Issues: (i) Whether excess stock of gold, silver and diamond detected during survey under section 133A is taxable as business income or as unexplained investment attractable to section 69B read with section 115BBE of the Income-tax Act, 1961; (ii) Whether the Assessing Officer was justified in disallowing sales promotion expenses of Rs. 2,83,490/- for lack of supporting evidence; (iii) Whether the Assessing Officer was justified in disallowing meal expenses of Rs. 4,12,520/- where alleged double booking occurred; (iv) Whether the Assessing Officer was justified in disallowing 15% (Rs. 1,30,341/-) of vehicle expenses for personal use.

Issue (i): Whether excess stock declared during survey is to be taxed as business income or as unexplained investment under section 69B r.w.s. 115BBE of the Income-tax Act, 1961.

Analysis: The excess stock was gold, silver and diamond declared at the assessee's jeweller business premises and the assessee has no other business activity. The amount was credited to trading and profit and loss accounts and disclosed in returns. Earlier year treatment and coordinate decisions were considered; where the surrender relates directly to the regular business activity and the same item of stock, courts and tribunals have treated such surrender as business income and not as unexplained investment taxable at special rates under section 115BBE.

Conclusion: In favour of Assessee. The excess stock of Rs. 4,42,86,847/- is to be taxed as business income and not as unexplained investment under section 69B r.w.s. 115BBE.

Issue (ii): Whether sales promotion expenses of Rs. 2,83,490/- disallowed by the Assessing Officer for lack of documentary evidence should be restored or sustained.

Analysis: The Assessing Officer rejected vouchers as self-made and found cash payments unsupported. The CIT(A) restricted disallowance to 10% without further documentary basis. The Tribunal examined absence of satisfactory evidence before the CIT(A) and the original AO finding of non-genuine expenditure.

Conclusion: In favour of Revenue. The Tribunal restored the AO's addition of Rs. 2,83,490/-.

Issue (iii): Whether meal expenses of Rs. 4,12,520/- disallowed by AO on account of duplicate booking should be sustained or reduced.

Analysis: AO found double booking (staff welfare and meal expenses) and disallowed accordingly; CIT(A) granted part relief without logical basis. The Tribunal found the AO's finding of duplication and lack of justification for CIT(A)'s partial allowance.

Conclusion: In favour of Revenue. The Tribunal set aside the CIT(A)'s relief and restored the disallowance.

Issue (iv): Whether disallowance of vehicle expenses at 15% (Rs. 1,30,341/-) for personal use is justified or should be restricted to 10% as done by CIT(A) or to 5% as claimed.

Analysis: The assessee admitted personal use of two cars and no log book or supporting evidence was produced to substantiate lower personal use. AO disallowed 15% in absence of evidence; CIT(A) reduced to 10% without sound reasoning.

Conclusion: In favour of Revenue. The Tribunal restored the AO's disallowance at 15%.

Final Conclusion: The appeal by the Revenue is partly allowed: the Tribunal upheld the CIT(A)'s conclusion that the excess stock surrendered during survey is taxable as business income (favouring the assessee) but allowed the Revenue's grounds on disallowance of sales promotion, meal and vehicle expenses and restored the Assessing Officer's additions (favouring the Revenue).

Ratio Decidendi: Where an amount surrendered on account of excess stock detected during survey has a direct nexus with the assessee's regular business activity and is reflected in books and returns, it is taxable as business income and provisions for unexplained investment attracting special rate under section 115BBE are not applicable.

Issues: Whether the addition of entire cash/credits in the bank account maintained with Renuka Mata Multi State Urban Co-operative Credit Society Ltd. can be treated as the assessee's unexplained income or a reasonable proportion (commission) of deposits should be adopted as taxable income.

Analysis: The Assessing Officer reopened assessment under Section 147 of the Income-tax Act, 1961 and treated bank credits as unexplained income. The CIT(A) upheld the addition for failure to provide documentary evidence. The Tribunal examined investigation reports regarding modus operandi of the Society (operation on an angadia/accommodation entries model) and relied on appellate precedents where only a small percentage of deposits was treated as commission income of the account-holder. Considering (i) absence of assets or lavish expenditure attributable to the alleged income, (ii) the Investigation Wing's findings that many account-holders were mere name-lenders and accounts were operated by real beneficiaries, and (iii) relevant judicial decisions that adopted low commission rates where beneficiaries could not be identified, the Tribunal concluded that taxing the entire deposits as the assessee's income would be unjust. Applying the Tribunal's discretion in the facts of this case, and following comparable precedents, the Tribunal fixed a reasonable rate of income to be attributed to the assessee.

