Issues: (i) Whether the addition of alleged on-money could be sustained on the basis of a third-party Excel sheet and statements, without any incriminating material directly linked to the assessee; (ii) Whether the addition could survive when the assessee was denied supply of the relied-upon material and opportunity to cross-examine the witnesses.

Issue (i): Whether the addition of alleged on-money could be sustained on the basis of a third-party Excel sheet and statements, without any incriminating material directly linked to the assessee.

Analysis: The addition was founded on a pen drive/Excel sheet recovered from a third party and statements of persons connected with the developer. No cash voucher, receipt, ledger, signed document, or other material directly attributable to the assessee was found during the search or post-search proceedings. The assessee had denied payment of any cash. The property was also purchased at a value higher than the stamp duty valuation, and no comparable transaction from the same shopping mall was brought on record to support the alleged on-money valuation.

Conclusion: The addition could not be sustained on the basis of such uncorroborated third-party material and was rightly deleted.

Issue (ii): Whether the addition could survive when the assessee was denied supply of the relied-upon material and opportunity to cross-examine the witnesses.

Analysis: The authorities below relied upon statements recorded during search, but the relied-upon material was not effectively confronted to the assessee, and no opportunity of cross-examination was granted. In such circumstances, the Revenue was required to corroborate the evidence independently, especially when the assessee had specifically disputed the alleged cash payment. The failure to provide cross-examination and to establish corroboration rendered the foundation of the addition legally infirm.

Conclusion: The denial of cross-examination and absence of corroborative evidence vitiated the addition.

Final Conclusion: The composite addition sustained in the assessment was unsustainable in law and fact, and the assessee's appeals succeeded.

Ratio Decidendi: An addition based solely on uncorroborated third-party material and statements, without direct incriminating evidence against the assessee and without affording cross-examination, cannot be sustained.

Issues: Whether the assessee was entitled to proportionate deduction of capital gains under Section 54GB for investment in equity shares of an eligible start-up.

Analysis: The applicable proviso extended the benefit for investments in an eligible start-up where the residential property was transferred up to 31 March 2022; hence, a transfer in September 2021 was within the eligible period. Section 54GB contained no Rs.50 lakh ceiling and expressly permitted proportionate non-chargeability of capital gains where the cost of the new asset was lower than the net consideration. The record established subscription to equity shares, the requisite shareholding, and utilisation towards new assets. The appellate findings concerning lack of manufacturing activity, deficient shareholding and non-utilisation were not findings in the assessment order and disregarded confirmations and financial material furnished by the investee company. The adverse findings were therefore contrary to the record.

Conclusion: The assessee was entitled to deduction of Rs.1,48,16,241 under Section 54GB of the Income-tax Act, 1961.

Issues: (i) Whether absence of an express dissolution or irrevocability clause justified rejection of registration under Section 12AB of the Income-tax Act, 1961. (ii) Whether payments made to persons connected with the trust amounted to prohibited benefit to specified persons under Section 13(3) of the Income-tax Act, 1961, warranting denial of registration and approval under Section 80G of the Income-tax Act, 1961.

Issue (i): Whether absence of an express dissolution or irrevocability clause justified rejection of registration under Section 12AB of the Income-tax Act, 1961.

Analysis: At the registration stage, the relevant examination concerns the charitable character of the objects and the genuineness of the proposed activities, not hypothetical future contingencies. The trust deed provided that its assets could not be used for purposes other than the trust's charitable objects. The absence of an express dissolution or irrevocability clause was therefore treated as a technical objection and could not, by itself, justify rejection of registration.

Conclusion: Absence of an express dissolution or irrevocability clause was not a valid ground to reject registration under Section 12AB of the Income-tax Act, 1961.

Issue (ii): Whether payments made to persons connected with the trust amounted to prohibited benefit to specified persons under Section 13(3) of the Income-tax Act, 1961, warranting denial of registration and approval under Section 80G of the Income-tax Act, 1961.

Analysis: The payments to the concerned persons were found to relate to land acquisition and expenditure incurred for fulfilling the trust's objects. The alleged payment to another connected person was factually incorrect, as the amount had been paid to an educational trust. The payments were consequently treated as expenditure for charitable purposes rather than as personal benefit to specified persons. The objects were genuinely charitable and the proposed activities were aligned with those objects.

