GST Show Cause Notice Upheld: Procedural Technicality Cannot Override Substantive Legal Communication Under Section 73

GST Show Cause Notice Upheld: Procedural Technicality Cannot Override Substantive Legal Communication Under Section 73Case-LawsGSTHC rejected the petition challenging a GST show cause notice, holding that an inadvertent misdescription in document title do

GST Show Cause Notice Upheld: Procedural Technicality Cannot Override Substantive Legal Communication Under Section 73
Case-Laws
GST
HC rejected the petition challenging a GST show cause notice, holding that an inadvertent misdescription in document title does not invalidate its substantive content. The court found the document clearly identifiable as a valid Section 73 notice through portal description, watermarks, and accompanying context. The ex-parte order was deemed sustainable, em

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Tax Credit Dispute: Appellate Path Opened with Nuanced Pre-Deposit Guidelines for Challenging Ineligible Input Tax Claims

Tax Credit Dispute: Appellate Path Opened with Nuanced Pre-Deposit Guidelines for Challenging Ineligible Input Tax ClaimsCase-LawsGSTHC held that the demand for ineligible input tax credit used for discharging outward tax liability involves potential dupl

Tax Credit Dispute: Appellate Path Opened with Nuanced Pre-Deposit Guidelines for Challenging Ineligible Input Tax Claims
Case-Laws
GST
HC held that the demand for ineligible input tax credit used for discharging outward tax liability involves potential duplication of demands. The court relegated the petitioner to the Appellate Authority, permitting appeal filing by 15th July, 2025, with pre-deposit mandated only for specific demand paragraphs. The court directed that any existing depos

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Tax Notification 56/2023 Struck Down: Limitation Period Extension Invalidated, Demand Order Nullified Under Section 168A CGST Act

Tax Notification 56/2023 Struck Down: Limitation Period Extension Invalidated, Demand Order Nullified Under Section 168A CGST ActCase-LawsGSTHC invalidated Notification No. 56/2023-Central Tax, which extended limitation periods under Section 168A of CGST

Tax Notification 56/2023 Struck Down: Limitation Period Extension Invalidated, Demand Order Nullified Under Section 168A CGST Act
Case-Laws
GST
HC invalidated Notification No. 56/2023-Central Tax, which extended limitation periods under Section 168A of CGST Act for financial years 2018-19 and 2019-20. The court found the notification legally unsustainable, effectively setting aside the time limitation extension and consequently nullifying the subsequent demand order of Rs. 1,20,01,973 r

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GST Liability Payment Approved in Instalments, Authorities Directed to Review Petitioner's Financial Constraints Within 3 Weeks

GST Liability Payment Approved in Instalments, Authorities Directed to Review Petitioner’s Financial Constraints Within 3 WeeksCase-LawsGSTHC allowed the petitioner’s application for GST liability payment in instalments under Section 80 of CGST Act, direc

GST Liability Payment Approved in Instalments, Authorities Directed to Review Petitioner's Financial Constraints Within 3 Weeks
Case-Laws
GST
HC allowed the petitioner's application for GST liability payment in instalments under Section 80 of CGST Act, directing respondent authorities to consider the representation within three weeks. The court recognized the petitioner's financial constraints and mandated a reasoned decision on the instalment request, subject to interest payment under

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Taxpayers Gain Relief: Section 128A Clarifies GST Payment Procedures and Dispute Resolution Mechanisms for Pre-November 2024 Periods

Taxpayers Gain Relief: Section 128A Clarifies GST Payment Procedures and Dispute Resolution Mechanisms for Pre-November 2024 PeriodsCircularsGST – StatesLegal Circular Analysis: The circular addresses key interpretative issues regarding Section 128A of th

Taxpayers Gain Relief: Section 128A Clarifies GST Payment Procedures and Dispute Resolution Mechanisms for Pre-November 2024 Periods
Circulars
GST – States
Legal Circular Analysis: The circular addresses key interpretative issues regarding Section 128A of the Assam GST Act, 2017, specifically clarifying two critical points. First, taxpayers who paid taxes through GSTR-3B before 1st November 2024 remain eligible for benefits under Section 128A, subject to proper officer verification. Sec

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Forged GST Challenge Exposed: Fabricated Docs Lead to Criminal Investigation and Petition Dismissal

