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

The Delhi High Court has granted bail to three accused in a ₹641 crore money laundering and cyber fraud scam, overriding the stringent twin conditions prescribed under Section 45 of the Prevention of Money Laundering Act (PMLA), 2002. The Court observed that prolonged incarceration and undue delay in trial completion take precedence over statutory restrictions on bail. The accused, including Vipin Yadav, Ajay, and Rakesh Karwa, were implicated in a scam involving fake job offers, bogus investment schemes, and mule accounts, with funds routed internationally including cryptocurrency transactions.

The Bench of Justice Amit Mahajan emphasized that the constitutional right to life and liberty under Article 21 must override the procedural constraints of the PMLA when trial delays are significant. The investigation remains ongoing with over a thousand documents and numerous witnesses, making swift trial completion unlikely. The Court granted bail with strict conditions while reprimanding the Enforcement Directorate’s arbitrary arrest strategy, underscoring the need for fair and balanced judicial process in serious economic offences.

The Gujarat High Court observed that the "specified date" for furnishing a tax audit report under Section 44AB of the Income Tax Act, 1961 and the "due date" for filing the income tax return under Section 139(1) are inherently linked and must be treated together. The court questioned the Central Board of Direct Taxes (CBDT) for extending the audit report deadline from 30 September 2025 to 31 October 2025 without similarly extending the corresponding due date for filing returns, which remained on 31 October 2025.

The Division Bench of Justice Bhargav D. Karia and Justice Pranav Trivedi emphasized that the CBDT cannot unilaterally extend the audit report deadline without extending the return filing due date under its statutory powers. The court issued notice to the CBDT and the Union of India seeking an explanation for this discrepancy and scheduled further hearings, highlighting the need for administrative coherence and legislative compliance in setting these deadlines. This matter is slated for priority listing and continued scrutiny, underscoring the importance of aligned timelines for tax compliance.

The Andhra Pradesh High Court addressed the legality of Goods and Service Tax (GST) audit and assessment proceedings brought against Sakthi Ferro Alloys India Pvt. Ltd. The Court examined issues under Section 65 of the Andhra Pradesh GST Act, 2017 and Section 74 of the GST Act, 2017, which deals with the levy of penalties in cases of fraud or willful suppression. The High Court found that the audit for financial years 2017-18 to 2020-21 had exceeded the statutory limit prescribed under the law, and that Section 74 was incorrectly invoked by the authorities. This resulted in the invalidation of the proceedings and related demands, allowing the petitioner to seek redress through the appellate process.

The Division Bench of Justice R. Raghunandan Rao and Justice Challa Gunaranjan disposed of the writ petition by permitting the petitioner-assessee to file an appeal before the appellate authority within three weeks. The Court ruled that the limitation period would not affect the appeal and considered the 10% of disputed tax already paid as valid pre-deposit under Section 107 of the GST Act. The petitioner was allowed to raise all relevant defenses before the appellate forum, and all pending miscellaneous petitions were closed.

The Kerala High Court has ruled that disposing of multiple income tax appeals through a common order bearing a single Document Identification Number (DIN) is legally valid. This ruling came in a case where the petitioner, Kerala State Council for Science, Technology and Environment, challenged an appellate order under Section 250 of the Income Tax Act, 1961, which consolidated seven appeals related to assessment years from 2012-13 to 2023-24 involving Section 11 benefits. While the Court upheld the legal validity of the consolidated disposal due to identical legal issues, it acknowledged that the single DIN and a cause title referencing a different case could cause practical difficulties in filing separate appeals before the Income Tax Tribunal.

The single bench led by Justice Ziyad Rahman A.A directed the appellate authority to rectify the cause title error suo motu within two weeks. The Court further ruled that separate appeals filed by the petitioner against the common order must be accepted by the Income Tax Tribunal and not rejected solely because there is only one DIN.

The Kerala High Court ] stayed income tax recovery proceedings initiated against Shibu Mathew, pending the disposal of his stay petition filed alongside an income tax appeal for the assessment year 2022-23 under the Income Tax Act. Justice Ziyad Rahman A.A directed the Commissioner to decide the stay petition within two months and ordered that recovery proceedings be kept in abeyance until such decision is taken. This ruling emphasizes that filing a valid stay petition under Section 220(6) automatically suspends recovery efforts and protects taxpayers from coercive actions until the petition is adjudicated.

The Bench of Justice Ziyad Rahman A.A reinforced the principle established in CIT vs. M/S. Kalki Investment & Holdings Pvt. Ltd., holding that the tax department cannot bypass the stay petition by initiating immediate recovery. Even if the stay petition is rejected, recovery must await the outcome of any legal challenge, especially where the rejection is capricious or illegal. This judgment safeguards fundamental rights under Article 21 of the Constitution, ensuring fairness and due process in tax recovery.

The Kerala High Court restored income tax appeals filed by Sea Castle An Ayurvedic and Leisure Hotel after finding that the Assessing Officer (AO) violated principles of natural justice by passing orders without granting the appellant a hearing opportunity. The legal issue concerned the disallowance of deductions claimed under Section 43B of the Income Tax Act, 1961, for interest paid to Kerala Financial Corporation. Despite the appellant’s significant delay in pursuing statutory remedies, the AO’s failure to provide a hearing was held to be a fundamental procedural violation warranting restoration of the appeals.

The Division Bench of Justice Amit Rawal and Justice P.V. Balakrishnan acknowledged the appellant’s unjustified 588-day delay and vague excuses but ruled that denial of natural justice could not be compensated by delay alone. The Court set aside the orders of the Commissioner and the Income Tax Appellate Tribunal, imposing costs of ₹3 lakhs payable to the Mediation and Conciliation Centre as a precondition for restoration. The appellant was directed to appear before the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, for fresh adjudication with costs paid, emphasizing the paramountcy of fair hearing in tax proceedings despite procedural delays.

The Gujarat High Court granted leave to appeal against an acquittal in a ₹6 lakh cheque bounce case, involving alleged dishonour of a cheque under Section 138 of the Negotiable Instruments Act, 1881. The applicant, Ranchhodbhai N. Gambhava, challenged the trial court’s acquittal of the accused on grounds that the trial court failed to properly appreciate evidence proving the existence of a legally enforceable debt and the dishonoured cheque issued due to insufficient funds. The case pertained to a cheque issued by the accused from his Union Bank of India account, which was returned unpaid, leading to the complaint.

