Issues: (i) Whether rejection of the books of account under Section 145(3) of the Income-tax Act, 1961 was justified; (ii) Whether cash deposited during the demonetisation period, recorded in the books and explained as cash sales and debtor realisations, could be assessed as unexplained money under Section 69A of the Income-tax Act, 1961.

Issue (i): Whether rejection of the books of account under Section 145(3) of the Income-tax Act, 1961 was justified.

Analysis: Rejection of books requires specific defects rendering the accounts incapable of correctly determining business income. The disclosed turnover, gross profit and business income were accepted, with no finding of suppressed sales, inflated purchases or discrepancy in the trading account. The computerised books and supporting records were offered for physical verification, but no effective opportunity for such verification was provided. Suspicion arising from the pattern of cash receipts and retention of cash, without supporting inquiry or evidence of falsity, was insufficient.

Conclusion: Rejection of the books under Section 145(3) of the Income-tax Act, 1961 was unjustified, in favour of the assessee.

Issue (ii): Whether cash deposited during the demonetisation period, recorded in the books and explained as cash sales and debtor realisations, could be assessed as unexplained money under Section 69A of the Income-tax Act, 1961.

Analysis: Section 69A requires, among other conditions, that the money must not be recorded in the books of account. The deposits were within the recorded cash balance and were linked to disclosed cash sales and debtor realisations. The corresponding turnover and business profits were not disturbed, and no inquiry from identified parties, fictitious sale, unrecorded source, or material outside the books was established. Mere disbelief of the recorded explanation or rejection of books does not convert recorded receipts into money not recorded in the books. Taxing the same disclosed business receipts again as unexplained money would result in double addition absent proof of an outside source.

Conclusion: The cash deposits could not be treated as unexplained money under Section 69A of the Income-tax Act, 1961, and the addition was deleted, in favour of the assessee.

Final Conclusion: Recorded cash arising from accepted business turnover cannot be separately assessed as unexplained money unless the statutory requirement of non-recording in the books and an undisclosed source are established.

Ratio Decidendi: An amount recorded in the assessee's books and traceable to accepted business receipts cannot be brought to tax under Section 69A merely because the explanation is doubted; rejection of books alone does not satisfy the statutory condition that the money be unrecorded.

Issues: (i) Whether an order under Section 74A(5) could be passed without granting a personal hearing after issuance of the notice where an adverse decision was contemplated; (ii) Whether an order could be passed before expiry of the sixty-day period available for payment of tax and interest under Section 74A(8)(ii).

Issue (i): Whether an order under Section 74A(5) could be passed without granting a personal hearing after issuance of the notice where an adverse decision was contemplated.

Analysis: Section 75(4) mandates a hearing where an adverse decision is contemplated. The notice in question itself stated that personal hearing was not applicable, and no hearing was afforded after its issuance. An earlier hearing concerning a different input-tax-credit mismatch matter did not satisfy the statutory right to personal hearing in relation to the notice giving rise to the impugned order. This constituted a breach of principles of natural justice.

Conclusion: The order under Section 74A(5), having been passed without the mandatory opportunity of hearing, was unsustainable, in favour of the assessee.

Issue (ii): Whether an order could be passed before expiry of the sixty-day period available for payment of tax and interest under Section 74A(8)(ii).

Analysis: Section 74A(8)(ii) permits payment of the demanded tax with applicable interest under Section 50 within sixty days from the show-cause notice, upon which no penalty is payable and the proceedings stand concluded. The impugned order was admittedly made before expiry of that statutory period, defeating the statutory period for payment available to the assessee.

Conclusion: The order passed before expiry of the sixty-day period under Section 74A(8)(ii) was contrary to law, in favour of the assessee.

Final Conclusion: The assessment and rectification orders were invalid for denial of the statutory hearing and curtailment of the statutory payment period; costs were imposed on the officer concerned.

Ratio Decidendi: An adverse GST determination cannot validly be made without the hearing mandated by Section 75(4), nor before expiry of the statutory period expressly granted under Section 74A(8)(ii) for payment of tax and interest.