Forged GST Challenge Exposed: Fabricated Docs Lead to Criminal Investigation and Petition DismissalCase-LawsGSTHC found SCNs and affidavits to be forged, with fictitious petitioners submitting fabricated documents challenging GST registration cancellation

Forged GST Challenge Exposed: Fabricated Docs Lead to Criminal Investigation and Petition Dismissal
Case-Laws
GST
HC found SCNs and affidavits to be forged, with fictitious petitioners submitting fabricated documents challenging GST registration cancellation. Court directed DGGI officials to conduct thorough investigation and file complaint with Crime Branch within one week. Registrar General instructed to lodge complaint against petitioners under relevant sections of Bharatiya Nyaya Sa

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Services to Intermediary Not Directly Supplied to Government Disqualify Tax Exemption Under Notification 12/2017

Services to Intermediary Not Directly Supplied to Government Disqualify Tax Exemption Under Notification 12/2017Case-LawsGSTThe AAAR determined that the appellant’s services do not qualify for tax exemption under Notification No. 12/2017. The key issue ce

Services to Intermediary Not Directly Supplied to Government Disqualify Tax Exemption Under Notification 12/2017
Case-Laws
GST
The AAAR determined that the appellant's services do not qualify for tax exemption under Notification No. 12/2017. The key issue centered on service supply conditions, specifically direct service provision to government entities. While the appellant provided manpower services to Webel Technology Limited for a government project, the services were not directly su

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High Court Strikes Down Tax Credit Disallowance Orders, Mandates Comprehensive Reevaluation of Electronic Credit Ledger Compartments

High Court Strikes Down Tax Credit Disallowance Orders, Mandates Comprehensive Reevaluation of Electronic Credit Ledger CompartmentsCase-LawsGSTHC allowed the petition challenging Exhibit-P1 and Exhibit-P2 orders related to ITC disallowance. Relying on th

High Court Strikes Down Tax Credit Disallowance Orders, Mandates Comprehensive Reevaluation of Electronic Credit Ledger Compartments
Case-Laws
GST
HC allowed the petition challenging Exhibit-P1 and Exhibit-P2 orders related to ITC disallowance. Relying on the precedent in Rejimon Padickapparambil Alex v. UOI, the court held that electronic credit ledger represents a tax fund with distinct compartments for CGST, IGST, and SGST. The impugned orders were set aside, directing the respondent

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Bail Granted in Tax Evasion Case: Insufficient Evidence and No Proven Pattern of Deliberate Tax Fraud

Bail Granted in Tax Evasion Case: Insufficient Evidence and No Proven Pattern of Deliberate Tax FraudCase-LawsGSTHC granted bail to the respondent in a tax evasion case after 13 days in custody. The court noted the investigation agency has sufficient powe

Bail Granted in Tax Evasion Case: Insufficient Evidence and No Proven Pattern of Deliberate Tax Fraud
Case-Laws
GST
HC granted bail to the respondent in a tax evasion case after 13 days in custody. The court noted the investigation agency has sufficient powers to examine GST department and bank records. The respondent, a Delhi resident, was not shown to be a habitual tax offender. Despite the investigation starting in 2020, no criminal complaint was filed, potentially rendering the resp

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Procedural Gaps in E-Way Bill Compliance Don't Automatically Trigger Penalties Without Proven Tax Evasion Intent

Procedural Gaps in E-Way Bill Compliance Don’t Automatically Trigger Penalties Without Proven Tax Evasion IntentCase-LawsGSTHC determined that mere non-completion of part-B of e-way bill does not automatically warrant penalty under Section 129 of U.P. G.S

Procedural Gaps in E-Way Bill Compliance Don't Automatically Trigger Penalties Without Proven Tax Evasion Intent
Case-Laws
GST
HC determined that mere non-completion of part-B of e-way bill does not automatically warrant penalty under Section 129 of U.P. G.S.T. Act, 2017. The court found no evidence of tax evasion attempt by the petitioner. Without a specific finding regarding intentional tax evasion, the penalty levy was deemed unsustainable. Consistent with prior judicial precedents,

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Legal Challenge Upholds Natural Justice: Section 169 Violation Leads to Order Reversal and Procedural Fairness Restoration

Legal Challenge Upholds Natural Justice: Section 169 Violation Leads to Order Reversal and Procedural Fairness RestorationCase-LawsGSTHC allowed the petition in part, finding a violation of natural justice principles. The court set aside orders dated 20.0

