Issues: Whether the High Court was justified in directing a refund procedure, not contemplated by Section 54 of the Central Goods and Services Tax Act, 2017, whereby the taxable person would deposit the refundable amount in a designated account and seek to pass the benefit to consumers through tariff adjustments instead of crediting the refundable amount to the Consumer Welfare Fund under Section 57.

Analysis: Section 54(5) of the Central Goods and Services Tax Act, 2017 contemplates that on satisfaction that a refund is allowable the officer shall make an order and the amount so determined is to be credited to the Consumer Welfare Fund referred to in Section 57. Section 54(8) provides limited exceptions permitting payment of refundable amounts to applicants; Section 54(8)(e) permits payment to the applicant only where the applicant has not passed on the incidence of the tax to any other person. In the present matter it is admitted that the respondent had passed on the incidence of the tax to consumers, hence the statutory exception in Section 54(8)(e) is inapplicable. The procedure fashioned by the High Court - acceptance of an undertaking to create a designated bank account and to seek tariff adjustments before the electricity regulator so as to indirectly recompense consumers - is not provided for under Section 54 or the Rules framed thereunder and constitutes a departure from the statutory refund mechanism which requires credit to the Consumer Welfare Fund unless a statutory exception applies.

Conclusion: The High Court's procedure for disbursal of the refund is not sustainable in law; the refundable amount is to be credited to the Consumer Welfare Fund under Section 57 of the Central Goods and Services Tax Act, 2017 and the appeal is allowed.

Issues: Whether the Court should condone the delay and grant liberty to the petitioner to file an appeal against the assessment order dated 18.06.2025 challenging interest and penalty imposed.

Analysis: The petitioner had filed a reply to the show cause notice (DRC-01 dated 12.09.2024) and participated in the personal hearing before the assessing authority. The assessment order was passed on 18.06.2025 and the disputed tax amount was thereafter recovered. The petitioner says he remained unaware of the assessment order due to negligence of his consultant and therefore seeks condonation of an eight-month delay in filing an appeal. The respondent contests the plea, relying on the fact that the petitioner had actively participated in proceedings and therefore had a duty to monitor subsequent developments on the GST web portal. The Court examined the record and found no satisfactory explanation for the long inaction; it emphasized the assessee's responsibility to verify the departmental portal and that participation in proceedings coupled with failure to take steps for eight months without adequate cause does not justify condonation of delay.

Conclusion: The petitioner's request for condonation of delay and for liberty to file an appeal is rejected; the petition is dismissed as devoid of merits.

Ratio Decidendi: Where an assessee has participated in adjudicatory proceedings, an unexplained or inadequately explained prolonged delay in challenging the consequent assessment (including an eight-month inaction) and failure to verify departmental communications on the statutory portal do not ordinarily justify condonation of delay for filing an appeal.

Issues: Whether Section 16(2)(c) of the Central Goods and Services Tax Act, 2017 can be invoked to deny Input Tax Credit to a bona fide purchasing dealer where the selling dealer has failed to deposit the tax collected with the Government.

Analysis: Section 16(2)(c) operates to deny ITC in specified circumstances but does not, on its face, distinguish between bona fide purchasers and purchasers involved in collusive or fraudulent transactions. Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 set out distinct procedures for determination of tax where there is no fraud or where fraud/wilful misstatement/suppression is alleged respectively. Established principles require that penal or disproportionate consequences not be visited on a taxpayer acting in good faith. Applying the reasoning in M/s Sahil Enterprises (Tripura High Court), reading down is appropriate to preserve constitutionality under Article 14 by confining the denial of ITC under Section 16(2)(c) to transactions that are not bona fide, or are collusive or fraudulent. In the present case the impugned show cause notice and order under Section 73 contain no findings that the purchase transactions were collusive, fraudulent, or otherwise not bona fide; the assessment proceeded under the procedure for non-fraudulent cases rather than under Section 74 for fraud.

Conclusion: Section 16(2)(c) cannot be applied to deny ITC where the purchasing dealer has bona fide transacted and there is no finding of collusion, fraud, or wilful misstatement; accordingly the purchaser is entitled to the claimed ITC.

Issues: (i) Whether the petitioner can be exempted from making the statutory pre-deposit (10% of penalty) while filing an appeal under the GST regime despite having paid outstanding tax dues and having delayed filing the appeal.

