Annual Tax and Corporate Law Digest 2025: High Court Cases [Part XXVI]

M/s Educomp SolutionsLimited vsState of Chhattisgarh CITATION : 2025 TAXSCAN (HC) 1528

The Chhattisgarh High Court dismissed the petition that challenged the invocation of encashing a Bank guarantee during the period of moratorium under Section 14 of the Insolvency and Bankruptcy Code (IBC), 2016. The dismissal was on finding pending active arbitration proceedings before the competent forum.

A division bench of Shri Ramesh Sinha, Chief Justice and Justice Shri Bibhu Datta Guru observed that taking into consideration the fact that fresh arbitration proceedings have already been initiated in pursuance to the order dated 05.03.2025 passed by the Co-ordinate Bench of this Court in ARBA No.67/2021 and the said arbitration proceedings are currently pending and are under active consideration before the competent Arbitral forum, no fruitful purpose would be served in continuing with the present petition. The court dismissed the petition.

ANOOP ALIAS ANUP vsSTATE OFHARYANA CITATION : 2025 TAXSCAN (HC) 1529

In a recent ruling, the Punjab and Haryana High Court granted bail to a man accused of being involved in a Rs. 1.33 crore online scam by posing as officials from the Customs Department and the CBI.

The single-judge bench comprising Justice Anoop Chitkara observed that although the petitioner was not named in the FIR, there was evidence linking him to the case. The court also observed that pre-trial custody should not be treated like punishment. Considering the 6 months he already spent in custody, the seriousness of the charge, and other facts, the court granted bail.

MOHAMMADSHAHIDvsTHECOMMISSIONEROFCUSTOMS&ORS CITATION : 2025 TAXSCAN (HC) 1530

In a recent ruling, the Delhi High Court refused to allow the immediate release of gold items seized from a passenger at IGI Airport, raising serious concern over an alleged attempt to disguise gold coins as silver.

The court directed the petitioner to appear before the Customs Department on 31 July 2025 for the appraisal process. It allowed the Customs Department to pass an order imposing applicable customs duties as per law. The court also directed the petitioner to pay warehousing charges from the date of detention of the goods.

ALISHER OCHILOV vsCOMMISSIONEROF CUSTOMS CITATION : 2025 TAXSCAN (HC) 1531

In a recent decision, the Delhi High Court directed the Customs Department to release two gold chains belonging to an Uzbek national after finding that the department had not issued a show cause notice even after detaining the goods for over a year.

The division bench comprising Justice Prathiba M. Singh and Justice Rajneesh Kumar Gupta observed that the gold jewellery appeared to be used as personal items. The court also referred to past decisions from the Supreme Court and the Delhi High Court, which held that used personal jewellery worn by a passenger falls under the definition of “personal effects” and should not be detained under the Baggage Rules, 2016.

LAXMI CHAUHAN vsCOMMISSIONER OFCUSTOMS AIRPORT AND GENERAL & ANR CITATION : 2025 TAXSCAN (HC) 1532

In a recent ruling, the Delhi High Court held that a pre-filled waiver of the right to a show cause notice is not legally valid and cannot be used by the Customs Department to bypass the procedure required under law. The Court ordered the release of seized jewellery upon payment, despite an earlier confiscation order by Customs authorities.

The division bench comprising Justice Prathiba M. Singh and Justice Rajneesh Kumar Gupta observed that a waiver of the right to a show cause notice cannot be enforced if it is based on a pre-filled form and not a properly explained or voluntary choice.

MANISH PACKAGINGPRIVATE LIMITEDvs THE STATE OF MADHYA PRADESH CITATION : 2025 TAXSCAN (HC) 1533

The High Court of Madhya Pradesh, upheld the levy of ₹3.58 lakh Integrated Goods and Services Tax ( IGST ) and an equal penalty on goods worth ₹19.18 lakh, after finding that the assessee transported PVC film over 2001 km without completing Part B of the E-Way bill.

Justice Vivek Rusia and Justice Binod Kumar Dwivedi examined Section 129 of the Madhya Pradesh Goods and Services Tax Act, 2017, which dealt with detention and seizure of goods transported in violation of the Act or its rules. It noted that the section allowed release of goods on payment of tax and penalty or on furnishing security and further provided for proceedings under Section 130 if payment was not made within seven days.