Issues: Whether the applicant should be granted bail pending investigation into alleged evasion of customs and anti-dumping duty through use of allegedly invalid certificates of origin.

Analysis: The investigation was substantially documentary in nature, the applicant had remained in judicial custody for 31 days, and his father, alleged to have handled import-related work, was also in custody. The later supplier communications and revised origin documents required verification, which could be undertaken while requiring the applicant's attendance. The apprehension that the applicant would independently tamper with evidence was found unsupported, as relevant documents had been seized and the principal connected person was in custody.

Outcome: Bail granted on conditions, including execution of bond, cooperation with investigation, attendance when called, surrender of passport, and restrictions on travel abroad.

Issues: Whether a Mono Ethylene Glycol Reclamation Plant, classified under Chapter 84 and used for offshore and onshore petroleum operations, qualified for exemption under Serial No. 404 read with Serial No. 4 of List 33 of Notification No. 50/2017-Customs for the period before creation of a specific entry in 2024.

Analysis: Serial No. 404 grants exemption to goods described in column 3 of List 33, provided they fall within the chapters, headings, sub-headings or tariff items specified in column 2 of the main notification and satisfy the prescribed conditions. The notification does not require the goods also to conform to the heading stated in column 2 of List 33. The relevant condition was met because the plant fell within Chapter 84, was imported by a specified person, and was used for petroleum operations under the New Exploration Licensing Policy.

Analysis: The description at Serial No. 4 of List 33, covering equipment or units for specialised services for offshore and onshore petroleum operations, has a scope wider than tariff heading 8430. Reading the List 33 heading as a restrictive condition would render the separate description of specialised-service equipment ineffective. The sector regulator's certification of the plant's end use and the Tax Research Unit clarification addressing mismatches between listed descriptions and tariff headings supported this construction.

Analysis: The later insertion of a specific entry for the plant operated prospectively and did not exclude goods otherwise covered by the pre-existing general description. As the exemption entry was unambiguous and served the beneficial purpose of facilitating petroleum exploration, production and processing, the rule favouring Revenue where an exemption notification is ambiguous was inapplicable.

Conclusion: The plant was eligible for the exemption under Serial No. 404 read with Serial No. 4 of List 33 of Notification No. 50/2017-Customs for the relevant pre-amendment period, in favour of the assessee.

Issues: (i) Whether the refund claim for excess export duty was barred by limitation under Section 27 of the Customs Act, 1962; (ii) Whether interest on the sanctioned refund was payable under Section 27A of the Customs Act, 1962 and, if so, from which date.

Issue (i): Whether the refund claim for excess export duty was barred by limitation under Section 27 of the Customs Act, 1962.

Analysis: A refund founded on an alleged mistake in the construction or application of law must be pursued under the self-contained refund mechanism in Section 27; Section 17 of the Limitation Act, 1963 and Article 265 of the Constitution of India cannot independently displace its limitation regime. On the facts, the contemporaneous EDI computation treated FOB value as cum-duty value, and the asserted later discovery of a mistake was unsupported.

Analysis: Although clearance for export following payment supported the existence of an assessment of the duty reflected in the contemporaneous records, the additional amount paid by challan was not reflected in the shipping bills, let export orders, or any assessment record. The departmental Note dated 21.09.2015 recomputed the duty pursuant to the remand and constituted reassessment within Section 2(2) and Section 27(1B)(c). The claim filed before that reassessment, together with the correction request on record, was therefore not time-barred. The finding that unjust enrichment was not attracted remained undisturbed.

Conclusion: The refund claim was within limitation and the sanctioned refund of excess export duty was validly payable, in favour of the assessee.

Issue (ii): Whether interest on the sanctioned refund was payable under Section 27A of the Customs Act, 1962 and, if so, from which date.

Analysis: Section 27A requires payment of interest where an ascertained refund ordered is not paid within three months of a refund application. Since the excess amount became ascertained only upon reassessment on 21.09.2015, treating the 2009 application date as the starting point for interest would be inconsistent with the finding that the refund cause of action arose upon reassessment. The three-month period accordingly ran from 21.09.2015.

