Revisional jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to the interests of the Revenue. This requirement applies where revision of block assessments is proposed on the ground that the Assessing Officer failed to inquire into seized material. Where assessment records contain explanations for seized documents and related group assessments arising from the same search involved adequate inquiry, revision on that ground is unsustainable.

Approval of an insolvency resolution plan freezes creditors' liabilities under the plan and extinguishes claims not included in it. The approved plan has overriding effect over other statutory enactments. An income-tax assessment completed after approval was liable to be quashed despite prior permission to continue assessment proceedings, where the tax department had notice of the insolvency proceedings and was included as an operational creditor.

Amounts recovered from petitioners towards tax collection at source dues on mining royalty are to be returned upon an application by the affected petitioner. Recovery notices were issued to the petitioners for those dues, which were linked to a tax demand against the Mining Department that was quashed by a Division Bench.

The pending stay application is to be decided on 20 November 2026, when the petitioner is represented, in accordance with the applicable instruction and law. Coercive recovery is barred until 21 November 2026. No determination has been made on the merits of either the stay application or the underlying tax demand.

Integrated tax credit on imports is supported by bills of entry and proof of payment and cannot be denied solely for lack of domestic-supplier reporting or entry under a different return category. Import credit is reported separately from domestic-supplier credit, and the supplier-reporting provision invoked was not in force in the relevant financial year. The related tax, interest and penalty demands could not be sustained. For the special first-appeal window, the pre-deposit was 12.5% of disputed tax, with at least 20% payable through the cash ledger. The filing deadline was separate from the payment-mode condition: an appeal filed on time with the full deposit paid through the credit ledger was not time-barred. No further cash deposit was required in the circumstances, including a cash payment at the Tribunal stage.

Section 16(2)(aa) of the Central Goods and Services Tax Act, 2017, effective from 1 January 2022, cannot support an input tax credit demand for financial year 2018-19. Section 75(7) prohibits confirmation of a demand on grounds not specified in the show cause notice. An allegation that suppliers failed to file returns does not give notice of the distinct charge that they failed to pay tax; a demand cannot be confirmed on that new ground. A demand based on these grounds, together with associated interest and penalty, cannot be sustained.

Input tax credit reported under an incorrect tax head may remain admissible if reconciliation of original records and the electronic credit ledger establishes its availability, admissibility and utilisation. The aggregate ledger balance is relevant to interest on wrongly availed and reversed IGST credit. Entitlement under section 16 of the CGST and UPGST Acts depends on cumulative conditions, including actual payment of the tax charged to the Government. Invoice reflection in GSTR-2A alone does not establish entitlement, and credit is inadmissible where the claimant does not establish the supplier's tax payment.

Revenue appeals withdrawn after being filed below the prescribed monetary limit without sufficient reason or exceptional circumstances may justify litigation costs payable by the appellant to the respondent. Such filing can consume tribunal time and cause unnecessary litigation expense. Section 120 of the Central Goods and Services Tax Act, 2017 permits monetary limits for departmental appeals; the applicable circular prescribes a Rs. 20 lakh limit for GSTAT appeals.

The specified works-contract GST concession requires a qualifying government recipient and predominantly non-commercial, non-industrial use. Government supervision or funding alone does not establish recipient status, and social objectives do not alter a factory's industrial use. Interest on unpaid tax is compensatory and does not depend on bona fide conduct; the non-fraud penalty applies unless tax and interest are paid within the prescribed period after notice. Promissory estoppel cannot override statutory liability. Cum-tax recomputation is unavailable where invoices and sales records show receipts as tax-exclusive. Input tax credit claimants must establish eligibility, including payment of tax on the supplies; supplier return-filing records alone do not establish such payment. Interest applies to wrongly availed and utilised credit.

GST paid under the CGST and SGST heads for a transaction subsequently held to be inter-State may be transferred and credited to the IGST head through the refund and adjustment provisions. No interest is payable on the IGST in those circumstances. Proceedings and penalties under Section 74 require fraud, wilful misrepresentation or suppression causing the relevant shortfall, with foundational facts apparent from the notice. Payment under the wrong head alone, without a deliberate attempt to evade tax, does not justify those proceedings or penalties. Any IGST liability beyond the amount already paid remains undetermined.

