Taxpayer Must Comply with GST Circular 224/18/2024, Pre-Deposit Mandatory Under Section 112(8) for Appellate Rights

Taxpayer Must Comply with GST Circular 224/18/2024, Pre-Deposit Mandatory Under Section 112(8) for Appellate RightsCase-LawsGSTHC held that petitioner must comply with Circular No. 224/18/2024-GST by making pre-deposit under Section 112(8) of CGST Act and

Taxpayer Must Comply with GST Circular 224/18/2024, Pre-Deposit Mandatory Under Section 112(8) for Appellate Rights
Case-Laws
GST
HC held that petitioner must comply with Circular No. 224/18/2024-GST by making pre-deposit under Section 112(8) of CGST Act and filing a mandatory undertaking/declaration with proper jurisdictional officer. Petitioner demonstrated willingness to submit required documentation. Writ petition disposed of, granting liberty to petitioner to file the requisite undertaking/declaration in accordance with the circular's stipulations, thereby preserving potential appellate rights pending Appellate Tribunal's formal constitution.
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Electronic Credit Ledger Unblocked: Rule 86A Challenge Succeeds After Procedural Flaws Expose Lack of Fair Hearing

Electronic Credit Ledger Unblocked: Rule 86A Challenge Succeeds After Procedural Flaws Expose Lack of Fair HearingCase-LawsGSTHC allows petition challenging blocking of electronic credit ledger under Rule 86A of CGST Rules. The court found the impugned or

Electronic Credit Ledger Unblocked: Rule 86A Challenge Succeeds After Procedural Flaws Expose Lack of Fair Hearing
Case-Laws
GST
HC allows petition challenging blocking of electronic credit ledger under Rule 86A of CGST Rules. The court found the impugned order invalid due to lack of pre-decisional hearing and absence of cogent reasons. The order invoking Section 86A was quashed, directing immediate unblocking of the electronic credit ledger. Respondents retain liberty to proceed against petitioner in accordance with law. Petitioner mandated to appear before respondent on specified date, with automatic revival of proceedings if non-compliance occurs.
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Simultaneous Proceedings Challenged, Petitioner Granted Relief Under Sections 70 and 74, to proceed before Central Authority only

Simultaneous Proceedings Challenged, Petitioner Granted Relief Under Sections 70 and 74, to proceed before Central Authority onlyCase-LawsGSTHC allows petition challenging simultaneous GST proceedings, quashing the SCN issued by state authorities under Se

Simultaneous Proceedings Challenged, Petitioner Granted Relief Under Sections 70 and 74, to proceed before Central Authority only
Case-Laws
GST
HC allows petition challenging simultaneous GST proceedings, quashing the SCN issued by state authorities under Section 70 and Section 74. The court directed the petitioner to file reply before the central GST authority, considering recent circulars and precedential judgments. The key relief includes: (i) quashing of impugned SCN, (ii) liberty to file comprehensive reply, and (iii) mandate for respondent to reconsider claims in accordance with recent GST circulars and judicial interpretations, particularly regarding input tax credit and valuation for tax payment.
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GST official nabbed for taking Rs 45,000 from Noida bizman

GST official nabbed for taking Rs 45,000 from Noida bizmanGSTDated:- 20-5-2025PTINoida, May 20 (PTI) A GST official was caught red handed while taking a bribe of Rs 45,000 from a Noida-based businessman on Monday, police said.
The arrest was made by the

GST official nabbed for taking Rs 45,000 from Noida bizman
GST
Dated:- 20-5-2025
PTI
Noida, May 20 (PTI) A GST official was caught red handed while taking a bribe of Rs 45,000 from a Noida-based businessman on Monday, police said.
The arrest was made by the Vigilance Team, Meerut Sector. A case has been registered against the GST officer at Knowledge Park Police Station in Greater Noida, they said.
Pramod Tiwari, the complainant, claimed that his firm's VAT and GST have been deposited in the concerned department on time. However, on April 29, he received a call from a person, Bhudev, who told him that the assessment of the year 2016-17 and 2017-18 is pending, they said.
Along with this, Tiwari was also asked to deposit the

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Tax Compliance Clarity: Section 128A MGST Act Explains Eligibility, Payment Processes, and Dispute Resolution Mechanisms