Conclusion: Interest is payable on the refund from 22.12.2015 until actual payment at the notified rate, in favour of the assessee.

Final Conclusion: The reassessment date governs both the maintainability of the refund claim and commencement of the statutory interest period; the original refund sanction is restored with interest computed from the stipulated post-reassessment date.

Ratio Decidendi: Where excess duty was not part of the original assessment and is first quantified through a departmental reassessment, the reassessment date is the relevant date for refund limitation and for calculating statutory interest on the ascertained refund.

Issues: (i) Whether technical testing and analysis services rendered by a clinical research organisation undertaking sponsor-approved clinical trials are exempt from service tax under the relevant exemption notifications; (ii) Whether the amount recovered from employees upon premature resignation was taxable as commercial training or coaching service; (iii) Whether invocation of the extended period of limitation was valid; and (iv) Whether interest and penalties were sustainable.

Issue (i): Whether technical testing and analysis services rendered by a clinical research organisation undertaking sponsor-approved clinical trials are exempt from service tax under the relevant exemption notifications.

Analysis: The exemption covered testing and analysis of newly developed drugs on human participants by a clinical research organisation approved to conduct clinical trials by the Drugs Controller General of India. Under the applicable regulatory framework, trial permission is issued to the sponsor, while a clinical research organisation performs delegated trial functions under written arrangements. The clinical research organisation had performed that role for sponsors holding approvals for the concerned trials and had registered the trial activity with the clinical-trials registry. Requiring a separate institutional approval which the regulator did not issue to clinical research organisations would impose an impossible condition. Strict construction of an exemption applies only where genuine ambiguity remains.

Conclusion: The technical testing and analysis services were exempt from service tax; the related demand was unsustainable, in favour of the assessee.

Issue (ii): Whether the amount recovered from employees upon premature resignation was taxable as commercial training or coaching service.

Analysis: The recovery represented a deposit taken from employees trained and appointed subject to a minimum service commitment, refundable upon completion of that commitment and forfeited or recovered upon premature resignation. It was not a fee charged by a commercial training or coaching centre for imparting skill or knowledge. The employer-employee relationship remained one of contract of service. The amount was compensation for breach of the employment commitment and was not consideration for commercial training or coaching or for tolerating an act or situation.

Conclusion: The employee recoveries were not consideration for any taxable service; the demand under commercial training or coaching service was unsustainable, in favour of the assessee.

Issue (iii): Whether invocation of the extended period of limitation was valid.

Analysis: The extended period requires fraud, collusion, wilful misstatement, suppression of facts, or contravention accompanied by intent to evade tax. The Department had sought and received full particulars of the clinical research activity several years before issuance of the notices. Non-registration or non-filing based on a disclosed and tenable belief in exemption did not constitute deliberate suppression or a positive act undertaken with intent to evade tax.

Conclusion: Invocation of the extended period of limitation was invalid, in favour of the assessee.

Issue (iv): Whether interest and penalties were sustainable.

Analysis: As the principal service-tax demands did not survive, interest could not be sustained. Further, the ingredients necessary for penal liability, including suppression or contravention with intent to evade tax, were absent.

Conclusion: Interest and all penalties were unsustainable, in favour of the assessee.

Final Conclusion: The services and employee recoveries were outside the asserted tax liabilities, the extended limitation was unavailable, and no consequential fiscal or penal liability remained.

Ratio Decidendi: An exemption for clinical-research services cannot be construed to require a separate regulatory approval that the competent regulator does not issue to clinical research organisations; and employee bond-forfeiture recoveries are compensatory, not consideration for a taxable service.

Issues: (i) Whether sub-letting hoarding sites to advertising agencies before 1 May 2006 attracted service tax as Advertising Agency Service; (ii) Whether the post-1 May 2006 demand for sale of space or time for advertisement could be sustained by invoking the extended period of limitation.

Issue (i): Whether sub-letting hoarding sites to advertising agencies before 1 May 2006 attracted service tax as Advertising Agency Service.

