Issues: Whether the addition arising from the alleged cash transactions should be confined to an estimated 8% profit element rather than the entire amount.

Analysis: In the assessee's prior assessment years, the departmental authorities had accepted estimation of income at 8% in respect of similar cash transactions. Applying that consistent treatment to the year in question, the addition was directed to be computed only at 8% of the alleged transaction amount of Rs. 2,87,345.

Conclusion: The addition is restricted to Rs. 22,987, being 8% of Rs. 2,87,345; the balance of the addition cannot stand.

Issues: Whether reassessment could be sustained where no addition was made in respect of the income forming the recorded reason for reopening, but additions were made on other matters.

Analysis: Section 147, read with Explanation 3, permits assessment of other income noticed in a validly reopened proceeding, but does not remove the requirement that the income forming the recorded reason for reopening be assessed or reassessed. The long-term capital gains identified in the recorded reasons were not added; the disallowance under Section 54F and the addition under income from other sources were distinct matters. The binding jurisdictional rule therefore precluded sustaining the reassessment solely on those other additions.

Conclusion: The reassessment under Section 143(3) read with Section 147 was unsustainable and was quashed; the consequential additions, including the disallowance under Section 54F, could not survive.

Issues: (i) Whether reopening of the assessment was valid under Section 147 of the Income-tax Act, 1961; (ii) Whether an addition based on third-party statements without affording cross-examination was sustainable; (iii) Whether the loan-credit addition was sustainable on the evidence of genuineness and repayment.

Issue (i): Whether reopening of the assessment was valid under Section 147 of the Income-tax Act, 1961.

Analysis: Reassessment jurisdiction requires an independent reason to believe, founded on relevant material, that income chargeable to tax has escaped assessment. The recorded reasons neither identified a failure to disclose material facts nor demonstrated independent verification of the existing assessment records. They proceeded on factually incorrect material and borrowed satisfaction, without tangible material establishing escapement of income.

Conclusion: The reopening was invalid and is quashed, in favour of the assessee.

Issue (ii): Whether an addition based on third-party statements without affording cross-examination was sustainable.

Analysis: Where an addition rests on third-party statements or material, principles of natural justice require disclosure of such material and an effective opportunity to rebut it, including cross-examination of the persons whose statements are relied upon. The absence of that opportunity left the material untested.

Conclusion: The addition founded on third-party statements without cross-examination was unsustainable, in favour of the assessee.

Issue (iii): Whether the loan-credit addition was sustainable on the evidence of genuineness and repayment.

Analysis: The loan transactions were recorded in the books and supported by ledger accounts, PAN particulars, bank statements, confirmations, and repayment details. Subsequent repayment of the loans supported the genuineness of the credits and did not justify their treatment as unexplained cash credits.

Conclusion: The loan-credit addition was deleted, in favour of the assessee.

Final Conclusion: The invalid reopening and the independent defects in the loan-credit addition render the reassessment demand unsustainable.

Ratio Decidendi: Reassessment jurisdiction cannot be invoked on borrowed satisfaction or factually incorrect reasons lacking independently verified tangible material establishing escapement of income.

Issues: Whether an addition for unexplained money could be sustained solely on an unsigned excel sheet recovered from a third party, without cross-examination of the relevant persons or independent corroborative evidence.

Analysis: The material relied upon consisted of an unsigned third-party excel sheet that did not identify or bear the signature of the assessee. An adverse addition founded on such material required an opportunity to cross-examine the persons connected with it and independent evidence establishing that the alleged cash payment had actually been made. In the absence of cross-examination and corroboration, the excel sheet remained an unreliable third-party document incapable of supporting the addition.

Conclusion: The addition under Section 69A read with Section 115BBE of the Income-tax Act, 1961, was unsustainable and was deleted.

Issues: Whether cash receipts recorded in the regular books as collections from identified business debtors could be treated as unexplained money under Section 69A of the Income-tax Act, 1961.