The Division Bench of Justice S.V. Pinto, observed prima facie that the trial court had not evaluated the evidence in its correct perspective and held that the application for leave to appeal deserved consideration. The High Court accordingly granted leave to appeal against the acquittal, allowing the case to be revisited on the merits to ensure proper justice.

The Jammu & Kashmir and Ladakh High Court upheld the automatic cross-empowerment of Goods and Service Tax (GST) officers under Section 6 of the CGST Act, 2017, dismissing multiple petitions challenging show cause notices issued by the Joint Commissioner, CGST Commissionerate, Jammu. The petitions involved allegations of fraudulent availment of bogus Input Tax Credit (ITC) through paper transactions by companies operating within the Jammu and Kashmir Integrated Textile Park, Kathua. The court held that intelligence-based enforcement actions do not require separate government notification for cross-empowerment, which is inherent by law. It clarified that both Central and State tax authorities have jurisdiction to act across the entire GST value chain when initiating intelligence-led probes, irrespective of the administrative allocation of taxpayers.

The Division Bench of Justice Sanjeev Kumar and Justice Sanjay Parihar emphasized that monetary limits for jurisdiction under departmental circulars are administrative guidelines and do not curtail the authority of senior officers like the Joint Commissioner. While the bench left the issue of bunching under Section 74 of the CGST Act open for adjudication, it rejected all contentions against jurisdiction and authority, affirming the legality of enforcement actions based on intelligence inputs. The court upheld the show cause notices and dismissed the writ petitions, allowing petitioners to raise other grounds before the authorities concerned during further proceedings.

The Kerala High Court recently recalled its previous judgment due to improper clubbing of distinct Goods and Services Tax (GST) cases and restored a writ petition concerning refund claims under the inverted tax structure scheme. The case involved P.M. Subair, Managing Partner of M/s. Ansar Oil Industries, whose original writ petition was wrongly disposed of alongside petitions challenging the constitutional validity of Section 16(2)(c) of the CGST/KSGST Act, 2017. The Court found that the issues in the refund claim petition were fundamentally different and had not been addressed due to improper clubbing.

The Bench of Justice Ziyad Rahman A.A. observed a patent error in the impugned judgment and held that the petitioner's distinct reliefs were not considered in the common judgment. Consequently, the Court recalled the earlier judgment dated 28.06.2024 and restored the original writ petition for fresh adjudication. The Court directed that the restored writ petition be listed for hearing on 26.09.2025, ensuring separate consideration of the petitioner’s specific legal issues related to GST refund claims.

The Kerala High Court stayed income tax recovery proceedings initiated against Edakkalathur Devassy Daiz, arising from an assessment order for the assessment year 2017-18. The legal issue involved the discretionary stay of recovery pending adjudication of the stay petition filed along with an appeal before the Income Tax Appellate Tribunal, under the Income Tax Act. The Court emphasized that recovery cannot proceed while the stay petition is pending and must await the Tribunal’s decision to ensure procedural fairness.

The Bench of Justice Ziyad Rahman A.A. disposed of the writ petition by directing the Income Tax Appellate Tribunal to take up and decide the stay application after providing the petitioner an opportunity for hearing and to pass appropriate orders within three months from the judgment date. Until such a decision is rendered, all recovery proceedings pursuant to the assessment and appellate orders were stayed, safeguarding the petitioner’s statutory rights during the appellate process.

The High Court of Karnataka granted relief to Charles River Laboratories Inc. by dismissing the Revenue’s appeal on the ground that the tax effect was below ₹2 crore, the threshold prescribed under CBDT Circular No. 9/2024 dated 17.09.2024. The case involved the question of whether payments received by the U.S.-based company qualified as Fees for Technical Services (FTS) under Section 9(1)(vii) of the Income Tax Act, 1961 and Article 12 of the India-USA DTAA. The Revenue had challenged an Income Tax Appellate Tribunal (ITAT), Bengaluru Bench order dated 01.06.2023, which held that the services did not satisfy the “make available” condition under the DTAA and therefore did not constitute FTS according to the CBDT Circular No. 5/2024 dated 15.03.2024.

The matter was heard by a Division Bench of Justice S.G. Pandit and Justice K.V. Aravind, who noted that the tax effect of ₹1.02 crore was below the revised monetary threshold for filing appeals before High Courts. The Court held that the present appeal did not raise a direct issue regarding the applicability of the DTAA itself, but only on whether the Tribunal correctly interpreted it. Therefore, that no exception to the monetary threshold applied, the High Court dismissed the appeal as not maintainable.

The High Court of Delhi set aside two separate orders issued under Section 73 of the CGST Act, 2017 against Poorvi Cards, holding that issuing duplicate Show Cause Notices (SCNs) for the same tax period (July 2017 to March 2018) and amount was unsustainable. The petitioner had applied for GST registration cancellation on 7th October 2022, but received two SCNs, one dated 22nd September 2023 demanding ₹5,26,558 and another dated 26th December 2023 demanding ₹39,31,392 for the same period. The petitioner challenged this duplication and argued that the issuance of two parallel proceedings for the same matter was procedurally flawed.

The matter was heard by a Division Bench comprising Justice Prathiba M. Singh and Justice Shail Jain held that the petitioner was not afforded a proper opportunity of hearing, as no reply was filed and no effective personal hearing was granted. The Court remanded the matter to the Adjudicating Authority for fresh adjudication and granted time until 15th November 2025 for the petitioner to submit a consolidated reply to the SCNs. The Adjudicating Authority was directed to issue a hearing notice through email and mobile communication, consider the reply, and pass a fresh order. The Court clarified that any new order would be subject to the outcome of S.L.P. No. 4240/2025 pending before the Supreme Court regarding Notification No. 09/2023-Central Tax. The writ petition was disposed of without addressing the case’s merits, leaving all rights and remedies open to both parties.

The High Court of Delhi set aside the Order-in-Appeal dated 30th June 2025 in the case of A.L. Exports, after finding that a technical glitch on the GST portal had resulted in a personal hearing notice being generated after the appeal was already decided. The petitioner had claimed a refund of ₹36,61,166 towards Input Tax Credit (ITC) on exports made without payment of integrated tax, but the claim was rejected by the Assistant Commissioner, CGST on 24th January 2025 for non-submission of supporting documents. Upon appeal, hearing notices were sent by speed-post, which the petitioner did not attend. However, on 1st July 2025, the petitioner received a GST portal notice for a hearing scheduled on 2nd July 2025, only to be informed that the appeal had already been disposed of a day earlier.