Tax Compliance Clarity: Section 128A MGST Act Explains Eligibility, Payment Processes, and Dispute Resolution MechanismsCircularsGST – StatesThe trade circular addresses key interpretative issues regarding Section 128A of the MGST Act, 2017, specifically

Tax Compliance Clarity: Section 128A MGST Act Explains Eligibility, Payment Processes, and Dispute Resolution Mechanisms
Circulars
GST – States
The trade circular addresses key interpretative issues regarding Section 128A of the MGST Act, 2017, specifically clarifying two critical points: (1) taxpayers who paid taxes through GSTR-3B before 1st November 2024 remain eligible for benefits under Section 128A, subject to proper officer verification; and (2) for notices/orders spanning periods partially within and outside Section 128A's scope, taxpayers can file specific forms (SPL-01/SPL-02) after paying tax liability for covered periods, with appellate authorities empowered to adjudicate remaining periods appropriately. The circular aims to provide uniform implementation guidance for tax dispute resolution.
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Procedural Defects in GST Assessment Undermine Liability of penalty Determination Under Section 122(2)(b)

Procedural Defects in GST Assessment Undermine Liability of penalty Determination Under Section 122(2)(b)Case-LawsGSTHC determined that the imposition of penalty under Section 122(2)(b) of the GST Act, 2017 was procedurally flawed due to non-compliance wi

Procedural Defects in GST Assessment Undermine Liability of penalty Determination Under Section 122(2)(b)
Case-Laws
GST
HC determined that the imposition of penalty under Section 122(2)(b) of the GST Act, 2017 was procedurally flawed due to non-compliance with Rule 142(1A) regarding communication of tax details. The court found the tax liability determination for July 2017 to March 2019 legally erroneous. As an interim measure, the court directed the petitioner to deposit 20% of the tax amount determined in the original order within two weeks, with a consequent restraint on coercive recovery measures by the tax authorities pending further adjudication.
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Provisional Bank Account Attachment Under Section 83 Quashed Due to Lack of Substantive Revenue Risk Evidence

Provisional Bank Account Attachment Under Section 83 Quashed Due to Lack of Substantive Revenue Risk EvidenceCase-LawsGSTHC quashed the provisional attachment of petitioner’s bank account under Section 83 of CGST Act, 2017. The court found the respondents

Provisional Bank Account Attachment Under Section 83 Quashed Due to Lack of Substantive Revenue Risk Evidence
Case-Laws
GST
HC quashed the provisional attachment of petitioner's bank account under Section 83 of CGST Act, 2017. The court found the respondents' action arbitrary, lacking substantive evidence of revenue risk. Despite petitioner's non-cooperation in show cause proceedings, the attachment was deemed invalid as the authorities failed to demonstrate a reasonable apprehension of revenue default. The court emphasized that provisional attachment requires cogent material basis and cannot be justified by mere procedural non-compliance. The impugned order was set aside, with directions to immediately de-freeze the petitioner's bank account, reinforcing the principle that administrative powers must be exercised with due diligence and proportionality.
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Taxpayer Wins GST Address Amendment Rights with One-Month Window and Guaranteed Input Tax Credit Unblocking

Taxpayer Wins GST Address Amendment Rights with One-Month Window and Guaranteed Input Tax Credit UnblockingCase-LawsGSTHC granted the petitioner an opportunity to submit documentation for amending GST registration address within one month. The court manda

Taxpayer Wins GST Address Amendment Rights with One-Month Window and Guaranteed Input Tax Credit Unblocking
Case-Laws
GST
HC granted the petitioner an opportunity to submit documentation for amending GST registration address within one month. The court mandated a personal hearing and directed that the address change application be processed within three months. Any blocked Input Tax Credit shall be unblocked. The order does not impact other potential proceedings related to the petitioner's GSTN number, effectively disposing of the writ petition with procedural directives for rectification.
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Tax Dispute Resolved: Petitioner Granted Opportunity to Respond and Challenge Ex-Parte Order Under Section 74(9)

Tax Dispute Resolved: Petitioner Granted Opportunity to Respond and Challenge Ex-Parte Order Under Section 74(9)Case-LawsGSTHC allowed the petition challenging tax demand, setting aside the ex-parte order dated 05.10.2023 under Section 74(9) of CGST/KGST