Analysis: The Court examined the limited question of whether any exemption from the statutory pre-deposit requirement is available to a taxpayer under the GST regime where tax dues have been paid during adjudication and the appeal filing time has lapsed while the taxpayer was corresponding with authorities. The respondents contended there is no power to exempt pre-deposit and that questions regarding the correctness of imposition of tax or penalty must be decided by the appellate authority upon filing of the appeal with the statutory deposit. The Court observed that merits of liability (tax/penalty) are to be decided on appeal and cannot be used to seek exemption from the pre-deposit requirement. Having noted the petitioner's correspondence with authorities and the missed deadline, the Court granted procedural relief by permitting the petitioner to file the appeal within two weeks with the statutory deposit and a delay condonation application, directing the appellate authority to consider the delay sympathetically and, if satisfied, decide the appeal on merits within a reasonable time, preferably within twelve weeks from receipt of a copy of the order.

Conclusion: Exemption from the statutory pre-deposit requirement is not available; issue decided against the assessee.

Issues: Whether, in view of non-production of books before the Assessing Officer and completion of assessment under Section 144, the estimation of profit under Section 44AD should be revisited by providing a final opportunity to the assessee to produce books, and whether the appeal should be allowed for statistical purposes to enable fresh consideration by the Assessing Officer.

Analysis: The adjudication addressed the consequence of non-furnishing of books resulting in assessment under Section 144 and the correctness of estimating profit at 8% under Section 44AD. The proceeding examined whether principles of natural justice require a final opportunity to produce books and details before the Assessing Officer so that the estimation can be reconsidered on substantive evidence rather than solely on record leading to assessment under Section 144. The order directed that a final opportunity be afforded to the assessee to produce books and details and that the Assessing Officer shall, after careful consideration of such documents, pass the necessary order in accordance with law.

Conclusion: Appeal allowed for statistical purposes and the matter remitted to the Assessing Officer for fresh adjudication after affording the assessee a final opportunity to produce books of account and relevant details.

Final Conclusion: The decision effects a remand for de novo consideration by the Assessing Officer to secure compliance with natural justice and enable substantive adjudication on the basis of accounts and documents furnished by the assessee.

Ratio Decidendi: Where assessment is completed under Section 144 due to non-production of books, principles of natural justice may require remand and a final opportunity to produce books so that estimation under Section 44AD is based on substantive materials rather than solely on the prior non-compliance.

Issues: Whether the addition of Rs. 6,99,50,000 treated as unexplained cash credit under Section 68 of the Income-tax Act, 1961 can be sustained where the assessee furnished particulars of subscribing shareholders and the subscribers complied with notices under Section 133(6) by producing PANs, ITRs, audited financial statements, bank statements and explanations regarding source of payment.

Analysis: The Tribunal examined whether the assessee discharged the initial onus under Section 68 by establishing identity, creditworthiness and genuineness of the share subscription. The subscribers were identified by valid PAN/CIN and service of notices under Section 133(6) was established. The subscribers furnished income-tax returns, audited financial statements, bank statements showing source of funds and allotment documents. The assessing officer's assessment record did not take note of these contemporaneous documents and placed emphasis on non-appearance to summons under Section 131 after many years. Relevant judicial precedents and factual comparators were considered in assessing the weight of documentary evidence and the practical difficulties of compelling personal attendance after a prolonged period. The Tribunal concluded that the three ingredients required by Section 68 (identity, creditworthiness and genuineness) were satisfied on the material placed before the assessing officer and on record.

Conclusion: The addition under Section 68 of the Income-tax Act, 1961 is deleted and the appeal is allowed in favour of the assessee.

Issues: (i) Whether the excess share premium of Rs. 10,21,00,000 charged u/s 56(2)(viib) of the Income-tax Act, 1961 on issuance of shares is chargeable where the assessee adopted Discounted Cash Flow (DCF) valuation under Rule 11UA and issued shares to existing promoters.

