GST Statute is a self contained Law and General Criminal Law Cannot Be Used as a Shortcut

The Court quashed criminal proceedings arising from delayed deposit of ₹8,629 GST/TDS, holding that the U.P. GST Act provides a complete mechanism for dealing with such defaults through interest, penalty and prosecution.

Since there was no allegation of misappropriation, forgery, cheating or wrongful gain, the authorities could not bypass the GST framework and invoke Section 316(5) BNS. 

Independently, the Court held that BNS could not be applied to conduct occurring in FY 2017-18, before the new penal law came into force. The authorities remain free to proceed under the GST Act in accordance with law.