Eligible transitional input tax credit cannot be denied solely because it was declared under an incorrect provision or column in Form TRAN-1. Section 140 of the Central Goods and Services Tax Act, 2017 and Rule 117 of the Central Goods and Services Tax Rules, 2017 govern the transition of eligible credit. Unutilised credit is a vested right that cannot be defeated on a technical ground when eligibility and quantum are undisputed and the declaration is filed within time.

Under Section 107 of the Central Goods and Services Tax Act, 2017, an appeal against cancellation of GST registration must be filed within three months, with a further month available on sufficient cause. The appellate authority has no power to condone delay beyond that extension. The right of appeal is statutory, and writ jurisdiction cannot be used to bypass the limitation period merely because a taxpayer's own omission has caused the appellate remedy to lapse. Lack of familiarity with the GST portal does not make a writ challenge maintainable in these circumstances.

Under Section 169 of the GST Act, sufficient service and effective service of notices are distinct considerations where portal-based communication does not give the recipient an opportunity to respond. When portal-based service is ineffective and the recipient is denied a hearing, failure to use an alternative statutory mode of service violates natural justice and vitiates the proceedings. This also affects the sustainability of related recovery action.

Rule 96(10) of the Central Goods and Services Tax Rules, 2017 was omitted on 8 October 2024 without a saving clause. Section 6 of the General Clauses Act, 1897 does not apply to the omission of a rule; proceedings under an omitted rule can continue only if preserved by an express provision or other legal device. Show cause notices issued after the omission without such preservation lack statutory backing and are legally ineffective.

Writ jurisdiction may be exercised in appropriate circumstances to reopen a statutory GST appeal dismissed as time-barred, notwithstanding the statutory limit on the appellate authority's power to condone delay. Reopening restores the opportunity for a hearing and decision on the merits where the tax computation was not adjudicated because the appeal was dismissed on limitation.

Objections to GST prosecution based on prior sanction and a monetary threshold may be pursued before the writ court or at an appropriate subsequent stage. The FIR also alleged offences under the Bharatiya Nyaya Sanhita, 2023, and interim protection against it was not warranted. The merits of the GST-related contentions remain open.

The assessment years specified in the English version of the notification for the Andhra Pradesh Electricity Regulatory Commission under section 10(46) of the Income-tax Act, 1961 are corrected from the period 2019-20 through 2023-24 to the period 2020-21 through 2024-25. This removes assessment year 2019-20 and adds assessment year 2024-25. The Hindi version remains unchanged.

Where a Bill of Export is filed under a claim of drawback or a similar scheme under the Customs and Central Excise Duties Drawback Rules, 2017, the SEZ unit, developer or Domestic Tariff Area supplier must claim the benefit from the Specified Officer. If the unit or developer does not intend to claim the benefit, it must give the supplier a disclaimer so that the supplier may claim it. The substituted rule takes effect from its publication in the Official Gazette on 30 October 2026.

Resident individual status and transaction value determine deemed export declaration and service import reporting requirements. A resident individual, defined as a natural person resident in India, is deemed to submit an Export Declaration Form for services upon providing the authorised dealer with the required payment receipt information for crediting the exporter's account. Other service exporters receive the same treatment where the inward remittance does not exceed Rs. 10 lakh or its foreign currency equivalent. For service imports by persons other than resident individuals, authorised dealers must enter details in IDPMS within five working days of receiving them if the invoice or contract value exceeds Rs. 10 lakh or its equivalent. The amendments take effect from 1 October 2026.

Indian Missions abroad must take up quality complaints and trade disputes with the relevant authorities for appropriate redress, whether the complaints are filed by applicants or referred by the concerned Foreign Trade divisions. The Missions and the divisions must periodically update the action taken and status of each complaint on the DGFT portal until resolution or final disposal. Complainants must be able to access all updates through the portal, with timely updates continuing until the matter is resolved, closed or otherwise disposed of under the prescribed procedure.