JAG MOHAN GARG vs MR.RAHULJINDAL RESOLUTION PROFESSIONAL CITATION : 2025 TAXSCAN (HC) 1534

The High Court of Delhi, permits Resolution Professional (RP ) to convene 39th CoC meeting despite the petitioner’s objection citing a pending National Company Law Tribunal (NCLT) application, but directed that all decisions taken in the meeting would remain subject to the tribunal’s final decision.

Justice Manmeet Pritam Singh Arora heard both sides and allowed the respondent to go ahead with the 24.06.2025 meeting, stating that any decisions made would depend on the outcome of I.A. No. 2863/2025 before the NCLT.

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SHIPRA ESTATE LIMITEDvsINDIABULLS HOUSING FINANCE LTD. CITATION : 2025 TAXSCAN (HC) 1535

The Delhi High Court observed that an application for extension of the time period for passing an arbitral award under Section 29A(4) read with Section 29A(5) is maintainable even after the expiry of the twelve-month or the extended six-month period.

The Court does not find any impediment in the mandate of the Arbitrator being extended.It is stated that the mandate of the Arbitrator came to an end on 03.09.2023 and since then, the matter has been hanging in the Court only on the ground that an Order has been passed by the NCLAT stating that further steps will not be taken in pursuance of the impugned order.

M/s. Bikash Panigrahivs TheCommissioner Commercial Tax CITATION : 2025 TAXSCAN (HC) 1536

The Orissa High Court has held that writ petition is not maintainable being filed beyond the condonable period provided under Section 107 of the GST Act.

A bench of Chief Justice Harish Tandon and Justice Mr. Murahari Sri Raman observed that if notice/order is uploaded on common GST portal, the same shall be considered as service on the assessee (petitioner) in view of unambiguous provisions contained in Section 169 of the GST Act and the writ petition is not maintainable being filed beyond the condonable period provided under Section 107 of the GST Act.

Brijsons Hotel PrivateLimitedvs Union of India CITATION : 2025 TAXSCAN (HC) 1537

The Calcutta High Court has held that the registrar is not in a position to take a decision When removal of Director is pending consideration before the National company Law Tribunal ( NCLT ). The provision of Rule 11 of the Rules, 2014 requires the Registrar to verify the documents and find out as to whether the Company has violated any of the provisions of the Act and the Rules which relates to vacation or removal of Directors before approving or invalidating Form No. DIR-12.

A single bench of Justice Amrita Sinha disposed of the petition by directing the Registrar of Companies to take a decision in respect of the application made by the petitioners in terms of Rule 11 of the Rules, 2014 at the earliest, but positively within a period of four weeks.

M/S Tehri Iron AndSteel CastingLimited And 2 vs State Of U.P CITATION : 2025 TAXSCAN (HC) 1538

In a recent case, the Allahabad High Court quashed the passed under section 28(2) (ii) of the U.P. VAT Act 2008 and under section 9(4) of the U.P. Tax on Entry of Goods Act 2007 demanding tax, holding that once the Resolution Plan has been approved by the NCLT, the Commercial Tax Department cannot create further dues.

In view of the above law laid down by the Supreme Court, the division bench of Justice Shekhar B. Saraf and Justice Praveen Kumar Giri viewed that the principle is crystal clear that once the Resolution Plan has been approved by the NCLT, all other creditors are barred from raising their claims subsequently, as the same would disrupt the entire resolution process.

ZILLION INFRAPROJECTSPRIVATELIMITED vs TENOVA TECHNOLOGIES PRIVATE LIMITED CITATION : 2025 TAXSCAN (HC) 1539

The Karnataka High Court dismissed the plaint in terms of proceedings pending before National Company Law Tribunal (NCLT), since that was objected to by the petitioner and the matter being at the stage of arguments, the court disposed of the petition, reserving liberty to the respondent-plaintiff to urge all the contentions that he is wanting to draw into as additional written statement before the concerned Court.

A single bench of Justice M.Nagaprasanna observed that such arguments are advanced by the plaintiff before the concerned Court taking cue from the plaint that is filed or the additional written statement that is sought to be preferred before the concerned Court. The concerned court shall answer the same in accordance with law and take the suit to its logical conclusion.