Analysis: Mere sub-letting of advertising sites to an advertising agency, without providing the services comprised in the taxable category, did not make the hoarding owner liable to service tax.

Conclusion: Sub-letting hoarding sites to advertising agencies during the pre-1 May 2006 period was not taxable as Advertising Agency Service, in favour of the assessee.

Issue (ii): Whether the post-1 May 2006 demand for sale of space or time for advertisement could be sustained by invoking the extended period of limitation.

Analysis: The arrangement was revenue-neutral because the advertising agencies paid tax on the consideration received from clients, including amounts paid for the hoarding space. The demand was based on statutory records, with no positive act of concealment identified. Regular returns had been filed, and the liability involved an interpretational dispute amid conflicting views. A bare allegation of suppression could not justify extended limitation.

Conclusion: The extended period of limitation was not invocable; the post-1 May 2006 demand, interest and penalties were unsustainable, in favour of the assessee.

Final Conclusion: The tax demands for both periods, together with consequential interest and penalties, could not be sustained.

Ratio Decidendi: Extended limitation cannot be invoked on a bare allegation of suppression where the demand arises from disclosed statutory records and the liability involves a bona fide interpretational dispute.

Issues: (i) Whether the unsecured-loan addition was sustainable despite evidence of the creditors' identity, creditworthiness and genuine transactions; (ii) Whether purchase inflation could be inferred from a comparison between the purchase price of rice and the valuation of closing stock; (iii) Whether an addition based on estimated rice yield was valid without rejection of the books of account; (iv) Whether cash paddy purchases from farmers were disallowable as unverifiable despite supporting registers, gate passes and vouchers.

Issue (i): Whether the unsecured-loan addition was sustainable despite evidence of the creditors' identity, creditworthiness and genuine transactions.

Analysis: The assessee furnished PAN details, income-tax returns, bank statements, confirmations, financial statements and cash-flow statements of the loan creditors. The creditors were regular return filers carrying on business, with turnover and disclosed presumptive income supporting the cash deposits preceding the advances. No discrepancy was identified in the evidence, and part of the loans from the same creditors had been accepted. An addition founded only on suspicion concerning preceding cash deposits, without contrary material, was impermissible.

Conclusion: The identity, creditworthiness and genuineness of the loan transactions stood established; the unsecured-loan addition was deleted in favour of the assessee.

Issue (ii): Whether purchase inflation could be inferred from a comparison between the purchase price of rice and the valuation of closing stock.

Analysis: The stock register and purchase records established that the entire quantity of purchased rice was sold during the year and that no purchased rice remained in closing stock. The closing stock valued at the lower of cost or market value related to manufactured rice, consistently valued under the established accounting method, and not to purchased rice. The comparison adopted for alleging inflated purchases was therefore factually erroneous.

Conclusion: The purchase-inflation addition was unsustainable and was deleted in favour of the assessee.

Issue (iii): Whether an addition based on estimated rice yield was valid without rejection of the books of account.

Analysis: Variation in rice yield was supported by the nature and quality of paddy, including moisture conditions, while the quantitative records and audited accounts were maintained. Estimation of income requires satisfaction of the conditions for rejection of books under Section 145(3) of the Income-tax Act, 1961, followed by best judgment assessment under Section 144 of that Act. No defect warranting rejection of the books was recorded, and the assessment had been framed under Section 143(3) of the Income-tax Act, 1961. A marginal comparison with a prior year's yield could not independently support estimated suppressed sales.

Conclusion: The yield-based addition, made without valid rejection of the books of account, was deleted in favour of the assessee.

Issue (iv): Whether cash paddy purchases from farmers were disallowable as unverifiable despite supporting registers, gate passes and vouchers.

Analysis: The purchase register, production register, stock register, mill-gate passes and vouchers recorded the dates, quantities, rates, amounts and recipients of payments for paddy purchases. Small farmers supplying agricultural produce were not expected to issue tax invoices. The books were audited, and no defect was found in the contemporaneous records correlating purchases with production and sales. The finding of unverifiability was based on suspicion rather than contrary evidence.

Conclusion: The cash-purchase addition was unsustainable and was deleted in favour of the assessee.

