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GST - Case Laws
Showing 161 to 180 of 2178 Records
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2023 (12) TMI 423
Maintainability of petition - availability of alternative remedy - Provisional attachment of bank account - HELD THAT:- Now as an order has been passed by the adjudicating officer deciding the show cause notices and as the petitioner is now desirous to assail the said order-in-original by adopting the appropriate remedy as available in law, it would be appropriate for the petitioner to proceed with such course of action of filing of an appeal to assail the order-in-original. Mr. Pathak states that such appeal would be filed within a period of four weeks from today.
In so far as the petitioner's bank account is concerned, it would be open for the petitioner to make an application before the appellate authority praying for appropriate orders in regard to the revoking of the provisional attachment, contending that the impugned order dated 27 June, 2023 provisionally attaching the petitioner’s bank account is illegal. If such an application is made, the same be decided as expeditiously as possible and preferably within a period of three weeks from the date of filing of the said application.
The petition stands disposed of
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2023 (12) TMI 422
Recovery of amounts of ITC stated to be illegally availed by the company - HELD THAT:- It would be appropriate that the respondents move an application before the NCLT to seek appropriate orders on the action as sought to be taken against the petitioner.
Status quo, as on today, be maintained for a period of one week from the day a copy of this order is available, only to enable the respondents department to approach the NCLT and to obtain appropriate orders.
Petition disposed off.
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2023 (12) TMI 421
Validity of SCN - levy 'tax on betting and gambling' - Valuation - Constitutional validity of Section 15(5) of the Central Goods and Services Tax Act, 2017 - Rule 31A(3) of the Central Goods and Services Tax Rules, 2017 - provisions of the CGST Act, the CGST Rules and Notifications thereunder along with corresponding provisions of the MGST Act, the MGST Rules and Notifications thereunder, to the extent they purport to levy 'tax on betting and gambling' in exercise of legislative power under Article 246A of the COI - restriction on Respondent No. 3 or its officers / sub-ordinates from taking any coercive action against the Petitioners - restricting the Respondent No. 4 and Respondent No. 5 from adjudicating the Impugned SCN pending final disposal of this writ petition.
HELD THAT:- This Court considering the challenge to the provisions of the Act and Rules has ‘admitted’ the petitions. Insofar as the show cause notice was concerned, the Court recorded a statement on behalf of the department that the petitioners in such case without prejudice to the rights and contentions as raised in the petitions, may file response to the impugned show cause notices, and that, the Adjudicating Officer would not pass any final orders on the show cause notice without leave of the Court. Such statement as made on behalf of the department came to be accepted by the Court. The petitioners were accordingly directed to respond to the show cause notice - Petitioner submits that similar order can be passed on the present proceedings.
Attention also drawn to the orders passed by the High Court of Sikkim in the case of Delta Corp Limited and Anr. vs. Union of India & ors. [2023 (10) TMI 1205 - SIKKIM HIGH COURT], where the Court had directed that a status-quo be maintained on the show cause notices - attention also drawn to an order passed by Division Bench of the Gujarat High Court in the case of NXGN Sports Interactive Private Limited vs. Union of India & ors [2023 (11) TMI 357 - GUJARAT HIGH COURT] wherein ad-interim relief was granted restraining revenue from taking any further steps on the adjudication of the show cause notice while permitting the petitioners to file a response to the show cause notice.
Issue notice to the Attorney General, returnable on 17th January, 2024, insofar as the challenge to the provisions of Section 15(5) of the CGST Act, 2017 being unconstitutional and violative of Articles 246A and 366(12) of the Constitution of India is prayed for - Let the pleadings of the proceedings be completed on or before the adjourned date of hearing.
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2023 (12) TMI 420
Seeking grant of bail - applicant has been arrested without assigning any reason to believe nor any satisfaction to justified his arrest as provided in the Code - HELD THAT:- The applicant has been arrested without assigning any reason to believe nor any satisfaction to justified his arrest as provided in the Act - Offences as alleged are punishable up-to 5 years imprisonment - No notice for recovery of G.S.T. has been issued against the applicant and he is illegally arrested.
It is a settled law that while granting bail, the court has to keep in mind the nature of accusation, the nature of the evidence in support thereof, the severity of the punishment which conviction will entail, the character of the accused, the circumstances which are peculiar to the accused, his role and involvement in the offence, his involvement in other cases and reasonable apprehension of the witnesses being tampered with.
