Issues: Whether costs imposed in seizure proceedings could be recovered from the pensionary benefits of officers who were not parties to the writ petition and were not heard.

Analysis: The direction affecting the pensionary benefits of the concerned officers was unwarranted because those officers were neither impleaded in the writ proceedings nor afforded an opportunity of hearing before such recovery was authorised.

Conclusion: The direction permitting recovery of costs from the pensionary benefits of the concerned officers was set aside.

Issues: Whether reassessment proceedings for entry tax arising from invoices raised for alleged meter tampering should be determined in light of the subsequent status of those invoices, including arbitral awards.

Analysis: Subsequent arbitral proceedings concerning the invoices had resulted, in certain cases, in awards favouring the consumers. The appellant was therefore relegated to the Assessing Officer to place, by affidavit, the exact status of every invoice forming the basis of the reassessment notices. The reassessment is to be determined on the amount, if any, actually received against those invoices.

Conclusion: The Assessing Officer shall decide the pending reassessment proceedings in accordance with law after considering the actual amounts received against the relevant invoices.

Issues: Whether a review petition repeating grounds and prayers already considered in prior miscellaneous applications is maintainable.

Analysis: The grounds and reliefs sought had already been raised and considered in the earlier miscellaneous applications, which were dismissed after hearing both sides, with a clarification limiting the effect of the earlier order to the peculiar facts of the case. The repeated request for identical relief was therefore misconceived and without merit.

Conclusion: The review petition was not maintainable and was dismissed as defective and on merits.

Outcome: Appeals disposed of with liberty to seek revival upon obtaining leave of the Company Court.

Issues: (i) Whether the pre-deposit made by the dealer satisfied the requirement for admission of the appeal under proviso (2) to Section 31(1) of the Telangana Value Added Tax Act, 2005; (ii) Whether the penalty notice and penalty order could survive independently when the appeal against the fresh assessment was liable to be restored.

Issue (i): Whether the pre-deposit made by the dealer satisfied the requirement for admission of the appeal under proviso (2) to Section 31(1) of the Telangana Value Added Tax Act, 2005.

Analysis: The statutory condition required proof of payment of tax admitted to be due, or instalments granted, and proof of payment of 12.5% of the difference between the tax assessed and the tax admitted for the relevant period. The dealer had disputed the entire liability, and the amount already deposited in the earlier round exceeded 12.5% of the difference of tax assessed in the fresh assessment. The earlier deposit, made to sustain the prior appeal, remained available for the fresh appeal after remand.

Conclusion: The pre-deposit requirement was satisfied, and the appeal could not have been dismissed for want of further deposit.

Issue (ii): Whether the penalty notice and penalty order could survive independently when the appeal against the fresh assessment was liable to be restored.

Analysis: The penalty arose from non-payment of the demand under the fresh assessment and was dependent on the result of the appeal challenging that assessment. Once the appellate dismissal was found unsustainable and the appeal was restored for decision on merits, the penalty could not independently stand at that stage.

Conclusion: The penalty order was quashed, with liberty to impose penalty depending on the outcome of the restored appeal.

Final Conclusion: The appeals were allowed, the High Court's order was set aside, and the dealer's appeal was restored for decision on merits, with the penalty issue left to follow the result of that appeal.

Ratio Decidendi: Where the assessee has already deposited an amount exceeding the statutory pre-deposit computed on the disputed tax difference, an appeal cannot be rejected for non-compliance of the pre-deposit condition, and any penalty dependent on that assessment must await the outcome of the restored appeal.

Issues: Whether goods imported into a unit situated in a Special Economic Zone for authorised operations were entitled to exemption from entry tax under the West Bengal Special Economic Zone Act, 2003, and whether the assessment order and demand notices could survive after the administrative decision granting such exemption.

Analysis: The competent authority, in compliance with the earlier direction, determined that the goods imported into the unit located in the Falta Special Economic Zone for authorised operations were eligible for exemption from entry tax under Section 27(i) read with Section 30 of the West Bengal Special Economic Zone Act, 2003. Once that decision was taken, there remained no live controversy requiring further adjudication on the levy. The Court also noted that any future inquiry by the department regarding goods not entering the SEZ would be a matter for the department to examine in appropriate proceedings.

Conclusion: The exemption claim was accepted and the assessment order ceased to survive, along with the demand notices.

Issues: (i) Whether the review petitions filed after a delay of 522 days are maintainable and whether the delay has been satisfactorily explained; (ii) Whether the review petitions disclose any error apparent on the face of the record or any other ground of merit warranting reconsideration of the impugned orders.

Issue (i): Whether the delay of 522 days in filing the review petitions is satisfactorily explained and whether the petitions are maintainable.

Analysis: The review petitions were filed with an unexplained delay of 522 days; defects in the petitions identified in the Office Report remained uncured; the application for listing in open court was rejected. The absence of a satisfactory explanation for the delay and failure to cure the communicated defects were considered in assessing maintainability.