Final Conclusion: All four impugned additions lacked a valid evidentiary or legal foundation and could not be sustained.

Issues: Whether a fully disclosed claim for deduction of employees' PF and ESI contributions, subsequently disallowed following clarification of law, constituted under-reporting of income attracting penalty under section 270A.

Analysis: Section 270A penalises under-reporting of income, while section 36(1)(va) governs the deduction of employees' contributions. The contributions were disclosed in the tax-audit report, books of account and return, and the claim was consistent with the legal position prevailing when it was made. The disallowance resulted from subsequent judicial clarification that the contributions had to be deposited within the due dates prescribed under the respective statutes. A legal claim unsupported after such clarification, where all particulars are truly and fully disclosed, does not amount to under-reporting or furnishing inaccurate particulars.

Conclusion: The claim did not constitute under-reporting of income; the penalty under section 270A was unsustainable and was directed to be deleted, in favour of the assessee.

Issues: Whether a penalty notice issued without specifying whether the charge was concealment of income particulars or furnishing inaccurate particulars was valid.

Analysis: The notice under Section 274 read with Section 271(1)(c) retained both statutory limbs without striking off the inapplicable charge. This mechanical notice failed to inform the assessee of the precise default alleged and deprived the assessee of an effective opportunity to respond. The defect was held to be fundamental and to vitiate the initiation of penalty proceedings.

Conclusion: The penalty notice was invalid, and the consequential penalty order could not be sustained.

Issues: (i) Whether an addition may rest solely on a retracted survey statement where the audited books disclose a lower profit and no defect or corroborating material is found; (ii) Whether unsecured loans were unexplained cash credits when confirmations, income-tax returns and bank statements of the lenders were furnished and the loans were repaid during the year; (iii) Whether disallowance of contractual expenditure was permissible for short deduction of tax at source under Section 194C; and (iv) Whether capital introduction was unexplained under Section 69 despite a bank trail showing its source from the assessee's proprietary concern.

Issue (i): Whether an addition may rest solely on a retracted survey statement where the audited books disclose a lower profit and no defect or corroborating material is found.

Analysis: A survey admission, without corroborating material, could not by itself sustain an addition. The audited books had not been shown to contain any defect, notwithstanding their rejection under Section 145(3), and the lower profit disclosed in the profit and loss account could not be displaced solely on the basis of the retracted statement.

Conclusion: The addition for the difference in profit was deleted, in favour of the assessee.

Issue (ii): Whether unsecured loans were unexplained cash credits when confirmations, income-tax returns and bank statements of the lenders were furnished and the loans were repaid during the year.

Analysis: The documentary material furnished established the loan transactions and the lenders, and the loans had also been repaid during the relevant year. No addition under Section 68 was sustainable on these facts.

Conclusion: The addition for unsecured loans was deleted, in favour of the assessee.

Issue (iii): Whether disallowance of contractual expenditure was permissible for short deduction of tax at source under Section 194C.

Analysis: Tax had been deducted at a lower rate on contractual payments. A disallowance could arise where tax was not deducted at all, but not merely because of a shortfall in the rate of deduction.

Conclusion: The disallowance for short deduction of tax at source was deleted, in favour of the assessee.

Issue (iv): Whether capital introduction was unexplained under Section 69 despite a bank trail showing its source from the assessee's proprietary concern.

Analysis: The bank records traced the capital introduced through the savings account to withdrawals from the current account of the assessee's proprietary concern. The source of the capital stood explained by material already available on record.

Conclusion: The addition for unexplained capital introduction was deleted, in favour of the assessee.

Final Conclusion: The disputed additions were unsustainable under the applicable provisions, and the assessed income must be recomputed after excluding those additions.

Issues: Whether, where purchases from named suppliers are not fully verified but the goods are reflected in stock records and the corresponding sales are accepted, the entire purchase amount, a 10% ad hoc addition, or only an additional profit element is taxable.

