An ex parte refund-rejection order issued without considering the reply to the show-cause notice or providing a hearing violates the principles of natural justice. The matter must be restored to the adjudicating authority from the stage of the reply, with fresh notice and a reasonable opportunity of hearing. A reasoned order must then be passed in accordance with law.

Payment of admitted tax liability in instalments falls within the statutory discretion of the Commissioner of State Tax. Where no instalment application has been made to that competent authority, the taxpayer must first seek relief through an application for consideration in accordance with law. The writ petition was disposed of with liberty to apply for instalment payment.

A consolidated demand-cum-show cause notice may cover multiple financial years under the CGST Act, as neither Section 73 nor Section 74 imposes a statutory bar on such consolidation. The applicable provision depends on whether fraud, wilful misstatement, or suppression of facts with intent to evade tax is established. That factual determination is for the Proper Officer, subject to statutory appellate review. Accordingly, an objection to jurisdiction based solely on consolidation of multiple financial years does not invalidate the notice.

GST demand challenges should ordinarily proceed through the statutory appellate mechanism rather than writ jurisdiction where an efficacious remedy before the GST Appellate Tribunal exists. Article 226 jurisdiction is discretionary and is generally unsuitable for disputes requiring detailed examination of evidence. An inspection-authorising officer's later appellate role does not by itself establish bias, because inspection authorisation is distinct from adjudicatory functions. Allegations concerning suppressed sales, estimated turnover, tax rates, and reconciliation of bank deposits, returns, and seized records require evidentiary assessment. Writ intervention is not warranted absent established denial of natural justice, jurisdictional error, bias, or other exceptional grounds.

Interest on a GST refund may be claimed under Section 56 where a refund ordered under Section 54(5) is not issued within sixty days of receiving the refund application. The proviso also applies where a refund follows a final order of an adjudicating authority, appellate authority, appellate tribunal or court and the consequential refund application remains unprocessed beyond sixty days. A taxpayer may apply to the competent authority for such interest, and the application must be decided in accordance with law.

GST registration cancelled for non-existence at the declared principal place of business may be restored where the address discrepancy arose from a genuine mistake involving offices in the same building following redevelopment. As no GST dues were outstanding, restoration subject to payment of applicable charges, late fees and penalty permits lawful business operations while protecting revenue interests.

A petitioner may invoke the statutory rectification mechanism to correct an impugned assessment order before the Proper Officer. The writ petition was disposed of with liberty to pursue that rectification remedy.

A writ petition challenging an appealable GST adjudication order is not maintainable where an efficacious statutory appeal is available under the CGST Act. The asserted denial of relied-upon documents did not justify bypassing that remedy because no supporting particulars or prejudice were shown, while the record indicated electronic supply of the show-cause notice and relied-upon documents and a response to the hearing notice. No exceptional circumstance was established. The merits of the tax demand and the parties' substantive contentions were not examined, and the petitioner was required to pursue the statutory appeal within the permitted period.

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.