Electrically operated three-wheeled e-rickshaws, e-carts and hydraulic e-carts are classifiable under tariff heading 8703, while e-scooters fall under heading 8711. Where the vehicle's motor, inverter, control module, drivetrain and body are fitted, supplying it without a battery does not change its essential character as a vehicle propelled solely by electrical energy. The specified two- and three-wheeled vehicles therefore qualify for 5% GST. Refund entitlement for accumulated input tax credit arising from an inverted duty structure falls outside the categories permitted for advance rulings and is not admitted.

Transfer of an entire proprietorship business to an LLP without consideration constitutes a supply under GST where the arrangement transfers assets, liabilities, employees, rights and customer relationships for uninterrupted continuation of the business. A transfer of the business as a whole, when made as a going concern, is classified as a supply of services rather than goods. Nil-rate exemption for transfer of a going concern depends on establishing that the business satisfies applicable going-concern standards. If that status is not established, stock and business assets transferred on cessation are deemed supplies of goods and attract GST at the rates applicable to those goods.

Advance-ruling questions must relate to a supply of goods or services undertaken or proposed to be undertaken by the applicant under the CGST Act. Questions concerning an alleged supply by a faculty member to an institute, including the individual's GST registration and invoicing obligations, do not concern a supply made or proposed by the applicant. Such questions therefore fall outside the statutory scope of an advance-ruling application by the institute and are not maintainable.

GST paid on balance works is separately reimbursable where the accepted Bill of Quantities expressly requires rates "without taxes," notwithstanding a PWD Manual clause contemplating tax-inclusive quoted rates. The tender terms governing the accepted bid prevent the quoted amount from being treated as inclusive of GST. As the Bill of Quantities referred to the sales-tax regime, while the liability arose under GST, and the original tender pre-dated GST for continuation of abandoned works, GST inclusion was not within the parties' contemplation. Reimbursement requires proof of GST payment through relevant GST returns.

Cancelled GST registration may be restored under the applicable revival framework only upon filing all pending pre- and post-cancellation returns and paying tax, interest, penalty, fine and fees in cash. Input tax credit cannot be used for these payments and may be utilised only after departmental scrutiny and approval. Restoration remains subject to compliance with these conditions and consideration of the taxpayer's representation.

Government works contractors that paid the incremental GST liability arising when GST replaced VAT during an ongoing works contract may seek reimbursement from the State as recipient of the service. The reimbursement right covers only the differential tax attributable solely to the GST transition, rather than other contract liabilities. Where the contractor has discharged that incremental liability, mandamus may compel reimbursement, subject to verification of underlying records and calculations. The reimbursable amount is therefore confined to the verified differential GST liability.

GST refund claims are subject to a mandatory two-year limitation period, but writ jurisdiction may permit condonation where sufficient cause justifies departure from that period. A duplicate reversal of transitional credit, discovered only during a later review of records, may constitute sufficient cause for restoring a delayed refund application. Following restoration, the statutory authority must examine supporting documents and determine the claimant's substantive refund entitlement afresh.

The enhanced turnover threshold for composition levy under the CGST Act applied from 1 April 2019 through the implementing notification. It did not extend to the 2018-19 tax period because the earlier notification did not make the increased threshold available for that period. Taxpayers for 2018-19 therefore remained subject to the pre-enhancement composition-levy threshold.

Verification of the asserted completion of the Rule 88C process was necessary before adjudicating liability under Section 73. The response containing relevant details required examination to determine whether Rule 88C had concluded in the petitioner's favour and, if so, whether that conclusion affected the sustainability of the Section 73 proceedings. The adjudication order was quashed and remanded for reconsideration.

Parallel GST proceedings under Sections 73 and 74 for the same tax period cannot continue while an earlier proceeding remains unresolved, as this would create simultaneous adjudication. Later notices, adjudication orders and consequential recovery action were quashed. The earlier proceeding must be determined after allowing the taxpayer to submit documents supporting the exemption claim and granting a personal hearing. Its consideration cannot be denied on limitation where intervening parallel proceedings had been initiated.