Madhur Gulati vs Stateof U.P.and Another CITATION : 2025 TAXSCAN (HC) 1540

The Allahabad high court held that protection of Insolvency Bankruptcy Code (IBC), 2016 is only applicable to corporate debtors and not to persons who draw cheques in Individual capacity. The court allowed the applicants to raise all contentions, legal or factual, before the court below while contesting the proceedings.

A single bench of Justice Vikas Budhwar is not entering into the merits of the summoning order while leaving it open for the applicants to raise all contentions, legal or factual, before the court below while contesting the proceedings and the Court has no reason to disbelieve that the same shall be considered in correct perspective.

TATA PLAY LTD vs SALESTAXOFFICER CLASS II CITATION : 2025 TAXSCAN (HC) 1541

In a recent ruling, the Delhi High Court held that under the GST Act, allowing three adjournments during adjudication proceedings is permissible, but not mandatory.

The court found that Tata Play had been given sufficient opportunity and that no violation of natural justice had occurred. The court dismissed the writ petition. However, it did allow Tata Play to file a statutory appeal under Section 107 of the CGST Act by 31.08.2025, directing that the appeal be decided on its merits.

M/s. HM Leisure vsAssistantCommissioner of CGST CITATION : 2025 TAXSCAN (HC) 1542

In a recent decision, the Bombay High Court quashed a GST order after finding that the tax officer had proceeded with adjudication even though the same matter was already under consideration by the Directorate General of GST Intelligence (DGGI) and stayed by the Karnataka High Court.

The bench comprising Justices Bharati Dangre and Nivedita P. Mehta observed that if two different authorities initiate proceedings on the same matter and assessment period, it creates confusion, legal uncertainty, and hardship to the assessee.

Commissioner StateTaxes vs M/sReliance Jio Infocomm Limited CITATION : 2025 TAXSCAN (HC) 1543

In a recent ruling, the Jammu & Kashmir and Ladakh High Court held that no penalty can be imposed under the Entry Tax Act solely for bypassing a check post, in the absence of any allegation of fake or false documents.

The division bench comprising Justice Tashi Rabstan and Justice Moksha Khajuria Kazmi observed that Section 4(3) of the Entry Tax Act allows for a penalty only when fake or false documents are found. There was no such allegation or finding, so the court held that the imposition of a penalty had no legal backing.

Tvl. Vairam AgenciesVodafoneCell vs The State Tax Officer CITATION : 2025 TAXSCAN (HC) 1544

The Madurai Bench of the Madras High Court has refused to interfere with a GST ( Goods and Services Tax ) assessment order issued under Section 74 of the GST Act, 2017, as the manager continued business despite the demise of the proprietor.

Justice C. Saravanan, presiding over the matter, rejected both contentions. It was noted that notwithstanding the death of the proprietor, the business had continued to operate. Inward supplies from Vodafone were recorded till 31.03.2018, amounting to ₹3.45 crores, leading to a deemed outward supply value of ₹3.79 crores under Rule 30 of the CGST Rules, 2017. The resultant GST liability was calculated to be ₹68,38,728 (CGST and SGST of ₹34,19,364 each) at an 18% tax rate.

Tvl.Dimora vs TheAssistantCommissioner (State Tax) CITATION : 2025 TAXSCAN (HC) 1545

In a recent ruling, the Madurai Bench of the Madras High Court has held that service of GST notices through the common portal alone is not valid when the taxpayer’s registration stands cancelled and the portal becomes inaccessible.

The Bench observed that “When the assessee could not even access the portal, we have to conclude that there was no notice of service on the assessee. In this view of the matter, we hold that the orders impugned in the writ petitions were vitiated on account of breach of principles of natural justice.”

M/s.LRS and Co vs TheState TaxOfficer CITATION : 2025 TAXSCAN (HC) 1546

In a recent ruling, the Madurai Bench of the Madras High Court quashed a GST demand issued in Form DRC-01D against a government contractor, after it was established that the entire admitted tax liability along with interest had already been paid.

Justice C. Saravanan thus quashed the impugned order and directed the jurisdictional officer to pass suitable appropriation orders, acknowledging the payments made and ordering refund of any excess amount, if applicable.

M/S Rai Wines Ras BaharColonyvs The Commisssioner Of Income Tax CITATION : 2025 TAXSCAN (HC) 1547

The Allahabad High Court has held that when a best assessment is done, it is for the assessee to bring on record the facts that may reveal that the findings are perverse in nature.