The matter was heard by a Division Bench of Justice Prathiba M. Singh and Justice Shail Jain observed that the petitioner was denied an opportunity to be heard, as the hearing notices had not been uploaded on the GST portal, and there was no clarity on whether they were received by email. The Court noted that when the petitioner appeared in response to the first portal notice on 2nd July 2025, the Order-in-Appeal had already been passed, and the notice appeared to be system-generated after disposal. Thus, the Court set aside the impugned Order-in-Appeal and directed that the appeal be reheard on merits. The Appellate Authority was instructed to issue a hearing notice via the petitioner’s email and mobile, and to pass a reasoned order after granting an opportunity of hearing.

The Jammu & Kashmir High Court held that while the J&K GST Act, 2017 prescribes a strict limitation under Section 107 for filing appeals, constitutional courts are empowered to condone delay in exceptional circumstances to ensure complete justice. The ruling came in response to a writ petition filed by M/s Parshotam Electronics, challenging an order dated 05.07.2024, by which the State Taxes Appellate Authority dismissed its appeal as time-barred.

The matter was heard by a Division Bench comprising Justices Rajesh Sekhri and Rajnesh Oswal observed that while appellate authorities under the GST Act cannot condone delay beyond the statutory period, constitutional courts are not so restricted. The Court held that the petitioner’s medical condition constituted a bona fide ground for condonation and quashed the appellate authority’s order dismissing the appeal. The Court further clarified that it had not expressed any opinion on the validity of the underlying tax demand, thereby keeping all issues open for the appellate authority to decide.

The Madras High Court modified the conditions imposed in a provisional release order under Section 110 of the Customs Act, 1962, concerning a consignment of PVC coated fabrics imported by K P Impex from China through Chennai Port. The Directorate of Revenue Intelligence (DRI) had initiated proceedings for alleged misclassification and undervaluation, leading to seizure of the goods. The Additional Commissioner of Customs had permitted provisional release on the condition of (i) remittance of re-determined duty, (ii) execution of a bond for ₹39 lakh, and (iii) furnishing a bank guarantee of ₹11 lakh. The petitioner challenged the requirement of a bank guarantee, arguing it was unduly harsh and relied on precedents like Green Line v. Commissioner of Customs (2016) and Sri Venkateshwara Paper Boards (2022).

The matter was heard by the bench of Justice N. Anand Venkatesh , held that while protecting revenue is necessary, unnecessary hardship to the importer should be avoided when adjudication is pending. The Court noted that the department’s interest could be safeguarded through execution of bonds instead of a bank guarantee. Accordingly, it modified the order to require (i) remittance of declared duty, (ii) payment of 50% of the differential duty, (iii) execution of a bond for ₹39 lakh, and (iv) execution of an additional bond of ₹11 lakh in place of the bank guarantee. Customs authorities were directed to release the goods within seven days of compliance, and both parties were instructed to cooperate to ensure timely conclusion of adjudication proceedings.

The Madras High Court ruled that continued retention of seized goods during pending adjudication is not always necessary, especially where the outcome may only involve imposition of duty, fine, or penalty. The ruling came in a writ petition filed by M/s Aashi Creations, an importer of textile fabric coated with plastics from China. The goods were seized under Section 110 of the Customs Act, 1962 by the Directorate of Revenue Intelligence (DRI) on grounds of misclassification and undervaluation, following CRCL laboratory testing. The petitioner requested re-export of the consignment, which the supplier had agreed to take back, but the Customs Department refused permission citing pending adjudication.

The matter was heard by the bench of Justice N. Anand Venkatesh, held that where the likely consequences under Section 111 and Section 125 of the Customs Act are limited to confiscation with an option for redemption on payment of fine, detention of goods was not justified. The Court noted the need to balance Revenue protection with avoidance of undue hardship to the importer. Accordingly, it allowed re-export of the seized consignment, subject to the petitioner (i) executing a bond for the entire differential duty and (ii) furnishing a bank guarantee equal to 20% of the re-determined value of the goods. The Customs authorities were directed to permit re-export within twelve days of compliance.

The Madurai Bench of the Madras High Court held that mere uploading of a Show Cause Notice (SCN) on the GST portal is insufficient where a taxpayer's GST registration stands cancelled, emphasizing the need for service through registered post to uphold principles of natural justice. The case arose from a writ petition filed by K. Chandra, a government works contractor, challenging an assessment order dated 23 January 2025 passed under Section 73 of the Tamil Nadu GST Act, 2017, demanding ₹8.62 lakh in tax, interest, and penalty. Though the petitioner’s GST registration was cancelled in October 2020, the SCN was uploaded on the portal in November 2024, which the petitioner could not access, leading to an ex parte assessment.

The matter was heard by the bench of Justice G.R. Swaminathan, cited the precedent in Tvl. Apollo Medicals v. State Tax Officer (2025) setting aside the assessment order for violating natural justice, but treated it as a valid show cause notice, granting the petitioner three weeks to file a reply. The Assessing Officer was directed to conduct a fresh hearing and issue a speaking order within eight months. Considering that over 90% of the disputed tax had already been recovered, the Court also ordered the immediate lifting of the bank account attachment, ensuring procedural fairness while balancing Revenue interests.

The Andhra Pradesh High Court has ruled that summary assessment orders (Form DRC-07) under the GST regime must be duly signed by the assessing authority, and that prior issuance of an intimation notice under Rule 142(1A) of the CGST Rules, 2017 is mandatory, especially for tax periods before its amendment in October 2020. The case arose from a writ petition by Abrars Today Fashion Mall, a registered GST dealer, challenging an assessment order dated 29.03.2023 imposing a penalty under Section 122(1)(ii) of the CGST Act for the period July 2017 to December 2021.

The matter was heard by a Division Bench of Justice R. Raghunandan Rao and Justice T.C.D. Sekhar held that unsigned orders cannot be treated as curable defects under Sections 160 and 169 of the GST Act. The Court relied on its own past judgments where unsigned orders were struck down. On the second issue, it reiterated its position from W.P. No. 12850/2022 that issuance of notice under Rule 142(1A) was compulsory for pre-amendment tax periods. Since no such notice was issued a fact conceded by the Revenue the Court found procedural violation, and accordingly set aside both the assessment and appellate orders. The matter was remanded to the Assessing Officer to follow proper procedure and issue a fresh order. The Court also directed that the limitation period be computed by excluding the duration between the original and remanded orders.