Conclusion: The appeals are partly allowed. The Assessing Officer is directed to compute the assessee's income by adopting 2% of the deposits/credits in the bank account maintained with Renuka Mata Multi State Urban Co-operative Credit Society Ltd. instead of treating the entire deposits as the assessee's income.

Issues: Whether the addition of cash deposits as unexplained income under section 69A of the Income-tax Act, 1961 is sustainable where the assessing officer, in rectification proceedings under section 154 of the Income-tax Act, 1961, has accepted the source of such deposits as retirement benefits and revised the returned income.

Analysis: The Tribunal examined the sequence of orders: original addition as unexplained cash under section 69A; subsequent rectification under section 154 where the assessing officer accepted that the deposits arose from retirement benefits and accepted a revised taxable income; and a later direction under section 263 leading to a reassessment under section 147 read with section 263 and section 144B that again made the addition. The Tribunal relied on the effect of the Department's own admission in the section 154 proceedings regarding the nature and source of the deposits and considered whether such admission permits sustaining an addition under section 69A. The Tribunal found that once the assessing officer, through rectification, accepted the source of the cash deposits as retirement benefits and revised the income accordingly, there remained no legal basis to treat the same amounts as unexplained money and to re-impose the addition under section 69A.

Conclusion: The addition under section 69A of the Income-tax Act, 1961 is not sustainable in view of the acceptance of source in rectification proceedings under section 154; the appellate order is set aside and the assessing officer is directed to delete the additions. The appeal is allowed in favour of the assessee.

Issues: Whether the estimation of net profit at 0.70% after rejection of the books of account was justified and whether the appellate order suffered from non-consideration of the record or absence of adjudication on merits.

Analysis: The books of account were found to contain defects, but the appellate authority held that rejection of the books and estimation of income must rest on reasonable and credible material rather than assumptions alone. The estimation of net profit was made by taking the highest net profit rate from the assessee's preceding years and by considering the overall profitability pattern of the assessee's business. The Tribunal found that the appellate order was reasoned, that the assessee failed to produce any material to dislodge the estimate, and that the defects in the books did not by themselves negate the adopted profit estimation once the authorities had applied a rational basis drawn from past results and the facts on record.

Conclusion: The estimation of net profit at 0.70% was upheld and the challenge to the appellate order failed.

Final Conclusion: The appeal was dismissed, and the income estimation made by the appellate authority remained undisturbed.

Ratio Decidendi: Where books of account contain defects, the income may be estimated on a rational basis by relying on past profitability and relevant surrounding circumstances, and such estimation will not be interfered with absent material to show that it is arbitrary or unsupported.

Issues: Whether the subsequent complaint and the proceedings arising from it were barred by issue estoppel in view of the earlier decision on the same factual matrix.

Analysis: The material facts were common to both proceedings: the alleged transfer of shares arose out of the same family settlement, the same implementation agreement, and the same set of letters and returns filed before the ROC. The earlier complaint based on the same allegations had already been finally decided on merits, with a finding that the dispute was essentially civil in nature and did not disclose the necessary ingredients of the alleged offence. The principle of issue estoppel applies where an issue has been distinctly raised and conclusively determined, and a later proceeding between the same parties cannot advance allegations inconsistent with that finding.

Conclusion: The subsequent complaint was barred by issue estoppel and could not survive.

Final Conclusion: The complaint and all proceedings flowing from it, including the impugned orders, were set aside.

Ratio Decidendi: Where an earlier complaint on the same facts has been finally decided on merits, a later complaint based on the same factual issue is barred by issue estoppel and cannot reopen matters already conclusively determined.

Issues: (i) Whether municipal property-tax dues relating to the period prior to the petitioners' purchase could be retrospectively assessed and enforced against them. (ii) Whether, after liquidation under the Insolvency and Bankruptcy Code, 2016, municipal dues had to be lodged and realised only through the liquidation process. (iii) Whether the auction-sale conditions could fasten pre-existing municipal liabilities on the petitioners as purchasers.

Issue (i): Whether municipal property-tax dues relating to the period prior to the petitioners' purchase could be retrospectively assessed and enforced against them.

