Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 04/08/2026 Introduction Procedural amendments in tax law often appear straightforward until they collide with proceedings that are already underway. One such issue arose after the Finance Act, 2025 substituted the proviso to Section 107(6) of the CGST Act with…
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From the Department’s Burden to the Taxpayer’s Burden: How Madras High Court Flips the Onus on Extended Period Notices Under GST
Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 03/08/2026 Introduction Every so often, a judgment does more than decide a dispute—it reshapes the way an entire area of law is understood and applied. The recent decision of the Hon’ble Madras High Court in Fastenex Pvt. Ltd. &…
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No Notification No Portal – P&H High Court Denies Deemed Service of GST Orders on a non-notified GST Portal
Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 29/07/2026 Introduction For every registered taxpayer under the GST regime, the GST Common Portal has become the primary interface with the tax administration. Registration, return filing, refund applications, and departmental communications are all routed through the portal, making it…
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From Common Adjudicating Authority to the Jurisdictional Commissioner: Has CBIC Quietly Rewritten the Jurisdictional Philosophy for DGGI Cases?
Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 27/07/2026 Introduction The CBIC has recently issued Circular No. 256/02/2026-GST dated 25 July 2026, prescribing the procedure for filing departmental appeals before the GST Appellate Tribunal (GSTAT) in matters adjudicated by the Common Adjudicating Authority (CAA)—commonly referred to as…
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Crossing the line
Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 24/07/2026 Introduction The GST Council is the cornerstone of India’s cooperative federal tax framework. While it is constitutionally entrusted with making recommendations on GST, the power to issue notifications under the CGST Act rests with the Central Government. An…
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When the Notice is AI-Assisted but the Officer isn’t: SRO India and the Case against Mechanical Adjudication in GST
Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 23/07/2026 Introduction Artificial Intelligence is rapidly finding its place across legal practice—from research and drafting to document review. Yet an important constitutional question arises when AI crosses the line from assisting legal professionals to performing functions that the law…
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‘Possibility’ is not ‘Proceeding’: Orissa High Court curbs routine Withholding of GST Refunds under Section 54(11)
Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 20/07/2026 Introduction: Can GST Refunds Be Withheld Merely Because the Department May File an Appeal? Refunds constitute one of the most litigated aspects of the GST regime. While the statutory framework seeks to ensure timely release of amounts lawfully…
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Correction, Not Reconstruction – The Settled Limits on Corrigenda in Tax Adjudication
Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 14/07/2026 Introduction: Can a Corrigendum Rewrite a Show Cause Notice? You have attended the personal hearing, filed a comprehensive reply, addressed every allegation raised in the Show Cause Notice, and the matter stands reserved for final orders. The litigation…
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Hard Locking Without the Key: The Missing Legislative framework behind the GSTR-3B ITC Lock
Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 18/07/2026 Introduction: Can Technology Override the Statute? The GST ecosystem is on the verge of one of its most significant procedural transformations. With the proposed hard-locking of GSTR-3B, taxpayers may soon lose the ability to manually edit Input Tax…
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Five Hundred and Four: GSTAT’s Reckoning with the Limits of Limitation
Author: Ashwarya Sharma, Advocate, Co-Founder & Legal Head, RB LawCorpPublished on: 14/07/2026 Introduction: When Limitation Becomes the Largest Question Before GSTAT “The law of limitation is a law of peace, justice and repose.” Few principles in procedural law have enjoyed such enduring acceptance. Limitation statutes exist not merely to regulate…