Cancellation of GST registration was overturned on appeal, restoring the taxpayer's registration. As the taxpayer thereafter filed GST returns regularly and continued as a registered taxpayer, the Revenue's challenge to the restoration became infructuous. No basis existed to interfere with the appellate restoration order, leaving the registration restored.

Section 107(11) of the CGST/KGST Acts confines the first appellate authority, after any necessary further inquiry, to confirming, modifying, or annulling the order under appeal and prohibits referral back to the original adjudicating authority. Where documents require verification, the appellate authority must obtain and assess them itself, determine the disputed issues, and issue a reasoned decision on merits in compliance with Section 107(12) and principles of natural justice. A direction requiring the original authority to verify evidence and then delete or reconfirm demand constitutes an impermissible remand, exceeds appellate jurisdiction, and is unsustainable.

Monetary limits for departmental GST appeals before the GSTAT apply to interest-only disputes by reference to the disputed interest amount. Circular No. 207/1/2024-GST prescribes a threshold of Rs. 20 lakh for such appeals. Where the disputed interest is below that limit and no listed exclusion applies, the departmental appeal is not maintainable. The stated interest demand fell below the prescribed threshold, so the monetary-limit policy required dismissal of the Revenue's challenge to deletion of interest.

Refund of unutilised input tax credit under Section 54(3) requires a specific show cause notice identifying the allegedly ineligible credit, including the relevant invoices, nature and basis, so that the claimant has a meaningful opportunity to respond. Refund rejection cannot rest on grounds introduced at the appellate stage that were absent from the notice. Where rejection rests on alleged wrongful availment or utilisation of credit, eligibility must first be determined through statutory proceedings under Sections 73 or 74; refund processing cannot collaterally reopen credit eligibility. These requirements preserve natural justice and confine refund adjudication to disclosed grounds and the prescribed recovery mechanism.

Maintainability based on the availability of an alternative appellate remedy must be heard first. Interim protection has been reimposed until 15 June 2026 pending completion of pleadings, which must be filed within the stipulated timelines. The application stands disposed of subject to those directions, preserving interim relief while the threshold maintainability issue is addressed.

Refund of integrated tax paid on zero-rated export of services may be claimed by an SEZ unit where the tax was discharged using input tax credit validly distributed on a proportionate basis by an Input Service Distributor. The supplier-only refund mechanism for direct supplies to an SEZ unit does not apply to, or bar, the SEZ unit's own refund claim where no supplier directly made the relevant supply to it. The declaration prescribed for direct supplies to an SEZ unit or developer is likewise inapplicable where credit was distributed through an Input Service Distributor. Refund claims in these circumstances require processing in accordance with law.

Contractual supply arrangements and indemnity clauses do not prevent criminal proceedings where allegations prima facie disclose deception, forgery, conspiracy and fraudulent GST transactions. Allegedly introducing non-existent suppliers, providing documents to establish their genuineness, and using fabricated GST invoices, e-way bills, KYC records and registrations may indicate dishonest intention from the outset and inducement to release payments, rather than mere contractual non-performance. Civil and criminal liability may coexist in such circumstances. Questions relating to proof of criminal breach of trust and alleged connivance require trial-level determination. An FIR disclosing cognizable offences is not liable to quashing under inherent jurisdiction.

Blocked input tax credit under Rule 86A cannot be utilised for the Section 107 appeal pre-deposit while a valid restriction remains in force. Section 49(4) permits use of electronic credit ledger balances only in the prescribed manner and subject to prescribed conditions and restrictions; therefore, the ordinary ability to use available credit for statutory liabilities does not create an absolute right over blocked credit. Rule 86A is provisional, requires recorded reasons, and cannot operate beyond one year. Where grounds for restriction no longer exist, unblocking may be sought under Rule 86A(2); any proposed rejection should follow reasonable opportunity and a speaking order.

Voluntary GST payments under Section 74(5) must arise from self-ascertainment of tax liability and include applicable interest and penalty. Rule 142(2) requires an acknowledgement in Form GST DRC-04 for payment through Form GST DRC-03. Payments made during inspection or investigation without prior demand, assessment, quantification, or material demonstrating self-ascertainment do not satisfy this statutory framework. Recording nil interest and penalty, or failing to issue DRC-04, further indicates that a DRC-03 payment was not voluntary. Recovery during inspection or investigation must follow the prescribed statutory process.

Delay in filing a statutory appeal under the CGST Act beyond the prescribed period and the further condonable period was condoned on account of the appellant's asserted medical condition and advised bed rest. The factual issues raised in the appeal supported granting a further opportunity to pursue the statutory remedy. The dismissed appeal was restored to the Appellate Authority for adjudication on merits after adequate hearing in accordance with law.

Regular bail in alleged GST-evasion offences was considered justified after the investigation concluded and the accused had spent about four months in custody. The offences carried a maximum five-year sentence and were triable by a Magistrate. As the proposed evidence was documentary, witnesses were official, and the risk of tampering or influence was negligible, continued pre-trial detention was unwarranted. Delay in commencement and completion of trial further supported release, subject to appropriate safeguards.