Conclusion: The payments did not confer prohibited benefit on specified persons in violation of Section 13(3) of the Income-tax Act, 1961, and did not justify denial of registration or approval.

Final Conclusion: The trust was entitled to registration under Section 12AB after renewal of its provisional registration, with consequential consideration and grant of approval under Section 80G.

Ratio Decidendi: Registration of a charitable trust cannot be denied solely for want of an express dissolution or irrevocability clause where its objects are genuinely charitable and its proposed activities are aligned with those objects; expenditure shown to advance those objects does not constitute prohibited benefit to specified persons without proof of such benefit.

Issues: Whether the assessment order passed under Section 62 of the Tamil Nadu Goods and Services Tax Act, 2017 could survive when the return was filed belatedly and the time limit under the proviso was treated as directory.

Analysis: The Court followed its consistent line of decisions that the period prescribed for filing the return under Section 62 is directory. It held that where the return is ultimately filed, even beyond the prescribed period, the best judgment assessment cannot continue to operate and the impugned assessment loses its basis. The Court declined to depart from the binding precedents relied upon before it.

Conclusion: The assessment order was quashed and the writ petition was allowed in favour of the assessee.

Issues: Whether the Order-in-Original raising service tax demand based on income-tax return disclosures and departmental inputs should be set aside and the matter remitted to the stage of reply to the show-cause notice.

Analysis: The petitioner was denied effective participation in the adjudication and sought an opportunity to meet the show-cause notice on merits. The Court noted the earlier order in connected matters, where similar disputes had been relegated for reconsideration with specific observations for the to examine, including the applicability of Section 65B(44) of the Finance Act, 1994, the negative list, exemption under Notification No. 25/2012-ST dated 28.06.2012, liability under the applicable reverse charge framework, and limitation. The order under challenge was an ex parte Order-in-Original, and the Court found it appropriate to follow the same course adopted in the connected matters.

Conclusion: The Order-in-Original was set aside and the matter was remitted to the stage of reply to the show-cause notice, with liberty to the petitioner to file a fresh reply and all contentions kept open.

Issues: (i) whether the assessee trust could be assessed as an Association of Persons and subjected to tax in its own hands; (ii) whether the trust was a revocable trust within the meaning of sections 61 to 63 of the Income-tax Act, 1961, so that its income was taxable in the hands of the beneficiaries and not the trust; (iii) whether section 164 of the Income-tax Act, 1961 applied to the assessee and justified the additions and disallowances made by the Assessing Officer.

Issue (i): whether the assessee trust could be assessed as an Association of Persons and subjected to tax in its own hands.

Analysis: The trust was formed under the regulatory framework governing securitisation companies and reconstruction companies and operated as a structured vehicle for asset reconstruction. The beneficiaries were identifiable and their shares were determinable with reference to the trust documents and contribution records. The arrangement did not exhibit the elements of common volition, joint management, or a voluntary coming together for a common purpose that are necessary to constitute an Association of Persons.

Conclusion: The assessee could not be assessed as an Association of Persons, and this contention of the Revenue was rejected.

Issue (ii): whether the trust was a revocable trust within the meaning of sections 61 to 63 of the Income-tax Act, 1961, so that its income was taxable in the hands of the beneficiaries and not the trust.

Analysis: Sections 61 to 63 were treated as a self-contained code dealing with revocable transfers. A transfer is revocable where the governing instrument provides for re-transfer of the income or assets, or confers a right to re-assume power over them. The existence of a collective or conditional mechanism for revocation does not destroy the revocable character of the transfer. On the trust deed and the regulatory structure, the contribution arrangement satisfied the statutory requirements of revocability.

Conclusion: The trust was held to be a revocable trust governed by sections 61 to 63, and the income was not taxable in the hands of the trust.

Issue (iii): whether section 164 of the Income-tax Act, 1961 applied to the assessee and justified the additions and disallowances made by the Assessing Officer.

Analysis: Once the income was held to fall within the revocable transfer provisions, section 164 had no independent application. The additions made on the footing that the trust was taxable as an AOP and that interest and other receipts were to be assessed differently, along with the disallowances of expenses, could not survive.