Analysis: Section 69A applies where money is established to be unexplained. The disputed receipts were recorded in the regular books and were supported by party-wise ledgers, identified debtor particulars, audited accounts, sales and purchase registers, stock records and VAT returns. No defect was identified in the underlying business records, the books were not rejected, and no independent verification was undertaken from the identified parties. The absence of debtor confirmations alone could not displace the documentary evidence or establish unexplained money. Acceptance of Specified Bank Notes during demonetisation, without contrary material connecting the receipts to undisclosed income, also did not establish an unexplained source. Suspicion could not substitute proof.

Conclusion: The receipts were not established to be unexplained money under Section 69A of the Income-tax Act, 1961, and the addition was deleted in favour of the assessee.

Issues: (i) Whether the addition for unexplained investment in intangible assets and the consequential depreciation disallowance required verification; (ii) Whether the assessed-income computation, based on adjustments in the intimation under section 143(1), involved duplication of disallowances.

Issue (i): Whether the addition for unexplained investment in intangible assets and the consequential depreciation disallowance required verification.

Analysis: Section 69 of the Income-tax Act, 1961 applies to investments whose nature and source remain unexplained, while section 115BBE governs their taxation. The difference between the recorded cost of intangible assets and the supporting documents produced could not be determined without examining the books of account, invoices, agreements, ledgers, payment records, salary records, and evidence concerning software customisation and development. The depreciation disallowance was consequential to the addition.

Conclusion: The addition for unexplained investment and the consequential depreciation disallowance are remitted for fresh verification and adjudication.

Issue (ii): Whether the assessed-income computation, based on adjustments in the intimation under section 143(1), involved duplication of disallowances.

Analysis: Verification was required by comparing the original and revised returns, the intimation under section 143(1), the computation of income, tax audit report, and assessment order to ascertain whether the disputed expenses had already been disallowed and whether the assessment duplicated those disallowances.

Conclusion: The computation issue is remitted for verification and fresh adjudication.

Final Conclusion: The disputed additions and computation adjustments must be reconsidered on verification of the relevant records after providing a reasonable opportunity to furnish supporting evidence and explanations.

Issues: (i) Whether the relevant date of import for applying an import-policy restriction under the Foreign Trade Policy is the date of shipment or dispatch or the date of filing of the Bill of Entry or clearance for home consumption; (ii) Whether Notification No. 02/2026-27 applies to goods dispatched and arrived in India before its electronic Gazette publication merely because the Bills of Entry were filed thereafter.

Issue (i): Whether the relevant date of import for applying an import-policy restriction under the Foreign Trade Policy is the date of shipment or dispatch or the date of filing of the Bill of Entry or clearance for home consumption.

Analysis: Paragraph 1.05(b) of the Foreign Trade Policy, read with paragraphs 2.17(a) and 11.11 of the Handbook of Procedures, 2023, defines the date of import by reference to shipment or dispatch from the supplying country. For air imports, the relevant Airway Bill evidencing departure from the last airport in the exporting country is determinative. The Bill of Entry or out-of-charge date is relevant under Section 15 of the Customs Act, 1962 for determining the rate of customs duty, but does not govern the applicability of an import-policy restriction under the Foreign Trade Policy.

Conclusion: The relevant date of import for the import-policy restriction is the shipment or dispatch date determined under the Foreign Trade Policy and Handbook of Procedures, not the post-notification Bill of Entry or clearance date. This issue is decided in favour of the assessee.

Issue (ii): Whether Notification No. 02/2026-27 applies to goods dispatched and arrived in India before its electronic Gazette publication merely because the Bills of Entry were filed thereafter.

