Notification No. 56/2023-CT ultra vires section 168A for extending timeline for passing Order u/s 73(9) for FY 2018-19 and 2019-20

Employees cannot be penalized for corporate tax liabilities unless they directly benefit from evasion

A genuine buyer should not be punished for a supplier's failure to deposit tax. Authorities must follow due process and first attempt to recover tax from the defaulting supplier.

Department should act only against defaulting suppliers, unless collusion is proved

Court  clarified that retrospective cancellation doesn’t automatically strip bona fide purchasers of ITC, provided they transacted with due diligence. The case demarcates innocent buyers from fraudulent suppliers under GST and protects legitimate business interests.

Mere upload of notice on portal isn't enough if taxpayer remains unaware

ITC cannot be denied merely due to supplier registration cancellation

Issue of Show Cause Notice is must u/s 73 before initiating recovery proceedings 

Recovery of short-paid interest on delayed tax payments must comply with Section 73(1)’s requirement of a SCN followed by personal hearing. The failure to follow such procedure renders any demand or enforcement action invalid, upholding both statutory mandate and natural justice.