Analysis: Section 56(2)(viib) taxes consideration received on issue of shares in excess of fair market value (FMV), with FMV determinable by prescribed methods or by substantiation to the satisfaction of the Assessing Officer. Rule 11UA provides prescribed valuation methods including the DCF method and NAV method; the assessee is entitled to adopt any prescribed method and obtain a valuation report accordingly. The authorities may scrutinise and test the valuation under the method chosen by the assessee but cannot substitute a different valuation method. The DCF method inherently involves projections and assumptions; reliability must be judged on whether projections were reasonable and supported by contemporaneous materials, not by comparison with subsequent actuals. Contemporaneous documents here include sanctioned project plans, bank sanction letter, land holdings and circle rates, construction WIP and advances from customers, and the valuer's inputs such as FAR, project life, costs and weighted average cost of capital. The DCF report relied on such contemporaneous inputs and reasonable assumptions; subsequent non-recognition of revenue was attributable to accounting method and later delays and does not vitiate the valuation. The Assessing Officer substituted NAV using book values without considering contemporaneous market circle rates and without applying the valuation method elected by the assessee; this substitution is impermissible. Where application of NAV using prevailing market values yields FMV higher than issue price, there is no charge under Section 56(2)(viib).

Conclusion: The DCF valuation under Rule 11UA was sustainable on the facts and the Assessing Officer could not substitute the method; the share premium charged was not excessive and the addition of Rs. 10,21,00,000 u/s 56(2)(viib) is deleted in favour of the assessee.

Issues: Whether the assessing officer could, in assessment for AY 2017-18, substitute the cost of acquisition of listed shares (paid in FY 2014-15 and accepted in AY 2015-16) with market prices on dematerialization dates and deny exemption under section 10(38) of the Income-tax Act, 1961.

Analysis: The admitted facts show purchase of shares in FY 2014-15 and sale in FY 2016-17, with the cost of acquisition having been verified and accepted in scrutiny assessment proceedings for AY 2015-16 after enquiries under section 133(6) of the Income-tax Act, 1961. Each previous year is a distinct unit for assessment and the charge to tax is on income of the relevant previous year as per sections 3 and 4 and definitions in sections 2(45) and 5 of the Income-tax Act, 1961. Absent a challenge to the purchase year or payment in the year of sale, revisiting and substituting the declared purchase consideration in a later assessment year, without bringing cogent adverse evidence, is impermissible. The assessing officer also lacked material to justify treating the differential as income under section 56(1) in the year of sale.

Conclusion: The substitution of the assessee's declared cost of acquisition by market prices on dematerialization dates and denial of exemption under section 10(38) in AY 2017-18 is not sustained; outcome is in favour of the assessee.

Issues: (i) Whether duty-free raw cashew nuts imported under advance authorisation were diverted in breach of the actual user condition, the customs notification, and the Foreign Trade Policy, so as to sustain confiscation and duty demand; (ii) Whether penalty on the customs brokers was sustainable for merely facilitating clearance and transport of the goods.

Issue (i): Whether duty-free raw cashew nuts imported under advance authorisation were diverted in breach of the actual user condition, the customs notification, and the Foreign Trade Policy, so as to sustain confiscation and duty demand.

Analysis: The imported goods were covered by advance authorisations and were subject to the actual user condition under the notification and the Foreign Trade Policy. The evidence showed that the goods were not processed in the authorised premises, were routed to other units without permission, no proper accounts were maintained, and substantial quantities were sold in the local market or otherwise diverted. The Court treated the transfer to other units and the subsequent sales as contrary to the conditions of the exemption and the policy governing advance authorisation.

Conclusion: The issue was answered in favour of Revenue. The confiscation and consequential duty liability were upheld against the importer and connected persons.

Issue (ii): Whether penalty on the customs brokers was sustainable for merely facilitating clearance and transport of the goods.

Analysis: The material showed that the customs brokers acted on the instructions received for clearance and dispatch, but there was no sufficient proof that they themselves participated in the diversion with an intention to evade revenue. Their role was confined to logistics and customs clearance, and the requisite mens rea for penalty was not established on the record as against them.

Conclusion: The issue was answered in favour of the brokers. The penalty imposed on them was not sustained.

Final Conclusion: The common judgment resulted in reversal of the Tribunal insofar as the importer-related appeals were concerned, while the appeals relating to the customs brokers failed, leaving the revenue's demand and confiscation intact against the importer side and the broker penalties set aside only where not justified.