Analysis: The property had gone into liquidation before the petitioners purchased it. The municipal authority had not crystallised or lodged the claimed dues with the liquidator for the relevant earlier period. The Court held that the petitioners, being strangers to the property for the prior period, could not be saddled with liability for a time when they were not owners, and any pre-liquidation claim had to follow the insolvency framework rather than a fresh retrospective levy against the purchasers.

Conclusion: The retrospective municipal demand for periods prior to 26 September 2019 was unsustainable against the petitioners.

Issue (ii): Whether, after liquidation under the Insolvency and Bankruptcy Code, 2016, municipal dues had to be lodged and realised only through the liquidation process.

Analysis: The Court applied the overriding effect of the Insolvency and Bankruptcy Code, 2016 and treated municipal property-tax dues as operational debt. It held that once liquidation commences, statutory and municipal claims must be asserted before the liquidator and dealt with under the statutory priority framework. Independent recovery under municipal law outside the Code was impermissible where no claim had been lodged in the liquidation process.

Conclusion: Pre-liquidation municipal dues could be enforced only in accordance with the Insolvency and Bankruptcy Code, 2016, particularly the liquidation and priority scheme.

Issue (iii): Whether the auction-sale conditions could fasten pre-existing municipal liabilities on the petitioners as purchasers.

Analysis: The sale terms on an "as is where is" and "whatever there is" basis did not override the statutory scheme under the Insolvency and Bankruptcy Code, 2016. In the absence of any quantified arrear demand existing against the petitioners at the time of transfer, and in the absence of a claim lodged before the liquidator, the contractual clause could not revive or preserve an otherwise unenforceable municipal demand against the auction purchasers.

Conclusion: The sale conditions did not make the petitioners liable for pre-liquidation municipal dues.

Final Conclusion: The impugned notice, assessment and tax bill were set aside to the extent they sought to burden the petitioners with dues for the period before transfer, while the municipal authority was left free to assess and recover tax only from the date of title transfer in accordance with law.

Ratio Decidendi: In liquidation, municipal dues are subject to the Insolvency and Bankruptcy Code, 2016 and cannot be independently enforced against an auction purchaser for the pre-transfer period unless duly asserted in the liquidation process and dealt with under the statutory priority framework.

Issues: Whether, after approval of a resolution plan by the Adjudicating Authority under Section 31(1) of the Insolvency and Bankruptcy Code, 2016, pending tax appeals against statutory dues can be continued before the Appellate Tribunal or must be treated as concluded/closed.

Analysis: The Tribunal examined the NCLT order approving resolution plans under Section 31(1) of the Insolvency and Bankruptcy Code, 2016 and applied the Supreme Court's decision in Ghanashyam Mishra and Sons Pvt. Ltd. v. Edelweiss Asset Reconstruction Company Ltd. The analysis relied on the IBC provisions creating a moratorium under Section 14, the binding effect of an approved resolution plan under Section 31(1), and the overriding operation of the IBC under Section 238. The Tribunal noted that once a resolution plan is approved, claims not included in the plan stand extinguished and proceedings in respect of such claims cannot be initiated or continued. The Tribunal also considered that continuation of any pending appeal depends on whether the approved resolution plan expressly permits such continuation; absent such provision, the appellate authority becomes functus officio.

Conclusion: Against the appellant. The appeals cannot be continued and stand concluded/disposed of by operation of the approved resolution plan and the IBC.

Issues: Whether the delay in filing the appeal against the impugned order dated 27.02.2021 is liable to be condoned.

Analysis: The Tribunal examined the correspondence and the dispatch record produced by the adjudicating authority, including the dispatch register entry with postal barcode and various communications between the department, banks and the applicant showing recovery steps taken and acknowledgements by the applicant. The Tribunal found that the applicant became aware of the adjudged demand and engaged with the department and banks as early as October 2023; medical certificates produced pre-dated the impugned order and did not establish hospitalization preventing filing of appeal. Although statutory proof of delivery under Section 37C of the Central Excise Act, 1944 (as applied to service tax matters) was not placed on record, the sequence of events indicated the applicant had constructive knowledge of the order well before filing. Considering the inordinate delay of almost 1,400 days and unsatisfactory explanation, the Tribunal concluded that ordinary condonation was not justified but, in view of overall circumstances and ends of justice, a monetary deposit into PMNRF was an appropriate condition to permit the appeal to proceed to admission.