The Punjab and Haryana High Court addressed the issue of advocates using mobile phones during court proceedings to search answers via AI tools or Google. The legal issue centered on courtroom decorum and professional conduct, as the petitioner’s counsel attempted to look up information on his phone while responding to queries from the bench.

The matter was heard by the Bench of Justice Sanjay Vashisth, ruled that advocates are expected to be fully prepared before appearing and should not rely on real-time searches during hearings. The Court cited a similar incident in Ravneet Singh Sandhu @ Manveer Singh v. UT of Chandigarh (2025), where a mobile phone was seized for the same reason. To deter such practices, the Court directed that a copy of the order be sent to the President and Secretary of the Bar Association, urging them to inform members. The Court warned that repeated violations may attract stricter action and listed the matter for further hearing on 20 November 2025.

The Delhi High Court addressed the concern of an imposition of an enhanced penalty under Section 114AA of the Customs Act, 1962, on a freight forwarder involved in the illegal export of red sandalwood. The issue centered on whether an additional penalty could be imposed on the respondent, who facilitated the shipment without verifying the exporter’s credentials, despite already having been penalized under Section 114 for aiding the export of prohibited goods without valid CITES authorization.

The matter was heard by a Division Bench comprising Justice Prathiba M. Singh and Justice Shail Jain dismissed the Customs Department’s appeal for an enhanced penalty, holding that the existing penalty of ₹10 lakh was adequate given the respondent’s limited and intermediary role. The Bench observed that imposing an additional penalty under Section 114AA, which could be five times the value of the goods, would be disproportionate. The Court left the broader legal question regarding the application of Section 114AA open for consideration in an appropriate future proceeding.

The Delhi High Court addressed the issue of limitation periods under the Prevention of Money Laundering Act, 2002 (PMLA) in the context of the COVID-19 pandemic. The key legal question was whether the suo motu extension of limitation periods by the Supreme Court during the pandemic applied to the 180-day statutory period for confirmation of provisional attachment orders under Section 5(3) of the PMLA. The matter arose from provisional attachment orders issued by the Enforcement Directorate against Vikas WSP Ltd and its directors, which were challenged as having lapsed due to expiration of the limitation period.

The matter was heard by a Division Bench of Justice Anil Kshetarpal and Justice Harish Vaidyanathan Shankar held that in the absence of specific legislative provisions extending the limitation under the PMLA, the Supreme Court’s suo motu directions during the COVID-19 pandemic continued to apply. The Court observed that these directions, issued under Articles 141 and 142 of the Constitution, have binding and overriding force unless explicitly excluded by law. The Bench set aside the earlier Single Judge’s order that had declared the attachments lapsed, ruling that the 180-day limitation period was validly extended for the pandemic period, and accordingly dismissed the writ petitions challenging the provisional attachment orders.

The Bombay High Court addressed the validity of service of a GST show cause notice (SCN) in a case concerning retrospective cancellation of GST registration. The legal issue centered on whether sending the SCN to an outdated address after the petitioner’s registration was cancelled amounted to valid service under Section 108 of the CGST/MGST Act, 2017, and whether passing a revisional order without proper notice violated the principles of natural justice.

The matter was heard by a Division Bench of Justice M.S. Sonak and Justice Advait M. Sethna held that the SCN sent to the petitioner’s old address was invalid as the department had previously communicated with the petitioner at the updated Ahmedabad address. The Court ruled that there was no effective service of the notice dated 1 July 2024, and consequently, the revisional order dated 22 July 2024 was set aside for breach of natural justice. The Bench directed the department to re-serve the SCN at the correct address or through the petitioner’s counsel, allow the petitioner to file a reply, and pass a fresh reasoned order after hearing. The earlier cancellation order from June 2022 was revived and the writ petition was allowed with no order as to costs.

The Bombay High Court addressed the issue of restoration of GST registration where a taxpayer had fully paid all outstanding dues, including interest and late fees, and the delay in filing returns was found to be bona fide. The court examined whether cancellation of registration under such circumstances was justified and considered the principle of proportionality in relief.

The matter was heard by a Division Bench of Justice M.S. Sonak and Justice Advait M. Sethna held that since the petitioner, Azaria Corp LLP, had cleared all dues amounting to ₹16,46,186 along with interest and late fees of ₹6,27,935, the permanent cancellation of registration was disproportionate. The court ordered restoration of the GST registration subject to payment of a ₹50,000 CSR contribution to KEM Hospital. The department was directed to notify the petitioner within 15 days if any further dues were payable, failing which the cancellation would stand quashed.

The Madurai Bench of the Madras High Court recently addressed the legal issue concerning the validity of claiming customs duty exemption under the ASEAN-India Free Trade Agreement (AIFTA). The Court examined whether exemption can be granted without a valid and genuine Certificate of Origin as required under the customs laws and AIFTA rules. The case involved Olam Enterprises India Pvt. Ltd., which sought a refund of customs duty paid on imported teak round logs, relying on AIFTA Certificates of Origin that were alleged to be flawed.

The matter was heard by a Division Bench of Justice P. Velmurugan and Justice K.K. Ramakrishnan held that a Certificate of Origin under AIFTA must be strictly valid and genuine, and mere circumstantial matches, such as matching vessel names or quantities, cannot substitute for a legally compliant certificate. The Court found critical discrepancies in the certificate, including date mismatches and incorrect party details, which undermined its authenticity. Consequently, the High Court set aside the order of the CESTAT that had allowed the exemption and restored the original orders denying duty exemption to Olam Enterprises, ruling that the burden of proof lies on the importer to produce a flawless certificate to claim exemption.

The High Court of Delhi dealt with an issue concerning the imposition of an anti-profiteering order under Section 171 of the CGST Act, 2017, related to the alleged failure of Tata Play Ltd. to pass on Input Tax Credit (ITC) benefits to consumers. The matter arose from claims that Tata Play, a Direct-to-Home (DTH) service provider, engaged in profiteering by not adjusting prices despite changes in GST rates on inputs and services. The case involved interpreting the scope and application of anti-profiteering provisions, including the validity of the order passed by the National Anti Profiteering Authority (NAPA).