Legal Challenge Upholds Natural Justice: Section 169 Violation Leads to Order Reversal and Procedural Fairness Restoration
Case-Laws
GST
HC allowed the petition in part, finding a violation of natural justice principles. The court set aside orders dated 20.09.2023 and 08.05.2024 for non-compliance with Section 169 of Bihar Goods and Service Act, 2017. The matter was remanded to the concerned authority to issue a fresh summary show-cause notice, providing the petitioner adequate opportun

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Procedural Lapses and Delay Scrutinized: Writ Petition Dismissed Despite Potential Merits of Underlying Claim

Procedural Lapses and Delay Scrutinized: Writ Petition Dismissed Despite Potential Merits of Underlying ClaimCase-LawsGSTHC held that despite procedural irregularities in serving show-cause notice and adjudication process, the petitioners failed to provid

Procedural Lapses and Delay Scrutinized: Writ Petition Dismissed Despite Potential Merits of Underlying Claim
Case-Laws
GST
HC held that despite procedural irregularities in serving show-cause notice and adjudication process, the petitioners failed to provide adequate explanation for delay in filing the writ petition. While the court was not inclined to entertain the petition due to unexplained delay, it ensured the petitioners were not left without legal recourse. The writ petition was

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GST Registration Cancellation Upheld, Petitioner Granted Appeal Opportunity with Conditional Reactivation by Pre-Deposit

GST Registration Cancellation Upheld, Petitioner Granted Appeal Opportunity with Conditional Reactivation by Pre-DepositCase-LawsGSTHC dismissed the writ petition challenging GST registration cancellation, holding that the order does not warrant judicial

GST Registration Cancellation Upheld, Petitioner Granted Appeal Opportunity with Conditional Reactivation by Pre-Deposit
Case-Laws
GST
HC dismissed the writ petition challenging GST registration cancellation, holding that the order does not warrant judicial interference under writ jurisdiction. The court permitted the petitioner to file an appeal before the Appellate Authority by 10th July, 2025, with requisite pre-deposit. Upon filing the appeal and intimating the GST Department, the r

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Company Wins Challenge Against Tax Order Due to Procedural Defects and Lack of Substantive Reasoning in Decision-Making Process

Company Wins Challenge Against Tax Order Due to Procedural Defects and Lack of Substantive Reasoning in Decision-Making ProcessCase-LawsGSTHC held that the CTO’s order violated principles of natural justice by failing to provide the Company an opportunity

Company Wins Challenge Against Tax Order Due to Procedural Defects and Lack of Substantive Reasoning in Decision-Making Process
Case-Laws
GST
HC held that the CTO's order violated principles of natural justice by failing to provide the Company an opportunity to be heard and not addressing its legal submissions. The order lacked substantive reasoning, which is essential for a legally valid quasi-judicial decision. Consequently, the impugned demand order was set aside as it contravened pr

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GST inspector held in Haryana's Palwal while accepting bribe: Anti-Corruption Bureau

GST inspector held in Haryana’s Palwal while accepting bribe: Anti-Corruption BureauGSTDated:- 3-6-2025PTIFaridabad (Hry), Jun 2 (PTI) The Anti-Corruption Bureau (ACB) in Faridabad arrested a female GST inspector of the office of the Palwal district excis

GST inspector held in Haryana's Palwal while accepting bribe: Anti-Corruption Bureau
GST
Dated:- 3-6-2025
PTI
Faridabad (Hry), Jun 2 (PTI) The Anti-Corruption Bureau (ACB) in Faridabad arrested a female GST inspector of the office of the Palwal district excise and taxation commissioner on Monday while she was allegedly accepting a bribe of Rs 5,000 in lieu of issuing a GST number to a complainant, an official said.
According to a statement issued by the ACB, accused Sumitra was also arrested in Panipat in 2022 while accepting a bribe of Rs 2 lakh, along with co-accused ETO Roshan Lal. A senior ACB officer said in the Panipat case, a chargesheet was filed against both the accused in July 2022 and the matter is still sub-judice.