Section 61 return scrutiny and Rule 99 procedures are not mandatory jurisdictional preconditions for proceedings under Section 74A where the proper officer relies on independent material. Allegations of input tax credit claimed through fake invoices, fictitious entities, or supplies not actually received prima facie support initiation of fraud-based proceedings, while the underlying facts require statutory adjudication. Writ intervention against a show-cause notice is generally unavailable where objections involve disputed facts and no lack of jurisdiction, breach of natural justice, fundamental-rights violation, or surviving validity challenge is established. Merits defences remain available before the adjudicating authority.

Section 61 return scrutiny is a pre-adjudicatory verification mechanism and is not a mandatory prerequisite for tax-determination proceedings under Section 74A. Rule 99 applies only where return scrutiny has actually commenced. Independent verification alleging that works-contract sub-contractors were fictitious or non-existent may provide the factual foundation for fraud-based input tax credit proceedings. Disputes over the actual existence of suppliers, provision of services, and genuineness of invoices require evidentiary adjudication rather than threshold writ review. A show-cause notice should not ordinarily be challenged in writ jurisdiction where statutory adjudication remains available and no jurisdictional defect or recognised exception is established.

Regular bail in alleged GST-evasion proceedings involving suppression of online money-gaming receipts was granted after investigation had concluded. The High Court treated the documentary nature of the proposed evidence and the official status of witnesses as indicating negligible risk of evidence tampering or witness influence. It also considered the maximum punishment, Magistrate-triable nature of the offences, prolonged custody, societal roots of the accused, and the likelihood of trial delay. Bail was made subject to bonds and conditions against tampering with evidence, influencing witnesses, leaving the country without permission, or misusing liberty.

Voluntary GST payments during investigation under section 74(5) require genuine voluntariness and payment of the associated interest and penalty. DRC-03 payments lacking interest and penalty, coupled with absence of the rule 142(2) DRC-04 acknowledgment, may not qualify as voluntary payments. Where no prior demand or liability ascertainment exists and payment follows an unexplained direction to appear, recovery proceedings under section 79 do not cure the defect. Refund rejection was set aside, with refund plus interest directed, while issues in pending show-cause and adjudication proceedings remained open.

Blocked electronic credit ledger balances cannot be utilised for an appellate pre-deposit while a valid debit restriction under Rule 86A remains in force. Section 49(4) permits electronic credit ledger utilisation towards output-tax liabilities only subject to prescribed conditions and restrictions; it does not create an absolute right to use blocked credit. Rule 86A operates as a provisional measure requiring written reasons and permits unblocking when the grounds for restriction cease. Pending unblocking requests require expeditious consideration, with a reasoned order and reasonable opportunity where rejection is proposed.

Contractual indemnity does not bar criminal prosecution where allegations disclose cognizable offences rather than a mere civil breach. Claims that an agent introduced non-existent suppliers, produced documents to establish their genuineness, and facilitated fabricated GST invoices and supporting records for wrongful input-tax-credit claims may indicate dishonest intent from the inception of the transactions. Such disputed allegations require determination in criminal proceedings and cannot be conclusively resolved through inherent-jurisdiction proceedings to quash an FIR. The criminal proceedings were permitted to continue without any determination on the merits.

Rule 89 permits an SEZ unit exporting zero-rated services on payment of integrated tax to claim refund where it used input tax credit proportionately distributed through an Input Service Distributor. The supplier-only refund restriction in the proviso to Rule 89(1) applies to direct supplies of goods or services to an SEZ unit, preventing duplicate supplier and recipient claims. It does not apply where corporate-level input services are distributed as credit and no supplier can seek the refund. The declaration under Rule 89(2)(f) likewise applies only to direct, tax-collected supplies to an SEZ unit; its absence does not bar such a refund claim. Refund rejections were set aside for processing.

Vague show-cause notices alleging ineligible input tax credit without identifying invoices, the nature of ineligibility, or the basis for rejection cannot support denial of an inverted-duty refund. Invoice details supplied by the taxpayer do not cure that defect, and an appellate authority cannot introduce a distinct ground not stated in the notice, as doing so breaches natural justice. Eligibility of unutilised input tax credit must be determined through proceedings for wrongful availment or utilisation before the credit can be disallowed. Refund proceedings cannot be used collaterally to decide credit eligibility; absent a prior determination, refund denial on that basis is unsustainable.

Departmental appeals in interest-only GST disputes must be assessed against the disputed interest amount under the applicable monetary-limit circular. Where the interest in dispute is below the prescribed threshold for appeals before GSTAT and no specified exclusion applies, the departmental appeal is not maintainable and must be dismissed. The monetary threshold applies specifically to the interest component in an interest-only dispute rather than to any broader tax amount.