Conclusion: Section 164 was held inapplicable and the additions and disallowances were deleted.

Final Conclusion: The Revenue's appeals failed, and the relief granted by the first appellate authority was sustained on the ground that the securitisation trust was a revocable pass-through arrangement and not an AOP taxable in its own hands.

Ratio Decidendi: A securitisation trust formed under the statutory and regulatory framework, where the trust deed provides a revocation mechanism and the beneficiaries' shares are determinable, is a revocable trust under sections 61 to 63 of the Income-tax Act, 1961, cannot be treated as an Association of Persons, and section 164 does not apply.

Issues: (i) Whether the delay in filing the quantum appeal and the penalty appeal for assessment year 2022-23 should be condoned and the matters restored for decision on merits; (ii) whether penalty under section 270A of the Income-tax Act, 1961 was leviable for assessment year 2020-21 on the disallowance of deduction under section 80P, including the amount relating to interest on deposit with MSEDCL.

Issue (i): Whether the delay in filing the quantum appeal and the penalty appeal for assessment year 2022-23 should be condoned and the matters restored for decision on merits.

Analysis: The appeals for assessment year 2022-23 were dismissed by the first appellate authority solely on the ground of delay. The Tribunal applied the settled approach that substantial justice should prevail over technical considerations where the delay is not shown to be deliberate. It accepted the explanation that the assessment order had gone to an employee's email account and the assessee was therefore unable to file the appeals in time. In these circumstances, the Tribunal found it to restore both matters to the first appellate authority for condonation of delay and adjudication on merits after giving opportunity of hearing.

Conclusion: The delay was to be condoned and both appeals for assessment year 2022-23 were restored for fresh decision on merits.

Issue (ii): Whether penalty under section 270A of the Income-tax Act, 1961 was leviable for assessment year 2020-21 on the disallowance of deduction under section 80P, including the amount relating to interest on deposit with MSEDCL.

Analysis: For assessment year 2020-21, the quantum dispute had already been substantially resolved in the assessee's favour, with deduction under section 80P allowed for the major part of the disallowance relating to interest from cooperative banks. Penalty was therefore unsustainable on that part, as there was no basis to treat the related addition as warranting penalty once the underlying claim was held allowable. As regards the balance amount relating to the MSEDCL deposit, the Tribunal treated the issue as debatable and noted that penalty is not leviable on a debatable claim where the addition turns on a contested legal characterisation rather than concealment or deliberate inaccuracy.

Conclusion: Penalty under section 270A was deleted in full for assessment year 2020-21.

Final Conclusion: The quantum and penalty matters for assessment year 2022-23 were sent back for adjudication on merits, while the penalty for assessment year 2020-21 was annulled.

Ratio Decidendi: Where delay is not deliberate and substantial justice requires a merits adjudication, the appellate forum may condone delay and restore the matter; and penalty for under-reporting cannot survive on amounts arising from a debatable disallowance or from additions that are not ultimately sustainable on the governing legal position.

Issues: (i) Whether the applicant's two models of food supply amount to a composite supply and are classifiable as outdoor catering service under SAC 996334; (ii) Whether the supply is taxable at 5% without input tax credit and whether the applicant has an option to pay 18% with input tax credit.

Issue (i): Whether the applicant's two models of food supply amount to a composite supply and are classifiable as outdoor catering service under SAC 996334.

Analysis: The supply involved preparation of food, and in one model also included manpower for serving and on-site event support. In the other model, the food was prepared at the applicant's premises and transported to the recipient's location for occasional events. The combined supplies were naturally bundled in the ordinary course of business and therefore constituted a composite supply. Under Schedule II to the Central Goods and Services Tax Act, 2017, composite supplies of food for consideration are treated as a supply of service. The service description in the classification scheme specifically covers catering services in exhibition halls, events, marriage halls and other outdoor or indoor functions, which corresponds to the applicant's activity.

Conclusion: The applicant's food supply models are composite supplies treated as supply of service and are classifiable under SAC 996334.

Issue (ii): Whether the supply is taxable at 5% without input tax credit and whether the applicant has an option to pay 18% with input tax credit.