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Gross and Net GST revenue collections for the month of May, 2025

Gross and Net GST revenue collections for the month of May, 2025GSTDated:- 2-6-2025Please click on the link below to view the gross and net GST revenue collections for the month of May, 2025. News – Press release – PIB

Gross and Net GST revenue collections for the month of May, 2025
GST
Dated:- 2-6-2025

Please click on the link below to view the gross and net GST revenue collections for the month of May, 2025.
=============
Document 1
GST Gross and Net Collections as on 31/05/2025 (Amount in crores)
MonthlyYearly
GST CollectionsMay-24May-25% GrowthMay-24May-25% Growth
ABCD = C/B 1EFG = F/E-1
A.1. Domestic
CGST32,40935,43476,25584,067
SGST40,26543,90293,8041,03,274
IGST47,90258,7671,09,6981,28,271
CESS11,20711,68323,45923,976
Gross Domestic Revenue1,31,7831,49,78513.7%3,03,2163,39,58812.0%
A.2. Imports
IGST39,87950,07077,70695,824
CESS1,0761,1962,0842,355
Gross Import Revenue40,95651,26625.2%79,79098,17923.0%
A.3. Gross GST Revenue(A.1+A.2)
CGST32,40935,43476,25584,067
SGST40,26543,90293,8041,03,274
IGST87,7811,08,8361,87,4042,24,095
CESS12,28412,87925,54426,330
Total Gross GST Revenue1,72,7392,01,05016.4%3,83,0064,37,76714.3%
B.1. Domestic Refunds
CGST3,1764,2435,8907,474
SGST4,0695,

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ote : The above numbers are provisional and the actuals number may have slightly vary on finalisation
Table 1: State-wise growth of GST Revenues during May, 20251
State/UTMay-24May-25Growth (%)
Jammu and Kashmir52557810%
Himachal Pradesh8388491%
Punjab2,1902,41410%
Chandigarh23736353%
Uttarakhand1,8371,605-13%
Haryana9,28910,1709%
Delhi7,51210,36638%
Rajasthan4,4144,83710%
Uttar Pradesh9,0919,1300%
Bihar1,5211,87123%
Sikkim31242436%
Arunachal Pradesh9815153%
Nagaland456546%
Manipur59118102%
Mizoram3929-26%
Tripura739227%
Meghalaya17221223%
Assam1,2281,59230%
West Bengal5,3776,32118%
Jharkhand2,7002,9078%
Odisha5,0275,1082%
Chhattisgarh2,8532,8911%
Madhya Pradesh3,4023,73310%
Gujarat11,32511,7374%
Dadra and Nagar Haveli and Daman & Diu375351-6%
Maharashtra26,85431,53017%
Karnataka11,88914,29920%
Goa51958713%
Lakshadweep17445%
Kerala2,5943,21024%
Tamil Nadu9,76812,23025%
Puducherry23927515%
Andaman and Nicobar Islands375345%
Telangana4,9865,3106%
Andhra Pradesh3,8903,803-2%
Ladakh15298

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h1,5911,6594%2,5242,192-13%
Madhya Pradesh2,5482,7849%6,2685,930-5%
Gujarat8,0649,17814%12,31013,0746%
Dadra and Nagar Haveli an1331416%183171-6%
Maharashtra20,44022,53410%29,35632,1189%
Karnataka8,1569,36215%14,13913,698-3%
Goa4734893%766740-3%
Lakshadweep13249%91894%
Kerala2,6652,7834%5,5474,965-10%
Tamil Nadu7,5968,75815%12,67411,918-6%
Puducherry951028%235191-19%
Andaman and Nicobar Islaı4949-1%1321385%
Telangana3,6993,9457%7,2757,101-2%
Andhra Pradesh2,8612,801-2%6,1495,388-12%
Ladakh444811%859815%
Other Territory335153%14322859%
Grand Total93,8041,03,27410%1,68,1371,67,025-1%
2 Post-Settlement GST is cumulative of the GST revenues of the States/UTs and the SGST portion of the IGST settled to the States/UTs
Table 3 : State Wise/ Approving Authority wise Domestic Collection
Period Apr-25 to May-25
(Rs. In Crores)
state_CdStateCollection by Central FormationsCollection by State FormationsTOTALGrowth in 2025-26 (upto May-25) on 2023-24 (upto May-25)
No.of GSTINS as on 31st Ma

