Issues: Whether acceptance of the internal Transactional Net Margin Method and deletion of the transfer-pricing adjustment gave rise to a substantial question of law under Sections 92 to 92C of the Income-tax Act, 1961 and Rule 10B of the Income-tax Rules, 1962.

Analysis: The proposed question arose under the transfer-pricing framework governing determination of arm's length pricing. A prior binding decision had already determined the identical question arising from the same impugned order, and the issue was therefore fully covered.

Conclusion: No substantial question of law arose for consideration; the deletion of the transfer-pricing adjustment remained undisturbed.

Issues: Whether revision of the assessment under Section 263 was valid where the Assessing Officer had accepted the assessee's explanations on CENVAT credit valuation, excise-duty refund and additional depreciation.

Analysis: Revisionary jurisdiction under Section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. The Assessing Officer had considered the assessee's explanations and written submissions on each of the three matters and adopted a view permissible in law. The absence of detailed discussion in the assessment order did not, by itself, establish that the assessment was erroneous or prejudicial. The Tribunal's findings that no addition was warranted on the merits of the three matters disclosed no legal infirmity.

Conclusion: The order under Section 263 was invalid; the question of law was answered in favour of the assessee and against the Revenue.

Ratio Decidendi: An assessment adopting a legally permissible view after considering the assessee's explanation cannot be revised under Section 263 merely because the Commissioner prefers a different view, unless it is both erroneous and prejudicial to the interests of the Revenue.

Issues: Whether reopening of a completed scrutiny assessment under Section 147 of the Income-tax Act, 1961, by a notice under Section 148 issued after four years, was valid where unabsorbed depreciation and delayed TDS deposit had already been disclosed and considered.

Analysis: Reopening after four years is permissible only upon failure by the assessee to make a full and true disclosure of material facts necessary for assessment. A notice under Section 148 cannot be used to review a completed scrutiny assessment or revisit an issue already examined and dropped. The assessment record showed that the assessee had disclosed the unabsorbed depreciation and had clarified that no depreciation was claimed for the relevant year; the TDS issue had also been raised and dropped during the earlier proceedings.

Conclusion: The reassessment notice and the consequential order were invalid and were quashed.

Issues: Whether an adjudication order could be sustained where the assessee expressly sought a personal hearing in its reply to the show-cause notice but had inadvertently selected "No" in the hearing option in Form GST DRC-06.

Analysis: Section 75(4) requires an opportunity of hearing where a written request is made by the person chargeable with tax or penalty. The express request for a personal hearing in the reply to the show-cause notice had to be read holistically. An inadvertent selection of "No" in the form could not be treated as an express waiver of the right to be heard, and a mechanical reliance on that selection was impermissible.

Conclusion: Denial of a personal hearing despite the written request breached the principles of natural justice; the assessee is entitled to fresh adjudication after being heard.

Issues: Whether an adjudication order could stand where, despite an express request in the reply to the show-cause notice, the taxpayer was not afforded or notified of a personal hearing.

Analysis: The written reply and subsequent communication expressly requested a personal hearing to explain factual matters and supporting documents. No material showed that a hearing date was intimated after the reply was filed. The order nevertheless proceeded on the basis that no representative had attended to explain the transactions. Section 75(4) of the Maharashtra Goods and Services Tax Act, 2017 requires a fair opportunity of personal hearing where it is sought.

Conclusion: Denial of the requested personal hearing vitiated the adjudication; the issue was decided in favour of the assessee.

Issues: Whether penalty for concealment under Section 271(1)(c) is leviable where additional income was disclosed in the return filed under Section 153A pursuant to notice under Section 153C, and that return was accepted without any further addition.