Ratio Decidendi: Goods imported under advance authorisation must be used strictly in accordance with the actual user condition and the governing exemption conditions; unauthorised diversion, lack of accounting, and local sale justify denial of exemption and consequent customs action, while penalty on intermediaries requires proof of deliberate participation in the contravention.

Issues: Whether the National Company Law Tribunal correctly exercised its power under Section 59 of the Companies Act, 2013 to order rectification of the register of members, restore the shares to the registered shareholder and award damages/costs where duplicate share certificates were issued and shares were transferred without following prescribed procedure and due diligence.

Analysis: The Tribunal examined statutory provisions governing certificates and transfers (Sections 46, 56 and 59 of the Companies Act, 2013) and applicable regulatory guidelines (including SEBI Circular No. 1 (2000-2001) dated 09.05.2001 and transfer norms). The Tribunal analysed factual findings that the registered shareholder remained in possession of the original share certificate until dematerialisation request in 2018; that duplicate certificates were issued on the basis of belated/defective documents; that prescribed indemnity formats, notice and communication requirements and other prescribed checks were not complied with; that communications from the company/RTA were sent to an outdated address; and that material discrepancies existed in the documents submitted by the claimant (multiple inconsistent reasons for loss, non-standard indemnity, lack of evidence of payment). The Tribunal considered precedent (including Adesh Kaur v. Eicher Motors and Chalasani Udaya Shankar v. Lexus Technologies) establishing that where an open-and-shut case of fraud is shown and the aggrieved person is the victim, the Tribunal may exercise powers under Section 59 and order rectification and consequential reliefs. It rejected arguments that the petition was time-barred, that civil courts alone have jurisdiction over disputed title/forgery, or that non-joinder of the transferee barred relief, on the facts that the fraud was discovered only on dematerialisation and the statutory scheme and authorities permit Tribunal adjudication where powers are vested in it.

Conclusion: The Tribunal's order directing rectification of the register, restoration of the shares to the registered shareholder, or alternatively awarding damages equivalent to market value, together with costs, is upheld. The appeal is dismissed and the Tribunal's remedy under Section 59 in favour of the registered shareholder is affirmed.

Issues: (i) Whether the controversy raised by challenge to a provisional attachment under the Prevention of Money Laundering Act, 2002 is academic or infructuous and hence not amenable to adjudication by writ jurisdiction; (ii) Whether the impugned order quashing the provisional attachment dated March 29, 2022 should be set aside in view of subsequent confirmation by the Adjudicating Authority and availability of statutory appellate remedies.

Issue (i): Whether the controversy is academic or infructuous and not fit for writ adjudication.

Analysis: The provisional attachment was subsequently confirmed by the Adjudicating Authority under Section 8(3) of the PMLA and statutory appeals under Section 26 have been filed and remain pending. A comprehensive statutory scheme exists for adjudication, confirmation and appellate review of attachments under the PMLA. Where alternative efficacious statutory remedies are available and a later statutory determination (confirmation) has occurred, the dispute regarding the provisional attachment assumes an academic character.

Conclusion: The controversy is academic and not fit for fresh adjudication by writ jurisdiction.

Issue (ii): Whether the impugned Single Judge order quashing the provisional attachment should be set aside in the circumstances.

Analysis: The provisional attachment dated March 29, 2022 had been confirmed by the Adjudicating Authority on September 23, 2022. Given the confirmation and the existence of statutory appellate remedies, intervention by writ was restrained. Exceptional circumstances justifying departure from statutory remedy exhaustion were not found. Consequently, the earlier quashing order was rendered unsustainable in view of the subsequent statutory confirmation and the need to avoid multiplicity of litigation and protect public interest in preserving attached assets pending adjudication.

Conclusion: The impugned order quashing the provisional attachment is set aside; the appeal is allowed.

Final Conclusion: The appeal is allowed on the ground that the matter had become academic following confirmation of the provisional attachment by the Adjudicating Authority and because adequate statutory remedies under the PMLA are available; parties are directed to pursue the pending appellate proceedings expeditiously.

Ratio Decidendi: Where a statutory adjudicatory mechanism exists and a provisional attachment has been confirmed by the Adjudicating Authority, writ intervention is ordinarily restrained and disputes rendered academic should not be adjudicated by writ courts, absent exceptional circumstances.

Issues: Whether the addition of Rs. 1,25,98,834 made by the Assessing Officer on account of revaluation of closing stock is justified.