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317.7%5.0%6.3%
10Bihar2,93,5014717475712872,0763,65,2346771,123254302,0851,1481,8708253184,16022.7%14.4%18.4%
11Sikkim4,881415238604796,60069822640415110134650089421.0%30.1%25.0%
12Arunachal Pradesh8,404597111014211,82414217029134120124140148333.9%77.2%61.9%
13Nagaland4,4493238101826,5993949152105718825318758.5%33.1%43.1%
14Manipur5,881192560508,8548096130189981211912393.5%65.5%47.0%
15Mizoram3,611142580485,172233340593758110107-22.4%-31.2%-27.6%
16Tripura13,68637481009519,699537122014690119320242-1.9%7.5%3.6%
17Meghalaya12,5915058149025718,803901101033306140168252356358.7%25.3%38.6%
18Assam1,01,4244525844671071,6111,25,0066047905851292,1081,0561,3741,0522373,71923.4%16.0%19.1%
19West Bengal3,24,1411,5681,9832,5833386,4714,66,3672,3982,8482,1086858,0383,9664,8304,6901,02314,50919.9%10.5%14.5%
20Jharkhand91,4165526961,3531022,7031,21,2648321,1341,1301,2734,3701,3851,8302,4831,3757,074-1.0%15.1%8.3%
21Odisha1,52,3211,2781,4672,265635,0731,98,9351,4091,9271,1911,6836,2102,6873,3943,4561,7

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Tax Evasion Case: Section 122 Proceedings Can Continue Independently After Section 74 Concludes, Protecting Public Revenue Interests

Tax Evasion Case: Section 122 Proceedings Can Continue Independently After Section 74 Concludes, Protecting Public Revenue InterestsCase-LawsGSTHC held that proceedings under Section 122 of CGST Act do not automatically abate upon conclusion of Section 74

Tax Evasion Case: Section 122 Proceedings Can Continue Independently After Section 74 Concludes, Protecting Public Revenue Interests
Case-Laws
GST
HC held that proceedings under Section 122 of CGST Act do not automatically abate upon conclusion of Section 74 proceedings. The court interpreted 'offence' and 'penalty' broadly, recognizing that penalty provisions serve to protect public revenue and deter tax evasion. The statute allows independent penalty proceedings even after main tax pr

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Bail Granted to Accused in Fake Invoice Case Under CGST Act, Personal Liberty Prevails Over Investigative Constraints

Bail Granted to Accused in Fake Invoice Case Under CGST Act, Personal Liberty Prevails Over Investigative ConstraintsCase-LawsGSTHC granted regular bail to petitioners accused of operating a fake invoice racket under CGST Act. Despite allegations of tax e

Bail Granted to Accused in Fake Invoice Case Under CGST Act, Personal Liberty Prevails Over Investigative Constraints
Case-Laws
GST
HC granted regular bail to petitioners accused of operating a fake invoice racket under CGST Act. Despite allegations of tax evasion, the court noted that precise tax liability remains unassessed and documentary evidence would not be compromised by release. Considering petitioners' extended custody since 13.12.2024 and absence of need for further custodial

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Tax Credit Fraud Suspect Secures Bail After Court Finds No Witness Tampering Risk and Evaluates Documentary Evidence

Tax Credit Fraud Suspect Secures Bail After Court Finds No Witness Tampering Risk and Evaluates Documentary EvidenceCase-LawsGSTHC granted regular bail in tax credit fraud case, finding custodial detention unwarranted given documentary evidence nature. Th

Tax Credit Fraud Suspect Secures Bail After Court Finds No Witness Tampering Risk and Evaluates Documentary Evidence
Case-Laws
GST
HC granted regular bail in tax credit fraud case, finding custodial detention unwarranted given documentary evidence nature. The court considered economic offence gravity but determined no witness tampering risk exists. Bail was allowed subject to personal bond submission with two sureties, recognizing the allegations' economic nature while balancing investi

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Provisional Bank Account Attachment Under Section 83 Invalidated Due to Lack of Substantive Evidence and Procedural Compliance

Provisional Bank Account Attachment Under Section 83 Invalidated Due to Lack of Substantive Evidence and Procedural ComplianceCase-LawsGSTHC found the provisional attachment of petitioner’s bank account under Section 83 of Maharashtra GST Act, 2017 unsust