The court viewed that when a best assessment is done, it is for the assessee to bring on record the facts that may reveal that the findings are perverse in nature. The bench of Justice Shekhar B. Saraf and Justice Praveen Kumar Giri held that in absence of material brought on record to convince us to dislodge the decision of the CIT (Appeals) and the Tribunal, dismissed the appeal.

M/s. Savitri Industriesvs ChiefCommissioner of CT & GST CITATION : 2025 TAXSCAN (HC) 1548

In a recent case, the Orissa High Court dismissed the petition on the availability of an alternative remedy in the petition challenging Goods and Services Tax (GST) demand out of the disallowance of the Input Tax Credit (ITC).

A division bench of Chief Justice Mr. Harish Tandon and Justice Mr. Murahari Sri Raman considered that the appellate authority is the competent authority to deal with the facts as well as the law. The issues raised in the present case can very well be addressed in appeal under Section 107 of the GST Act. If need be other alternative fora are also put in place to question the appellate order after disposal of appeal.

JAJU BABU vs NATIONALCOMPANYLAW TRIBUNAL KOCHI CITATION : 2025 TAXSCAN (HC) 1549

The Kerala High Court allowed the writ petition was filed seeking the quashing of an order passed by the National Company Law Tribunal (NCLT), Kochi Bench which was violative of natural justice principle.

The single bench of Justice T.R. Ravi set aside the order and dircetd the 1st respondent to pass fresh orders, after hearing the petitioner on the contents of the affidavit filed by the 2nd respondent, after the matter was taken for orders earlier.

DipakkumarDharamsinhbhaiKakadiya vs Directorate of Revenue Intelligence Mumbai Zonal Unit CITATION : 2025 TAXSCAN (HC) 1550

In a recent case, the Bombay High Court allowed anticipatory Bail in case of Rs 44 Cr of customs duty evasion involving undervalued walnut imports. The applicants have demonstrated their willingness to pursue the statutory remedy of compounding the alleged offence.

A single bench of Justice R.N. Laddha considering the applicants’ willingness to comply with compounding provisions, the stage of the investigation, absence of prior criminal record, the documentary nature of the evidence, the willingness on the part of the applicants to jointly deposit a total amount of Rs.5 Crores with the respondent allowed the application subject to the conditions.

SANDEEP MAHAJAN vsMAHINDRA ANDMAHINDRA FINANCIAL SERVICES CITATION : 2025 TAXSCAN (HC) 1551

The Delhi High Court has held that any award passed by an arbitrator unilaterally appointed is invalid and set aside the Arbitral Award passed on the liquidated company.

The Supreme Court in Perkins Eastman has categorically held that any award passed by an arbitrator unilaterally appointed by an interested party is vitiated. Therefore, in view of the settled legal position and to uphold the sanctity of the arbitral process, the single bench of Justice Jasmeet Singh set aside the arbitral award.

PUNEETBATRA vsUNIONOFINDIA CITATION : 2025 TAXSCAN (HC) 1552

The GST Department was warned by the Delhi High Court for harassing a tax lawyer by raiding his offices in relation to a client's alleged GST evasion. It turned out that the lawyer was only submitting the client's tax case.

A division bench of Justices Prathiba M. Singh and Shail Jain observed that “The Advocate cannot be subjected to harassment in this manner unless and until there is some material for the GST Department to show that the advocate himself is not merely representing his client but is also personally involved in the alleged illegality. For the said purpose, some prima facie material would have to be shown by the GST Department.”

TRIGO IMAGEMENTSLOVAKIA vsMADHUSUDAN AUTO LIMITED CITATION : 2025 TAXSCAN (HC) 1553

The Delhi High Court transferred the Winding-up Petition filed after Appointment of a liquidator to the National Company Law Tribunal (NCLT). Trigo Imagement Slovakia, the petitioner filed the petition under Section 433(1)(e) of the Companies Act, 1956 for winding up of the Respondent Company.

A single bench of Justice Tara Vitasta Ganju transferred the petition to the National Company Law Tribunal. The Petitioner is at liberty to take appropriate steps in accordance with law for further proceedings before the National Company Law Tribunal.