Analysis: The purchases were supported by invoices, banking-channel payments, ledger accounts, purchase and sales registers, stock records, goods receipt documents, VAT records and transaction-wise quantitative mapping with accepted sales. The books and quantitative reconciliation disclosed no identified defect and there was no evidence that the purchase payments were returned in cash. Information identifying suppliers as suspicious, unserved notices and incomplete transport particulars justified doubt regarding the identity of the actual suppliers, but did not establish that goods recorded in stock and sold had not been purchased at all. Third-party material not disclosed to the assessee could not conclusively displace the documentary and quantitative evidence. The circumstances supported, at most, an inference that goods may have been procured through alternative sources, warranting taxation of any additional margin or saving rather than disallowance of the full purchase cost. The case was distinguishable from unexplained-expenditure cases because the source of expenditure, banking trail, stock movement and corresponding sales stood established. A 10% estimate lacked correlation with the assessee's trading margins, disclosed gross profit or comparable material.

Conclusion: Only an additional gross-profit element of 2% of the disputed purchases, over and above the gross profit already disclosed, is taxable; the balance of the 10% addition is deleted. This is in favour of the assessee.

Issues: Whether exemption under sections 11 and 10(23C) could be denied to a registered charitable trust solely because Form 10B was furnished belatedly.

Analysis: The assessee was a registered charitable trust engaged in charitable activities, and Form 10B was available during the appellate proceedings despite being furnished after the prescribed date and after processing of the return under section 143(1). The requirement of furnishing the audit report in Form 10B was treated as procedural and directory; a technical delay in compliance did not negate the substantive eligibility for exemption.

Conclusion: Belated filing of Form 10B does not disentitle the assessee to exemption under sections 11 and 10(23C); the denial of exemption was set aside and the Assessing Officer was directed to grant the claimed benefit.

Issues: (i) Whether the reassessment initiated under Section 148 on the basis of investigation information was valid where the recorded reasons reflected borrowed satisfaction; (ii) Whether the short-term capital loss on sale of shares could be disallowed merely by treating the transactions as penny-stock accommodation entries.

Issue (i): Whether the reassessment initiated under Section 148 on the basis of investigation information was valid where the recorded reasons reflected borrowed satisfaction.

Analysis: The information forming the basis of reopening referred to alleged escaped income of a substantially different amount from the loss ultimately disallowed in assessment. This showed absence of independent application of mind to the information received and reliance on borrowed satisfaction for reopening.

Conclusion: The reassessment was invalid. This issue was decided in favour of the assessee.

Issue (ii): Whether the short-term capital loss on sale of shares could be disallowed merely by treating the transactions as penny-stock accommodation entries.

Analysis: The assessee furnished contract notes, bank records, broker account, demat account and investment records showing that the share transactions were undertaken through the stock exchange using a registered broker. As no defect in this evidence was identified, a general allegation concerning penny-stock transactions did not displace the evidentiary burden discharged by the assessee.

Conclusion: The short-term capital loss was allowable and its disallowance was unsustainable. This issue was decided in favour of the assessee.

Final Conclusion: The reassessment and the corresponding disallowance addressed on merits cannot be sustained.

Issues: Whether cash payments made by a liquor contractor to its supplier attracted disallowance under section 40A(3) of the Income-tax Act, 1961.

Analysis: The cash-payment tabulation established that the payments exceeded the applicable daily threshold. However, section 40A(3) is intended to curb circulation of unaccounted money and not to disallow genuine business payments. The liquor trade operated by the assessee predominantly involved an unorganised cash-based business environment, and the cash payments to the supplier were satisfactorily explained in that factual setting.

Conclusion: The cash payments were treated as genuine and explained; the disallowance under section 40A(3) was deleted in favour of the assessee.

Issues: Whether service tax was payable where receipts attributed to newspaper sales were excluded and the remaining receipts were within the applicable threshold exemption.

Analysis: The receipts reflected in Form 26AS included substantial amounts from sale of newspapers. Sale of newspapers constituted a sale transaction and did not form part of taxable service receipts. After excluding those sale receipts, the value of receipts for each relevant period remained below Rs. 10 lakhs, the applicable threshold limit for service-tax liability.

