Issues: Whether the amounts collected as 'administrative charges' for supply of dry fly ash constitute consideration for a sale of goods or payment for taxable 'Support Service of Business or Commerce' and whether the impugned demands of service tax are sustainable.

Analysis: The matter turns on whether the transaction falls within the statutory definition of sale under the Sale of Goods Act, the Haryana VAT Act and Section 2(h) of the Central Excise Act, 1944, or alternatively constitutes a taxable service under Section 65(104c) of the Finance Act, 1994. Applying the dominant intention test, the transfer of property in dry fly ash for consideration and the regulatory context concerning supply of fly ash indicate the transaction is a sale; incidental provision of infrastructure or facilitation does not convert a sale into a taxable business support service. The Tribunal's prior decisions on identical facts hold that demands of service tax under 'Support Service of Business or Commerce' are not sustainable and set aside similar demands; those precedents are followed.

Conclusion: The impugned orders confirming service tax demands are set aside and the appeals are allowed; the decision is in favour of the assessee.

Issues: Whether the Delhi High Court had territorial jurisdiction to entertain the writ petition challenging the circular, rejection of no-objection certificates, and detention of imported goods at Chennai and Kolkata.

Analysis: Under Article 226(2) of the Constitution of India, read with the cause-of-action principle in Section 20(c) of the Code of Civil Procedure, 1908, jurisdiction depends on material or integral facts giving rise to the remedy sought. The situs of the authority issuing a circular or executive instruction does not, by itself, create a cause of action. The rejection of the no-objection certificates related to the petitioner's import activity and goods detained outside Delhi; the operative facts and alleged consequences arose at Chennai or Kolkata. No integral part of the cause of action arose within Delhi, and the mere issuance of the circular or electronic rejection from Delhi was insufficient to confer jurisdiction.

Conclusion: The Delhi High Court lacked territorial jurisdiction to entertain the writ petition; the issue is decided against the petitioner.

Issues: (i) Whether the delay in filing the appeal could be condoned. (ii) Whether the cash deposit addition treated as unexplained under section 68 was liable to be sustained in full. (iii) Whether section 115BBE applied to the impugned transaction.

Issue (i): Whether the delay in filing the appeal could be condoned.

Analysis: The appeal was filed with substantial delay, but the explanation offered was accepted as arising from circumstances beyond the assessee's control. The delay was therefore treated as satisfactorily explained.

Conclusion: The delay was condoned in favour of the assessee.

Issue (ii): Whether the cash deposit addition treated as unexplained under section 68 was liable to be sustained in full.

Analysis: The assessee was engaged in trading of electronic items and had a prior year cash-deposit pattern that lent support to the explanation that the impugned deposits represented cash sales and cash in hand. On the facts, the full addition was found to be excessive, and only a lump sum addition was considered appropriate.

Conclusion: The addition was restricted substantially and relief was granted to the assessee for the balance amount.

Issue (iii): Whether section 115BBE applied to the impugned transaction.

Analysis: The provision was held to apply only to transactions occurring on or after 01.04.2017. As the assessment year and transaction period were prior thereto, the assessee could not be subjected to taxation under that special regime.

Conclusion: The assessee was directed to be assessed under the normal provisions and not under section 115BBE.

Final Conclusion: The appeal succeeded only in part, with the major addition substantially reduced and the special taxation regime found inapplicable to the transaction.

Ratio Decidendi: Section 115BBE applies only to income arising from transactions on or after its commencement date, and where the explanation for cash deposits is not fully disproved, the addition may be restricted on a reasonable estimate.

Issues: Whether the arrest and remand of the arrestee were illegal for failure to disclose the grounds of arrest and comply with the mandatory arrest-memo requirements, and whether habeas corpus relief was maintainable.