The matter was heard by a Division Bench of Justice Prathiba M. Singh and Justice Shail Jain set aside the impugned anti-profiteering order amounting to Rs. 450 crore against Tata Play and remanded the case to the Principal Bench of the Goods and Services Tax Appellate Tribunal (GSTAT) for a fresh examination of whether actual profiteering had occurred. The Court noted that Tata Play had not increased its service prices despite GST rate hikes, absorbing additional tax costs and subsuming input tax credit benefits. The judgment ruled that any erroneous exercise of anti-profiteering powers can be challenged on merits and allowed the petitioner to submit additional evidence before the GSTAT. The Court also disposed of the writ petition challenging the Show Cause Notice (SCN) as infructuous and directed communication of the order to the GST Appellate Tribunal.

The Bombay High Court addressed the legal issue of whether pre-show cause consultation is mandatory before issuing service tax demands exceeding Rs. 50 lakhs under Section 73 of the Finance Act, 1994, as per the CBEC Circulars. The Court examined the binding nature of Circular No. 1053/02/2017-CX dated 10 March 2017 and Circular No. 1076/02/2020-CX dated 19 November 2020, which mandate pre-consultation in such cases except those involving preventive or offence-related matters. The petitioner, Rochem Separation Systems (India) Pvt. Ltd., challenged the validity of a show cause notice issued without adhering to this mandatory consultation process.

The matter was heard by a Division Bench comprising Justice M.S. Sonak and Justice Advait M. Sethna held that the CBEC circulars are binding on departmental officers and that pre-show cause consultation is a mandatory procedural requirement for service tax demands exceeding Rs. 50 lakhs. The Court emphasized that this consultation promotes trade facilitation and voluntary compliance and is not a mere formality. The Bench quashed the impugned show cause notices issued without prior consultation. However, the Court allowed the department to issue fresh pre-consultation notices within four weeks and complete the consultation process within six weeks, after which fresh show cause notices could be issued if necessary.

The Rajasthan High Court dealt with the issue of the Revenue’s repeated attempt to transfer a taxpayer’s case under Section 127 of the Income Tax Act, 1961. The petitioner, Murliwala Agrotech Pvt. Ltd., challenged the fresh transfer order dated 19 October 2022 issued by the Principal Commissioner of Income Tax, which sought to transfer the case despite an earlier similar transfer order being quashed by the court for violating natural justice and lack of opportunity to be heard. The core legal question involved the validity and justification of such repeated transfer orders when circumstances remained unchanged.

The matter was heard by a Division Bench comprising Chief Justice K.R. Shriram and Justice Ravi Chirania held that the Revenue’s renewed attempt to transfer the case was arbitrary, rigid, and unjustified, especially given that the factual situation was identical to that previously considered. The court ruled that no substantial change in circumstances existed to warrant the transfer, particularly in light of the faceless assessment system adopted by the Income Tax Department and the completed assessment of the related Brindavan Group. The transfer order dated 19 October 2022 was therefore quashed as contrary to law, and any actions taken during the pendency of the petition were declared invalid. The Court directed the Revenue to continue proceedings from the stage prior to the transfer and granted liberty to take lawful action under applicable provisions without implying endorsement of further transfers.

The Bombay High Court addressed a procedural issue concerning the belated delivery of an appellate order by the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), Mumbai. The Court examined a writ petition filed by M/s Himachal Futuristic Communication Ltd. challenging an Order-in-Original dated 30 July 2007 by the Commissioner of Customs, Central Excise and Service Tax, Panaji-Goa, and the subsequent appellate order of the CESTAT. The key legal issue was the nearly two-year delay in pronouncing the CESTAT order after the hearing held on 19 December 2022, which raised questions of natural justice and procedural propriety.

The matter was heard by a Division Bench comprising Justice Bharati Dangre and Justice Ashish S. Chavan held that such a substantial delay in delivering the judgment vitiated the CESTAT order itself, justifying its quashing without delving into the substantive merits of the case. The Court rejected the Revenue’s plea that an alternate remedy was available, affirming that the presence of another remedy does not bar judicial intervention where an order suffers from patent procedural flaws such as delay and violation of natural justice. The matter was remanded back to the Tribunal for fresh consideration, with directions to examine all grounds raised by the petitioner and decide the appeal promptly. The impugned order was quashed on grounds of procedural impropriety.

The Delhi High Court addressed the issue of waiver of the mandatory pre-deposit under Section 129E of the Customs Act, 1962, in the context of a gold smuggling case. The legal question centered on whether a suspended Assam Rifles sepoy, facing a penalty order, could be exempted from the statutory requirement to make a pre-deposit before filing an appeal, especially considering his financial hardship and service status.

The matter was heard by a Division Bench comprising Justice Prathiba M. Singh and Justice Shail Jain allowed the waiver of the pre-deposit for the petitioner, Bhola Yadav, who was earning a modest income and under suspension at the time. The Court directed the petitioner to file his appeal by 15 November 2025 before the Appellate Authority without making any pre-deposit. The writ petition and all pending applications were disposed of accordingly.

The Delhi High Court adjudicated on the validity of reassessment notices issued under Sections 148A(3) and 148 of the Income Tax Act, 1961, in the case involving Huawei Technologies Cooperatief U.A. The legal issue concerned whether the Assessing Officer (AO) was justified in issuing notices and passing orders for reassessment in the absence of any material indicating escapement of income, particularly when the petitioner was a non-resident entity earning only interest income on loans to its Indian subsidiary, with appropriate tax deducted at source under Section 194LC.

The matter was heard by a Division Bench comprising Justice V. Kameshwar Rao and Justice Vinod Kumar set aside the impugned order dated 28.06.2025 under Section 148A(3) and the notice dated 28.06.2025 under Section 148. The Court directed the AO to pass a fresh and reasoned order within four weeks after considering all relevant documents. It further clarified that the petitioner-assessee could challenge the fresh order through available legal remedies. All pending applications were disposed of as infructuous.

The High Court of Gujarat addressed an issue of whether a deposit made in the Goods and Service Tax (GST) Electronic Cash Ledger constitutes payment to the Government under Section 49 of the CGST Act, 2017. The case involved an application by the Superintendent of Central GST & Central Excise, Gandhinagar seeking the cancellation of bail granted to Virbhadrasinh Pratapsinh Chauhan.