Let applicant, Prateek Mittal be released on bail in the aforesaid case crime number on his furnishing a personal bond and two reliable sureties each in the like amount to the satisfaction of the court concerned subject to the conditions imposed - application allowed.
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2023 (12) TMI 419
Maintainability of appeal - appeal rejected as being defective for non-payment of the pre-deposit - whether by debiting ECRL, an assessee can claim to have satisfied the requirement of pre-deposit of a sum equal to 10 percent of the remaining amount of tax in dispute as per the order under appeal, for maintaining appeal as per Section 107 (6) of the CGST/BGST Act? - time limitation.
HELD THAT:- Plain reading of the statutory provision reveals that the option of filing appeal before the Appellate Authority is only within three months from the date on which the order is communicated to the person. Under Sub-Section 4 of Section 107 of the CGST/BGST Act, the Appellate Authority, subject to satisfaction that the appellant was prevented by sufficient cause from presenting appeal within three month period, is left with discretion to allow presentation of the same within a further period of one month. The statute thus circumscribes the maximum time frame within which, the person may avail remedy of appeal before the Appellate Authority.
Notification dated 26.12.2022 is concerned with Rule 108(3) of the CGST/BGST Rules regarding time limit for submission of certified copy of the decision or order appealed against, which is not the basis for holding the petitioner’s appeal being barred by delay. This court would thus find that submissions based on notification dated 26.12.2022 (supra) is not relevant to the instant case which involves period of limitation for filing the appeal.
In the instant case the issue is of filing of appeal being barred in view of limitation, specified and provided in Section 107 of the CGST/BGST Act, which provides for filing of appeal within three months. Section 107 (4) of the CGST/BGST Act also places a limit to the condonation of limitation. It specifically provides for allowing the appeal to be presented within a further period of one month only. In the instant case, it is not in dispute that even after allowing additional period of 30 days as per section 107 (4) of the CGST/BGST Act, the appeal has been filed belatedly. The appeals, therefore, were barred by limitation also.
The irresistible conclusions from simple reading of Section 49 of the Act, therefore, is that amount in ECRL cannot be utilized for the purposes of paying the pre-deposit (10 percent) under Section 107 (6) of the CGST/BGST Act as this amount is neither an output tax under the BGST/SGST Act, nor is this amount due under the Integrated Goods and Services Tax Act. This is further clarified from perusal of Sub-Sections (1) and (2) of Section 49 of the CGST/BGST Act. From plain reading of these two provisions, it is clear that actual deposits are made in the ECL through internet banking, credit or debit cards or any FD or RTGS settlement or by such other mode. The balance in ECRL, however, is a self-assessed input tax credit of the registered person. The amounts are credited on a provisional basis in the Electronic Credit Ledger, which is apparent from Section 41 of the BGST/SGST Act and are subject to an assessment proceedings to determine the amount of credit eligible for being utilized by the registered person.
This court is of the opinion that the appeals filed by the instant petitioners under Section 107 of the CGST/BGST Act were not maintainable as the pre-deposit (10 percent) as per Section 107 (6)(b) of the Act, was not complied with by the petitioners - conclusion of the Appellate Authority that payment of pre-deposit (10 percent) can only be made through ECL, requires no interference by this court exercising jurisdiction under Article 226 of the Constitution of India.
Petition dismissed.
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2023 (12) TMI 418
Seeking provisional release of the goods and the conveyance - HELD THAT:- By way of ad-interim relief, it is directed that the goods and conveyance of the petitioner shall be released provisionally, provided the petitioner complies with the conditions imposed.
This petition shall be listed with Special Civil Application No.5525 of 2023.
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2023 (12) TMI 363
Cancellation of petitioner’s GST registration - cancellation on the ground that the registration obtained by means of fraud, wilful misstatement or suppression of facts - HELD THAT:- The impugned SCN does not satisfy the rudimentary requirement of a show cause notice. In view of the above, the impugned order is void as having been passed in violation of the principles of natural justice. This is because the petitioner had no opportunity to respond to any allegation. The impugned order has been passed without affording the petitioner any opportunity to meet the allegations against it.