SUMAN SRIVASTAVA vsUNION BANKOF INDIA & ORS CITATION : 2025 TAXSCAN (HC) 1554

In a recent case, the Delhi High Court has held that liability of deceased guarantor to repay debt shall fall upon legal heirs who were party to the Debt Recovery Tribunal (DRT) proceedings and dismissed the petition against the Debt Recovery Appellate Tribunal (“DRAT”) order.

A division bench of Justice Subramonium Prasad and Justice Harish Vaidyanathan Shankar observed that the Petitioner has not filed the present Writ Petition with clean hands as there is clear evidence against the pleas taken by her. In light of such concealment of facts, the Court dismissed the petition and refused to interfere with the proceedings before DRT.

Ravi Singh Bhatia vsThePrinciple Commissioner of Income Tax CITATION : 2025 TAXSCAN (HC) 1555

In a recent ruling, the Jharkhand High Court held that a taxpayer’s reply submitted on the last permitted date must be considered by the Income Tax Department, and that deadlines should be counted by the calendar date, not by the exact time of day.

The Division Bench comprising Chief Justice Tarlok Singh Chauhan and Justice Sujit Narayan Prasad stated that if the department had acknowledged the first letter sent on 18 March 2024, there was no reason for it to ignore the detailed reply sent on the same day. The court remarked that “time is to be calculated not by the clock but by the calendar,” and that since the reply was filed on 18 March 2024, it was clearly within time.

Gurdit Dang vs State ofOdisha CITATION : 2025 TAXSCAN (HC) 1556

In a recent ruling, the Orissa High Court has granted bail to an accused in a high-profile Input Tax Credit ( ITC ) fraud case under the Odisha Goods and Services Tax ( OGST ) Act, 2017. The Court, while granting relief, stated that the critical stage of investigation where the possibility of tampering with evidence or influencing witnesses exists appeared to have concluded.

The bench, noting that the accused was a permanent resident of Rourkela and that extensive searches and document seizures had already taken place, the Court concluded that bail could be considered with strict conditions to ensure fairness.

Gurbax Lal vs State ofPunjaband another CITATION : 2025 TAXSCAN (HC) 1557

The Punjab and Haryana High Court has denied anticipatory bail to the accused involved in Rs. 425 crore GST fake billing case stating the necessity of custodial interrogation to unearth the full extent of the fraudulent network and modus operandi.

The Court, presided over by Justice Arvind Singh Sangwan, dismissed the twin bail applications moved by the petitioner, noting that his involvement appeared substantial and sophisticated, with wide-reaching financial and operational implications.

M/S Sai Steel vs TheState ofBihar CITATION : 2025 TAXSCAN (HC) 1558

The High Court of Patna, limitation period for claiming a Goods and Service Tax ( GST ) refund in cases of wrong tax deposit begins from the date the correct Integrated Goods and Service Tax (IGST ) is paid, not from the date the original Central Goods and Service Tax / State Goods and Service Tax ( CGST/SGST ) was paid.

Justice Rajeev Ranjan Prasad and Justice Shailendra Singh heard arguments from both the parties and observed that the Joint Commissioner of State Taxes, in the impugned order, acknowledged multiple times that the amount paid as SGST and CGST was eligible for refund. However, the refund application was ultimately rejected, citing Section 54 of the BGST Act, 2017, and stating it was barred by limitation.

HIMANGSHU KUMAR RAY vsSTATE OFWEST BENGAL CITATION : 2025 TAXSCAN (HC) 1559

In a recent ruling, the Calcutta High Court held that the GST Department cannot issue multiple notices to advocates seeking client information in connection with GST fraud investigations. The court explained that such actions violate the principle of advocate-client privilege as protected under Section 126 of the Indian Evidence Act.

The bench comprising Chief Justice T. S. Sivagnanam and Justice Hiranmay Bhattacharyya observed that the notices had been issued in a standardized format without any specific reference to individual cases or allegations.

Roshan Sharma vsDeputyCommissioner of Revenue CITATION : 2025 TAXSCAN (HC) 1560

The Calcutta High Court dismissed a writ petition seeking to challenge a GST officer’s order blocking his input tax credit (ITC) on the ground of alleged “fake” invoices.

The single bench of Justice Raja Basu Chowdhury held that the petitioner had failed to exhaust his statutory remedy of appeal before approaching the court, and that the High Court could not re-evaluate the merits of the tax officer’s findings.