The matter was heard by the Bench of Justice Divyesh A. Joshi dismissed the application for cancellation of bail, ruling that the deposit in the GST Electronic Cash Ledger was deemed as payment to the Government under Section 49 of the CGST Act. The Court referred to the precedent set in Arya Cotton Industries vs. Union of India (2024), which clarified that once amounts are credited to the Government account, the tax liability is discharged. The Court noted that the deposit was made within the stipulated time, and the conditions of the bail had been fully complied with. Consequently, the application was rejected, and the notice for cancellation of bail was discharged.

The Madras High Court addressed the issue of whether Customs authorities can mandate a Bureau of Indian Standards (BIS) registration certificate for plywood imports made by micro enterprises, where the Quality Control Order itself grants an exemption up to a specified date. The case involved Alankar Shipping and Trading Co. Pvt. Ltd., which had imported plywood from Vietnam and sought clearance from Customs without the mandatory BIS certification.

The matter was heard by the Bench of Justice N. Anand Venkatesh, held that Customs authorities could not insist on a BIS registration certificate for plywood imports made by MSMEs, as the statutory Quality Control Order provided an exemption for MSMEs until 28 August 2025. The Court ruled that executive circulars cannot override the provisions of the parent statute. Customs were directed to assess and clear the consignment without the BIS certificate and ordered the clearance process to be completed within two weeks of receiving the order.

The Madras High Court addressed the issue of an assessee facing a GST demand after failing to respond to a Show Cause Notice (SCN) and subsequently missing the statutory appeal deadline. The case involved Tvl. Cashewking Nut and Commodities, which was issued a GST SCN for the tax period April 2022 to March 2023. Despite not responding to the SCN, the petitioner later filed an appeal, but it was rejected as time-barred. The Court considered whether to grant a second chance for adjudication while imposing conditions on the petitioner’s compliance with a pre-deposit requirement.

The matter was heard by the Bench of Justice C. Saravanan,who quashed both the assessment order and the appellate order, which had rejected the petitioner’s appeal on technical grounds. The Court granted the petitioner a second opportunity for adjudication, directing them to make an additional pre-deposit of 15% of the disputed tax within 30 days and file a detailed response to the SCN with supporting documents. The Court ordered that after the petitioner’s compliance, the assessing officer should pass a fresh order within three months. The bank account attachment was also lifted upon compliance. The Court made it clear that if the petitioner failed to meet these conditions, the Revenue could proceed with recovery actions as if the writ petition had been dismissed.

The Madras High Court dealt with a Customs dispute where M/s Compuage Infocom Ltd. sought exemption from customs duty on CCTV cameras and network video recorders imported from Vietnam under Notification No. 46/2011-Cus, claiming benefits under the ASEAN-India Free Trade Agreement (FTA). The Deputy Commissioner of Customs had rejected the exemption claim. The legal issue centered around whether the Customs order violated the principles of natural justice by failing to consider the petitioner’s submission and providing no opportunity for a personal hearing.

The matter was heard by the Bench of Justice N. Anand Venkatesh, observed that the Customs authority failed to properly address the petitioner’s claim and supporting documents, including the certificate of origin from Vietnam, which was crucial for the exemption under the ASEAN-India FTA. The Court held that the authority was obligated to consider all relevant submissions and provide an opportunity for personal hearing, especially in the case of a dispute over exemption claims. The Court quashed the Customs order dated 19.07.2021 and remanded the matter to the Deputy Commissioner of Customs for fresh consideration, directing them to examine the petitioner’s exemption claim and provide a hearing before passing a final decision.

The Madras High Court addressed a case where Gayatri Exim, a Mumbai-based importer, sought permission to re-export 798 bales of textile fabric coated with plastics to its supplier in China, following a dispute over misclassification by Customs authorities. The Directorate of Revenue Intelligence (DRI) had seized the goods, holding them liable for confiscation under the Customs Act, 1962, after the samples failed to meet classification standards. The legal issue revolved around whether the goods, pending adjudication, could be re-exported to prevent undue hardship to the importer, with the Customs Act allowing penalties or differential duties to be imposed during adjudication.

The matter was heard by the Bench of Justice N. Anand Venkatesh, considering previous rulings and the nature of the investigation, ruled in favor of Gayatri Exim. The Court observed that while the misclassification issue and potential penalties were pending adjudication, there was no reason to unnecessarily detain the goods, especially when the overseas supplier was willing to take them back. The Court allowed the re-export of the consignment to China, subject to strict conditions, including the execution of a bond for the differential duty and a bank guarantee. The re-export must be completed within twelve days after fulfilling these conditions, thereby balancing the protection of revenue interests with alleviating the financial burden on the importer.

The High Court of Andhra Pradesh dealt with a writ petition filed by Sahiti Agencies, challenging a GST assessment order and show-cause notice issued under Section 74 of the Goods and Services Tax Act, 2017. The petitioner raised two main grounds: the absence of physical or digital signatures on the notice and the orders, making them invalid, and the issuance of a single show-cause notice and composite assessment order covering six assessment years from 2017-2023, which, according to the petitioner, was not permissible under the GST Act. The Court considered whether the lack of signatures and the improper grouping of multiple assessment years violated procedural requirements.

The matter was heard by the Bench comprising Justice R. Raghunandan Rao and Justice T. C. D. Sekhar, who set aside the impugned show-cause notice and composite assessment order. The Court found that while the failure to include digital signatures on the documents raised valid concerns, the petitioner’s response to the notices indicated that they did not challenge the proceedings on these grounds earlier. Regarding the composite order for multiple years, the Court held that separate notices and orders should have been issued for each tax period. The matter was remanded back to the authority for fresh adjudication, ensuring the petitioner would have an opportunity for a proper hearing.

The High Court of Delhi addressed a dispute concerning the transitional CENVAT credit claim of ₹9.34 crores made by Airports Authority of India (AAI) for the April–June 2017 period, prior to the implementation of the Goods and Services Tax (GST). The claim was disallowed by the Adjudicating Authority on two primary grounds: the credit was not reflected in the ST-3 return filed under the earlier service tax regime, and the supporting documents submitted with Form TRAN-1 were incomplete. The issue fell under Section 140 of the CGST Act, 2017, which governs the carry forward of CENVAT credit into the GST regime.

