the terms and conditions of each individual contract. Where contracts involve different parties and contractual arrangements, reimbursement obligations cannot be determined through uniform directions. Statutory tax authorities also cannot be directed to refrain from exercising powers contrary to the GST framework. Blanket directions requiring reimbursement of differential tax liability and restraining tax enforcement are therefore impermissible without a contract-specific determination.

Rule 26(3) requires GST adjudication orders issued electronically to bear a digital signature certificate, e-signature, or another notified verification mode, establishing authorship and accountability. Absence of a physical or electronic signature on the detailed adjudication order is a substantive failure, not a curable mistake, defect or omission. A signed DRC-07 cannot validate or cure the unsigned detailed order; the unsigned order is invalid.

Partial rejection of refund claims for unutilised input tax credit under Section 54(3), without affording an opportunity of hearing or recording reasons for the rejected portion, breaches the principles of natural justice and the obligation to issue a reasoned decision. Such procedural deficiencies render the partial rejection invalid, as affected claimants must be heard and given reasons enabling them to understand and challenge the basis of the decision.

GST registration cannot be retrospectively cancelled through a repeated show-cause notice founded on identical registration-fraud allegations after earlier proceedings on those allegations were dropped. Cancellation also cannot rest on allegations of fraudulent availment or passing of ineligible input tax credit unless those grounds are stated in the notice and the registrant has an opportunity to respond. Reliance on unstated grounds demonstrates non-application of mind and breaches procedural fairness. The repeated notice and cancellation were set aside, while fresh proceedings remain permissible on a proper notice with an opportunity of hearing; the underlying allegations' merits remain open.

Regular bail in prosecutions alleging fraudulent availment and transfer of input tax credit through bogus firms may be supported where the accused has remained in custody, the charge-sheet has been filed, and the evidence is documentary. Parity with bail granted in similar matters, including to a comparable co-accused, supports release on bail on those recorded circumstances.

GST provisions distinguish Section 74(1), which does not prescribe a minimum penalty, from Section 73(9), which does. A minor breach alone does not justify interference with the statutory minimum penalty; its validity must be directly challenged on constitutional grounds. Separately, an assessment issued without affording the taxpayer an opportunity of hearing breaches natural justice. The taxpayer must receive a reasonable opportunity to contest the tax proposals on merits, subject to remittance of the tax demand within the stipulated period, and the assessment requires fresh determination thereafter.

GST reimbursement under Notification No. 5050-F(Y) is governed by a temporal distinction between pre-GST and post-GST contracts. Paragraph 3(iv) applies only to contracts predating 1 July 2017, while paragraph 4 governs contracts executed after that date and qualifying ongoing projects. A post-GST reimbursement claim cannot be rejected by applying paragraph 3(iv); it must be considered under paragraph 4. Factual entitlement to reimbursement and the amount payable in an individual claim remain unaddressed.

GST adjudication challenges should ordinarily proceed through the statutory appeal where no patent jurisdictional defect is shown; evidentiary disputes concerning fraudulent input tax credit and supplier-related allegations require appellate factual assessment, and pre-deposit alone does not justify writ intervention. The bar on parallel proceedings applies only where Central and State GST actions concern the same liability or contravention and seek identical demand or relief; overlapping periods or input tax credit claims are insufficient. A consolidated notice covering multiple financial years under the fraud provision is not inherently without jurisdiction, while limitation, statutory conditions, and period-wise quantification remain open in appeal.

Section 107 of the Central Goods and Services Tax Act, 2017 provides a statutory appellate remedy against an Order-in-Original. A jurisdictional objection under Section 6(2)(b), including whether State GST and DGGI proceedings overlap, requires examination of disputed facts concerning the transactions, their factual foundation and the nature of the proceedings. Such objections, together with challenges to the demand and evidentiary findings, fall for consideration by the appellate authority. The statutory appeal must therefore be pursued, with the jurisdictional objection and all merits issues remaining open before that authority.