The impugned order is also not informed by reason as it does not set out any ground for cancelling the petitioner’s GST registration, save and except mentioning that it is pursuant to the impugned SCN. It is noted that there is a space for filling up the reasons, however, that space has been left blank.
The respondent is directed to forthwith restore the petitioner’s GST registration. It is clarified that this would not preclude the concerned authorities from initiating fresh proceedings albeit in accordance with the law - the impugned order as well as the impugned SCN are set aside - Petition disposed off.
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2023 (12) TMI 362
Correctness of decision making process adopted by the respondents - violation of principles of natural justice and statutory mandate ingrained in Sub Section 4 of Section 75 of the Goods and Services Tax (Act) - Requirement to provide opportunity of personal hearing - HELD THAT:- A plain reading of sub-section 4 of Section 75 of the Act makes it crystal clear that “opportunity of hearing” must be granted in two situations viz (a) where a request in specific is received in writing from the person chargeable; (b) where any adverse decision is contemplated against such person - This is trite that when language of statute is plain and unambiguous, it should be given effect to irrespective of its consequences.
In the instant case whether or not the petitioners have specifically asked for personal hearing, fact remains that the adverse decision was contemplated against the petitioners. In that event, it was obligatory and mandatory on the part of respondents to provide the petitioners opportunity of personal hearing. Admittedly, no opportunity of personal hearing has been provided in both the matters. Resultantly, the decision making process adopted by the respondents is vitiated and runs contrary to the principles of natural justice and statutory requirement of sub-section 4 of Section 75 of GST Act.
As a result, the impugned proceedings after the stage of reply of show cause notices, in both the cases are set-aside. The respondents shall provide opportunity of hearing to the petitioners - Petition disposed off.
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2023 (12) TMI 361
Refund of accumulated Input Tax Credit - inverted duty structure - denial on the ground that the rate of tax on input supply and output supply are the same - whether in the given facts refund of accumulated ITC is proscribed by virtue of Clause (ii) of the proviso to Section 54(3) of the CGST Act? - HELD THAT:- In terms of Section 54(1) of the CGST Act, any person claiming refund of tax and interest paid on such tax or any amount paid by him, is entitled to make an application for refund before expiry of two years from the relevant date, which is defined under Explanation (2) to Section 54 of the CGST Act. Sub-section (3) of Section 54 of the CGST Act provides that subject to provisions of Sub-section (10) of Section 54 of the CGST Act, a person may claim refund of unutilised ITC at the end of any tax period. However, the proviso to Sub-section (3) to Section 54 of the CGST Act restricts the entitlement to refund of unutilised ITC. It expressly provides that no refund of unutilised ITC would be allowed except in cases covered under Clauses (i) and (ii) of the proviso to Section 54(3) of the CGST Act. Under Clause (i) of the proviso to Section 54(3) of the CGST Act, refund of ITC is available in cases of zero rated supplies made without payment of tax. In terms of Clause (ii) of the proviso to Section 54(3) of the CGST Act, refund is admissible, where the credit is accumulated on account of rate of tax on inputs being higher than the rate of tax of output supplies.
The Supreme Court had considered the proviso to sub-section (3) to Section 54 in UNION OF INDIA & ORS. VERSUS VKC FOOTSTEPS INDIA PVT LTD. [2021 (9) TMI 626 - SUPREME COURT] had authoritatively held that the refund of unutilised ITC was confined to two categories as spelt out in Clauses (i) and (ii) of the proviso to Sub-section (3) of Section 54 of the CGST Act - petitioner’s claim for refund is founded on Clause (ii) of the proviso to Section 54(3) of the CGST Act. According to the petitioner, the rate of tax on certain inputs is higher than the tax paid on outputs (bottled LPG). Resultantly, the petitioner has been unable to fully utilise the ITC on its inputs.
It is also relevant to note that the Appellate Authority had, inter alia, found that the petitioner’s claim for refund would not be admissible by virtue of the Circular No. 135/05/2020 as in terms of the paragraph 3.2 of the said Circular refund of accumulated ITC was not available, where the input and output supplies were the same. It is implicit in the contentions advanced on behalf of the Revenue before us that, this ground stands virtually abandoned.
The concerned authority is directed to process the petitioner’s applications for refund along with applicable interest in accordance with law as expeditiously as possible and in any event, within a period of six weeks from date - Petition allowed.