Provisional Bank Account Attachment Under Section 83 Invalidated Due to Lack of Substantive Evidence and Procedural Compliance
Case-Laws
GST
HC found the provisional attachment of petitioner's bank account under Section 83 of Maharashtra GST Act, 2017 unsustainable. The attachment was based on proceedings under Section 67 which had already concluded without raising any tax demand or issuing show-cause notice. The Commissioner failed to provide material substantiating the opinion necessi

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Taxpayer Wins Input Tax Credit Refund Claim, Invalidates Restrictive Administrative Circular Under Section 54(1)

Taxpayer Wins Input Tax Credit Refund Claim, Invalidates Restrictive Administrative Circular Under Section 54(1)Case-LawsGSTHC held that the taxpayer’s refund application for unutilized Input Tax Credit (ITC) filed on 07.11.2022 for periods prior to 18.07

Taxpayer Wins Input Tax Credit Refund Claim, Invalidates Restrictive Administrative Circular Under Section 54(1)
Case-Laws
GST
HC held that the taxpayer's refund application for unutilized Input Tax Credit (ITC) filed on 07.11.2022 for periods prior to 18.07.2022 is maintainable, as it was within the statutory limitation period under Section 54(1). Following the precedent in Patanjali Foods case, the court quashed the department's rejection order, which improperly relied on Circular No.

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Improper Online GST Notice Service Violates Natural Justice, Invalidates Ex Parte Order Under Procedural Fairness Principles

Improper Online GST Notice Service Violates Natural Justice, Invalidates Ex Parte Order Under Procedural Fairness PrinciplesCase-LawsGSTHC held that service of notice via online GST portal under ‘View Additional Notice/Orders’ column is insufficient and v

Improper Online GST Notice Service Violates Natural Justice, Invalidates Ex Parte Order Under Procedural Fairness Principles
Case-Laws
GST
HC held that service of notice via online GST portal under 'View Additional Notice/Orders' column is insufficient and violates principles of natural justice. The court invalidated the ex parte order due to improper notice service. Recommended alternative service methods including registered post with acknowledgement, hand delivery, or courier to taxp

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Independent Service Provider Wins GST Refund Claim, Export Services Exempted Under Section 54 CGST Act

Independent Service Provider Wins GST Refund Claim, Export Services Exempted Under Section 54 CGST ActCase-LawsGSTHC determined that the petitioner is an independent service provider, not an intermediary under IGST Act. Services rendered to overseas recip

Independent Service Provider Wins GST Refund Claim, Export Services Exempted Under Section 54 CGST Act
Case-Laws
GST
HC determined that the petitioner is an independent service provider, not an intermediary under IGST Act. Services rendered to overseas recipients constitute export of services exempt from GST liability. The court quashed the appellate authority's order dated 01.09.2023, restored the original order dated 28.07.2022 granting refund for April and May 2022, and held that ref

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GST Adjudication Order Overturned: Principles of Natural Justice Violated, Petitioner Granted Fair Hearing Opportunity

GST Adjudication Order Overturned: Principles of Natural Justice Violated, Petitioner Granted Fair Hearing OpportunityCase-LawsGSTHC allowed the petition challenging GST adjudication proceedings, finding violation of principles of natural justice. The ex-

GST Adjudication Order Overturned: Principles of Natural Justice Violated, Petitioner Granted Fair Hearing Opportunity
Case-Laws
GST
HC allowed the petition challenging GST adjudication proceedings, finding violation of principles of natural justice. The ex-parte order was set aside due to petitioner's inability to respond to show cause notice under bona fide circumstances. The matter was remitted back to the tax authority to provide fair opportunity of hearing, requiring reconsideratio

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Two Public Officials Caught in Rs. 500,000 Bribery Scheme, Evidence Reveals Direct Involvement in Tax Liability Corruption

Two Public Officials Caught in Rs. 500,000 Bribery Scheme, Evidence Reveals Direct Involvement in Tax Liability CorruptionCase-LawsGSTHC rejected bail application for two accused involving bribery of public servant. The court found active participation of

Two Public Officials Caught in Rs. 500,000 Bribery Scheme, Evidence Reveals Direct Involvement in Tax Liability Corruption
Case-Laws
GST
HC rejected bail application for two accused involving bribery of public servant. The court found active participation of the accused in demanding and receiving bribe of Rs. 500,000 for settling tax liability. Evidence included seized mobile phone with voice recordings substantiating bribe allegations. The court determined the accused entered into crim

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