The matter was heard by a Division Bench comprising Justice Prathiba M. Singh and Justice Shail Jain declined to interfere with the order under writ jurisdiction, observing that there was no jurisdictional error or arbitrary exercise of power. However, the Court granted relief by allowing AAI to file an appeal under Section 107 of the CGST Act against the impugned order dated 21 August 2023. The Court extended the deadline for filing the appeal to 15 November 2025 and permitted AAI to submit additional supporting documents to substantiate its transitional credit claim. It was clarified that if the appeal is filed within the extended time, it will not be dismissed as time-barred and will be adjudicated on merits.

The Punjab & Haryana High Court addressed the issue of prolonged blocking of Input Tax Credit (ITC) under Rule 86A(3) of the Central Goods and Services Tax (CGST) Rules, 2017. The petitioner, M/s Mahadev Steel Industries, challenged the continued restriction on ITC amounting to ₹33,80,886/-, which had been blocked since 25.06.2024. 2

The matter was heard by a Division Bench comprising Justice Anupinder Singh Grewal and Justice Deepak Manchanda agreed with the petitioner’s contention, reiterating that the statutory time limit under Rule 86A(3) could not be extended beyond one year. The Court observed that once this period lapsed, the authorities had no legal basis to continue restricting the credit. Accordingly, the High Court directed the tax authorities to consider the petitioner’s request and pass an appropriate order regarding unblocking of ITC within one week.

The Karnataka High Court examined the validity of reassessment notices and orders issued under Sections 147, 148, and 148A of the Income Tax Act, 1961. The core issue was whether jurisdictional Income Tax Officers could issue reassessment notices physically, despite the statutory mandate under the Faceless Reassessment Scheme, 2022, notified by the Central Board of Direct Taxes (CBDT) on 29 March 2022. Petitioners challenged such physical reassessment notices issued for A.Y. 2017-18 and 2019-20, arguing that they violated Section 151A of the Act, which mandates a faceless and automated process for reassessment.

The matter was heard by the Bench of Justice M. Nagaprasanna, who quashed the reassessment notices and consequential orders, holding them to be without jurisdiction and contrary to the law laid down by Parliament. The Court emphasized that once a specific procedure is prescribed such as the faceless reassessment mechanism must be followed strictly, and any reassessment action taken in deviation thereof is invalid. The Court held that the physical issuance of reassessment notices was procedurally defective. While striking down the notices, the Court clarified that the Revenue retains the right to initiate fresh proceedings strictly via the faceless scheme should the Supreme Court uphold the reassessment framework.

The Madras High Court addressed the issue of cancellation and revival of GST registration in the case of NMH Design Build, whose registration had been cancelled via an order dated 6 February 2025 for failure to file returns and conduct business. The cancellation was based on a show cause notice to which the petitioner failed to respond. Though the petitioner had not availed the Amnesty Scheme or filed a revocation application under Section 30 of the CGST Act, it sought revival, arguing that there was no fraud or prejudice caused to the Revenue.

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The matter was heard by a Bench of Justice C. Saravanan, held that keeping dealers outside the GST system was detrimental to tax administration. The Court set aside the cancellation order and directed revival of the GST registration, while balancing Revenue interests by imposing a six-month moratorium on the use of Input Tax Credit (ITC) and the electronic credit ledger. During this period, tax liabilities must be discharged in cash or through fresh credits. The Court also granted the Department liberty to initiate penalty or recovery proceedings for the non-compliance period.

The Kerala High Court addressed a procedural challenge under the Income Tax Act, where Poovachal Rural Housing Co-operative Society Ltd., an assessee, contested a notice under Section 142(1) for the assessment year 2014–15. The notice from the National Faceless Assessment Centre (NFAC) required the online submission of the assessee’s voluminous cash book for F.Y. 2013-14, running into thousands of pages.

The matter was heard by a Bench of Justice Ziyad Rahman A.A. accepted the assessee’s plea and noted the practicality of a physical verification. The Court directed the NFAC to refer the matter to the Local Verification Unit (LVU) under the Principal CIT(VU), Kochi, for an on-site inspection of the cash book. The LVU was instructed to verify the documents at the assessee’s premises and report back for further assessment. The Court ruled that the verification and assessment should be completed expeditiously, thereby ensuring procedural fairness without compromising efficiency.

The Kerala High Court dismissed income tax appeals filed by Sravan Kumar Neela and Uma Maheshwara Rao Chinni, upholding an ITAT order that rejected their challenge to assessments under Section 69A of the Income Tax Act for A.Y. 2017-18. The dispute arose after ₹2.39 crore in cash was seized from the appellants during a flight from Hyderabad to Kozhikode in July 2016. The appellants had initially declared the amounts as “income from other sources” in their returns but later, during the appellate stage, attempted to introduce affidavits claiming the money belonged to others.

The matter was heard by a Division Bench of Justice A. Muhammed Mustaque and Justice Harisankar V. Menon held that the additional evidence submitted at the ITAT stage was a clear afterthought. Citing Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963, the Court ruled that the Tribunal is not bound to accept new evidence unless the assessee was prevented by valid reasons from presenting it earlier. Since the appellants had voluntarily filed returns including the seized amounts as their own income, the Court held that allowing revision at this stage would violate statutory provisions. Consequently, the High Court upheld the ITAT’s decision and dismissed both appeals, ruling in favor of the Revenue.

The Kerala High Court clarified that a remand by the Income Tax Appellate Tribunal (ITAT) must be treated as an open remit and not a binding direction limiting the scope of reassessment. The ruling came in appeals filed by Dr. K.M. Ashik, Director of M/s. Moidu Medicare Pvt. Ltd., against ITAT’s common order dated 30.01.2018 for A.Y.’s 2007-08, 2011-12, and 2012-13. The assessing officer had earlier taxed sums received from the company as a deemed dividend under Section 2(22)(e) of the Income Tax Act, 1961. The ITAT remitted the case for fresh consideration but observed that additions may instead be made under Section 68, as the appellant’s loan account did not appear in the company’s books.

The matter was heard by a Division Bench of Justice A. Muhammed Mustaque and Justice Harisankar V. Menon held that the ITAT’s reference to Section 68 was not a binding direction and should not restrict the assessing officer’s discretion. The Court ruled that the remand should be open, allowing the Department to re-examine the case afresh, including the assessee’s contentions that Section 2(22)(e) does not apply. It was further held that if Section 68 is invoked, the assessee must be given an opportunity to explain. Since revised assessments had already been completed and appeals were pending, the Court permitted the assessee to raise all arguments before the appellate authority.