Tax Dispute Resolved: Petitioner Granted Opportunity to Respond and Challenge Ex-Parte Order Under Section 74(9)
Case-Laws
GST
HC allowed the petition challenging tax demand, setting aside the ex-parte order dated 05.10.2023 under Section 74(9) of CGST/KGST Act. The court remitted the matter back to the first respondent, directing the petitioner to appear on 28.04.2025 and providing an opportunity to submit replies and documents. The order emphasizes a justice-oriented approach, allowing the petitioner to contest the proceedings and provide explanations for previous non-compliance. If the petitioner fails to appear on the specified date, the current order will be automatically recalled, and the petition will be restored.
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Manufacturers Win Right to Claim Input Tax Credit Refund for Zero-Rated Exports Despite Previous Circular Restrictions

Manufacturers Win Right to Claim Input Tax Credit Refund for Zero-Rated Exports Despite Previous Circular RestrictionsCase-LawsGSTHC allows petitioner’s claim for refund of unutilized Input Tax Credit (ITC) on compensation cess paid for coal used in manuf

Manufacturers Win Right to Claim Input Tax Credit Refund for Zero-Rated Exports Despite Previous Circular Restrictions
Case-Laws
GST
HC allows petitioner's claim for refund of unutilized Input Tax Credit (ITC) on compensation cess paid for coal used in manufacturing zero-rated export goods. The court held that when IGST is paid on zero-rated supplies, the petitioner is entitled to refund of input tax credit of compensation cess, notwithstanding restrictions in Circular No.125/44/2019. The respondents are directed to process and sanction the refund applications for the unutilized ITC, effectively quashing the previous adverse order and restoring the original refund sanctioning order.
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GST Registration Applicants Can Now Resolve Documentation Challenges Through Comprehensive Grievance Redressal Mechanism

GST Registration Applicants Can Now Resolve Documentation Challenges Through Comprehensive Grievance Redressal MechanismCircularsGST – StatesThe public notice outlines a comprehensive Grievance Redressal Mechanism for GST registration applications in the

GST Registration Applicants Can Now Resolve Documentation Challenges Through Comprehensive Grievance Redressal Mechanism
Circulars
GST – States
The public notice outlines a comprehensive Grievance Redressal Mechanism for GST registration applications in the Bengaluru Zone. Key provisions include detailed guidelines for documenting principal place of business, specifying acceptable proof of ownership or occupancy, and establishing clear documentation requirements for different business constitutions. Applicants with registration challenges can submit grievances via email to cgst-blr@gov.in or visit the GST Seva Kendra. The mechanism aims to streamline registration processes, reduce unnecessary documentation requests, and provide a structured approach for resolving registration-related issues, ensuring transparent and efficient GST registration processing for applicants in Karnataka.
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Petitioner Faces Serious Consequences for Submitting Fabricated Show Cause Notices Undermining Judicial Integrity

Petitioner Faces Serious Consequences for Submitting Fabricated Show Cause Notices Undermining Judicial IntegrityCase-LawsGSTHC recalled its previous order after discovering fabricated show cause notices (SCNs) submitted by the petitioner. The court issue

Petitioner Faces Serious Consequences for Submitting Fabricated Show Cause Notices Undermining Judicial Integrity
Case-Laws
GST
HC recalled its previous order after discovering fabricated show cause notices (SCNs) submitted by the petitioner. The court issued non-bailable warrants for the petitioner's production, directing counsel to identify individuals responsible for submitting fraudulent documentation. The court prima facie determined that the SCN was deliberately manipulated to obtain a favorable judicial order, mandating the petitioner's appearance and requiring counsel to file an explanatory affidavit regarding the origin of the falsified documents. The writ petition was restored to its original docket number, with strict judicial scrutiny of the procedural irregularities.
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GST Registration Cancellation Halted: Fabricated Show Cause Notice Exposes Critical Procedural Irregularities in Administrative Action

GST Registration Cancellation Halted: Fabricated Show Cause Notice Exposes Critical Procedural Irregularities in Administrative ActionCase-LawsGSTHC recalled the order due to fabrication of show cause notice (SCN), involving material fact deletion and ret