Analysis: Sections 153A and 153C prescribe assessment of the other person pursuant to search-related proceedings and override the ordinary return provisions; pending earlier returns or assessment proceedings cease to govern the assessment. The return filed in response to the Section 153C notice disclosed the additional income and was accepted as returned. Under Section 271(1)(c), read with Section 271(1)(iii) and Explanation 4(c), penalty depends on tax sought to be evaded, being the difference between tax on assessed income and tax chargeable after excluding the concealed income. Since there was no difference between the accepted returned income and assessed income, no tax was sought to be evaded. Explanation 5 was inapplicable because it concerns a searched person found with specified assets and did not determine the penalty issue.

Conclusion: No penalty under Section 271(1)(c) was leviable on the additional income disclosed in the Section 153A return filed pursuant to the Section 153C notice.

Issues: Whether revisionary jurisdiction under section 263 could be exercised over a reassessment order for an assessment year already settled by the Settlement Commission.

Analysis: Once an application is allowed to proceed under section 245D(1), the Settlement Commission obtains exclusive jurisdiction over the assessment case. Its jurisdiction extends to matters covered by the application and other matters relating to the case referred to in the Commissioner's report. A final settlement order under section 245D(4) attains statutory finality under section 245-I, leaving no scope for parallel assessment proceedings. The assessment year in question formed part of the final settlement order and a consequential order had been passed; the subsequent reassessment could not furnish a valid basis for revision.

Conclusion: The exercise of revisionary jurisdiction under section 263 was invalid and was set aside, in favour of the assessee.

Issues: Whether the Enforcement Directorate could continue retaining seized documents and digital devices and freezing the locker after expiry of the statutory 180-day period without permission of the Adjudicating Authority.

Analysis: Section 17 of the Prevention of Money Laundering Act, 2002 authorises search, seizure and freezing, subject to an application for retention or continuation of freezing before the Adjudicating Authority. Under Section 20(1) and Section 20(3), seized or frozen property may be retained or kept frozen for 180 days, after which it must be returned unless the Adjudicating Authority permits its continued retention or freezing. The 180-day period had expired, and no order permitting retention of the seized articles or continuation of the locker freeze had been obtained.

Conclusion: The Enforcement Directorate lost statutory authority to retain the seized articles or continue freezing the locker; the documents and digital devices must be returned and the locker released to the petitioner.

Issues: Whether a show-cause notice invoking Section 74 was valid when it did not disclose the factual basis for allegations of fraud, wilful misstatement, or suppression of facts to evade tax.

Analysis: Section 74, which carries a five-year limitation as against the three-year limitation under Section 73, can be invoked only where the notice itself discloses specific allegations and supporting material showing fraud, wilful misstatement, or suppression of facts to evade tax. Mere use of those expressions, without particulars demonstrating the basis for their application, cannot justify recourse to the extended limitation period. The notice contained no such factual disclosure or material.

Conclusion: The notice did not validly invoke Section 74 and was unsustainable.

Issues: Whether Section 147A of the Income-tax Act, 1961, inserted retrospectively by the Finance Act, 2026, is constitutionally valid, and whether reassessment notices issued by the Jurisdictional Assessing Officer without faceless automated allocation are sustainable.

Outcome: Notice was issued to the opposite parties. No separate interim order was made in view of the subsisting Supreme Court stay on further assessment and reassessment proceedings, and the matter remains pending for hearing.

Issues: Whether revision under Section 263 in respect of issues outside the scope of reassessment is barred by limitation reckoned from the original assessment order.

Analysis: Section 147 of the Income-tax Act, 1961 permits reassessment of escaped income, including other escaped income that comes to the Assessing Officer's notice during reassessment proceedings under Explanation 3. However, where reassessment is confined to specified grounds, the original assessment continues to operate for matters not forming the subject of reassessment. For revision under Section 263 concerning such unrelated matters, the limitation under Section 263(2) runs from the original assessment order and not the reassessment order.

Conclusion: Revision under Section 263 on issues not forming part of the reassessment was time-barred; the finding is in favour of the assessee.