Analysis: A notification acquires legal force only upon its electronic Gazette publication and cannot operate retrospectively without statutory authority. The restrictive notification could therefore operate only prospectively and could not affect goods already dispatched and arrived before publication. Its clauses excluding transitional arrangements did not alter this position. A subsequent executive memorandum lacked statutory force and could neither override the policy-defined date of import nor retrospectively expand the notification's application; conditional import authorisations did not redress that entitlement.

Conclusion: No. The restrictive notification is inapplicable to goods dispatched and arrived before its electronic Gazette publication, notwithstanding subsequent filing of Bills of Entry. This issue is decided in favour of the assessee.

Final Conclusion: Goods whose shipment or dispatch predates the effective publication of a restrictive import-policy amendment remain governed by the pre-existing import policy, and that position cannot be altered through a subsequent executive clarification.

Ratio Decidendi: For import restrictions under the Foreign Trade Policy, the policy-defined shipment or dispatch date governs the date of import; the customs clearance date applicable to duty assessment and an executive clarification cannot retrospectively vary that policy framework.

Issues: Whether cognizance for an alleged contravention of Section 217(4) of the Companies Act, 2013 was liable to be quashed.

Analysis: At the cognizance stage, scrutiny is confined to the complaint and supporting material for determining whether a prima facie case exists; defence material and explanations cannot be evaluated through a mini-trial. The complaint and supporting documents disclosed allegations of non-cooperation with the investigation, and the cognizance order reflected application of mind to that material.

Conclusion: The cognizance and issuance of process for the alleged offence under Section 217(4), punishable under Section 217(6), of the Companies Act, 2013 were not liable to be quashed.

Issues: Whether cancellation of GST registration for non-filing of returns should be revoked and the registration restored.

Analysis: The petitioner had not filed returns from July 2025 and had not responded to the show-cause notice, leading to cancellation of registration. Financial difficulties were accepted as a genuine explanation for the default. Revocation and restoration were made conditional upon enabling portal access, filing all pending returns, and payment of tax dues, interest, and belated-filing fees without adjustment against unutilised or unclaimed input tax credit. Any input tax credit may be utilised only after departmental scrutiny and approval.

Conclusion: The cancellation order was revoked and GST registration was directed to be restored, subject to the stipulated compliance conditions, in favour of the assessee.

Issues: Whether the assessee's appeal, filed 29 days after the ordinary appeal period but within the statutory condonable period, could be rejected solely for delay.

Analysis: Section 107(4) of the Central Goods and Services Tax Act, 2017 permits extension of the appeal period by one month on sufficient cause. The appeal was filed on 09.10.2026, within the one-month condonable period following expiry of the three-month period on 10.09.2026. The stated reason for delay, namely the director's maternity leave, was found genuine.

Conclusion: The rejection of the appeal for delay was set aside, and the 29-day delay was condoned.

Issues: Whether an ex parte GST order based solely on notices uploaded to the GST portal, despite repeated non-response, constituted effective service and satisfied the principles of natural justice.

Analysis: Section 169(1) of the Central Goods and Services Tax Act, 2017 recognises portal uploading as a valid mode of service, but also provides other modes. Where repeated portal notices elicit no response, the issuing officer must make a genuine effort to serve the taxpayer through other prescribed modes, preferably registered post, rather than merely complete a formal requirement. Exclusive reliance on portal uploading in such circumstances does not amount to effective service.

Conclusion: The service adopted was ineffective in the circumstances and the ex parte order violated the principles of natural justice.

Issues: Whether an ex parte GST assessment based solely on notices uploaded on the online portal, despite no response to repeated notices, violated principles of natural justice.

Analysis: Uploading a notice on the GST portal is a valid mode of service. However, where repeated notices elicit no response, Section 169(1) of the Central Goods and Services Tax Act, 2017 requires the officer to explore other prescribed modes of service, preferably registered post with acknowledgment due, to secure effective service. Mere portal upload in such circumstances amounts to an empty formality and does not afford a meaningful opportunity to reply or be heard.