GST Registration Cancellation Halted: Fabricated Show Cause Notice Exposes Critical Procedural Irregularities in Administrative Action
Case-Laws
GST
HC recalled the order due to fabrication of show cause notice (SCN), involving material fact deletion and retrospective GST registration cancellation. The court directed: (1) final order stands recalled, (2) proprietor must appear in subsequent hearing, (3) registry to list related writ petitions together, and (4) counsel to intimate petitioners in connected cases. The department challenged the original order, revealing multiple instances of potential SCN manipulation, leading to comprehensive judicial review and procedural rectification.
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CBIC celebrates ‘Sundays on Cycle’ – A fitness and GST awareness initiative in run up to completion of 8 years of GST

CBIC celebrates ‘Sundays on Cycle’ – A fitness and GST awareness initiative in run up to completion of 8 years of GSTGSTDated:- 19-5-2025In the run-up to completion of eight years of GST, the Central Board of Indirect Taxes and Customs (CBIC), in coordina

CBIC celebrates ‘Sundays on Cycle’ – A fitness and GST awareness initiative in run up to completion of 8 years of GST
GST
Dated:- 19-5-2025

In the run-up to completion of eight years of GST, the Central Board of Indirect Taxes and Customs (CBIC), in coordination with the FIT INDIA Movement, organised a nationwide cyclothon titled “Sundays on Cycle” under the aegis of FIT INDIA movement launched by the Prime Minister, Shri Narendra Modi. The flagship event was organised at Major Dhyan Chand National Stadium, New Delhi, early morning, with more than 100 CGST commssionerates also participating across the country.
Flagging the cyclothon at New Delhi, Shri Shashank Priya, Member (GST), CBIC, highlighted the transformational impact

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ding senior officers from CBIC – Shri Rajesh Sodhi, Principal Chief Commissioner, CGST Delhi Zone; Shri C.P. Goyal, Pr. Director General of GST (DGGST), CBIC, and Shri Mahesh Kumar Rustagi, Director General of Taxpayer Services (DGTS), CBIC; representatives from various ministries and departments, and members of the general public.
At the venue, a dedicated GST Help Desk “Know About GST” was set up to engage with participants and to answer queries about GST. To enhance accessibility and outreach, a wide array of informational brochures on key GST topics were distributed, and digital kiosks equipped with QR codes were strategically placed across the venue allowing participants to scan and download GST resource materials directly to their mo

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Tax Reimbursement Clarified: Quarterly Calculation Method Approved for Manufacturing Units Under J&K GST Scheme

Tax Reimbursement Clarified: Quarterly Calculation Method Approved for Manufacturing Units Under J&K GST SchemeCase-LawsGSTHC allowed the appeal, setting aside the previous order and judgment regarding budgetary support claims. The court held that cla

Tax Reimbursement Clarified: Quarterly Calculation Method Approved for Manufacturing Units Under J&K GST Scheme
Case-Laws
GST
HC allowed the appeal, setting aside the previous order and judgment regarding budgetary support claims. The court held that claims for reimbursement under the Jammu & Kashmir GST scheme shall be calculated and filed on a quarterly basis, covering periods of January-March, April-June, July-September, and October-December. The departmental clarification dated 26-04-2022 was deemed valid, rejecting the respondents' argument that a subsequent DPIIT clarification should supersede the HC's directive. The ruling enables manufacturing units to seek tax reimbursement by aggregating tax liabilities and input tax credits on a quarterly basis, providing a clear mechanism for budgetary support claims.
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Tax Dispute Resolution: Firm Wins Right to Challenge Liability and Seek 24-Month Installment Payment Plan Under Section 80

Tax Dispute Resolution: Firm Wins Right to Challenge Liability and Seek 24-Month Installment Payment Plan Under Section 80Case-LawsGSTHC granted the petitioner firm leave to file a fresh application for depositing the demanded tax amount in 24 equal month

Tax Dispute Resolution: Firm Wins Right to Challenge Liability and Seek 24-Month Installment Payment Plan Under Section 80
Case-Laws
GST
HC granted the petitioner firm leave to file a fresh application for depositing the demanded tax amount in 24 equal monthly installments under Section 80 of CGST Act. The Court directed the Commissioner to consider the application, provide a personal hearing, and issue a merit-based order within one month. The petitioner was permitted to raise grounds challenging the self-assessed tax liability in the new application. The original petition was disposed of, providing the firm an opportunity to seek relief through a revised installment payment request.
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Tax Notices Invalidated: Administrative Failure to Provide Meaningful Hearing Leads to Order Reversal Under Natural Justice Principles