Analysis: The relevant entry for outdoor catering at premises other than specified premises applies to the applicant's activity. The concessional rate under Entry 7(iv) applies subject to the condition that input tax credit on goods and services used in supplying the service is not taken. The broader residual entry for accommodation, food and beverage services does not override the specific entry. The explanation clarifies that supplies covered by the specific outdoor catering entry remain governed by that entry and cannot be shifted to the residual rate at the taxpayer's option.

Conclusion: The applicant is liable to pay GST at 5% without input tax credit and has no option to pay 18% with input tax credit.

Final Conclusion: The ruling fixes the applicant's outdoor catering supplies under the specific concessional service entry and rejects the claimed option to adopt the residual higher-rate entry with credit.

Ratio Decidendi: A specifically enumerated catering entry in the service-rate notification governs the supply where its conditions are met, and such supply cannot be shifted to a residual higher-rate entry merely because input tax credit is otherwise available under that residual entry.

Issues: Whether a cheque presented for the full amount, after part payments were made by the drawer and without the endorsement contemplated by the Negotiable Instruments Act, still represented a legally enforceable debt so as to attract an offence under Section 138.

Analysis: The legal position applied was that a cheque must represent a legally enforceable debt on the date of maturity or presentation. Where the drawer makes part payment after the cheque is drawn but before encashment, the debt reflected by the cheque is reduced. In such a situation, the payment has to be endorsed on the instrument in the manner required by Section 56 of the Negotiable Instruments Act, 1881, so that only the balance amount may be negotiated. If the cheque is presented for the full sum despite part payment and without such endorsement, it does not represent the legally enforceable debt. On the admitted facts, part payments were made after the first dishonour and the cheque was later re-presented for the full amount without the required endorsement.

Conclusion: The offence under Section 138 was not attracted, and the acquittal was justified.

Ratio Decidendi: For an offence under Section 138 of the Negotiable Instruments Act, 1881, the dishonoured cheque must represent the legally enforceable debt on the date of maturity or presentation, and part payments made before encashment must be endorsed on the cheque so that only the balance can be enforced.

Issues: (i) Whether the transfer pricing adjustment made by reclassifying SEIS reversal as operating expense and foreign exchange fluctuation as non-operating income was sustainable; (ii) Whether working capital adjustment under TNMM could be denied for want of daily working capital data.

Issue (i): Whether the transfer pricing adjustment made by reclassifying SEIS reversal as operating expense and foreign exchange fluctuation as non-operating income was sustainable.

Analysis: The adjustment was based on a recomputation of the assessee's operating margin by treating the SEIS reversal differently from the assessee's consistent treatment of SEIS items as non-operating, and by excluding foreign exchange gains arising from realization of export receivables from operating results. The record showed that the SEIS reversal arose from earlier accrual of incentive income that later stood reduced by revised rates and market conditions, while the foreign exchange fluctuation was directly connected with operating receivables from the service transaction. The resulting operating margin, once these items were correctly classified, remained within the arm's length range determined in the transfer pricing exercise.

Conclusion: The transfer pricing adjustment on this issue was not sustainable and was deleted in favour of the assessee.

Issue (ii): Whether working capital adjustment under TNMM could be denied for want of daily working capital data.

Analysis: Working capital adjustment is a recognised comparability adjustment under TNMM intended to neutralise differences in receivables, payables, and inventory that affect profitability. The absence of daily data was held not to be a valid reason to refuse the adjustment, because reasonably reliable approximations based on available balance-sheet figures may be used where they reasonably reflect the working capital position. The objections based on intra-year movements and differences in cost of capital were treated as matters relating to computation, not grounds to deny the adjustment altogether. On the computation placed on record, the adjusted comparable margin was below the assessee's margin.

Conclusion: Working capital adjustment was allowable and the assessee succeeded on this issue.

Final Conclusion: The substantive transfer pricing additions did not survive, and the assessee obtained relief on the core disputed adjustments, while the appeal was otherwise disposed of accordingly.

Ratio Decidendi: In TNMM benchmarking, items intrinsically linked to operating receipts must be classified consistently, and working capital adjustment cannot be denied merely because daily data is unavailable if a reasonable and reliable approximation can be made from the material on record.

Issues: (i) Whether the demand under Rule 6 of the Cenvat Credit Rules, 2004 could be sustained by applying the percentage reversal mechanism where the assessee had availed only proportionate credit and capital goods credit; (ii) whether the extended period of limitation could be invoked in the absence of suppression or wilful misstatement.