Analysis: The assessee is a society dealing in hardware items operating in remote locations. Stock verification statements and auditor-certified valuation reports were produced showing earlier downward valuation of old/damaged stock aggregating Rs. 99,10,235 up to 31.03.2014 and a further reduction of Rs. 26,88,599 during the relevant year, which together correspond to the claimed diminution in realizable value. The valuation exercise involved physical verification supervised by the Director of Societies, identification of old/damaged stock by branch heads, and estimation of realizable value with auditor approval; the methodology applied a percentage of MRP to estimate realizable value and was evidenced across years. The Assessing Officer did not invoke Section 145(3) to reject the audited books of account. On the record, the further reduction debited in the relevant year is limited to Rs. 26,88,599 and the overall valuation method is demonstrated as reasonable and non-arbitrary.

Conclusion: The addition of Rs. 1,25,98,834 on account of valuation of closing stock is deleted and the ground is allowed in part in favour of the assessee.

Issues: (i) Whether the adhoc 10% disallowance of miscellaneous/petty branch expenses debited under 'miscellaneous expenses' can be sustained where expenses are supported by internal vouchers and not specifically found non-genuine; (ii) Whether provisions for non-performing assets (NPA) created by the co-operative bank in accordance with RBI/NABARD guidelines are allowable deduction under Section 36(1)(viia) of the Income-tax Act, 1961.

Issue (i): Whether the adhoc disallowance of 10% of miscellaneous expenses is sustainable.

Analysis: The authorities below disallowed 10% of miscellaneous branch expenses on the basis that records comprised internally generated petty vouchers and the genuineness of expenses could not be established. The Tribunal found no specific findings demonstrating non-genuineness and held that disallowance was made by presumption and estimation without plausible basis. The Tribunal referred to authorities prohibiting disallowance purely on conjecture.

Conclusion: The disallowance is not sustainable and is set aside; decision is in favour of the assessee.

Issue (ii): Whether the provisions for NPA created by the co-operative bank are deductible under Section 36(1)(viia) of the Income-tax Act, 1961.

Analysis: Section 36(1)(viia) separately permits deduction in respect of provisions for bad and doubtful debts created inter alia by co-operative banks subject to specified limits, distinct from Section 36(1)(vii) which deals with write-offs. The assessee followed RBI/NABARD norms and supporting records were placed on record. The Tribunal held that the provision falls within the statutory scheme permitting deduction and that decisions cited by revenue on Section 36(1)(vii) are not apposite to provisioning under Section 36(1)(viia).

Conclusion: The provisions for NPA are allowable under Section 36(1)(viia); decision is in favour of the assessee.

Final Conclusion: The appeals are allowed and the additions/disallowances challenged in the appeals are deleted, resulting in a favourable outcome for the assessee across the assessed years.

Ratio Decidendi: Ad hoc disallowance based on estimation or presumption is impermissible; provisions for bad and doubtful debts created by a co-operative bank in accordance with RBI/NABARD norms are deductible under Section 36(1)(viia) of the Income-tax Act, 1961.

Issues: (i) Whether the High Court should interfere in writ jurisdiction with the seizure and the alleged extension of the period under Section 110(2) of the Customs Act, 1962 on the basis of disputed questions of fact relating to authenticity, authority, and compliance. (ii) Whether immediate release of the seized goods or directions for forensic and mobile tower verification were warranted before completion of statutory adjudication.

Issue (i): Whether the High Court should interfere in writ jurisdiction with the seizure and the alleged extension of the period under Section 110(2) of the Customs Act, 1962 on the basis of disputed questions of fact relating to authenticity, authority, and compliance.

Analysis: The dispute turned on factual questions concerning the genuineness of the extension document, the authority of the issuing officer, the timing of the show-cause notice, and the manner in which the seizure proceedings were conducted. Such questions could not be conclusively resolved without a full fact-finding enquiry. The matter was therefore treated as one that should be examined in the pending adjudication proceedings rather than in writ jurisdiction at an interlocutory stage.

Conclusion: No interference was warranted in writ jurisdiction on these disputed facts, and the challenge to the seizure and extension was not finally accepted.

Issue (ii): Whether immediate release of the seized goods or directions for forensic and mobile tower verification were warranted before completion of statutory adjudication.

