GST365Request a working session

Litigation intelligence for indirect-tax practices

Meet every demand with the grounds to resolve it.

Every show cause notice is the opening of a case. GST365 carries your practice's mapped precedent into the reply: the issues identified, the grounds drawn, a signable draft in hours. The questions of law are preserved from adjudication through to the writ court, the judgement always yours to make.

Request a working sessionSee the worked example
A product of IDT LAWS PRACTICE LLP · Engineered by JinaCode Systems

What this is

Litigation intelligence, delivered as software.

A senior practice carries a memory: the doctrines that turn a matter, the precedents that survive a change of regime, the ways a demand is contested and beaten. GST365 is software that holds that memory and puts it in your whole team's hands.

The precedent map

The GST question

Is an installed split air-conditioner a supply of goods, a works contract, or a service?

  • Property removable without material damage is movable, not immovable

    Supreme Court · Excise

  • Immovability turns on permanency of annexation and intent

    Supreme Court · Excise

  • Naturally bundled supplies take the character of the principal supply

    Tribunal · Service tax

  • Works contract is confined to immovable property, Section 2(119)

    High Court · VAT

  • Classification follows common parlance and function

    Supreme Court · VAT

  • The burden of reclassification rests on the department

    Supreme Court · Excise

One live GST question, resolved against the authorities that govern it. Illustrative; citations are withheld here.

01 · The corpus

Two decades of indirect-tax jurisprudence, VAT, excise and service tax, mapped to the GST provisions that inherited it.

02 · The method

Each notice reduced to its issues, each issue to its grounds, each ground to the authority and the forum that will hear it.

03 · The product

Software your practice runs, not a service you outsource. It assembles the draft; associates refine it and the partner signs.

Inside the software

A workspace your team runs, not a memo you wait for.

The same matter, carried from notice to signable draft inside GST365. Representative screens, anonymised, with citations withheld.

Matters / AC-INSTALL / Diagnostic
DiagnoseGroundDraft

The notice

Type
Show cause notice
Section
74
Issued
Limitation
Demand

Issues identified

4
  • 1

    Classification

    Classification: whether an installed air-conditioner is a supply of goods, a works contract in relation to immovable property, or a service under SAC 9987.

  • 2

    Immovability

    Immovability: whether an air-conditioner fixed for beneficial enjoyment, removable without material damage, becomes immovable property.

  • 3

    Composite supply

    Composite supply: whether the machine and its installation are naturally bundled, with the air-conditioner as the principal supply.

  • 4

    Quantification

    Quantification and penalty: the differential rate applied, and an equal penalty absent any finding of suppression.

Diagnostic completeMap grounds
Matters / AC-INSTALL / Draft
DiagnoseGroundDraft

Reply outline

  • Preliminary objections
  • Statement of facts
  • Grounds A to C
  • Questions of law
  • Prayer
  • Annexures
First draft · For counsel review

II. Grounds

Ground A. An air-conditioner affixed for beneficial enjoyment, removable without material damage, is movable property; it fails the tests of permanency and annexation that mark immovable property.

Reliance: · Supreme Court on the permanency test, an excise-era line carried into GST.

Ground B. The supply is a composite supply with the machine as the principal supply; installation is ancillary and does not change its essential character.

Draft assembledExport

Representative interface. The delivered draft carries every authority in full; your counsel reviews and signs it.

The problem

Senior time is the bottleneck, and first drafts consume it.

Notice volumes keep rising, and every serious one lands on the same few desks. The facts an associate can assemble; the issue framing, the grounds and the precedent line remain partner work, under a limitation clock.

The first draft eats days of the practice's scarcest resource. GST365 exists to return those days.

Who it is for

Some sectors never leave litigation.

Where demands are relentless and run to crores, a deeper first draft is not convenience. It is realisation preserved.

Online Gaming

Retrospective demands on face value

Real Estate & Infra

Works contract, TDR, JDA

Insurance

Co-insurance, input credit

Financial Services

ISD, cross-charge, interchange

FMCG & Retail

Classification and rate entries

E-commerce

Operator liability, TCS

Pharma & Healthcare

Exemptions, samples

Automobiles

Dealer discounts, demo credit

Exports & Services

Intermediary, place of supply

If your sector sits under a standing storm of notices, GST365 was built for it.

Worked example

From notice to signable draft

An anonymised classification dispute, abridged and redacted. This is what the software produces: a working paper your team reviews and signs.

Working paper · Reply to show cause notice

Classification & composite supply · Redacted

First draft · For counsel review

The notice. The notice proposes to treat the supply and installation of split air-conditioners at customer premises as a works contract in relation to immovable property, reclassifying the supply and raising a differential demand with interest and penalty. Ref: SCN No. dated , DIN .

I. Issues identified

  • Issue 1Classification: whether an installed air-conditioner is a supply of goods, a works contract in relation to immovable property, or a service under SAC 9987.
  • Issue 2Immovability: whether an air-conditioner fixed for beneficial enjoyment, removable without material damage, becomes immovable property.
  • Issue 3Composite supply: whether the machine and its installation are naturally bundled, with the air-conditioner as the principal supply.
  • Issue 4Quantification and penalty: the differential rate applied, and an equal penalty absent any finding of suppression.