Issue (i): Whether the demand under Rule 6 of the Cenvat Credit Rules, 2004 could be sustained by applying the percentage reversal mechanism where the assessee had availed only proportionate credit and capital goods credit.

Analysis: The credit taken on capital goods formed the major part of the disputed amount. Rule 6(4) permits capital goods credit unless such goods are used exclusively for exempted services, and therefore common use does not by itself justify denial of credit. The remaining credit was shown to be only proportionate credit relatable to taxable output services, which is permissible under Rule 6(3)(ii) and the procedure under Rule 6(3A). The percentage-based demand on the entire exempted turnover was therefore inconsistent with the statutory scheme.

Conclusion: The demand on merits was unsustainable and the issue was decided in favour of the assessee.

Issue (ii): Whether the extended period of limitation could be invoked in the absence of suppression or wilful misstatement.

Analysis: The assessee was registered, filing ST-3 returns, and the relevant credit pattern was reflected in the records. The controversy arose from interpretation of the applicable Rule 6 framework rather than from any concealment of material facts. Since the Department did not establish any positive act of suppression with intent to evade tax, invocation of the extended period was not justified.

Conclusion: The extended period was not invocable and the issue was decided in favour of the assessee.

Final Conclusion: The impugned demand and penalty could not survive either on merits or on limitation, and the appeal succeeded with consequential relief.

Ratio Decidendi: Where an assessee has taken only proportionate Cenvat credit and the capital goods credit is not hit by the exclusivity bar under Rule 6(4), a blanket percentage demand on exempted turnover is impermissible; in the absence of suppression or wilful misstatement, the extended period cannot be invoked.

Issues: Whether the Revenue could recover dues of the company from the personal bank account of its director under the post-GST recovery provisions, and whether the lien could be continued beyond the director's own penalty liability.

Analysis: The recovery machinery under Section 87 of the Finance Act, 1994 authorises recovery from money owing to the person against whom the liability exists and permits a garnishee type recovery from third parties, but it does not create a personal liability against a director for the company's tax dues. Section 174(2)(e) of the Central Goods and Services Tax Act, 2017 preserves recovery of crystallised liabilities under the repealed regime, but only to the extent such liability legally exists. The director's liability in the present case was confined to the penalty imposed under Section 78A of the Finance Act, 1994, and that amount had already been paid. In these circumstances, continued attachment of the director's personal account for the company's remaining dues was beyond the permissible scope of recovery.

Conclusion: The recovery notice and the balance lien against the petitioner's personal bank account were unsustainable, and the relief was granted in favour of the petitioner.

Final Conclusion: The petitioner could be proceeded against only for his own admitted penalty liability, which having been discharged, no further recovery from his personal assets for the company's dues could be sustained.

Ratio Decidendi: A director's personal bank account cannot be attached for recovery of company dues unless a specific personal liability is established by law; recovery provisions preserving old liabilities do not enlarge that liability beyond what is legally crystallised.

Issues: (i) Whether interest income earned from investments with co-operative banks was eligible for deduction under section 80P(2)(d) of the Income-tax Act, 1961. (ii) Whether hoarding charges received for permitting display of hoardings on the society's wall were assessable under the head "Income from House Property" with deduction under section 24(a) of the Income-tax Act, 1961.

Issue (i): Whether interest income earned from investments with co-operative banks was eligible for deduction under section 80P(2)(d) of the Income-tax Act, 1961.

Analysis: Deduction under section 80P(2)(d) applies to interest or dividend income received by a co-operative society from another co-operative society. The issue was governed by the settled legal position that a co-operative bank is a co-operative society for the purpose of section 80P(2)(d), and the restriction in section 80P(4) does not deny the benefit where the recipient income is otherwise covered by section 80P(2)(d). The income in question was only from co-operative banks, and the contrary view taken by the revenue authorities was not applicable on the facts.

Conclusion: The deduction under section 80P(2)(d) was allowable and the addition was deleted, in favour of the assessee.

Issue (ii): Whether hoarding charges received for permitting display of hoardings on the society's wall were assessable under the head "Income from House Property" with deduction under section 24(a) of the Income-tax Act, 1961.

