Withdrawal of an authorisation letter removes the legal basis for an inspection and for seizure or retention of documents under Section 67. Where the department withdraws the authorisation during proceedings challenging its validity without reserving liberty to retain material obtained, it cannot retain files and documents taken in that inspection and must return them immediately. Principles governing admissibility of evidence obtained through an illegal search do not determine the separate issue of whether the department may retain the seized material.

Section 67 inspection, search and seizure require distinct, specific authorisation, recorded reasons to believe based on relevant material, and compliance with Document Identification Number safeguards, including disclosure of any subsequently generated DIN. Although the described search was procedurally defective, it could not be invalidated in the stated proceedings because release of the seized goods had previously been obtained on payment without setting aside the seizure. Tax recovery during search cannot be compelled before demand proceedings; payment under Section 74(5) requires written self-ascertainment, communication to the proper officer, Form GST DRC-4 acknowledgement, and written information on provisional release. Payment obtained without these safeguards is involuntary and may be refundable, subject to fresh assessment after notice and enquiry.

Representations on the computation of interest on self-assessed tax and the effect of Electronic Cash Ledger amounts must be decided before coercive recovery under garnishee notices. As divergent judicial views existed and the competent respondent had not adjudicated the representations, the substantive merits of the interest computation and garnishee proceedings were left open. The respondent must issue a reasoned decision within six weeks, and no precipitative recovery action may be taken under the impugned notices until that decision is communicated.

Disputed interest on self-assessed tax, including whether amounts available in the Electronic Cash Ledger should be adjusted or deducted, must be determined before garnishee recovery proceeds. Noting conflicting judicial views and that the taxpayer's representations remained undecided, the HC directed the competent respondent to issue a reasoned order in accordance with law and applicable precedents. No coercive action under the garnishee notices may be taken until the decision is communicated; if adverse, it will remain inoperative for a further three weeks. The petition was disposed of without deciding the merits of the interest liability.

GST inspection, search and seizure are distinct powers, and a search authorisation must identify the specific power exercised, be supported by recorded reasons to believe, and comply with Document Identification Number safeguards. Any exception to DIN generation requires a contemporaneous record of the technical difficulty, and a subsequently generated DIN must be communicated to the noticee. Tax recovery during search cannot precede adjudication unless payment is genuinely voluntary, based on the taxpayer's written self-ascertainment and prescribed acknowledgement. Taxpayers must also be informed of the option to obtain provisional release through bond and security. Where these safeguards are absent, payment may support a refund claim, subject to fresh assessment after notice and enquiry.

Retention of seized documents under GST requires a valid seizure authorisation and continuing necessity for proceedings under the Act. Sections 67(2) and 67(11) operate together: documents may be retained only when seized by a duly authorised official and required for GST proceedings. Where the underlying authorisation is withdrawn, the basis for seizure and consequential retention ceases, and the authorities cannot retain materials obtained during the inspection. The text states that all files and documents must be returned immediately and that a statement recorded during the inspection carries no legal consequence.

An efficacious statutory appeal generally bars writ jurisdiction against an appealable GST adjudication order unless exceptional circumstances are properly pleaded and supported. A natural justice challenge based on non-supply of relied-upon documents requires particulars identifying the documents withheld and the resulting prejudice; a bare allegation is insufficient, particularly where the order records service of the show cause notice and documents through registered and other email addresses. The article notes that writ petitions should not be used to bypass the appellate process or mandatory pre-deposit. The petition was treated as not maintainable, with liberty to pursue the statutory appeal subject to statutory requirements and with merits left open.

GST registration cancelled for non-existence at the declared principal place of business was considered for restoration where the address discrepancy arose from a genuine mistake. The HC noted that the change of address was not intended to circumvent the law, no GST demand was outstanding, and the taxpayer undertook to pay applicable charges, late fees and penalty. Finding that restoration would permit lawful conduct of business without prejudicing Revenue, the HC directed restoration of the cancelled registration subject to payment of the amounts intimated by the respondents.

GST writ jurisdiction ordinarily does not displace the statutory appellate remedy where a demand dispute requires examination of contested evidence. The text identifies alleged suppressed sales, applicable tax rates, and reconciliation of bank deposits, returns and seized records as factual matters unsuitable for determination under Article 226. It further distinguishes cases involving pure questions of law. Authorisation of an inspection is described as distinct from adjudicatory functions; without material establishing bias, an officer's later appellate role does not itself demonstrate denial of natural justice, lack of authority or jurisdictional error. The stated result is that the writ challenge was dismissed, leaving the taxpayer to pursue the GST appellate remedy.

A consolidated demand-cum-show cause notice covering multiple financial years is not barred under the CGST Act, whether issued under the ordinary demand provision or the provision concerning fraud, wilful misstatement or suppression. The article notes that the selection of the latter provision depends on factual findings about conduct intended to evade tax and ordinarily cannot be decided in writ proceedings at the notice stage; affected persons must respond before the Proper Officer and use statutory appellate remedies. Where a fresh reply opportunity is granted, adjudication is restored to the notice stage, with the court-directed period excluded when calculating the time available for adjudication.