Tax Notices Invalidated: Administrative Failure to Provide Meaningful Hearing Leads to Order Reversal Under Natural Justice PrinciplesCase-LawsGSTHC set aside the impugned order challenging tax notices due to procedural irregularities, specifically the la

Tax Notices Invalidated: Administrative Failure to Provide Meaningful Hearing Leads to Order Reversal Under Natural Justice Principles
Case-Laws
GST
HC set aside the impugned order challenging tax notices due to procedural irregularities, specifically the lack of meaningful opportunity for the petitioner to be heard. The court found the administrative order was passed mechanically without properly considering the petitioner's reply or providing substantive personal hearing. Consequently, the court directed that the petitioner be afforded a proper opportunity to contest the matter on merits, thereby nullifying the existing show cause notices and subsequent orders.
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High Court Overturns Tax Assessment Order, Mandates Fresh Hearing and Fair Review of Procedural Compliance

High Court Overturns Tax Assessment Order, Mandates Fresh Hearing and Fair Review of Procedural ComplianceCase-LawsGSTHC allowed the appeal u/s 107 of CGST/WBGST Act, 2017, remanding the matter back to appellate authority for adjudication on merits. The c

High Court Overturns Tax Assessment Order, Mandates Fresh Hearing and Fair Review of Procedural Compliance
Case-Laws
GST
HC allowed the appeal u/s 107 of CGST/WBGST Act, 2017, remanding the matter back to appellate authority for adjudication on merits. The court found procedural irregularities in the original order, specifically the lack of personal hearing and premature dismissal. The bank account attachment order was set aside, noting the petitioner had already paid pre-deposit and a substantial portion of disputed tax. The appellate tribunal's non-constitution was also considered. The order mandates a fresh review of the original tax dispute, ensuring procedural fairness and adherence to statutory provisions.
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GST Show Cause Notice Challenge Dismissed, Petitioner Granted Extended Appeal Window Until July 10, 2025

GST Show Cause Notice Challenge Dismissed, Petitioner Granted Extended Appeal Window Until July 10, 2025Case-LawsGSTHC dismissed the petition challenging SCN under GST law, granting the petitioner time until 10th July, 2025 to file an appeal before the ap

GST Show Cause Notice Challenge Dismissed, Petitioner Granted Extended Appeal Window Until July 10, 2025
Case-Laws
GST
HC dismissed the petition challenging SCN under GST law, granting the petitioner time until 10th July, 2025 to file an appeal before the appellate authority under Section 107 of CGST Act, 2017. The court's observations shall not impact the appellate authority's decision, and the validity of the notification remains unresolved, subject to the Supreme Court's pending judgment in the referenced case. The petition was disposed of with liberty to pursue appellate remedies.
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Judicial Intervention Secures 5% Tax Rate for PPSB Bed Sheets, Mandates Refund Processing Within 12 Weeks

Judicial Intervention Secures 5% Tax Rate for PPSB Bed Sheets, Mandates Refund Processing Within 12 WeeksCase-LawsGSTHC ruled in favor of the petitioner regarding PPSB bed sheets classification, finding the Appellate Authority erroneously misinterpreted s

Judicial Intervention Secures 5% Tax Rate for PPSB Bed Sheets, Mandates Refund Processing Within 12 Weeks
Case-Laws
GST
HC ruled in favor of the petitioner regarding PPSB bed sheets classification, finding the Appellate Authority erroneously misinterpreted statutory provisions. The court determined that PPSB bed sheets should be taxed at 5% under Chapter 6304, not 12% under Chapter 5603. The HC directed respondents to process the petitioner's refund applications within 12 weeks, including applicable statutory interest, and modified the previous orders that incorrectly classified the bed sheets. The writ petitions were disposed of, effectively overturning the Appellate Authority's previous decisions.
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Anticipatory Bail Granted in GST Evasion Case: No Evidence of Intentional Investigation Obstruction, Bond Imposed

Anticipatory Bail Granted in GST Evasion Case: No Evidence of Intentional Investigation Obstruction, Bond ImposedCase-LawsGSTDSC granted anticipatory bail in GST evasion matter involving fake invoices and input tax credit manipulation. Court found no evid