II. Grounds, mapped to authority

  • Ground AAn air-conditioner affixed for beneficial enjoyment, removable without material damage, is movable property; it fails the tests of permanency and annexation that mark immovable property.Reliance: · Supreme Court on the permanency test, an excise-era line carried into GST
  • Ground BThe supply is a composite supply with the machine as the principal supply; installation is ancillary and does not change its essential character.Reliance: · The naturally-bundled principle, service-tax era, now Section 2(30)
  • Ground CIn any event, installation and commissioning is classifiable under SAC 9987, not a works contract in relation to immovable property under Section 2(119).Reliance: · Works-contract and classification line, VAT era

III. Draft reply, as structured

  1. 01Preliminary submissions and objection on limitation
  2. 02The equipment, the installation and the site facts
  3. 03The tests for immovable property, and the composite-supply rule
  4. 04Grounds A to C, with reliance
  5. 05Questions of law preserved for appeal
  6. 06Quantification without prejudice, and prayer

Annexure A: precedent map on movability and composite supply · Annexure B: the installation contract and site photographs

Working paper · Privileged & confidentialp. 1 of 14

Illustrative extract from a working paper, redacted and abridged. Party names and citations are withheld here; in the delivered draft, every proposition carries its authority in full.

Questions of law

The law did not begin in 2017.

A reply that merely reconciles figures concedes the frame. The matters that turn are won on questions of law: whether the provision reaches the facts at all, whether the notice is valid in form and in time, whether the demand survives doctrine the courts settled long ago.

Two decades of VAT, excise and service-tax jurisprudence did not lapse with GST. The precedent maps trace each provision to the authority that settled it, so counsel can contest a demand at its root: before the department, in appeal, and in the writ court. Built for the taxpayer's side of the table.

Doctrine, carried forward

Essential character governs classification

Settled under the central excise tariff

Rate-entry disputes under the GST notifications

A disclosed position is not suppression

Settled in the excise era

Extended limitation invoked under Section 74

A hearing must precede an adverse order

Settled across the VAT regimes

Orders passed without the Section 75(4) hearing

Taxing entries are construed strictly

Settled by the constitutional courts

Classification and exemption entries under GST

Illustrative pairings from the precedent maps; the delivered memo carries the citations in full.

Adjudication · First appeal · Tribunal · Writ jurisdiction

How it fits your practice

Diagnose. Ground. Draft. The partner signs.

01

Diagnose

The notice is read against a structured diagnostic framework: the form, the section invoked, the limitation clock, and the issues actually in play.

02

Ground

Each issue is mapped to grounds and the precedent line that carries them, including the VAT and excise era authority that survives into GST, with contrary authority acknowledged rather than hidden.

03

Draft

A signable first draft, structured the way the practice files: preliminary objections, grounds, reliance, prayer, annexures. A partner reviews, marks and signs.

Leverage, not replacement: associates produce senior-quality first drafts, and judgement stays where it belongs.

The hard questions

Where a matter turns on doctrine, not arithmetic.

The demands worth contesting are won on a fine point: a test settled decades ago, a saving buried in the mechanics. This is the calibre of question GST365 is built for, and the doctrine it carries to each. Illustrative and anonymised.

The question

Supply and installation of a split air-conditioner: a supply of goods, a works contract, or a service?

The position

A composite supply with the air-conditioner as the principal supply. The works-contract entry, confined to immovable property, does not reach it.

What decides it

The permanency test. Fixed only for beneficial enjoyment and removable without material damage, the unit stays movable: an excise-era line carried into GST.

The question

On a transfer of business as a going concern, some transferred goods cannot be accounted for. Reverse the input credit, or treat them as a deemed supply?

The position

A deemed supply under Section 35, not a reversal of input tax credit.

What decides it

The interest. Tax on a deemed supply carries none, where a credit reversal does: the same tax at a better outcome, and the point a hurried reply gives away.

The question

On the same transfer, must the transferee reverse input credit on services whose benefit continues after it?

The position

No reversal falls on the transferee.

What decides it

Input-service credit is tested in the year of receipt; the transferred right to receive the service carries no further reversal liability.

Illustrative questions from indirect-tax practice, anonymised. GST365 carries the doctrine and produces the working paper; your counsel reviews and signs it.

05 · Rigour

Doctrinal depth you can interrogate.

GST365 is built on a structured diagnostic framework reviewed by practising indirect-tax counsel: the issue taxonomies, grounds patterns and precedent maps a senior practice accumulates over years, made explicit and repeatable.

The drafting engine uses artificial intelligence; the reliability posture does not ask you to trust it. Every proposition in a draft is tied to its authority for verification, contested positions are flagged rather than smoothed over, and each draft leaves the system as a working paper for counsel review, never as a finished filing.

Who is behind it

Built by people who draft these replies.

IDT LAWS PRACTICE LLP

The practice

An indirect-tax practice that drafts show cause notice replies, argues them, and lives with the consequences. The diagnostic framework inside GST365 is the framework the practice works by.

JinaCode Systems

The engineering house

JCS builds the drafting engine and the precedent maps, to the practice's specification and under its review.

Put a notice genre you handle in front of it.

Request a working session, or ask for a sample diagnostic against a genre your practice sees: classification, ITC reversal, RCM, refund.

Request a working sessionRequest a sample diagnostic