Conclusion: The delay is not satisfactorily explained and the review petitions are not maintainable on the ground of delay.

Issue (ii): Whether the review petitions disclose an error apparent on the face of the record or any merit justifying review.

Analysis: A review requires an error apparent on the face of the record or other recognised grounds; on examination of the petitions, the impugned orders and annexed papers, no such error or merit was found. The petitions therefore do not satisfy the substantive threshold for review even apart from the delay.

Conclusion: The review petitions do not disclose any error apparent on the face of the record or any other merit warranting review and are dismissed on merits.

Final Conclusion: The review petitions are dismissed both for inordinate and unexplained delay and for lack of merit; pending applications are disposed of.

Ratio Decidendi: A review petition must be filed within a reasonably explained time and must demonstrate an error apparent on the face of the record or other recognised grounds; failure to satisfactorily explain delay or to show such an error warrants dismissal of the review.

Outcome: Delay in filing and refiling was condoned and the special leave petition was dismissed.

Outcome: The application for condonation of an inordinate delay of 1381 days was dismissed, and the special leave petition stood dismissed.

Issues: (i) Whether the delay of 237 days in filing the Review Petition can be condoned; (ii) Whether the Review Petition merits interference with the earlier order.

Issue (i): Whether the delay of 237 days in filing the Review Petition can be condoned.

Analysis: The Court examined the applicant's explanation for delay and found it unsatisfactory. The petition was considered despite the admitted delay, but the reasons provided did not justify condonation under the governing principles for extension of time and laches applicable to review proceedings.

Conclusion: Delay not condoned; decision adverse to the Revenue and favourable to the assessee.

Issue (ii): Whether the Review Petition merits interference with the earlier order.

Analysis: On consideration of the Review Petition on merits, the Court found no arguable ground to reopen or review the order dated 16.04.2025 in Civil Appeal No.1208 of 2025, applying the narrow scope of review and the requirement of demonstrable error or miscarriage of justice for review relief.

Conclusion: No case made out for review; review petition dismissed on merits; decision adverse to the Revenue and favourable to the assessee.

Final Conclusion: The Review Petition is dismissed both on the ground of unexplained delay and on merits, and any pending interlocutory application is disposed of.

Ratio Decidendi: A review petition will not be entertained where there is unexplained, inordinate delay and where no arguable error or manifest injustice is shown to justify reopening a final order.

Outcome: Delay was condoned, but no interference was called for in exercise of jurisdiction under Article 136 of the Constitution of India, and the special leave petition was dismissed.

Outcome: Delay condoned. The Special Leave Petition was dismissed and the accompanying interlocutory application(s), if any, stood disposed of.

Outcome: The miscellaneous applications were dismissed; the prior order was clarified to be confined to the peculiar facts of the case and not to affect other matters under the Rajasthan Sales Tax Act, 1994 or the Rajasthan Value Added Tax Act, 2003.

Outcome: Delay condoned. The impugned order was modified to waive the costs imposed by the High Court, and the special leave petition was dismissed.

Issues: Whether the appeals were barred from being pursued before the Supreme Court on account of the monetary threshold prescribed in the circular governing tax effect, and whether that threshold applied to pending appeals arising under the repealed sales tax regime.

Analysis: The circular dated 26.06.2024 prescribed a monetary limit of Rs. 2 crore for appeals before the Supreme Court and expressly referred to disputes involving tax demand, with the aggregate tax in dispute alone to be considered for applying the limit. The Court read the expression used in the circular, including the direction that appeals should not be pursued, as applicable not merely to fresh filings but also to pending appeals. The reliance placed on the repealing provision was rejected for the purpose of overriding the circular. The substantive question of law raised in the appeal was not examined and was left open.

Conclusion: The appeals were held to be barred by the monetary limit in the circular and were dismissed in favour of the assessee.

Outcome: The appeal was disposed of with no interference in the High Court's order.

Outcome: The special leave petitions were dismissed as not pressed, with liberty to avail the remedy under the West Bengal Sales Tax (Settlement of Dispute) Act, 1999 as amended in 2025.

Issues: Whether the interim order dated 03.06.2024 staying the impugned order and recovery notices should be made absolute till the final decision of the pending writ petition.

Analysis: The appeal was disposed of on the basis that the writ petition remained pending before the High Court and the interim order had already operated for more than one year. The prayer to continue the interim protection until final adjudication of the writ petition was found reasonable and acceptable.

Conclusion: The interim order was made absolute and was directed to operate till the final decision in the writ petition.

Outcome: The petitions were not pressed and were dismissed, with liberty to the petitioners to avail the remedy before the competent authority under the West Bengal Sales Tax (Settlement of Dispute) regime as amended in 2025.