Statutory appeal limitation bars excess condonation while implemented registration restoration limits later departmental challenges in GST disputes.
Section 107 fixes a mandatory appellate timetable: an appeal must be filed within three months, with condonation on sufficient cause for no more than one additional month. The First Appellate Authority has no equitable or inherent jurisdiction beyond that ceiling, and Article 226 relief cannot enlarge its statutory power. Yet, where delayed appeals were implemented, registrations restored, compliance verified, and businesses resumed operations, a later departmental challenge may be incapable of effective relief because reversal could disturb supplies, invoicing, and recipients' input tax credit. Revocation and appeal remain distinct remedies, though an appeal remains subject to statutory limitation. (AI Summary)

Employment agreement disputes remain outside commercial jurisdiction despite remuneration, sales-linked claims, confidentiality clauses, or intellectual-property assignments.
Employment agreements requiring personal service are service disputes rather than commercial disputes, notwithstanding remuneration, high stakes, sales-related payments, confidentiality obligations, non-compete conditions, or intellectual-property assignments. Claims for salary, reimbursements, incentives, or commission arising from that relationship are outside Commercial Court jurisdiction. Where such a claim is filed before a Commercial Court, the plaint should be returned for presentation before the appropriate court rather than dismissed. (AI Summary)

Customs pre-deposit discretion should be restored to prevent rigid appeal barriers and reduce avoidable writ litigation.
Mandatory pre-deposit in customs appeals requires seven and a half per cent deposit for first appeals and certain Tribunal appeals, and ten per cent for Tribunal appeals against Commissioner (Appeals) orders, subject to an overall cap of rupees ten crores. The post-2014 regime removed appellate discretion to waive or reduce pre-deposit. Restoration of guided discretion is advocated by reference to prima facie merits, applicable precedents, relative case strength, financial capacity, business operations, and hardship affecting continuity and employment. (AI Summary)

Same subject matter in GST proceedings requires identity of liability, not shared registered persons, periods, suppliers, or ITC.
Section 6(2)(b) of the CGST Act bars parallel action by Central and State GST authorities only where both proceedings concern the same liability, deficiency, or contravention requiring adjudication. Common registered person, financial year, supplier, input tax credit amount, or overlapping factual background does not establish identity. Changing provisions cannot avoid the bar if the underlying contravention is unchanged; however, a later fraud-based input tax credit proceeding involving invoices without actual supply may remain distinct from a general input tax credit eligibility or mismatch proceeding. (AI Summary)

Uncrystallized provident fund interest and damages remain contingent liabilities, allowing resolution plans to preserve CIRP certainty and timelines.
Provident-fund sums due to employees are excluded from the liquidation estate, but statutory interest and damages that were not determined before commencement of the corporate insolvency resolution process may be contingent liabilities. A resolution plan may provide for determined provident-fund dues without separately providing for uncrystallised interest and damages. The committee of creditors may reserve an amount for such contingencies, but is not required to do so merely because liability may later arise. Resolution applicants must be able to identify assumed liabilities within the fixed insolvency timeline. (AI Summary)

Advocate-client privilege protects confidential communications but permits GST inquiry into counsel's own alleged operational conduct under controlled digital safeguards.
Advocate-client privilege protects confidential professional communications, not every record held in an Advocate's office or digital device. A GST inquiry may distinguish privileged advice from the Advocate's own alleged commercial, financial or operational conduct where prima facie material connects that conduct to the investigation. Search powers may apply to an Advocate's cabin within authorised premises, while examination of seized electronic data requires cloning, supervised access, segregation of unrelated client files, and use confined to material relevant to the identified investigation. (AI Summary)

Rectification applications require written decisions, while suo motu correction remains discretionary and adverse amendments require prior hearing.
Rectification of mistakes apparent from the record permits income-tax authorities to amend their own orders and specified intimations, but matters considered and decided in appeal or revision are excluded. Suo motu rectification is discretionary. On an application by the assessee, deductor, collector, or, in relevant first-appeal matters, the Assessing Officer, the authority must issue a written order making the amendment or refusing the claim within six months. Adverse amendments require prior notice and a reasonable opportunity of hearing; consequential refunds must be made and demand notices served where liability increases. (AI Summary)

Marginal relief under the new tax regime limits tax on qualifying income above the rebate threshold.
Marginal relief is proposed for resident individuals under the new tax regime whose total income exceeds Rs. 7 lakh. Tax payable must not exceed the income exceeding that threshold. Tax is computed before rebate, and the excess income over Rs. 7 lakh is determined. Where pre-rebate tax exceeds the excess income, the Section 87A rebate equals the difference; where the difference is negative, no rebate is allowed. (AI Summary)

Good-faith protection for tax officers depends on lawful adjudication, not procedural violations that undermine taxpayer safeguards.
Section 157 of the CGST Act limits suits, prosecutions and other legal proceedings against designated Tribunal personnel and tax officers to acts done or intended in good faith under the Act or rules. Good faith is not automatic immunity where adjudication departs from procedural safeguards, including personal hearings, the confines of show cause notices, correct demand provisions, proportionate penalties, statutory payment opportunities and consideration of taxpayer replies. Appellate scrutiny may test whether such orders comply with statutory requirements and procedural fairness. (AI Summary)

Digital compliance strengthens board governance through automated oversight, cybersecurity, privacy controls, and responsible artificial intelligence supervision.
Digital compliance integrates technology into corporate and board functions to support observance of applicable laws, internal policies, and governance standards. It includes electronic records, digital board meetings, automated monitoring, electronic filings, digital signatures, secure document management, and data protection. Board oversight covers cybersecurity, personal data protection, digital risk, artificial intelligence governance, fraud prevention, business continuity, and digitally supported ESG disclosures. Company secretaries support digital governance through regulatory advice, timely compliance, electronic records, digital due diligence, and ethical governance. (AI Summary)