Anticipatory Bail Granted in GST Evasion Case: No Evidence of Intentional Investigation Obstruction, Bond Imposed
Case-Laws
GST
DSC granted anticipatory bail in GST evasion matter involving fake invoices and input tax credit manipulation. Court found no evidence of applicant evading investigation, noting voluntary appearance and cooperation with Department. Bail granted subject to Rs. 2,00,000 bond with blood relative surety, contingent on potential arrest under Section 69 of GST Act. Department's arguments challenging applicant's credibility were rejected due to lack of concrete material demonstrating flight risk or intentional non-cooperation. Applicant permitted pre-arrest bail with standard judicial safeguards.
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CGST Delhi South Commissionerate awarded BIS IS 15700:2018 Certification for Excellence in Public Service Delivery

CGST Delhi South Commissionerate awarded BIS IS 15700:2018 Certification for Excellence in Public Service DeliveryGSTDated:- 17-5-2025The Central Goods and Services Tax (CGST) Delhi South Commissionerate has been awarded the Bureau of Indian Standards (BI

CGST Delhi South Commissionerate awarded BIS IS 15700:2018 Certification for Excellence in Public Service Delivery
GST
Dated:- 17-5-2025

The Central Goods and Services Tax (CGST) Delhi South Commissionerate has been awarded the Bureau of Indian Standards (BIS) IS 15700:2018 certification, recognising its commitment to excellence in public service delivery.
This certification acknowledges the Delhi South Commissionerate's adherence to the highest standards of service quality, tr

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Taxpayer Wins Partial Relief: 10% Tax Deposit Secures Interim Stay Under CGST Section 112(8)

Taxpayer Wins Partial Relief: 10% Tax Deposit Secures Interim Stay Under CGST Section 112(8)Case-LawsGSTHC granted conditional interim relief in tax dispute, directing petitioner to deposit 10% of remaining disputed tax amount within four weeks. Unconditi

Taxpayer Wins Partial Relief: 10% Tax Deposit Secures Interim Stay Under CGST Section 112(8)
Case-Laws
GST
HC granted conditional interim relief in tax dispute, directing petitioner to deposit 10% of remaining disputed tax amount within four weeks. Unconditional stay of demand issued for four weeks, with continued interim order contingent upon petitioner's compliance with deposit requirement. Order allows partial stay under Section 112(8) of CGST/WBGST Act, 2017, providing temporary relief pending final adjudication of writ petition.
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Tax Authority Fails to Follow Proper Procedure, Best Judgment Assessment Under GST Nullified for Lack of Mandatory Notice

Tax Authority Fails to Follow Proper Procedure, Best Judgment Assessment Under GST Nullified for Lack of Mandatory NoticeCase-LawsGSTHC nullified best judgment assessment under GST due to procedural irregularities. The court found the assessment order inv

Tax Authority Fails to Follow Proper Procedure, Best Judgment Assessment Under GST Nullified for Lack of Mandatory Notice
Case-Laws
GST
HC nullified best judgment assessment under GST due to procedural irregularities. The court found the assessment order invalid as the tax authority failed to issue mandatory notice under Section 46 and did not provide an opportunity of hearing, thereby violating principles of natural justice. The assessment order lacked substantive material and reasoning required for Section 62 invocation. Consequently, both assessment orders dated 27.08.2019 and 29.01.2025 were quashed, emphasizing the necessity of procedural compliance in tax assessment proceedings.
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Legal Challenge Upheld: CGST Section 107 Appeal Permitted with Pre-Deposit, Limitation Period Extended to July 10th

Legal Challenge Upheld: CGST Section 107 Appeal Permitted with Pre-Deposit, Limitation Period Extended to July 10thCase-LawsGSTHC allowed the appellate remedy under Section 107 of CGST Act, 2017, permitting the Petitioner to file an appeal by 10th July, 2

Legal Challenge Upheld: CGST Section 107 Appeal Permitted with Pre-Deposit, Limitation Period Extended to July 10th
Case-Laws
GST
HC allowed the appellate remedy under Section 107 of CGST Act, 2017, permitting the Petitioner to file an appeal by 10th July, 2025 with pre-deposit. The appeal, if filed within the stipulated timeframe, will not be dismissed on limitation grounds and will be heard on merits. The court explicitly left open the issue regarding the validity of the impugned notifications, making the order subject to the Supreme Court's decision in the pending SLP. The petitioner was granted a belated opportunity to challenge the order while preserving the right to contest notification validity in future proceedings.
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