Conclusion: The delay in filing the appeal is not satisfactorily explained and is excessive; condonation is refused in the ordinary course but the appeal may be allowed to proceed on compliance with the Tribunal's direction to deposit a cost of Rs.1,00,000 into the Prime Minister's National Relief Fund within six weeks, failing which the file will be closed.

Issues: (i) Whether the complaint was liable to be quashed on the ground that the complainant was misdescribed and had no privity with the petitioner; (ii) Whether the cheque dated 18.05.2023 was supported by a legally enforceable liability so as to sustain proceedings under Section 138 of the Negotiable Instruments Act, 1881.

Issue (i): Whether the complaint was liable to be quashed on the ground that the complainant was misdescribed and had no privity with the petitioner.

Analysis: The documents showed that the lease arrangement, termination notice, cheque, and earlier proceedings were all in the name of Triangles Consolidated Ltd., while the complaint was filed in the name of Triangles Consolidated Pvt. Ltd. The discrepancy appeared to be a misdescription rather than a distinct legal entity dispute capable of being finally resolved at the quashing stage. The Court held that the complainant should be afforded an to explain its locus standi during trial.

Conclusion: The complaint was not quashed on this ground.

Issue (ii): Whether the cheque dated 18.05.2023 was supported by a legally enforceable liability so as to sustain proceedings under Section 138 of the Negotiable Instruments Act, 1881.

Analysis: The admitted material showed that a security deposit of Rs. 15 lakhs had been paid at the inception of the lease, that an eviction notice had been issued, and that the cheque amount was subsequently transferred back by RTGS on 06.06.2023. The Court found that the complainant had received Rs. 15 lakhs in respect of the cheque and that no legally enforceable liability survived. The belated plea that the amount represented damages for fit-outs was not supported by the demand notice or the parallel proceedings.

Conclusion: The cheque was not backed by a legally enforceable liability and the Section 138 proceedings could not stand.

Final Conclusion: The criminal complaint and all proceedings arising from it, including the summoning order, were set aside because the foundational liability for the cheque was absent.

Ratio Decidendi: A prosecution under Section 138 of the Negotiable Instruments Act, 1881 cannot survive where the cheque amount has already been discharged and no legally enforceable liability remains; a mere nomenclatural discrepancy in the complainant's name will not by itself justify quashing if it is only a misdescription.

Issues: Whether the imported alloy steel material was classifiable as waste and scrap under the Customs Tariff Act, and whether the reclassification and consequential re-valuation were sustainable.

Analysis: Section Note 8 to Section XV defines waste and scrap as metal waste and scrap from the manufacture or mechanical working of metals, and metal goods definitely not usable as such because of breakage, cutting-up, wear or other reasons. The goods were found to be off-specification material, unsuitable for the original intended use, and fit only for melting purpose. The authorities placed undue emphasis on chemical composition and did not establish reliable evidence that the goods were alloy steel bars or otherwise not scrap. The relevant section and chapter notes were not properly applied.

Conclusion: The goods were correctly treated as waste and scrap, and the reclassification as well as the consequential re-valuation were unsustainable.

Final Conclusion: The impugned order was set aside and the appeals were allowed with consequential relief according to law.

Ratio Decidendi: Where imported metal goods are shown to be off-specification and unusable as such, their chemical composition alone does not displace classification as waste and scrap under the tariff notes.

Issues: (i) Whether Section 10A of the Insolvency and Bankruptcy Code is attracted in the present case; (ii) Whether the outstanding amount at the time of filing of the company petition was below the statutory threshold (Rs. 1 crore) because of prior payment and absence of agreement to pay interest, rendering the petition not maintainable.

Issue (i): Whether Section 10A of the Insolvency and Bankruptcy Code applies to the petition filed in CP(IB) No.69 of 2021.

Analysis: The Court examined the date of default recorded in Part IV of the petition and the dates relied upon by the appellant. The petition records the date of default as 19.04.2019 while the default claimed as on 29.12.2020 includes interest computed thereafter. Section 10A is concerned with defaults occurring within the prescribed period; since the date of default falls beyond the temporal scope relied upon by the appellant, Section 10A cannot be invoked to bar the petition. The Court also considered the invoiced terms which provided for interest after a 60-day credit period and evidence showing acceptance of invoices and purchase orders signed on behalf of the corporate debtor.

Conclusion: Section 10A of the Insolvency and Bankruptcy Code is not attracted; conclusion is against the appellant.