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2023 (12) TMI 360
Imposition of GST - grant of lease/royalty by the petitioner - HELD THAT:- In the wake of preceding discussion, the impugned order dated 02.08.2023 shall remain stayed till the next date of listing.
Connect this matter with Writ Tax No.606 of 2023 (M/s Amorous Trading India Private Limited v. State of U.P. and 2 others).
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2023 (12) TMI 359
Maintainability of petition - availability of an efficacious alternative statutory remedy - writ petition against a show cause notice is maintainable or not - HELD THAT:- Various grounds have been raised while challenging the show cause notice, however, the fact remains that the Respondent No. 2 has only issued a show cause notice and the petitioner has been asked to explain within 30 days as to why GST cannot be imposed and recovered from the petitioner.
The Apex Court in the case of HINDUSTAN COCA COLA BEVERAGE (P) LTD. VERSUS UNION OF INDIA AND OTHERS [2014 (9) TMI 585 - SUPREME COURT] in which it is held that:- "when the statute provides for statutory appeal, the said remedy is to be availed by the litigating parties". In HAMEED KUNJU VERSUS NAZIM [2017 (7) TMI 1414 - SUPREME COURT], the Apex Court held that any petition under Article 227 of Constitution of India should be dismissed in limine where there is statutory provision of appeal. In another case ANSAL HOUSING AND CONSTRUCTION LTD. VERSUS STATE OF U.P. AND ORS. [2016 (3) TMI 1435 - SUPREME COURT] it is held that when there statutory appeal is provided, then the said remedy has to be availed.
In view of the aforesaid and also looking to the fact of availability of an efficacious alternative statutory remedy, it is not found proper to entertain this petition - The petition is dismissed on the ground of efficacious alternative statutory remedy.
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2023 (12) TMI 358
Actual owner of goods - Detention order - penalty imposed under section 129 (1) (b) of UPGST Act - HELD THAT:- The petitioner is to be treated as owner of the goods as the goods were detained along with proper e-invoice and e-way bill.
In view of the same, the release of the goods upon payment penalty is required to be made under section 129 (1) (a) of the Act. In the present case, the order passed by the Assistant Commissioner dated November 22, 2023 has quantified the penalty under section 129 (1) (b) of the Act and, accordingly, the same is bad in law.
The impugned order set aside - petition disposed off.
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2023 (12) TMI 357
Extension of time limit specified under Section 73 of the Act by virtue of the powers under Section 168A of the Act - case of petitioner is that having once extended the period by virtue of notification dated 05.07.2022, no subsequent extension could be made - HELD THAT:- Essentially, the notifications are of the Union of India and by virtue of such power the respondent No. 5 – State has issued a show-cause notice dated 29.09.2023.
Issue Notice to the respondents returnable on 30.11.2023.
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2023 (12) TMI 356
Violation of principles of natural justice - Form GST DRC-01 served on the petitioner contains only the summary - annexure to DRC-01 was not furnished to the petitioner to enable them to respond - opportunity granted was not real but illusory - HELD THAT:- This Court finds merit in the submission of the learned counsel for the petitioner inasmuch as the impugned order suffers from more than one infirmity. Firstly, DRC-01 is not supported by the Annexure to show cause notice and thus the petitioner was not provided with the particulars necessary to respond. Secondly, the assessment order is made on 17.03.2020. One fails to understand as to how the show cause notice as well as the assessment order has been made on the very same day. Thus, the impugned order is made without affording any opportunity. Assuming that the order is made on 19.03.2020, it is submitted that 48 hours notice is nevertheless inadequate to respond. This Court finds that the opportunity granted was not real but illusory, thereby vitiating the proceedings.
The impugned order is set-aside - Petition disposed off.
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2023 (12) TMI 355
Maintainability of petition - no second appellate forum - petitioner has already deposited 10% of the demanded tax amount before the first appellate authority - HELD THAT:- Since the petitioner wants to avail the remedy under the provisions of law by approaching 2nd appellate tribunal, which has not yet been constituted, as an interim measure subject to the Petitioner depositing entire tax demand within a period of fifteen days from today, the rest of the demand shall remain stayed during the pendency of the writ petition.
Application disposed off.