Conclusion: No service-tax liability arose on the remaining receipts; consequently, no penalty was imposable.

Issues: Whether service tax under the reverse charge mechanism was payable on royalty for mining leases executed before 01.04.2016 during the negative list regime.

Analysis: All relevant mining lease deeds had been executed before 01.04.2016, including the lease deed executed on 16.10.2015. Applying the Tribunal's earlier decisions on mining royalty, the demand for the subsequent period could not be sustained merely because royalty became payable during that period.

Conclusion: No service tax was payable under the reverse charge mechanism on the mining royalty in question; the demand and consequential penalty were unsustainable.

Issues: Whether writ jurisdiction under Article 226 of the Constitution of India should be exercised to interfere with an input tax credit adjudication on allegations of absence of notice under Section 73(1), defects in Form GST DRC-07, violation of Section 75, and denial of hearing, despite an available statutory appeal.

Analysis: Section 73(1) of the Central Goods and Services Tax Act, 2017 requires service of a show-cause notice, while Rule 142(1)(a) of the Central Goods and Services Tax Rules, 2017 requires an electronic summary in Form GST DRC-01; the summary does not replace the statutory notice. The admitted receipt of a demand-cum-show-cause notice identifying the alleged wrongful input tax credit precluded a finding of total absence of notice or jurisdictional error. Form GST DRC-07 under Rule 142(5) is only a summary of the adjudication order; any asserted mismatch with the notice or order, the alleged breach of Section 75(7), and compliance with the hearing requirement under Section 75(4) require scrutiny of the relevant records in appellate proceedings. The alleged entitlement to input tax credit also involved disputed questions of fact concerning the genuineness of transactions and satisfaction of statutory conditions. The doctrine of alternative remedy ordinarily governs fiscal disputes, and the pleaded facts did not establish a recognised exception based on want of jurisdiction or breach of principles of natural justice.

Conclusion: Exercise of writ jurisdiction was not warranted; the remaining challenges concerning demand, procedure, and input tax credit entitlement may be pursued before the statutory appellate forum.

Issues: Whether the absence of concealment of beneficial ownership or a future benefit to a third party excluded the transactions from Section 2(9)(A) of the Prohibition of Benami Property Transactions Act, 1988, and disclosed an error apparent on the face of the record warranting review.

Analysis: Section 2(9)(A) requires that consideration be provided by the beneficial owner and that the property be held in the name of a benamidar for the immediate or future benefit of that beneficial owner. It does not require concealment of the beneficial owner, benefit to a third party, or the use of illegitimate funds. Legitimate funds routed through banking channels may also constitute a benami transaction where the statutory ingredients are fulfilled. The illustrative factors for determining a benami transaction do not override the specific requirements of the applicable statutory clause. The admitted transfer of demonetized currency to benamidars, its deposit and routing through entity bank accounts, and its return in acceptable currency for the applicants' benefit supported the original finding.

Conclusion: The absence of concealment or benefit to a third party did not take the transactions outside Section 2(9)(A), and no error apparent on the face of the record was established to justify review.

Issues: Whether the rejection of a transitional Form 10A application deprived the trust of its pre-existing registration under Section 12AA for Assessment Year 2020-21 and justified denial of exemption under Sections 11 and 12.

Analysis: The registration granted under Section 12AA in 2007 continued unless lawfully cancelled or withdrawn. Rejection of the subsequent Form 10A application was distinct from cancellation of the existing registration and did not extinguish it. The Finance Act, 2020 version of Section 12AB was retrospectively omitted through TOLA from 01.06.2020, and the fresh Section 12AB regime operated from 01.04.2021. Section 12A(2) preserved continuity of exemption in the migration regime. A subsisting registration could not be disregarded by the Assessing Officer, particularly where exemption had been consistently allowed in earlier years on identical facts and no substantive breach of charitable conditions was found.

Conclusion: The original Section 12AA registration remained effective for Assessment Year 2020-21, and rejection of the transitional application did not create a registration gap. Denial of exemption under Sections 11 and 12 and taxation of the surplus were unsustainable; the exemption is to be granted subject to verification of other statutory conditions.