The Kerala High Court set aside the Deputy Commissioner’s revisional order under Section 56 of the Kerala Value Added Tax (KVAT) Act, 2003, holding that tax clarifications issued under Section 94 cannot operate retrospectively. The case involved K.G. Rejimon, proprietor of M/s Thermal Tech Engineers, whose VAT assessment for A.Y. 2009-10 was revised after initially being settled in his favour. The petitioner’s product, “thermic fluid heaters,” was initially taxed at 12.5%, later revised to 4% based on appellate directions. However, following a clarificatory order dated 07.04.2016 stating that the item attracted 12.5% tax, the Deputy Commissioner initiated suo motu revision to cancel the revised assessment.

The matter was heard by a Division Bench of Justice A. Muhammed Mustaque and Justice Harisankar V. Menon held that although the Deputy Commissioner was justified in invoking revisional powers and the petitioner failed to prove the correct classification of the product under the HSN Code, the retrospective application of the clarificatory order was impermissible. Citing Section 94(2) of the KVAT Act, the Court ruled that tax clarifications can only operate prospectively to avoid undue prejudice to assessees. As a result, the Deputy Commissioner’s order and the confirmation by the Commissioner of State Tax were quashed.

The Bombay High Court held that a pending customs prosecution cannot bar a person from traveling abroad to attend the International Furniture Fair. The case arose when Sruti Vijaykumar challenged the Additional Chief Judicial Magistrate’s order granting Respondent No.1 permission to travel abroad from 4th to 10th September 2025, despite ongoing investigation and bail conditions including passport surrender in a customs offence case registered by the Directorate of Revenue Intelligence (DRI), Mumbai.

The matter was heard by the Bench of Justice S.M. Modak observed that the fundamental right to travel abroad cannot be restrained merely due to an ongoing investigation or prosecution. The Court noted that the accused had surrendered his passport but sought permission for travel to attend a furniture fair in Paris, a fact undisputed by the DRI. The Court observed the concern for potential evidence tampering but balanced it against the short duration of travel and the fundamental right involved. Accordingly, the Court upheld the trial court’s order permitting travel, subject to the condition that the accused shall not contact exporters linked to the case and must return for the bail cancellation hearing. The writ petition was dismissed.

The High Court of Karnataka recently dealt with an appeal filed by the Revenue challenging the Income Tax Appellate Tribunal’s (ITAT) order regarding the genuineness of cash sales recorded on the demonetisation day, 8th November 2016. The legal issue before the Court was whether ₹6.61 crore cash sales declared by Aura Jewels for the A.Y. 2017-18 could be treated as unexplained cash receipts under Section 68 of the Income Tax Act, 1961. The Assessing Officer had disallowed these sales, questioning their authenticity due to the unusually large amount transacted on a single day and the absence of PAN and full customer details.

The matter was heard by a Division Bench comprising Justice Vibhu Bakhru and Justice C.M. Joshi upheld the decisions of both the Commissioner of Income Tax (Appeals) and the ITAT, which had accepted the assessee’s explanation supported by invoices, stock records, and barcode details linking sales to inventory. The Court observed that the genuineness of cash receipts was a question of fact and found no perversity in the well-reasoned findings of the lower authorities. Consequently, the Karnataka High Court dismissed the Revenue’s appeal, holding that no substantial question of law arose from the matter.

The High Court of Delhi addressed the legal issue concerning the validity of settlement applications filed under Section 245C of the Income Tax Act, 1961, during the period from February 1 to March 31, 2021, despite the retrospective abolition of the Income Tax Settlement Commission (ITSC) by the Finance Act, 2021. The case involved Megha Engineering and Infrastructure Ltd., which filed its settlement application after a search and seizure operation and subsequent notices under Sections 153A and 153C. The key question was whether such applications, submitted after the ITSC’s abolition date of February 1, 2021, retained validity and whether taxpayers had a vested right to have these applications considered under the law.

The matter was heard by a Division Bench comprising Justice V. Kameshwar Rao and Justice Vinod Kumar held that the retrospective abolition of the ITSC could not invalidate settlement applications filed within the stipulated period, recognizing that the statutory right to approach the Settlement Commission created vested rights for taxpayers. The Court invalidated certain CBDT notifications that restricted eligibility, directed the Interim Board for Settlement to consider the pending applications, and stayed the assessment notices under Sections 143(2) and 142(1) until the settlement applications were decided.

The Jharkhand High Court dealt with the legal issue of whether an appeal under the Jharkhand Goods and Services Tax (GST) Act, 2017, can be dismissed solely on the ground of non-submission of certified copies. The case arose under Section 73 of the Act, where the petitioner, Sanjeet Kumar Bhagat, challenged a summary show-cause notice and an order dismissing his statutory GST appeal without hearing or notice, on the technical ground of the absence of certified copies.

The matter was heard by a Division Bench comprising Chief Justice Tarlok Singh Chauhan and Justice Rajesh Shankar held that adopting a hyper-technical approach in tax matters, especially those involving financial liability, is impermissible. The Court ruled that appeals filed within the prescribed time must be adjudicated on merits, and taxpayers should not be deprived of justice due to procedural lapses. Consequently, the Court quashed the appellate authority’s order and allowed the writ petition, directing the parties to appear before the appellate authority for a hearing and mandating the appeal be decided expeditiously, preferably by December 31, 2025.

The Chhattisgarh High Court examined the validity of recovering Goods and Services Tax (GST) dues from an assessee’s Electronic Credit Ledger (ECRL) under Section 79(1)(a) of the Central Goods and Services Tax (CGST) Act, 2017. The petitioner, Shivam Metallurgicals Private Limited, challenged the deduction of ₹2,87,914 from its ECRL, contending that the recovery was unauthorized, illegal, and violated principles of natural justice, especially as it had filed a rectification application and an appeal against the assessment order dated 25.02.2025.

The matter was heard by the Bench of Justice Naresh Kumar Chandravanshi, upheld the recovery, noting that the assessment order demanding ₹10,32,672 was duly served with a 30-day payment period which the assessee failed to comply with. Since no stay was granted on the assessment and the recovery from the ECRL was made before the appeal was filed, the Court held that the department acted within its legal authority under Section 79(1)(a) to recover unpaid tax from any money under its control. Consequently, the writ petition was dismissed at admission, affirming that recovery from the electronic credit ledger is valid when the GST demand remains unpaid within the prescribed time.