MAHESHDAN PRABHUDANLANGA vsSTATE OF GUJARAT CITATION : 2025 TAXSCAN (HC) 1561

The Gujarat High Court dismissed the bail application of a senior journalist associated with The Hindu, who is accused of serious offences under the Prevention of Money Laundering Act, 2002 ( PMLA ).

Justice M.R. Mengdey, while refusing bail, observed that the applicant’s conduct raised grave concerns regarding tampering of evidence and influencing witnesses, thereby causing potential prejudice to the ongoing investigation.

M/S Satguru CattleFeeds vsState of Bihar CITATION : 2025 TAXSCAN (HC) 1562

The Patna High Court quashed the GST ( Goods and Services Tax ) order issued without granting a personal hearing to the taxpayer after submission of a reply to the show cause notice.

The Division Bench comprising Justice Rajeev Ranjan Prasad and Justice Shailendra Singh ruled that the denial of post-reply hearing violated the mandatory requirements under Section 75(4) of the CGST/BGST Act, 2017.

INDERPAL SINGH vsCOMMISSIONEROF CUSTOMS CITATION : 2025 TAXSCAN (HC) 1563

The Delhi High Court allowed to file an appeal which was time elapsed against a customs confiscation order stating the denial of personal hearing and non-service of SCN to the petitioner.

The bench directed to release the gold chain subject to payment of Rs. 45,000/-. Further, although the statutory period for filing an appeal had lapsed, the Court, in the interest of justice, permitted the petitioner to file an appeal before the Appellate Authority within 30 days.

CAPRI GLOBAL HOUSINGFINANCE LTDvs THE STATE OF MADHYA PRADESH CITATION : 2025 TAXSCAN (HC) 1564

The Madhya Pradesh High Court directed the District Magistrate (DM) to re execute the dispossession of the mortgaged property on finding illegal reentry of the borrower to the dispossessed property under section 14 of Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002(SARFAESI).

A division bench comprising Justice Anand Pathak and Justice Hirdesh observed that since the Securitization Act itself provides mechanism for recovery of loan amount, therefore, in the attending facts and circumstances of the case, no effective legal remedy is available to the petitioner.

Sanjay Singhal vs StateofHaryana CITATION : 2025 TAXSCAN (HC) 1565

The High Court of Punjab and Haryana granted bail based on conditions prescribed against the offence of Rs 7 crore transaction by misusing the PAN card of another person. The case arose out of a complaint registered in a police station about a fake firm named SBJ Enterprises.

A single bench of Justice Sumeet Goel viewed that further detention of the petitioner as an undertrial is not warranted in the facts and circumstances of the case. The petitioner is ordered to be released on regular bail on his furnishing bail/surety bonds to the satisfaction of the concerned CJM/Duty Magistrate.

M/s.Azam LaminatorsPrivateLimited vs Additional Director CITATION : 2025 TAXSCAN (HC) 1566

The Madras High Court, while upholding the applicability of 5% GST ( Goods and Services Tax ) on “Nizam Pakku,” quashed show cause notice sought to reclassify the product under a higher tax bracket without considering the decisions rendered by the Supreme Court, CESTAT and AAAR on the classification.

The Madras High Court quashed the impugned show cause notice and allowed the writ petition, reiterating that “Nizam Pakku” falls under Chapter 0802 of the CTA and is liable to GST at 5%.

Bharat AluminiumCompany Limitedvs State of Chhattisgarh CITATION : 2025 TAXSCAN (HC) 1567

In a recent case, the Chhattisgarh High Court held that Bharat Aluminium Company Limited( BACL ), the petitioner is not entitled to ITC on electricity consumed for township maintenance, as such consumption is not in the course or furtherance of business under Section 16(1) of the CGST Act. The court observed that the benefit of amendment in shape of Explanation 1(d) to Rule 43 of the CGST Rules would be available only for the period after 5-7-2022.

A single bench of Justice Sanjay K. Agrawal found that the appellate authority adjudicated the appeal preferred under Section 107 of the Chhattisgarh Goods and Services Tax Act, 2017 on 17-9-2020 and thereafter, the notification dated 5-7-2022 inserting Explanation 1(d) to Rule 43 of the CGST Rules came into force with effect from 5th July, 2022 on the recommendation made by the GST Council.