Transport of goods in a vehicle different from that declared in the e-way bill requires updated Part-B and a valid documentary trail for the vehicle actually carrying the goods. Where no reliable contemporaneous evidence establishes breakdown of the originally declared vehicle or transfer of goods, an unexplained vehicle and weight discrepancy remains non-compliant. A later e-way bill generated by the purchaser, unavailable when the goods were intercepted, does not cure defective accompanying documentation. Detention proceedings and penalty under the Uttar Pradesh Goods and Services Tax Act, 2017 are therefore justified where the actual vehicle lacks a valid e-way bill.

Re-credit of tax or input tax credit debited from the electronic credit ledger is available only within the prescribed refund framework. Section 54, Rule 86(4A), Rule 92(1A) and the applicable circular require a refund claim and a reasoned finding that the debited amount is admissible before re-credit can be granted. Tax liability cannot be reduced through an unexplained computation; the revised amount must be correlated with self-assessed and auto-generated returns, audit reports and other record material. Both re-credit entitlement and revised liability require fresh, reasoned determination after hearing the parties.

Ex parte GST adjudication involving a mismatch between Form GSTR-3B and Form GSTR-2A should permit the taxpayer to submit invoices, e-way bills and other material supporting the genuineness of transactions. A fresh opportunity to respond to the show-cause notice enables complete and reasoned adjudication, subject to deposit of part of the disputed tax demand. The taxpayer may establish transaction genuineness before a reasoned determination is made.

Effective notice and a fair opportunity of hearing are essential to GST adjudication. Service of show-cause and hearing communications solely on the registered e-mail address of an erstwhile auditor, where the assessee no longer had contact with that auditor, may not provide an effective opportunity to respond or submit supporting transaction records. Where non-response is plausibly bona fide, an ex parte adjudication cannot be sustained without affording the assessee an opportunity to file a response and participate in fresh consideration by the adjudicating authority.

Transitional-credit-based refund claims require a merits determination by the Central Tax Authorities where prior communications do not decide the claimed entitlement. Portal availability and jurisdictional observations do not constitute an appealable refund decision. The claimed transitional credit, import-related circumstances and reversal of input tax credit require verification under applicable law. Interest arising from reversal of input tax credit cannot be sustained before the refund entitlement based on transitional credit is determined. The refund claim remains open for fresh consideration, and consequential interest action cannot continue unless that entitlement is resolved.

Cancellation of GST registration for fraud, wilful misstatement or suppression of facts requires the proper officer to form the requisite opinion under Section 29(2)(e) after providing due opportunity. Where proposed cancellation rests on a list identifying enterprises as fake, physical verification of the business premises under Rule 25 is necessary to determine whether genuine business is carried on, particularly when the registered person provides material concerning State-authority proceedings. A show-cause notice and cancellation founded solely on such a list, without physical verification, cannot be sustained. Fresh cancellation action may proceed after verification in accordance with Rule 25.

GST registration cancelled solely for continuous non-filing of returns should be restored where no tax-evasion process is alleged. Continued cancellation prevents the taxpayer from conducting business and issuing invoices, which may hinder rather than facilitate tax recovery; final liability can be determined only after returns are filed. Registration was restored subject to filing all pending returns and paying applicable tax, interest, fine and penalty within the stipulated period.

Service-tax liability on turnover from trading in farm products requires examination of whether that turnover is taxable. Non-filing of a response or absence from hearings does not remove the need to consider the material issue of taxability. Liability cannot be sustained without giving the taxpayer an effective opportunity to submit a response and supporting documents, followed by fresh consideration of the turnover's service-tax treatment.

Omission of Rule 96(10) of the Central Goods and Services Tax Rules, 2017, without a saving or sunset clause ends its restriction on export refund claims, including pending proceedings. A refund claim must therefore be considered without that restriction where the show-cause notice was issued after the omission became effective. The omission operates to remove the basis for applying Rule 96(10) in the pending refund proceedings.