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2023 (12) TMI 354
Cancellation of registration of petitioner - no service of SCN - petitioner could not file reply - self-contradictory impugned order - HELD THAT:- It would be just and proper to remand the matter back to respondent No. 5 to re-do the exercise after giving an opportunity of hearing to the petitioner.
Matter remanded back to the file of the respondent No. 5. Since petitioner is now in receipt of a copy of the cancellation order including show cause notice dated 11-8-2022 which has been placed on record, it would be open to the petitioner to submit its reply to the show cause notice. If the petitioner submits its reply within seven days from today, the same shall be taken on board by respondent No. 5 who shall thereafter pass appropriate order in accordance with law after giving due opportunity of hearing to the petitioner.
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2023 (12) TMI 293
Refund of amount deposited by the petitioner during the course of search and inspection - petitioner claims that it was coerced to deposit the aforesaid amount and that the same cannot be considered as a deposit done voluntarily under Section 74(5) of the Central Goods & Services Tax Act, 2017 - HELD THAT:- A plain reading of the show cause notices would indicate that the same are premised on the mismatch of the ITC in terms of form GSTR-3B and form GSTR-2A. It is also material to note that although, the show cause notices indicate that the petitioner had deposited the tax and penalty on 29.07.2022, the quantum of proposed demand did not provide for any credit for the same. It is apparent that such show cause notices are in terms of Section 74(7) of the CGST Act inasmuch as they are not limited to the amount which falls short of the amount payable after accounting for the tax deposited - the respondents have neither acknowledged the amounts deposited by the taxpayer on 29.07.2022 nor have they granted the benefit of the said deposit, while issuing the proposed demand under Section 74(7) of the CGST Act.
In Vallabh Textiles v. Senior Intelligence Officer & Ors. [2022 (12) TMI 1038 - DELHI HIGH COURT] a Coordinate Bench of this Court had observed that not following the stipulated procedure would also lead to the conclusion that the payments were not voluntary.
Whilst the petitioner has accepted that there was a mismatch in its return regarding the ITC, he did not acknowledge that the ITC was incorrectly availed. On the contrary, the Director of the petitioner had acknowledged that in case there was any tax liability, the same would be paid with interest and penalty. Admittedly, the respondents have not ascertained the said liability and no notice has been issued to the petitioner as contemplated under Rule 142 (1A) of the CGST Rules communicating the details of any tax, interest or liability as ascertained - the petitioner’s contention is accepted that the payments made by it were not voluntary payments but under compelling circumstances.
The respondents are directed to refund the amount deposited by the petitioner by making a payment of ₹23,70,000/- in cash along with interest at the rate of 6% per annum from 13.12.2022 till the date of payment - the present petition is allowed.
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2023 (12) TMI 292
Search and seizure - reasons to believe - Whether the inspection carried out by the respondent authorities is illegal for want of reasons to believe that the conditions as set out in Section 67(1)(a) of the CGST Act are satisfied? - HELD THAT:- The interpretation of the expression ‘reasons to believe’ in Calcutta Discount Co. Ltd. v. Income Tax Officer, Companies District I Calcutta & Anr. [1960 (11) TMI 8 - SUPREME COURT] is instructive in interpreting the said expression as used in Section 67 of the CGST Act as well.
The sufficiency of the reasons is not amenable to judicial review. So long as there is material or information, which supplies a rational basis for forming a belief that the conditions as stipulated under Section 67(1) of the CGST Act are satisfied, the search or inspection authorized under the said section cannot be faulted.
In the present case, the information that the petitioner had purchased the goods from a supplier, which was found to be nonexistent at his principal place of business, has a direct link in forming the belief that the petitioner wrongfully availed of the ITC - there are no ground to declare any search or inspection conducted on 12.11.2022 as illegal or vitiated on the ground that there was no reason to believe that the petitioner had wrongfully availed the ITC.
Thus, there are no merit in the petitioner’s contention that the inspection conducted by the central officers were illegal. The provisions of Section 6(2)(b) of the CGST Act do not preclude the central officers from conducting an inspection for concluding an ongoing investigation merely because a prior inspection or search was conducted by the DGST authorities - the respondents are directed to refund the sum of ₹10,00,000/- deposited by the petitioner in FORM GST DRC-03 on 12.11.2022.
Petition disposed off.
