Penalty under Section 129 is confined to undocumented excess goods when the remaining goods are covered by a valid tax invoice and e-way bill and there is no cogent evidence that the documents are false or the transaction fictitious. The discovery of excess goods does not by itself make the entire consignment undocumented. Section 129 permits detention and penalty for goods transported in contravention of statutory requirements, but the penalty must correspond to the nature and extent of the established contravention. Separate proof of dishonest intention is not indispensable, but deliberate tax evasion concerning documented goods cannot be presumed without an adequate factual foundation.

GST refund limitation excludes 1 March 2020 to 28 February 2022 under Notification 13/2022-Central Tax. Where the relevant tax payment date fell within that period, the full two-year limit ran from 1 March 2022 to 29 February 2024, making an application filed on the last day timely. An application rectified in good faith after a deficiency memo relates back to a timely original filing but cannot cure a late original claim. GST paid on a taxable advance remains subject to the refund framework even if the corresponding supply does not materialise; it cannot be reclassified as a deposit to avoid limitation. The statutory time limit is a substantive eligibility condition that procedural circulars cannot relax. Non-consideration of a show-cause reply vitiates rejection, but appellate authorities must decide disputed points with reasons. A challenge to limitation calculations on admitted facts introduces no new charge if limitation was raised in the notice.

When a deceased sole proprietor's business has discontinued, Section 93(1)(b) limits the legal representative's GST liability to the inherited estate and the extent to which it can meet the charge. Recovery requires notice to the legal representative and identification of the estate; proceedings without those steps lack jurisdiction. Input tax credit remains available despite a GSTR-2A mismatch caused by suppliers reporting business-to-business invoices as business-to-consumer transactions, where purchases are genuine, supplier tax payment is established by unrebutted certificates and the credit is otherwise valid.

Input tax credit discrepancies between FORM GSTR-3B and FORM GSTR-2A arising from incorrect supplier reporting must be evaluated under the applicable circular using relevant documentary evidence. Its instructions apply to pending adjudication or appellate proceedings concerning FY 2017-18 and FY 2018-19. The FY 2017-18 proceedings remained pending when the circular was issued, after the original adjudication and first appellate orders; the evidence had not been assessed under its prescribed framework.

Input tax credit mismatches for FY 2017-18 and FY 2018-19 are covered by the instructions in Circular No. 183/15/2022-GST where adjudication or appellate proceedings remain pending. For the FY 2017-18 mismatch between FORM GSTR-3B and FORM GSTR-2A, additional supplier-return records require fresh consideration under the Circular, observing the principles of natural justice. Both sides agreed to fresh consideration and verification of the additional records.

Intra-State movement of rubber latex from an agriculturist's premises to the registered business premises of a taxable person is exempt from the e-way bill requirement regardless of value, provided the goods are accompanied by a delivery challan prescribed under Rule 55 of the Kerala State Goods and Services Tax Rules, 2017. An incorrect GSTIN belonging to an unrelated person in an otherwise proper challan was treated as a condonable clerical error where no material connected its holder to the transaction; the exemption remained available.

Differential cess and consequential interest and penalty are unsustainable when based solely on an apparent clerical error in GSTR-1 without evidence of actual short payment. The taxable value and CGST and SGST liabilities in GSTR-1 matched GSTR-3B, while cess was declared and paid through input tax credit in GSTR-3B. The GSTR-1 cess figure did not correspond with the taxable value or CGST and SGST amounts, and there was no evidence of suppressed outward supplies, suppressed taxable value or short payment of CGST or SGST.

Transitional input tax credit is available for eligible capital goods whose commercial use begins after the transition to GST, where substantive eligibility is established through invoices and purchase disclosures. Under the earlier VAT regime, the period for applying in Form 25 ran from commercial use rather than purchase. Failure to obtain Form 25B before the transition is a procedural impediment that does not extinguish otherwise eligible credit, which may be claimed through TRAN-1. Claimed carry-forward credit is not admissible where the final VAT return records no closing credit and no basis establishes the claimed balance.

Section 129(1) penalty proceedings require the show-cause notice to identify the provisions of the Act or Rules allegedly contravened, giving the recipient an opportunity to answer the precise allegations. A statutory breach omitted from the notice cannot later sustain the demand. Section 143(1) permits a principal to send inputs or capital goods to a job worker without payment of tax. Delayed generation of a job-work e-way bill after interception does not change an established job-work movement into a taxable supply. Where no tax is payable on the goods, the tax-linked penalty under section 129(1) is not leviable.