Analysis: The receipts were held to arise from letting of the property rights associated with the wall/structure and not as income from other sources. Following the binding coordinate-bench view in the assessee's own case, such receipts were assessable as income from house property, and the assessee was entitled to the statutory deduction under section 24(a).

Conclusion: The hoarding charges were assessable as income from house property and consequential deduction under section 24(a) was allowable, in favour of the assessee.

Final Conclusion: Both additions were deleted and the assessee's appeals succeeded in full.

Ratio Decidendi: Where a co-operative society earns interest from another co-operative society, the benefit of section 80P(2)(d) is available notwithstanding section 80P(4); and receipts from permitting hoardings on the property are taxable as income from house property when they arise from exploitation of the property itself.

Issues: Whether the petitioner should be relegated to the appellate remedy against the order-in-original and the rejection of benefit under Section 128A, and whether coercive action pursuant to the garnishee notice should be kept in abeyance for the period granted to file the appeal.

Outcome: The writ petition was disposed of with liberty to approach the appellate authority within two weeks with a delay condonation application and statutory pre-deposit, and no coercive steps were to be taken for that period.

Issues: Whether the writ petition challenging the GST assessment order should be entertained in the face of the statutory appellate remedy, and whether the petitioner should be permitted to pursue the appeal subject to pre-deposit.

Analysis: The impugned order related to confirmation of tax, interest, and penalty under the GST law. The petition was filed after expiry of the statutory period for appeal, and the order records that the petitioner had not availed the statutory reliefs available under section 74 of the GST enactment. In these circumstances, the petition was not examined on merits in writ jurisdiction. Instead, liberty was granted to approach the appellate authority with a pre-deposit of 25% of the disputed tax amount, and any amount already recovered was directed to be adjusted towards the pre-deposit. Consequential directions were also issued regarding consideration of the appeal on merits and lifting of bank attachment upon compliance.

Conclusion: The writ petition was not entertained on merits, but the petitioner was given liberty to file a statutory appeal subject to pre-deposit and compliance with the stated conditions.

Ratio Decidendi: Where an effective statutory appellate remedy exists and the writ petition is filed beyond the appeal period, the Court may decline merits adjudication and direct the petitioner to pursue the appellate remedy subject to pre-deposit and other compliance conditions.

Issues: Whether the impugned order deserved to be quashed and the matter remitted to the authority for fresh consideration.

Analysis: The writ petition was disposed of in terms of the earlier order relied upon by the Court. The impugned order was quashed as against the petitioner, and the petitioner was relegated to submit a reply to the show-cause notice. The authority was directed to consider the reply and pass orders in accordance with law.

Conclusion: The impugned order was set aside insofar as the petitioner was concerned, and the matter was remanded to the authority for consideration of the petitioner's reply and for fresh orders in accordance with law.

Issues: Whether the applicant was entitled to bail in a prosecution alleging fraudulent generation and use of fake input tax credit and bogus invoices under the CGST Act, 2017.

Analysis: The allegations related to documentary material, no custodial remand had been taken, the applicant had no criminal antecedents, the maximum punishment was up to five years, and the co-accused had already been granted bail. The Court also noted that the applicant had been in custody since 18.02.2026 and had undertaken to cooperate in the proceedings.

Conclusion: The applicant was found fit to be enlarged on bail, and bail was granted on parity and other attending circumstances.

Issues: (i) whether the time limits in section 129(3) of the Uttar Pradesh Goods and Services Tax Act, 2017 for issuing notice and passing the penalty order are mandatory or directory; (ii) whether, on the facts, the detention and penalty proceedings warranted interference and release of goods and vehicle against security.

Issue (i): whether the time limits in section 129(3) of the Uttar Pradesh Goods and Services Tax Act, 2017 for issuing notice and passing the penalty order are mandatory or directory.

Analysis: The statutory text was read in the light of settled principles that the use of the word "shall" is not conclusive. The decisive factors were the object of the amendment, the absence of any express consequence for breach, and the procedural nature of the prescription. The provision was held to be intended to secure expedition and discipline in detention proceedings, not to create an inflexible jurisdictional bar. Non-compliance may invite administrative or judicial scrutiny, but it does not by itself render the proceedings time barred.

