Tag Archives: Assistant Commissioner

Composite GST Notices and Orders Clubbing Multiple Assessment Years Are Impermissible and Legally Unsustainable

By | August 29, 2026
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Composite GST Notices and Orders Clubbing Multiple Assessment Years Are Impermissible and Legally Unsustainable Composite GST Notices and Orders Clubbing Multiple Assessment Years Are Impermissible and Legally Unsustainable Issue Whether issuing single, composite show-cause notices and passing composite assessment/demand orders clubbing multiple assessment years under Sections 73, 74, and 75 of the CGST/KGST Act is… Read More »

Portal Service Post-Cancellation of GST Registration Is Invalid and Order Quashed for Violation of Hearing Rights

By | August 21, 2026
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Portal Service Post-Cancellation of GST Registration Is Invalid and Order Quashed for Violation of Hearing Rights Issue Whether an adjudication order passed under Section 73 is legally valid when the Show Cause Notice (SCN) was served exclusively through the GST portal after the cancellation of the assessee’s registration and no opportunity of personal hearing was… Read More »

Taxpayers initiating Section 128A waiver after Section 73 action are eligible despite belated return filings.

By | August 21, 2026
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Taxpayers initiating Section 128A waiver after Section 73 action are eligible despite belated return filings. Issue Whether a taxpayer against whom proceedings under Section 73 were initiated can be denied interest/penalty waiver under Section 128A on the ground that the demand relates to self-assessed tax from belatedly filed GSTR-3B returns. Whether tax authorities can declare… Read More »

IGST Remitted Inadvertently Under Wrong Major Head Must Be Appropriated Towards CGST and SGST Liabilities

By | August 1, 2026
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IGST Remitted Inadvertently Under Wrong Major Head Must Be Appropriated Towards CGST and SGST Liabilities Issue Whether a taxpayer who inadvertently paid its entire tax liability under the IGST head instead of splitting it between CGST and SGST can seek direct adjustment/appropriation of the IGST payment towards CGST and SGST liabilities instead of paying fresh… Read More »

Reversal of Input Tax Credit Solely Due to Retrospective Cancellation of Supplier’s Registration Without Document Evaluation Is Invalid

By | August 1, 2026
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Reversal of Input Tax Credit Solely Due to Retrospective Cancellation of Supplier’s Registration Without Document Evaluation Is Invalid Issue Whether the reversal of Input Tax Credit (ITC) under Section 73 can be confirmed solely on the ground of retrospective cancellation of the supplier’s registration, without considering the documentary evidence submitted by the purchaser and after… Read More »

Objective Evidence of Fraudulent Invoices and Missing Physical Deliveries Justifies Blocking of Input Tax Credit under Rule 86A

By | July 15, 2026
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Objective Evidence of Fraudulent Invoices and Missing Physical Deliveries Justifies Blocking of Input Tax Credit under Rule 86A Issue Whether the tax department’s decision to block the petitioner’s Input Tax Credit (ITC) of approximately ₹4.11 crore under Rule 86A of the CGST Rules was legally valid, based on objective “reasons to believe” that the underlying… Read More »

Composite Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Issued Year-Wise

By | July 11, 2026
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Composite Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Issued Year-Wise Composite Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Issued Year-Wise Issue Whether the revenue authorities are legally permitted to issue a single, consolidated Show Cause Notice (SCN) and subsequent demand orders under Section… Read More »

Parallel scrutiny and audit proceedings are valid separate actions under GST despite structural corporate changes.

By | July 7, 2026
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Parallel scrutiny and audit proceedings are valid separate actions under GST despite structural corporate changes. Issue Whether the revenue department can legally run separate, parallel audit-based and scrutiny-based proceedings for the same period under Sections 65 and 61 of the CGST/TNGST Act, and whether a Show Cause Notice under Section 74 is valid if it… Read More »

Composite GST Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Quashed

By | July 7, 2026
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Composite GST Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Quashed Issue Whether a consolidated or composite Show Cause Notice (SCN) issued under Section 73 of the CGST/SGST Act covering multiple financial years (2019-2020 to 2023-2024) is legally sustainable, or if the tax authorities are mandated to issue separate, year-wise… Read More »

Composite GST Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Quashed

By | July 7, 2026
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Composite GST Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Quashed Issue Whether a consolidated Show Cause Notice (SCN) issued under Section 73 of the CGST/SGST Act covering multiple financial years (2019–20 to 2021–22) is legally sustainable, or if the tax authorities are mandated to issue separate notices for each… Read More »