Section 75(4) of the Central Goods and Services Tax Act requires a personal hearing when an adverse decision is contemplated; notices and written replies do not replace that right. An appellate review that merely adopts departmental figures without independently examining relevant records does not cure the breach. A return mismatch alone cannot sustain a demand based on alleged excess input tax credit. Section 155 places the burden of proving credit on the claimant, and the relevant books, invoices, returns and reverse-charge records require verification. Section 44 and Rule 80 do not provide for online alteration of a filed annual return; a bona fide error requires factual verification. Section 113(1) permits fresh adjudication after consideration of additional evidence.

Delayed filing of the annual return in Form GSTR-9 attracts a late fee under Section 47. A separate general penalty under Section 125 is not warranted for the same delay because that provision applies only where no other penalty is provided for the contravention. The specific late-fee mechanism covers the filing default, so the late fee remains payable but the separate general penalty is invalid.

The petitioner was granted liberty to pursue the statutory appellate remedy against an assessment order despite delay in challenging it. The appellate authority was directed not to raise limitation in relation to the appeal.

Under Section 169(1) of the Central Goods and Services Tax Act, 2017, uploading notices on the GST portal is a valid mode of service alongside other prescribed modes. Where repeated non-response follows portal uploads, officers must make a genuine effort to use other prescribed modes, preferably registered post. Sole reliance on portal uploads in those circumstances denies a meaningful opportunity to reply and be heard. An ex parte GST assessment made without effective service and a meaningful hearing violates natural justice.

GST portal upload is a valid mode of service, but repeated non-response to assessment notices requires the officer to explore other prescribed modes under Section 169(1) of the Central Goods and Services Tax Act, 2017, preferably registered post with acknowledgment due. Portal upload alone in these circumstances does not afford a meaningful opportunity to reply or be heard and breaches natural justice. Safeguards for fresh adjudication include an opportunity to submit objections and clear notice of a personal hearing. A bank-account attachment cannot survive the setting aside of the underlying assessment.

Section 169(1) of the Central Goods and Services Tax Act, 2017 recognises uploading notices to the GST portal as a valid mode of service alongside other prescribed modes. When repeated portal notices receive no response, the issuing officer must make a genuine effort to serve the taxpayer through another prescribed mode, preferably registered post. Exclusive reliance on portal uploads in those circumstances does not constitute effective service, and an ex parte GST order based on that service violates the principles of natural justice.

Section 107(4) of the Central Goods and Services Tax Act, 2017 permits extension of the three-month appeal period by one month where sufficient cause for delay is shown. An appeal filed 29 days after the ordinary period remained within the condonable period, and the director's maternity leave was accepted as a genuine reason for delay. The rejection for delay was set aside, and the delay was condoned.

GST registration cancelled for non-filing of returns is to be restored subject to portal access, filing all pending returns and paying tax dues, interest and late-filing fees. Financial difficulties were accepted as a genuine explanation for the default, despite the failure to respond to the show-cause notice. The required payments cannot be adjusted against unutilised or unclaimed input tax credit, which may be used only after departmental scrutiny and approval.

Delay-condonation grounds in statutory GST appeals require fair and meaningful consideration. Section 107 of the Uttar Pradesh Goods and Services Tax Act, 2017 provides the appellate framework. Rejection cannot rest on a bare assertion that the grounds are insufficient; the reasons must demonstrate deliberation and support the conclusion. Rejection without consideration of the grounds and adequate reasons is unsustainable. Fresh consideration requires a speaking order in accordance with law.

Alleged non-deposit of input tax credit must be addressed through the statutory recovery mechanism under sections 73 and 74 of the Central Goods and Services Tax Act, 2017, rather than by cancelling GST registration where returns have been filed regularly. Cancellation in these circumstances does not follow the prescribed legal procedure, and revocation must be allowed in accordance with law. Authorities remain free to initiate proceedings for other violations by issuing a show-cause notice in accordance with the prescribed procedure.

Effective service of GST notices requires more than portal upload where a taxpayer repeatedly does not respond. Although uploading notices on the common portal is a valid mode of service, officers must consider other available statutory modes to ensure effective service and a meaningful opportunity of hearing. Mere portal upload without such effort is an empty formality that violates principles of natural justice in an ex parte assessment. The ex parte assessment and consequential summary order were quashed and remanded for fresh adjudication, with an opportunity to file objections and receive a personal hearing subject to a stipulated condition. The related bank-account attachment could not continue, and the accounts were to be de-frozen upon compliance.