Issue (ii): Whether the principal outstanding was below Rs. 1 crore at the time of filing because (a) a payment of Rs. 3,03,963/- was made prior to service of the demand notice and (b) there was no agreement for payment of interest, so interest could not be included to reach the threshold.

Analysis: The Court reviewed Part IV of the petition, the ledger, invoices, purchase orders and the reply to the demand notice. The Court found invoices and corresponding purchase orders bearing signatures on behalf of the corporate debtor and invoice terms providing for interest at 24% per annum after the agreed credit period. The ledger and supporting documents filed by the respondent show computation of interest in accordance with the invoiced terms, resulting in the claimed outstanding exceeding Rs. 1 crore on 29.12.2020. The Court did not accept the appellant's contention that specific invoices were paid or that interest was never agreed; documentary records did not support the appellant's assertion that the principal alone was below the threshold at filing.

Conclusion: The claim that the outstanding principal was below Rs. 1 crore is rejected; conclusion is against the appellant and in favour of the respondent.

Final Conclusion: The impugned order dismissing objections to maintainability is upheld; the appeal is dismissed and the company petition was correctly treated as maintainable because the outstanding, including interest as per agreed invoice terms, exceeded the statutory threshold at the relevant time.

Ratio Decidendi: Where invoices and accompanying purchase orders establish agreed terms for interest and the date of default predates any statutory cutoff relied upon by the appellant, interest properly computed under those terms may be included in determining the outstanding for assessing maintainability of a company petition under the Code.

Issues: (i) Whether services described as horticulture/garden maintenance are exempt under the negative list (Section 66D(d)) and whether demands on such turnover are time-barred; (ii) Whether the balance turnover on manpower supply is taxable (taking into account partial valuation) and whether penalty and extended period invocation are sustainable for the shortfall.

Issue (i): Whether horticulture/garden maintenance services are exempt from service tax under the negative list and whether demand on that turnover is time-barred.

Analysis: The exemption scope under Section 66D(d) of the Finance Act, 1994 and the definition of "agriculture" in Section 65B(3) of the Finance Act, 1994 were applied to activities such as watering, weeding, manuring, pruning and plant protection. Prior Tribunal authority interpreting horticulture as falling within agricultural activity and within the negative list was followed. The question of extended period was considered in the light of absence of evidence of deliberate intention to evade tax and prior guidance indicating non-liability.

Conclusion: The demand on turnover of Rs.40,16,924 relating to horticulture services is not sustainable and is set aside on merits and on account of time bar; decision is in favour of the assessee on this issue.

Issue (ii): Whether the shortfall in service tax on manpower supply services (taxable on 25% of gross) is chargeable and whether penalty/extended period invocation is maintainable.

Analysis: The applicable partial valuation for manpower supply was applied to the stated turnover to compute taxable value and tax liability. Records show partial payment of tax and a remaining short payment of Rs.12,870. There is no evidence of deliberate suppression or wilful intent to evade tax supporting invocation of extended period for penalty. Therefore liability for the shortfall and interest arises, but penalty and extended-period consequences require proof of wilful suppression.

Conclusion: The appellant is liable to pay the outstanding service tax of Rs.12,870 along with applicable interest; imposition of penalty is set aside. This conclusion is against the assessee on the limited issue of the unpaid tax but in favour of the assessee on penalty.

Final Conclusion: The appeal is partly allowed - tax demand on horticulture turnover is quashed and time-barred, while a limited balance tax with interest is sustained for manpower supply; all penalties are set aside.

Ratio Decidendi: Services properly characterized as horticulture/garden maintenance fall within the negative list under Section 66D(d) read with Section 65B(3) of the Finance Act, 1994 and demands thereon are unsustainable where no evidence of deliberate evasion exists; liabilities arising from incorrect calculation of tax on manpower supply remain chargeable but penalties requiring wilful suppression cannot be imposed without supporting evidence.

Outcome: The matter and the pending criminal complaints were closed in terms of the settlement; the suo motu action was also closed.

Issues: Whether the assessment of a person other than the searched person under Section 153C was barred by limitation.

Analysis: The seized material relating to the assessee was held to have been handed over to the assessee's Assessing Officer when the assessee's case was transferred under Section 127 to the Central Circle having jurisdiction over the searched person. Since the Assessing Officer for both persons was the same thereafter, no separate physical transmission of seized material was required. The limitation period under Section 153B(1)(b)(ii) was consequently reckoned from the date of that transfer, and the assessment completed thereafter fell outside the prescribed period.