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2023 (12) TMI 291
Validity of reversal of Input Tax Credit (ITC) during investigation / search proceedings - Validity of search / inspection conducted at business premises - Allegation of availment of inadmissible ITC and shortage of cash - whether the inspection conducted by the Delhi GST Authorities was illegal for want of proper authorization? - HELD THAT:- If the tax is not paid on self-ascertainment basis, the assessee cannot be extended the benefit of Section 73(6) of the DGST Act or Section 74(6) of the DGST Act. In the present case, the petitioner has stoutly disputed that the reversal of ITC was voluntary. In cases where the payment made during search is not voluntary, the taxpayer is required to be refunded the said deposit while reserving the right of the GST authorities to proceed against the said taxpayer to the full extent in accordance with law - It is also material to note that the respondents have not issued an acknowledgment in FORM GST DRC-04. Thus, the procedure under Rule 142 of Delhi Goods & Services Tax Rules, 2017 (the DGST Rules) has not been followed.
In the present case, the petitioner has stoutly disputed that the reversal of ITC was voluntary. Undisputedly, the same has been made while the petitioner’s premises were being searched and he was being subjected to questioning / enquiries - it is not difficult to accept that the petitioner may have found the circumstances intimidating and had, accordingly, agreed to reverse the ITC.
The respondents are directed to reverse the ITC amounting to ₹22,14,226/- in the petitioner’s ECL - petition disposed off.
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2023 (12) TMI 290
Condonation of delay in filing appeal before the appellate authority - applicability of provisions of section 5 of the Limitation Act, 1963 are attracted to the appeal filing period of limitation prescribed under Section 107 of the Act of 2017 or not - HELD THAT:- Parties have agreed that, Appellate Tribunal contemplated under Section 109 of the Act of 2017 has not been established so far as the State of West Bengal is concerned, as on date. The statutory remedy of approaching the Tribunal against the order of the Appellant Authority impugned in the writ petition is therefore not available to the appellant.
In Assistant Commissioner (CT) LTU. Kakinada [2020 (5) TMI 149 - SUPREME COURT], the Supreme Court has considered the issue as to whether the High Court in exercise of its writ jurisdiction ought to entertain a challenge to an assessment order on the sole ground that the statutory remedy appeal against that order stood foreclosed by the law of limitation or not. It has answered such issue in the negative against the writ petitioner and in favour of the revenue. It had observed that, where the writ petitioner has statutory alternative remedy available and did not avail of such remedy within the statutory period of limitation prescribed the writ courts should exercise self-restrain and not entertain a writ petition at the behest of such writ petitioner.
A Constitution Bench of the Supreme Court has, in New India Assurance Company Ltd [2020 (3) TMI 1368 - SUPREME COURT] held that, the period of limitation for filing reply/response to the complaint, under the provisions of Section 13 of the Consumer Protection Act, 1986 cannot be extended beyond the prescribed period of 30 days along with a discretionary extension of 15 days aggregating to 45 days from the date of receipt of the copy of the complaint.
Section 107 of the Act of 2017 does not exclude the applicability of the Act of 1963 expressly. It does not exclude the applicability of the Act of 1963 impliedly also if one has to consider the provisions of Section 108 of the Act of 2017 which provides for a power of revision to the designated authority, against an order of adjudication. In case of revision a far more enlarged period of time for the Revisional Authority to intervene has been prescribed. Two periods of limitations have been prescribed for two different authorities namely, the Appellate Authority and the Revisional Authority in respect of the same order of adjudication - Section 107 does not have a non-obstante clause rendering Section 29(2) of the Act of 1963 nonapplicable. In absence of specific exclusion of the Section 5 of the Act of 1963 it would be improper to read an implied exclusion thereof. Moreover, Section 107 in its entirety has not expressly stated that, Section 5 of the Act of 1963 stands excluded.
Since provisions of Section 5 of the Act of 1963 have not been expressly or impliedly excluded by Section 107 of the Act of 2017 by virtue of Section 29 (2) of the Act of 1963, Section 5 of the Act of 1963 stands attracted. The prescribed period of 30 days from the date of communication of the adjudication order and the discretionary period of 30 days thereafter, aggregating to 60 days is not final and that, in given facts and circumstances of a case, the period for filling the appeal can be extended by the Appellate Authority.
The issue that has been framed is answered in the affirmative, in favour of the appellant and against the revenue.
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