Section 75(4) requires a personal hearing before an adverse GST decision; a prior hearing on an unrelated input-tax-credit mismatch does not satisfy that requirement. Section 74A(8)(ii) allows payment of tax and interest within sixty days of the show-cause notice, without penalty and with proceedings concluded. Determination before that period expires curtails the statutory payment right.

Disclosure of relied-upon analytics reports is required where they form the basis of a customs classification dispute. Setting out the report's parameters, entries and core findings in a show-cause notice does not give the affected party an adequate opportunity to answer the case. Non-supply of the report and supporting documents breaches principles of natural justice and vitiates the adjudication order. Fresh adjudication must follow disclosure of all relied-upon material.

Manual filing of an appeal in FORM GST APL-01 with supporting documents is permitted where the rectification order being challenged is unavailable on the common portal under the amended appellate procedure. This enables the appeal to proceed despite the order's absence from the portal. The petitioner was allowed four weeks to file the appeal, with no limitation objection, for consideration on merits.

Section 75(4) mandates an opportunity of hearing where a show-cause notice contemplates an adverse decision. A taxpayer must be allowed to respond to the notice before the proper officer determines the matter through a reasoned order after hearing the taxpayer. An assessment made without that hearing does not comply with the mandatory statutory requirement and is unsustainable, requiring fresh adjudication in accordance with law.

GST treatment of actionable claims arising from betting and gambling extends to online gaming and fantasy sports played with stakes. Such actionable claims are treated as goods within the GST framework, and their supply is subject to prescribed valuation rules for betting, gambling and casino transactions. The 2023 amendments, including Rules 31B and 31C, are characterised as clarificatory and retrospective, requiring pending show-cause notices and proceedings to be determined on that basis. Casino-related valuation is to be recomputed under the specialised valuation rule applicable to casino transactions.

Proof of due service and receipt of summons is necessary before alleged non-compliance can support cognizance under the Bharatiya Nyaya Sanhita, 2023. For summons issued under the CGST Act, tracking records alone do not establish service or acknowledgment. Mere issuance therefore cannot demonstrate deliberate disobedience, evasion, or a prima facie case of wilful non-compliance. In the absence of evidence that the summons was duly served, refusal to take cognizance was sustained.

Anticipatory bail was unavailable where allegations prima facie indicated involvement in a conspiracy using forged invoices of non-existent firms, collecting tax without depositing it, and causing wrongful loss. Given the nascent investigation, custodial interrogation was considered necessary to establish the method of the alleged offences and the petitioner's connection with the fictitious firm. Pre-arrest bail remains an exceptional remedy requiring cautious exercise and exceptional circumstances, which were not established. The petitioner was therefore not entitled to anticipatory bail.

Section 75(4) of the CGST Act mandates a personal hearing whenever an adverse GST adjudication is contemplated. Show-cause notices that omit a hearing opportunity cannot support a valid adverse determination. Uploading notices and adjudication orders only under the portal's 'Additional Notice and Orders' tab may impede timely response and reinforce the procedural breach. An adjudication made without the mandatory hearing is invalid and requires fresh determination after considering the taxpayer's reply.

Restoration of Form GSTR-1 filing access on the GST common portal pending departmental proceedings depends on examination of the registered person's response and supporting material. No determination was made on the registration allegations or entitlement to portal access. The High Court required the registered person to submit a detailed representation to the issuing authority, which must decide it by a reasoned order after a personal hearing. Portal access must be activated only if the authority finds the person to be a bona fide registered proprietor.

Completion of the e-KYC process enabled the refund claim to be entertained and allowed. Administrative instructions were requested for similarly situated claimants, indicating that completed e-KYC should facilitate processing of comparable refund claims.

GST show-cause notices issued after cancellation of registration require physical service where the binding departmental circular so prescribes. Uploading notice solely on the common portal may not provide effective notice because a cancelled registrant may no longer operate or access the portal. Service only through the portal, more than four years after cancellation, was therefore insufficient and rendered the ex parte GST adjudication invalid.