Conclusion: The assessment under Section 153C was time-barred and was quashed, in favour of the assessee.

Issues: Whether the High Court was justified in quashing the proceedings for money-laundering offences by assessing the evidentiary merits at the pre-trial stage.

Analysis: The High Court assessed the recovery and the absence of evidence of the respondent's knowledge of deposits in his bank account. The disputed question concerning the respondent's knowledge and involvement in concealing proceeds of crime required determination at trial and could not be conclusively assessed while considering quashing.

Conclusion: The quashing of proceedings was unwarranted; the allegations must be adjudicated at trial.

Issues: Whether the addition made as unexplained investment under section 69 of the Income-tax Act, 1961, and sustained in appeal, was liable to be deleted in view of the coordinate bench decisions on identical facts.

Analysis: The appeals arose from additions treating cash payments towards purchase of a shop as unexplained investment. The Tribunal noted that the assessee relied on several prior decisions of coordinate benches concerning the same group and similar transactions. The Revenue was unable to distinguish those decisions on facts or law. Following the earlier rulings, the Tribunal found no material difference in the present matters and adopted the same view.

Conclusion: The addition under section 69 was deleted and the assessee's challenge succeeded.

Final Conclusion: The common order of the first appellate authority was set aside and all three appeals were allowed.

Ratio Decidendi: Where the facts and issue are materially identical to earlier coordinate bench decisions, and no distinguishing feature is shown, the Tribunal may follow those decisions and delete the addition for unexplained investment.

Issues: Whether any substantial question of law arose from the Tribunal's order dismissing the appeal for non-compliance with the mandatory pre-deposit requirement and for want of supporting records.

Analysis: The Tribunal had found non-compliance with the mandatory pre-deposit requirement under the applicable service tax framework and also noted that the supporting documents, including the show-cause notice and materials relied upon in the appeal, had not been placed on record. On review, the Court found no substantial question of law arising from that order. The delay in filing the appeal was separately condoned, but that did not affect the merits of the challenge.

Conclusion: No substantial question of law was made out, and the challenge to the Tribunal's order failed.

Issues: Whether delay in filing Form 67 could justify denial of foreign tax credit claimed by the assessee.

Analysis: The credit claimed related to taxes paid outside India and was duly reflected in the return. Rule 128 of the Income-tax Rules, 1962 was examined and sub-rule (9) was held not to prescribe denial of foreign tax credit for delayed filing of Form 67. The requirement of filing Form 67 was treated as directory, not mandatory, and no adverse consequence for non-compliance was found in the rule. The provisions of section 90 and section 91 of the Income-tax Act, 1961 were noted to contain no timeline for furnishing such declaration, and the treaty position under the DTAA was also relied upon.

Conclusion: Delay in filing Form 67 did not justify denial of the foreign tax credit. The credit was directed to be allowed in favour of the assessee.

Final Conclusion: The assessee was held entitled to relief for foreign tax credit, and the matter was sent back only for verification and allowance of the claim.

Ratio Decidendi: Furnishing Form 67 for foreign tax credit is a directory procedural requirement, and delay in filing it cannot by itself defeat a substantive claim for credit where the tax paid abroad and the underlying claim are otherwise duly disclosed.

Issues: Whether the reassessment notice for assessment year 2015-16, issued on 31 March 2021 with sanction of the Principal Commissioner instead of the Joint Commissioner, was valid.

Analysis: The notice fell under the pre-1 April 2021 reassessment regime. The applicable limitation period, as extended under the governing COVID-19 relaxation framework, treated the notice as issued within four years from the end of the relevant assessment year. Consequently, Section 151(2) of the Income-tax Act, 1961 required statutory sanction from the Joint Commissioner. The Principal Commissioner was not the specified authority for such sanction. Strict compliance with the statutory mandate concerning the specified authority was necessary; sanction by an unauthorized authority constituted a jurisdictional defect.

Conclusion: The reassessment notice was invalid, and the consequential order disposing of objections, assessment order, demand notice, penalty-initiation notice, and consequential proceedings were quashed in favour of the assessee.

Issues: Whether the anticipatory bail application could be entertained where no order authorising arrest had been passed.

Analysis: No order under Section 69 of the Central Goods and Services Tax Act, 2017 had been passed. In its absence, the applicant could not be arrested; consequently, the apprehension of arrest did not warrant entertainment of the anticipatory bail application at that stage.

Conclusion: The anticipatory bail application could not be entertained at that stage.