Payment of admitted GST liability in instalments falls within the Commissioner of State Tax's power. Where the taxpayer did not dispute the liability and sought permission to pay it in instalments, the appropriate course was to apply to the competent authority for consideration under applicable law. The High Court permitted the taxpayer to make that application and directed the Commissioner of State Tax to consider it within the stipulated period, disposing of the writ petition.

For claims seeking only interest on GST refunds already sanctioned and disbursed, Rule 89(2)(m) CGST Rules certification was stated to be unnecessary because interest cannot be passed on to an end consumer. The Proper Officer was directed to examine the refund particulars and decide the interest claims under law without insisting on certification that the incidence had not been passed to another person. The petitions were disposed of with directions to complete scrutiny and determine the claimed interest within the stipulated period.

Writ jurisdiction against a GST demand was not considered appropriate where allegations of fraudulent registration, identity theft and forgery created disputed factual questions requiring evidence. As the impugned order addressed the taxpayers' submissions after a hearing, its factual findings were suitable for review by the statutory appellate authority. The High Court therefore declined to examine the merits and directed the taxpayers to pursue the available statutory appeal, with liberty to seek exclusion of the time spent prosecuting the writ petition for limitation purposes.

Rule 86A(2) permits an authorised officer to allow debit from a blocked electronic credit ledger when satisfied that the conditions justifying the input tax credit restriction no longer exist. The High Court directed the taxpayer to provide a copy of its unblocking application after the respondents stated it was unavailable. The application must be considered and decided expeditiously on its merits in accordance with law. Records must be returned unless required, in which case copies must be supplied.

Anti-profiteering provisions did not require a price reduction for homebuyers in the Digangana Housing Complex because the eligible input tax credit-to-purchase-value ratio decreased after GST implementation. The investigation compared eligible pre-GST credit, transitional credit, post-GST input tax credit, purchase value, and reversals attributable to exempt supplies for the project continuing across both tax periods. As no additional input tax credit benefit accrued, no contravention of the requirement to pass on such benefit through commensurate price reduction was established. The Tribunal accepted the final investigation report and disposed of the proceedings without further directions.

Characterisation of flat-sale proceeds depends primarily on the taxpayer's intention, determined from the totality of circumstances, including the stated objects, consistent investment treatment, period of holding, leasing efforts, absence of other projects, and lack of regular trading activity. Although book treatment is not conclusive, it is relevant. Sales over different years after unsuccessful efforts to obtain tenants did not amount to an adventure in the nature of trade. Where the Revenue had accepted capital-gains treatment in earlier years and no distinguishing facts or incriminating material existed, consistency required the same treatment. The proceeds were therefore assessable as capital gains rather than business income, and the Revenue's appeal was dismissed.

Government grants earmarked for specified purposes and subject to utilisation restrictions do not constitute the recipient's income; accordingly, an unspent micro-irrigation scheme grant was not taxable. Interest payable on unutilised grant under applicable Government resolutions was treated as an allowable liability. Under the block-of-assets principle, depreciation remains available where business assets form part of a used block, even if individual assets have been retired from active use; simultaneous use of every asset is unnecessary. The related depreciation disallowance was deleted, and the capital-gains issue was treated as academic.

Revision under section 263 cannot extend to matters already considered in an appeal: where the appeal covered the genuineness of purchases and profit estimation, Explanation 1(c) barred revision on those purchases. Revision also cannot substitute the Commissioner's view for the Assessing Officer's plausible view after inquiry; having examined supporting documents and estimated only the profit element in unverifiable purchases, the assessment could not be revised to tax the entire purchases as unexplained expenditure. Further, a supplier's non-genuineness alone does not establish remission or cessation of a trading liability, so the outstanding credit could not be taxed on that basis. The revisionary order was set aside and the appeal allowed.

Rejection of books of account for failure to maintain quality-wise diamond stock records requires material showing that the accounts are incorrect or incomplete. The note states that absence of particulars such as size, clarity, colour and shape, without specific defects in books, registers, inventory, vouchers or primary documents, does not justify invoking section 145(3). It further notes that consistently followed accounting methods, supported by stock valuation reports and audit records and accepted in other scrutiny assessments, undermine a best-judgment profit estimate lacking a rational basis. On these stated facts, the rejection of books was treated as unsustainable and the consequential estimated-profit addition was deleted.

Foreign tax credit for overseas legal and consultancy receipts is examined under the India-Japan DTAA and Rule 128. The notes state that Article 14 on independent personal services applies to individuals, while the Article 12(4) exclusion for professional services is confined to payments made to individuals; therefore, a partnership firm's Japanese legal-service receipts are not excluded from foreign tax credit on the basis that Article 14 exclusively governs them. Where gross overseas receipts are included in Indian taxable income and supported by Form 67 and authenticated foreign tax-deduction certificates, Rule 128 contains no stated restriction on credit for overseas taxes withheld.