Analysis: The arrest memo was tested against the requirements flowing from Article 22(1) of the Constitution of India and the statutory safeguards under Sections 47 and 48 of the Bharatiya Nagarik Suraksha Sanhita, 2023. The Court found that the memo did not substantially contain the grounds and supporting material required by the prescribed format, and that mere intimation of the offence, sections invoked, and arrest-related formalities did not amount to compliance with the mandate to communicate full particulars of the grounds of arrest. Non-compliance with these requirements was treated as a breach of the constitutional and statutory safeguards governing arrest and detention.

Conclusion: The arrest and consequent remand were held illegal, and habeas corpus relief was granted.

Ratio Decidendi: Failure to communicate the grounds of arrest and to comply with the mandatory arrest-memo safeguards required by Article 22(1) and Sections 47 and 48 of the Bharatiya Nagarik Suraksha Sanhita, 2023 renders the arrest illegal and justifies release in habeas corpus proceedings.

Issues: Whether additions towards alleged on-money in the purchase of shop could be sustained under section 153C of the Income-tax Act, 1961 on the basis of a third-party statement and an Excel sheet seized in the search of another group, without providing the assessee a copy of the material or an opportunity of cross-examination.

Analysis: The additions were founded primarily on the statement of an employee of the searched group and the alleged Excel sheet. The assessee was not supplied with the Excel sheet, the assessment order did not reproduce the relevant entries or disclose date-wise linkage, and no independent corroborative material was brought on record to establish actual payment by the assessee. The Tribunal noted the consistent view of coordinate benches that where the assessee denies the payment, reliance is placed only on third-party material, and cross-examination is not afforded, the addition cannot be sustained. On the facts, the material remained uncorroborated and the assessee was not duly confronted with the specific evidence relied upon.

Conclusion: The additions towards alleged on-money were not sustainable and were deleted.

Issues: Whether additions towards alleged on-money in respect of purchase of a shop, made in proceedings under section 153C on the basis of a third-party statement and an Excel sheet found during search, could be sustained without supplying the material to the assessee, bringing independent corroboration on record, or allowing cross-examination.

Analysis: The additions were founded primarily on a statement recorded during search and an alleged Excel sheet said to contain details of on-money receipts. The assessee was not provided a copy of the Excel sheet, the assessment order did not reproduce the relevant entries or date-wise linkage, and no independent evidence was brought on record to establish actual payment by the assessee. The Tribunal also noted the consistent view taken in similar Rubberwala Group matters that a third-party statement and uncorroborated digital data, by themselves, are insufficient where the assessee denies the payment and is denied an opportunity to test the evidence through cross-examination.

Conclusion: The additions could not be sustained and were deleted. The issue was decided in favour of the assessee.

Ratio Decidendi: An addition based on third-party material cannot be sustained unless the material is confronted to the assessee, supported by independent corroboration, and tested through cross-examination where sought.

Issues: Whether the disallowance under section 14A read with Rule 8D could be sustained by considering all investments or had to be confined only to investments yielding exempt income, and whether the same disallowance could be added while computing book profit under section 115JB.

Analysis: The assessee had earned exempt dividend income and had already made a suo motu disallowance. The Tribunal accepted the view taken by the CIT(A) that, for the purpose of section 14A read with Rule 8D, only those investments which actually yielded exempt income during the relevant year were to be considered. The Tribunal further noted that the CIT(A) had followed the binding co-ordinate bench ruling in Vireet Investment and found no infirmity in the deletion of the balance disallowance. The Revenue's challenge to the addition under section 115JB also failed in view of the same reasoning.

Conclusion: The Revenue's grounds were rejected and the deletion of the disallowance under section 14A and the corresponding adjustment under section 115JB was upheld in favour of the assessee.

Issues: Whether the addition of Rs.23,00,000 made under section 68 of the Income-tax Act, 1961 treating an unsecured loan as unexplained credit is justified and payable in the hands of the assessee for assessment year 2014-15.