Section 6(2)(b) of the CGST Act bars parallel central and state GST proceedings only where they concern the identical liability or contravention. Commonality of the assessee, financial year, supplier, or similar tax exposure is insufficient. Alleged fraudulent input tax credit based on invoices unsupported by actual supply may constitute a distinct contravention where it was not previously adjudicated; different GSTINs under a common trade name are relevant but not conclusive. Objections involving evidence, receipt of goods, fraud, suppression, and tax, interest or penalty should be pursued through the statutory appellate remedy rather than writ jurisdiction, absent exceptional circumstances.

Section 6(2)(b) of the CGST Act bars parallel Central and State GST proceedings only where they seek to adjudicate the identical liability or contravention; shared assessee, tax period, input tax credit, or transactional background does not suffice. Allegations of fraudulent credit based on invoices without actual goods supply remain distinct unless that precise infraction was already adjudicated in State proceedings, so the Central proceedings were not barred. Writ review remains available despite a statutory appeal, but disputes over replies, relied-upon material, genuineness, goods receipt, fraud, suppression, and duplicate liability ordinarily require examination of the adjudication record in appeal absent exceptional circumstances. The writ petition was dismissed, with merits left open in appeal.

Availability of a statutory appeal against an Order-in-Original required the writ challenge to be pursued before the appellate authority. The objection that parallel Central and State GST proceedings concerned the same subject matter required factual examination of their scope, allegations, transactions, liabilities and evidentiary foundations. That inquiry, together with challenges to the demand and evidentiary findings, was left for appellate consideration. The writ petition was dismissed, while all contentions on jurisdiction, parallel proceedings and the demand remained open in appeal.

Availability of an efficacious statutory appeal materially constrains Article 226 writ jurisdiction in GST adjudication. Once show-cause proceedings culminate in an Order-in-Original, disputes over overlapping State and Central input tax credit proceedings, factual and evidentiary material, and a multi-year notice should ordinarily be examined on appeal. A statutory pre-deposit obligation and the earlier filing of a writ during pending notice proceedings do not alone justify bypassing that remedy. Absent patent jurisdictional infirmity, appellate review remains available on all permissible grounds; the writ petition was dismissed with liberty to appeal.

GST reimbursement under the contractual tax-transition notification must be assessed under paragraph 4 for post-GST contracts and ongoing projects with estimates approved before 1 July 2017, applying GST rates. Paragraph 3(iv), confined to pre-GST contracts, cannot govern or defeat claims concerning contracts executed after that date. The reimbursement claim requires reconsideration under paragraph 4 following a personal hearing and a reasoned decision; coercive action remains restrained pending that determination.

GST registration cancellation based on alleged fraudulent availment and passing of ineligible input tax credit cannot rest on grounds omitted from the show-cause notice. Repeated cancellation proceedings founded on allegations previously dropped by the same officer indicate non-application of mind. The cancellation notice and order were quashed without determination on the merits. Fresh proceedings may be initiated only through a new show-cause notice, with an opportunity of hearing and compliance with law.

GST-related tax fraud allegations based on non-response and non-payment of Central or State GST must be addressed under the CGST Act where proceedings under that special enactment have already commenced. Sections 4 and 5 of the BNSS preserve the investigative and procedural framework prescribed by special statutes, preventing recourse to general criminal law for offences governed by such statutes. On this basis, BNS prosecution for the alleged GST defaults, including the charge-sheet and cognizance order against the taxpayer, was set aside.

GST assessment and rectification orders are subject to the statutory appellate mechanism, requiring exhaustion of that alternative remedy before a writ challenge is directly entertained. Where a GST demand and rejection of a rectification application were challenged without first filing an appeal, the writ petition was dismissed on that ground. Liberty was granted to file the statutory appeal within 30 days; if filed within that period, it must be entertained without a limitation objection and decided on merits. All substantive contentions remain open in the appellate proceedings.

Leasing by a Town Panchayat of weekly-market entrance-fee collection rights to tender contractors is undertaken in its capacity as a public authority where it directly relates to the statutory function of markets and fairs. The phrase "in relation to" covers integral, incidental and ancillary arrangements needed to discharge that function. Contractors' collection under Panchayat-prescribed fees, receipts and conditions does not change the activity's statutory character or make it independently commercial. The leasing is neither a supply of goods nor a supply of services and therefore falls outside GST under the applicable notification.