Analysis: The Adjudicating Authority was regarded as the proper forum for deciding the merits of the show-cause notice and for considering evidence relating to alleged forgery and procedural compliance. In the absence of a sufficient basis to displace the ongoing statutory process, the Court declined to order immediate release of the seized assets or direct independent forensic inquiry at this stage. Instead, it protected the status quo and required expeditious completion of adjudication.

Conclusion: Immediate release and pre-adjudication forensic directions were declined, but the adjudication was directed to be completed expeditiously.

Final Conclusion: The challenge was not finally allowed on merits, but the appellant obtained limited procedural protection through an expedited adjudication direction and continuation of status quo over the seized assets.

Ratio Decidendi: Where seizure-related disputes depend on contested factual questions and the statutory adjudicatory process is still pending, writ interference at the interlocutory stage is not justified; such matters should ordinarily be left to the designated adjudicating authority.

Issues: (i) Whether the Section 7 application was maintainable where the principal default arose during the period protected by Section 10A of the Insolvency and Bankruptcy Code, 2016, and whether, after excluding the portion of debt and default falling within Section 10A, the remaining default meets the minimum threshold under Section 4 of the Insolvency and Bankruptcy Code, 2016.

Analysis: The statutory scheme of Section 10A of the Insolvency and Bankruptcy Code, 2016 provides for suspension of initiation of corporate insolvency resolution process in respect of defaults arising on or after 25 March 2020 for the specified protected period and expressly provides that no application shall ever be filed for defaults occurring during that period. The particulars of financial debt filed in Part IV of the original and the subsequent Section 7 petitions show that the principal instalments fell due in March, April and May 2020, dates that indisputably fall within the Section 10A protected period. The subsequent Section 7 petition, though reworking interest to exclude the Section 10A period, continued to claim the same principal amount, which on the pleadings crystallizes the date(s) of default within the prohibited period. Where a default is pleaded with specific dates that fall within Section 10A, that amount must be excluded for purposes of maintaining a Section 7 application. Once the principal amounts arising during Section 10A are excluded, only the post-Section 10A interest remained, and that amount fell below the statutory threshold prescribed under Section 4 for initiation of CIRP. Reliance on the concept of continuing default does not permit circumventing the statutory embargo created by Section 10A where the date(s) of default have been specifically pleaded within the protected period; the protection afforded by Section 10A would otherwise be nullified.

Conclusion: Issue (i) is answered against the Appellant and in favour of the Respondent: the portion of debt which fell due during the Section 10A protected period must be excluded, and after such exclusion the remaining default does not meet the threshold under Section 4, rendering the Section 7 application non-maintainable; the appeal is dismissed.

Issues: (i) Whether the writ petitions were maintainable despite the statutory appellate remedy under section 76 of the Regulation; (ii) whether the notice of assessment of tax and interest under section 32 was barred by limitation; (iii) whether the impugned notices were vitiated by breach of the principles of natural justice.

Issue (i): Whether the writ petitions were maintainable despite the statutory appellate remedy under section 76 of the Regulation.

Analysis: The Regulation provides a complete appellate mechanism before the Appellate Tribunal. The Court reiterated that availability of an efficacious alternative remedy is a rule of self-imposed restraint, particularly in fiscal matters. The petitioner had also chosen to invoke the statutory objection procedure under section 74 and suffered an adverse reasoned order. Since the Tribunal was subsequently constituted and was functional, the disputes ought to be tested in the statutory forum rather than in writ jurisdiction. The challenge did not disclose any exceptional ground warranting bypass of the appellate remedy.

Conclusion: The writ petitions were not maintainable on the ground of alternative remedy and the petitioners were to be relegated to the Appellate Tribunal.

Issue (ii): Whether the notice of assessment of tax and interest under section 32 was barred by limitation.

Analysis: The limitation plea depended upon disputed facts, including whether returns were duly filed and from which point the statutory period had to be computed. The respondents disputed the petitioner's factual foundation, and the returns were not placed before the Court. In these circumstances, limitation did not present a pure jurisdictional question fit for writ adjudication. The issue was better left to the statutory appellate forum, where evidence and factual controversy could be examined.

Conclusion: The notice was not held to be time-barred in writ jurisdiction, and the limitation objection was left to the statutory forum.