Conclusion: The ex parte assessment was vitiated by breach of principles of natural justice and was set aside for fresh adjudication after receipt of objections and grant of a clear personal-hearing notice. The bank-account attachment could not survive the setting aside of the assessment.

Issues: Whether an ex parte GST assessment based solely on portal-uploaded notices, without resort to other statutory modes of service after repeated non-response, violates principles of natural justice.

Analysis: Section 169(1) of the Central Goods and Services Tax Act, 2017 provides multiple valid modes for service of notices. Though uploading notices on the GST portal is a valid mode, repeated non-response requires the officer to make a genuine effort to effect effective service through other prescribed modes, preferably registered post. Reliance solely on portal uploads in such circumstances amounts to an empty formality and denies a meaningful opportunity to reply and be heard.

Conclusion: The ex parte assessment, having been made without effective service and a meaningful opportunity of hearing, violated the principles of natural justice.

Issues: Whether the petitioner should be permitted to pursue the statutory appellate remedy despite delay in challenging the assessment order.

Outcome: Liberty was granted to file an appeal before the appellate authority, which was directed not to raise limitation.

Issues: (i) Eligibility of a Government-controlled university for exemption under section 10(23C)(iiiab) where UGC grants and capital grants in kind are included in Government funding under Rule 2BBB; (ii) Sustainability of penalty for under-reporting or misreporting where the underlying addition is deleted.

Issue (i): Eligibility of a Government-controlled university for exemption under section 10(23C)(iiiab) where UGC grants and capital grants in kind are included in Government funding under Rule 2BBB.

Analysis: Exemption requires the institution to be a university or educational institution existing solely for education and not profit, and to be wholly or substantially financed by Government. Rule 2BBB treats this financing condition as fulfilled where Government grants exceed 50% of total receipts in the relevant previous year. Statutory control over the university's finances, expenditure, staffing and immovable property established Government control over its affairs.

Analysis: UGC funds originate from Central Government allocations and are distributed to universities through the statutory commission; they consequently form part of Government grants. Capital assistance in the form of Government-granted land was also includible for the financing computation. On including the UGC grant and the value attributable to the land grant, Government funding constituted 50.76% of total receipts, exceeding the prescribed threshold.

Conclusion: The exemption under section 10(23C)(iiiab) is allowable and this issue is decided in favour of the assessee.

Issue (ii): Sustainability of penalty for under-reporting or misreporting where the underlying addition is deleted.

Analysis: The penalty was founded solely on the addition resulting from denial of the exemption. Once that addition ceased to survive, there remained no basis for penalty.

Conclusion: The penalty is unsustainable and is deleted, in favour of the assessee.

Final Conclusion: The income is to be computed after giving effect to the statutory exemption, and the penalty founded exclusively on the resultant addition has no subsisting basis.

Ratio Decidendi: For the Government-financing test, funds routed through a statutory Government intermediary and Government capital grants in kind may be included in Government funding; where such funding exceeds the prescribed threshold, the educational institution is entitled to exemption.

Issues: Whether an adjudicating authority may confirm a tax demand exceeding the demand proposed in the show-cause notice, contrary to Section 75(7) of the Uttar Pradesh Goods and Services Tax Act, 2017.

Analysis: Section 75(7) prohibits confirmation of a demand exceeding that proposed in the show-cause notice. The notice proposed a substantially lower tax demand, interest and penalty than those confirmed in the adjudication order. Breach of this mandatory restriction rendered the excess confirmation jurisdictionally invalid.

Conclusion: An adjudicating authority cannot confirm a demand beyond that proposed in the show-cause notice; the impugned excess demand was invalid, in favour of the assessee.

Issues: Whether service of GST notices solely through portal uploads, despite repeated non-response and without recourse to other statutory modes of service, rendered the ex parte assessment and appellate rejection violative of principles of natural justice.