Reasoned GST adjudication requires genuine consideration of taxpayer replies and evidence; unexplained rejection breaches natural justice despite appellate remedies.
GST adjudication must result in a reasoned or speaking order demonstrating genuine consideration of the taxpayer's reply, submissions, and supporting material. An order that merely records receipt of a reply but rejects it without addressing the contentions or documents relied upon lacks the reasons necessary to disclose application of mind. Availability of an alternative statutory appeal does not preclude writ jurisdiction where principles of natural justice are breached by a non-speaking order. (AI Summary)

Merchant discount rate on UPI payments may attract GST on payment-processing services, subject to contractual and statutory conditions.
MDR on specified UPI transactions, if introduced, would ordinarily be a payment-processing charge collected from or deducted from the merchant's settlement, without necessarily creating a separate customer charge. GST, where applicable, would generally apply to the separate payment-processing or acquiring service and not to the amount transferred through UPI. The ultimate burden may be absorbed, renegotiated or reflected in prices. Eligible registered persons may claim input tax credit on GST charged on the service if statutory conditions are met, while composition taxpayers, unregistered persons and persons making exempt supplies may face unrecoverable costs. (AI Summary)

GST on UPI merchant discount charges applies to payment-processing services, while eligible businesses may claim input tax credit.
MDR on specified P2M UPI payments is treated as consideration for a separate payment-processing service. GST at 18% applies to the MDR actually charged, rather than directly to the underlying supply or the GST in the customer invoice, although MDR may be calculated on the gross payment. A registered merchant making taxable supplies may claim input tax credit on GST paid on MDR where the service is used for business and normal eligibility, documentation and credit restrictions are satisfied; exempt, composition and unregistered merchants may bear that GST as cost. (AI Summary)

Input tax credit verification requires reasoned scrutiny of invoices and reconciliations before demands, reducing avoidable GST disputes.
Input tax credit mismatch adjudication requires verification of invoice-wise evidence before confirming GST demands. Where credit claimed in Form GSTR-3B is absent from Form GSTR-2A, the proper officer must examine tax documents, receipt of goods or services, supplier payment including tax, required reversals, and the time limit for availing credit. Taxpayers must furnish requested information, while adjudication must consider reconciliations, follow binding circular-based verification requirements, and provide personal hearing. (AI Summary)

Sanctioned GST refunds require cash disbursement when business closure makes the electronic credit ledger unusable for the taxpayer.
Cash disbursement of a sanctioned GST refund is required where permanent business closure and surrender or cancellation of registration make re-credit of input tax credit in the Electronic Credit Ledger unusable. Although the normal refund mechanism releases only the cash-paid component in cash and re-credits the ITC-debited component, that mechanism presumes a going concern with future tax liabilities. Where the ledger has become non-functional, no statutory prohibition prevents payment of the sanctioned amount in cash or to the taxpayer's bank account, with applicable interest in accordance with law. (AI Summary)

Time-extension charges in CIRP remain outside resolution costs when project delays arise from the defaulting developer.
Time-extension charges under development lease deeds were examined for classification as corporate insolvency resolution process costs where homebuyers continued a stalled housing project through a Committee of Creditors-approved Pool and Build mechanism. The charges were characterised as penal consequences of the developer's delay rather than costs incurred by the resolution professional for project continuation. Their inclusion would transfer the defaulting developer's liability to homebuyers and the resolution applicant. Charges, including those sought under an extended policy beyond the original three-year lease arrangement, were excluded from CIRP costs. (AI Summary)

Depreciation eligibility may turn on whether asset use means actual working days or an elapsed period under revised wording.
Depreciation on newly acquired assets is restricted to 50% of the prescribed rate where the asset is acquired during the tax year and put to use for less than 180 days. The 2025 wording omits the expression "for a period" used in the corresponding 1961 provision. While the earlier expression is understood to refer to the elapsed period of use rather than actual working days, the revised wording may support an interpretation based on actual operational days, potentially causing disputes over full-year depreciation eligibility. (AI Summary)

GST document authentication requires a valid signature; portal upload and officer login alone cannot establish legal validity.
Rule 26(3) makes authentication of GST notices and adjudication orders mandatory through the prescribed signature or verification method. Portal upload, reference numbers, electronic generation, and an officer's authenticated login may evidence system access or transmission, but cannot replace authentication of the statutory document. Complete absence of authentication is a foundational defect: the notice or order is non est, cannot be cured as a minor procedural error, and cannot sustain recovery founded on it. (AI Summary)

Currency seizure as evidence may continue beyond the notice period when classified as a thing rather than goods.
Currency seized as evidence of hawala transactions, illegal gratification, or fraudulent licence closures may be a thing under Section 110(3) rather than goods under Section 110(1). The six-month show-cause notice safeguard applies to goods seized for confiscation, not to documents or things useful or relevant to Customs proceedings. Retention of currency as evidentiary material has no prescribed outer time limit, but requires a bona fide seizure and demonstrable nexus to the investigation. (AI Summary)

Verified case-law citations remain essential because unverified AI-generated authorities can undermine judicial and quasi-judicial decision-making.
A zero-tolerance approach is identified under which fabricated or non-existent AI-generated precedents cannot be treated as valid legal authority, even where the false material did not directly influence reasoning. Rigorous verification of case law is an essential responsibility of adjudicating officers. AI-assisted tools may support legal research but cannot replace human diligence in confirming the authenticity of authorities relied upon. (AI Summary)