Conclusion: The time limits in section 129(3) are directory and not mandatory.

Issue (ii): whether, on the facts, the detention and penalty proceedings warranted interference and release of goods and vehicle against security.

Analysis: The notice was issued within seven days of interception, and the order was passed on the eighth day after notice. That was treated as substantial compliance with the directory timeline. On the merits, the goods were traceable to a registered dealer and the petitioner was held entitled to release of the goods and vehicle against deposit of an amount equal to the penalty under protest, leaving other statutory remedies open.

Conclusion: Interference with the proceedings on limitation was declined, but relief for release of the goods and vehicle against security was granted in favour of the assessee.

Final Conclusion: The proceedings under section 129 were not invalidated for breach of the seven-day timeline, yet the petitioner obtained conditional release of the goods and vehicle, so the writ petition was allowed only in part.

Ratio Decidendi: A procedural time-limit in a fiscal detention provision, where no consequence of non-compliance is expressly provided, is ordinarily directory and breach of that timeline does not automatically nullify the proceedings.

Issues: Whether rejection of registration under section 12A(1)(ac)(vi) of the Income-tax Act, 1961 was justified on the ground that the assessee had not established genuineness of activities and the charitable nature of its objects.

Analysis: At the stage of registration, the enquiry is confined to a prima facie examination of the objects of the trust and the genuineness of its activities. The assessee's objects were not doubted. The denial of registration rested mainly on alleged insufficiency of evidence, certain bank transactions, and non-filing of return, but there was no cogent material to show that the activities were ingenuine or non-charitable. The record showed organisation of a medical conference and workshops, supported by photographs, invoices, and activity details. Such educational and awareness-oriented activities fall within the ambit of charity, and the mere presence of surplus or expenditure on venue and related services does not by itself establish a profit motive or warrant denial of registration. Procedural lapses and bank transactions are matters for assessment and do not conclude the registration enquiry.

Conclusion: The rejection of registration was not justified and the assessee was entitled to registration.

Final Conclusion: The impugned order was set aside and registration under section 12A was directed to be granted from the specified effective date, resulting in success for the assessee.

Ratio Decidendi: For registration under section 12A, the authority must confine itself to a prima facie assessment of the charitable objects and genuineness of activities, and registration cannot be refused merely on procedural deficiencies or accounting transactions absent material showing that the activities are non-genuine or non-charitable.

Issues: (i) Whether the cash deposits of Rs. 63,00,000 made during the demonetisation period could be treated as unexplained income; (ii) Whether the disallowance of Rs. 14,96,530 under section 40A(3) required deletion or fresh verification.

Issue (i): Whether the cash deposits of Rs. 63,00,000 made during the demonetisation period could be treated as unexplained income.

Analysis: The assessee maintained that cash sales were a regular feature of its jewellery business and produced month-wise cash sales figures for the current year and the preceding year. The cash sales in the relevant year were substantially lower than those in the preceding year, and the higher sales in October were consistent with the festive season pattern in the business. No independent evidence was brought to discredit the cash sales or to show that the deposits were unsupported by business receipts.

Conclusion: The addition of Rs. 63,00,000 was deleted and the issue was decided in favour of the assessee.

Issue (ii): Whether the disallowance of Rs. 14,96,530 under section 40A(3) required deletion or fresh verification.

Analysis: The cash vouchers reflected clubbed entries for payments made to different persons on the same day, and the individual payments under each voucher were below the statutory limit. At the same time, the vouchers did not contain complete particulars of the recipients or the nature of expenditure, and the authenticity of the expenses had also been doubted. Fresh verification was therefore necessary on genuineness and supporting evidence.

Conclusion: The matter was set aside to the Assessing Officer for fresh examination and the issue was allowed for statistical purposes.

Final Conclusion: The appeal succeeded on the cash-deposit addition and was restored for verification on the cash-expense disallowance, resulting in a partly favourable outcome for the assessee.

Ratio Decidendi: Where cash deposits are supported by regular business cash sales and no contrary evidence discredits the sales, the deposits cannot be treated as unexplained; and where cash payments are made to multiple persons under a common voucher, the applicability of section 40A(3) depends on the individual payments and the genuineness of the underlying expenditure.