Regular bail was granted in proceedings alleging wrongful availment and utilisation of input tax credit. Relevant considerations included the filing of the complaint, absence of criminal antecedents, continued custody, and the likelihood that trial would take time. The bail determination rested on custody status and personal circumstances in the pending GST-related offence.

Interim protection permits the petitioner to continue normal business activities and restrains coercive recovery or pressure to discharge an allegedly defaulting supplier's input tax credit liability until the next listing. The issue concerns whether search proceedings may continue after expiry of the stated authorisation validity where the search began within that period. The authorities' position supporting continuation was recorded, while allegations that the petitioner was pressured to pay the supplier's purported tax liability were to be addressed after obtaining instructions.

Operative appellate orders setting aside tax demands remain binding unless modified, stayed, or set aside through the prescribed process. Refund authorities cannot revisit the underlying input tax credit dispute when processing a consequential refund. Refund withholding requires the specified statutory conditions, including pending proceedings, the Commissioner's requisite opinion, and a hearing; a proposed challenge alone is insufficient. Writ jurisdiction may remain available despite an alternative appeal where action disregards a binding appellate order, is arbitrary, or breaches mandatory safeguards.

Article 226 writ jurisdiction ordinarily should not displace the statutory GST appellate remedy where alleged non-service of a show-cause notice or denial of personal hearing requires verification of service records, receipt, and related facts. Such fact-dependent and curable procedural objections should be examined in the statutory appeal rather than through writ proceedings. Lack of remand power does not curtail the Appellate Authority's jurisdiction to conduct a fresh, independent appraisal of the record and determine objections on merits. Notice-service and hearing objections therefore remain for adjudication in the statutory appellate process.

Personal hearing requirements under the Uttar Pradesh GST law require a fresh opportunity where no hearing occurs on the originally fixed date. Where no subsequent hearing date is intimated and an adjudication order is issued later without an adjournment sought by the assessee, the statutory requirement under section 75(4) and principles of natural justice are breached. Section 75(5) governs adjournments but does not dispense with a renewed hearing opportunity. Denial of a reasonable opportunity of personal hearing renders the adjudication invalid.

Binding GST appellate orders remain operative unless modified, stayed or set aside through statutory remedies; departmental review, an intended challenge, or a later appeal does not suspend them. Refund authorities must process a consequential refund arising from annulment of the underlying demand and cannot revisit adjudicated input tax credit entitlement during refund processing. Withholding pending proceedings requires compliance with statutory safeguards, including the prescribed opinion based on malfeasance or fraud and an opportunity of hearing; a proposed challenge to the appellate order is insufficient. Writ jurisdiction may be invoked despite an alternative appeal where refund rejection disregards a binding order and the appellate remedy is ineffective. The refund rejection was quashed and remanded for fresh consideration.

Parallel GST proceedings for the same tax period cannot continue while earlier proceedings on alleged nil or exempt turnover remain pending. The later show-cause notices, adjudication orders and consequential recovery action were quashed as duplicative proceedings. The exemption claim remains for examination in the earlier proceedings upon production of documents and after a personal hearing. Those earlier proceedings must be reconsidered afresh without limitation impeding consideration because the now-quashed parallel proceedings had been initiated.

Section 73 adjudication requires consideration of the taxpayer's claim that its Rule 88C(2) explanation was accepted and that the mismatch proceedings concluded in its favour. Where that claim remains unexamined, the taxpayer must receive an opportunity to provide the relevant details and response. The adjudication was quashed and restored for fresh consideration of whether the Rule 88C proceedings had concluded in the taxpayer's favour and whether that conclusion affected the sustainability of the Section 73 proceedings.

GST refund applications remain subject to a mandatory two-year limitation period, but writ jurisdiction may be available to condone delay. An asserted double reversal of TRAN-I credit, discovered only on examining records, can constitute just cause for such condonation. The time-bar rejection was set aside, and the refund claim was restored for fresh examination by the statutory authority upon production of supporting documents.

Government recipients of works-contract services must bear and reimburse the differential GST liability caused by the VAT-to-GST transition during contract execution. Reimbursement is limited to the incremental tax attributable to GST, rather than the full tax burden, and depends on verification of the contractor's records and calculations. A writ of mandamus required consideration of the contractor's representation, determination of the verified differential amount, and reimbursement within the stipulated period.