Analysis: Uploading notices on the GST portal is a valid mode of service. However, where repeated notices elicit no response, the proper officer must apply their mind and explore other modes available under Section 169(1) of the Central Goods and Services Tax Act, 2017, preferably registered post with acknowledgement due. Mere portal uploads in such circumstances amount to an empty formality rather than effective service, particularly where no meaningful opportunity of hearing is afforded.

Conclusion: In favour of the assessee, the ex parte assessment and appellate rejection were vitiated by breach of the principles of natural justice.

Issues: Whether general insurance services availed by a manufacturer after 1 April 2011 qualify as input services eligible for CENVAT credit under Rule 2(l) of the CENVAT Credit Rules, 2004.

Analysis: The post-amendment definition in Rule 2(l) deleted the expression "activities relating to business" to align the scope of input services with inputs. The specified exclusions concern, inter alia, construction-related services, motor-vehicle-related services and services primarily meant for employees' personal use or consumption. General insurance used in relation to the manufacturing activity was not covered by those exclusions and retained a direct or indirect nexus with manufacture of final products. The departmental clarification on sales commission did not restrict credit for services otherwise satisfying the principal limb of the definition.

Conclusion: General insurance service used in relation to manufacture remains an input service eligible for CENVAT credit after 1 April 2011; no substantial question of law arose.

Issues: (i) Whether the First Appellate Authority could condone delay in filing an appeal beyond the maximum period under Section 107(4) of the Central Goods and Services Tax Act, 2017; and (ii) Whether the Department's challenge remained maintainable after it implemented the order by restoring registration.

Issue (i): Whether the First Appellate Authority could condone delay in filing an appeal beyond the maximum period under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary limitation period and Section 107(4) permits condonation only within its fixed additional period. The First Appellate Authority, being a statutory authority, has no inherent power to extend that outer limit. Directions issued by a High Court in exercise of writ jurisdiction under Article 226 of the Constitution of India, on their particular facts, do not enlarge the statutory appellate jurisdiction. Equity follows the law and cannot override an express limitation provision.

Conclusion: The First Appellate Authority could not condone delay beyond the statutory maximum; this issue is decided against the assessee.

Issue (ii): Whether the Department's challenge remained maintainable after it implemented the order by restoring registration.

Analysis: The Department restored the registration pursuant to the impugned order, and the assessee thereafter continued business and filed returns on that basis. Having implemented the restoration and altered the assessee's legal and commercial position, the Department was estopped from seeking to invalidate that relief, since no effective appellate relief could then be granted.

Conclusion: The Department's challenge was not maintainable after restoration of registration; this issue is decided in favour of the assessee.

Final Conclusion: Although the condonation exceeded the First Appellate Authority's statutory power, the restoration already implemented by the Department could not be undone through the present challenge.

Ratio Decidendi: A statutory appellate authority cannot extend a legislatively fixed outer limitation period, and a department that has acted upon an order restoring registration cannot subsequently seek its ineffective reversal.

Issues: Whether an individual investor's compensation claim against a statutory auditor for a fraudulent prospectus under Section 35 of the Companies Act, 2013, could be adjudicated in a civil suit after insolvency proceedings and proceedings under Section 66 of the Insolvency and Bankruptcy Code, 2016 had been initiated against the company.

Analysis: Section 35 ordinarily confers upon an investor who subscribed to securities on the basis of a fraudulent prospectus a personal right to seek compensation from persons liable for the resulting loss. However, where the company is in insolvency and the alleged fraudulent conduct is subject to Section 66 proceedings, recoveries for such conduct form part of the collective insolvency process and are available for the benefit of the creditors. In those circumstances, the otherwise personal claim assumes the character of an action in rem and cannot be pursued for the exclusive benefit of a single creditor through a separate civil suit.

Conclusion: The claim against the statutory auditor could not be adjudicated in the civil suit; the available recourse lay under Section 66 of the Insolvency and Bankruptcy Code, 2016 for the collective benefit of creditors.