Issues: Whether the amendment to Section 17(2) of the Income-tax Act, 1961, concerning taxation of interest-free or concessional loans as perquisites, is unconstitutional.

Analysis: Earlier binding decisions had upheld Section 17(2)(viii) of the Income-tax Act, 1961 and Rule 3(7)(i) of the Income-tax Rules, 1962, holding the delegated mechanism for valuing concessional-loan benefits valid and non-arbitrary. The present constitutional challenge was squarely governed by those decisions.

Conclusion: The amendment to Section 17(2) of the Income-tax Act, 1961 is constitutionally valid.

Issues: Whether separate cash capital contributions, each below Rs. 2,00,000 and received from the same partner on different dates, could be aggregated to attract Section 269ST of the Income-tax Act, 1961 and penalty under Section 271DA of the Income-tax Act, 1961.

Analysis: Section 269ST applies where cash of Rs. 2,00,000 or more is received from a person in a single day, in respect of a single transaction, or in respect of transactions relating to one event or occasion. The cash contributions of Rs. 1,99,000 and Rs. 9,000 were received fifteen days apart, and neither receipt independently reached the statutory threshold. The record did not establish that the two receipts formed a single transaction or related to one event or occasion; their contribution towards the partner's capital account alone was insufficient to justify aggregation.

Conclusion: The cash contributions could not be aggregated under Section 269ST; consequently, penalty under Section 271DA was not sustainable.

Issues: Whether the addition based on the reported payment to the founder trustee and the consequential denial of exemption could be sustained solely on the original Form No. 10B without verification of the revised report and underlying records.

Analysis: Sections 13(1)(c), 13(2)(c) and 13(3) require a distinction between identifying a specified person, establishing that remuneration was actually paid or credited to that person, and determining whether any payment exceeded reasonable remuneration for services rendered. The status of a founder or trustee does not by itself establish a violation, and section 13(3) does not prescribe a general salary ceiling of Rs. 50,000. The original Form No. 10B remains relevant evidence, but the subsequently revised report cannot be rejected merely because it was filed after scrutiny commenced. Both reports must be tested against the salary and general ledgers, financial statements, bank records, payment vouchers, payroll and TDS records, and the auditor's explanation. If payment is established, its nature, services rendered and reasonableness must be examined before determining the effect on exemption under sections 11 and 12.

Conclusion: The addition and denial of exemption cannot rest solely on the original Form No. 10B; the issue requires an evidence-based fresh determination after verification of the relevant records.

Issues: Whether the High Court had territorial jurisdiction under Article 226 of the Constitution of India to entertain a challenge to seizure and non-release of imported goods detained at ICD, Dadri, Uttar Pradesh.

Analysis: The seizure, detention and proceedings concerning provisional release arose at ICD, Dadri, under the jurisdiction of the Commissioner of Customs, Noida. The asserted links with authorities headquartered in Delhi, including challenges concerning classification, reliance on the Chartered Engineer's certificate and CBIC policy, did not give rise to any part of the cause of action within Delhi. The doctrine of forum conveniens did not apply because the case involved absence of territorial jurisdiction rather than a choice between competent forums.

Conclusion: The High Court lacked territorial jurisdiction to adjudicate the challenge; the issues concerning classification, reliance on the Chartered Engineer's certificate and release of goods fall for consideration before the appropriate forum.

Issues: Whether writ petitions concerning foreign-exchange adjudication proceedings fall within Group IV governing revenue and tax matters, rather than Group IX governing residuary matters, for roster allocation.

Analysis: Rules 8A and 8B require Article 226 petitions to be assigned a group under the prescribed classification. Group IV includes adjudication proceedings and miscellaneous matters concerning revenue and tax laws. The foreign-exchange regulatory framework, its subject matter, and the cause-list classification treating foreign exchange as a revenue subject supported allocation to Group IV.

Conclusion: Foreign-exchange matters fall under Group IV and not Group IX; the classification issue is decided against the petitioners.