Issue (iii): Whether the impugned notices were vitiated by breach of the principles of natural justice.

Analysis: The statutory scheme did not require a pre-notice hearing before issuance of notices under sections 32 and 33. A post-decisional objection and hearing were available under section 74, and the petitioner in fact availed that remedy. The petitioner failed to demonstrate any actual prejudice caused by the absence of an earlier hearing. On that basis, the Court held that the notices were not invalid for violation of natural justice.

Conclusion: The notices were not vitiated by breach of natural justice.

Final Conclusion: The writ petitions were not entertained on merits and the matters were relegated to the statutory appellate remedy, with pre-August 19, 2025 cases directed to be transmitted to the Appellate Tribunal and later cases dismissed so that all disputes could be decided under the statutory framework.

Ratio Decidendi: In fiscal matters, writ jurisdiction will ordinarily not be exercised where an effective statutory appellate remedy exists, especially when the dispute involves contested facts and the statute itself provides a post-decisional remedial mechanism; limitation and natural justice objections do not justify writ intervention unless they disclose a clear jurisdictional or exceptional infirmity.

Issues: Whether an assessee that has paid the assessed tax and interest and has not appealed against the assessment order is denied immunity from penalty merely for failure to file Form 68 under Section 270AA of the Income-tax Act, 1961.

Analysis: Section 270AA grants immunity from penalty under Section 270A where the assessed tax and interest are paid within the prescribed period and no appeal is filed against the assessment order. The assessee fulfilled these substantive conditions after accepting the disallowance in the assessment framed pursuant to revision. Failure to file Form 68 was treated as a technical or venial procedural breach that could not defeat the vested substantive entitlement to immunity.

Conclusion: Non-filing of Form 68 does not disentitle the assessee from immunity under Section 270AA; the penalty under Section 270A is liable to be deleted. The issue is decided in favour of the assessee.

Issues: Whether a notice and assessment under Section 153C could validly be initiated where the deemed date of search in the case of the other person fell after 1 April 2021.

Analysis: Under the first proviso to Section 153C(1), the relevant search date for the other person is the date on which seized material is received by the Assessing Officer having jurisdiction over that person. As the actual receipt date was not available on record, the satisfaction-note date, 10 May 2022, was treated as the deemed receipt and search date. Section 153C(3), inserted by the Finance Act, 2021, excludes the application of Section 153C to searches initiated, or seized material requisitioned, on or after 1 April 2021.

Conclusion: The notice under Section 153C and the consequential assessment were without legal authority and were quashed, in favour of the assessee.

Issues: Whether interest awarded under Section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsorily acquired agricultural land is taxable as income from other sources after application of Section 57(iv), Section 56 and Section 145A of the Income-tax Act, 1961.

Analysis: The adopted reasoning distinguished interest under Section 28, which is an accretion to the value of the land and forms part of enhanced compensation, from interest for delayed payment under Section 34 of the Land Acquisition Act, 1894. The amendments concerning taxation of interest on compensation were directed to the timing of taxation of interest and did not alter the character of Section 28 interest as part of enhanced compensation. The contrary High Court decision was not applicable in preference to the Supreme Court position; dismissal of a special leave petition without reasons did not create a binding declaration of law.

Conclusion: Interest received under Section 28 of the Land Acquisition Act, 1894 formed part of enhanced compensation and was not assessable as income from other sources; the issue was decided in favour of the assessee.

Issues: Whether interest earned by a co-operative credit society from bank deposits of surplus funds maintained in connection with its credit-facility business is deductible under section 80P(2)(a)(i) of the Income-tax Act, 1961.

Analysis: The assessee was a co-operative credit society providing credit facilities exclusively to its members and was required under its governing regulatory framework to maintain deposits and reserve funds. The interest arose from funds connected with that business. The governing decisions establish that a credit society not holding an RBI banking licence is not a co-operative bank excluded by section 80P(4), and that income attributable to its credit-facility business qualifies for deduction. Interest on deposits of its own business funds retains its business character; the contrary treatment in Totgar's was confined to interest on members' sale proceeds temporarily retained by a society engaged principally in marketing agricultural produce.

Conclusion: The interest income of Rs.35,43,169 was business income eligible for deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961, and not income from other sources; the addition was directed to be deleted.