Issues: Whether a refund claim under Section 102 of the Finance Act, 2016, filed after the prescribed six-month period, is barred by limitation.

Analysis: Section 102 prescribed six months from the presidential assent to the Finance Bill, 2016, for filing the refund claim. As assent was received on 14.05.2016, the prescribed deadline was 14.11.2016, whereas the claim was filed on 14.02.2017. The binding position affirming rejection of such delayed claims was applied; the contrary High Court decision was not followed because it had not considered the Supreme Court decision on the same issue.

Conclusion: The refund claim filed after 14.11.2016 was time-barred and was liable to be rejected.

Issues: Whether an adjudicating authority may confirm tax, interest and penalty beyond the demand proposed in the show-cause notice under Section 75(7).

Analysis: The show-cause notice proposed tax alone and specified no interest or penalty, whereas the adjudication order additionally confirmed substantial interest and penalty. Section 75(7) imposes a mandatory limitation that the confirmed demand cannot exceed the demand proposed in the notice. Confirmation of amounts beyond that scope constitutes a jurisdictional error.

Conclusion: An adjudicating authority cannot confirm interest or penalty not proposed in the show-cause notice; an order confirming demand beyond the notice is without jurisdiction.

Issues: Whether proceedings for demand under Section 74 could validly be initiated and concluded in the name of a deceased sole proprietor despite the revenue authority having knowledge of the death and of the legal heir.

Analysis: Section 74 of the Central Goods and Services Tax Act, 2017 was invoked against a sole proprietor who had died before the impugned intimation, show-cause notice and demand order. The death and the legal heir's status had been disclosed to the revenue authority in earlier registration-cancellation proceedings and in prior demand proceedings. Initiating fresh proceedings in the deceased person's name, despite that knowledge, constituted a jurisdictional defect. No opinion was expressed on the merits of the alleged input-tax-credit liability.

Conclusion: The proceedings initiated and concluded against the deceased proprietor were without jurisdiction. Fresh proceedings may be initiated against the legal heir if permissible in law.

Issues: (i) Whether the State may withhold the income-tax and VAT components of the auction deposit after the auction transaction failed; and (ii) Whether interest is payable on the refundable deposit and, if so, at what rate and for what periods.

Issue (i): Whether the State may withhold the income-tax and VAT components of the auction deposit after the auction transaction failed.

Analysis: The auction purchaser neither received the iron ore nor obtained permission to lift it, and the entitlement to refund the entire deposit was accepted. Amounts paid towards income tax and VAT formed part of the demand arising from the auction and their remittance to tax departments could not prejudice the payer. As no taxable event occurred and the auction consideration was never supplied, continued retention of those amounts lacked justification and attracted the principles of restitution and unjust enrichment.

Conclusion: The withholding of Rs.15,41,436 towards income tax and VAT is invalid. The balance amount must be refunded, with the State left free to obtain reimbursement or adjustment from the concerned tax departments in accordance with law.

Issue (ii): Whether interest is payable on the refundable deposit and, if so, at what rate and for what periods.

Analysis: Interest is compensatory, being the normal accretion on money whose use has been wrongfully withheld. The absence of a contractual or express statutory interest provision does not defeat compensation where the State retains money that ought to have been refunded after the transaction failed.

Conclusion: Interest is payable at 8% per annum on Rs.2,89,05,436 from 31.07.2023 to 31.03.2025, with credit only for amounts actually paid on 31.03.2025. From 01.04.2025, interest at 8% per annum is payable on Rs.8,00,000 and Rs.15,41,436 until actual payment.

Final Conclusion: The failed auction requires complete restitution of the amounts demanded and paid, together with compensatory interest for their undue retention.

Ratio Decidendi: Where an auction transaction fails and the purchaser receives no consideration, the State must make complete restitution of all amounts paid pursuant to its demand; inter-departmental remittance cannot defeat that obligation, and compensatory interest follows undue retention.