Analysis: The Tribunal examined the assessment order, the appellate order and the records including investigation findings and the documents produced by the assessee. The Tribunal considered whether the creditor companies, including Jay Jyoti (India) Pvt. Ltd., were paper/shell entities and whether the assessee discharged the onus to prove the identity and creditworthiness of the lender and the genuineness of the loan transaction. The Tribunal also examined prior decisions of the Tribunal addressing the nature of companies in the Sharad Darak group and the evidentiary materials relied upon by the assessing officer and the first appellate authority. Applying the legal framework that places onus on the assessee to prove identity and creditworthiness but also requires assessment of documentary evidence and surrounding circumstances, the Tribunal found that the documents on record and the precedents relied upon by the Tribunal established that Jay Jyoti (India) Pvt. Ltd. and related companies are not paper or shell companies for the purposes of this case and that the addition under section 68 was not sustainable on the facts and evidence before it.

Conclusion: The addition of Rs.23,00,000 under section 68 of the Income-tax Act, 1961 is deleted and the appeal is allowed in favour of the assessee.

Ratio Decidendi: Where documentary evidence and relevant precedents establish that the creditor entity is not a paper or shell company and the surrounding facts do not sustain treatment of receipt as unexplained credit, an addition under section 68 cannot be sustained and must be deleted.

Issues: (i) Whether the impugned ex-parte interim order cum show cause notice dated 04.12.2025 passed by the Whole Time Member, SEBI calling for directions including deposit/impoundment and prohibitions calls for interference; (ii) Whether the quantum of amount sought to be secured/impounded by SEBI (Rs.546 Crores) is justified and what interim security, if any, should be directed.

Issue (i): Whether the impugned interim directions require interference by the Tribunal.

Analysis: The record shows allegations of use of live market data, testimonials uploaded after an administrative warning, paid WhatsApp groups providing recommendations and trading patterns of participants; the appellants declined to contest factual aspects before the Tribunal and the matter is at the stage of reply to the show cause notice. The material on record supports a prima facie inference of violations of SEBI (Investment Advisers) Regulations, 2013 and SEBI (Research Analysts) Regulations, 2014 for the period under consideration (2020-2025).

Conclusion: The Tribunal finds a prima facie case established by SEBI and does not set aside the impugned ex-parte interim directions.

Issue (ii): Whether the amount of Rs.546 Crores sought to be secured is justified as interim impoundment and what modification, if any, is appropriate.

Analysis: SEBI attributes Rs.546 Crores to fees for specified unregistered activities. Appellants produced a schedule showing taxes and other outlays and asserted fixed assets and amounts paid to government. The Tribunal accepted that some sums (taxes and governmental receipts) and fixed assets exist but declined to decide final entitlement or tax character; balancing the prima facie case and the appellants' submissions on assets, the Tribunal found it equitable to reduce the interim monetary security to a realistic secured amount while protecting SEBI's interest.

Conclusion: The Tribunal modifies the impugned directions and directs deposit of Rs.100 Crores in lieu of the earlier security; it further restrains alienation of fixed assets subject to disclosure and valuation and permits the appellants to file reply to the show cause notice.

Final Conclusion: The appeal is allowed in part; the Tribunal upholds the existence of a prima facie case against the appellants but moderates the interim monetary relief ordered by SEBI by directing a deposit of Rs.100 Crores and ancillary disclosure and restraint on alienation, while leaving all substantive issues open for final adjudication by the Whole Time Member, SEBI.

Issues: Whether interim relief should be granted for release of detained areca nut consignment and conveyances pending adjudication of show cause proceedings under Sections 129 and 130 of the Central Goods and Services Tax Act, 2017.

Analysis: The issue concerns interlocutory relief where seizure and detention were effected under Section 129 and show cause notice issued under Section 130. The petitioner disputes confiscation primarily on the ground of discrepancy in weighment and asserts that perishable goods and documentary compliance weigh against seizure and confiscation. Precedents relied upon indicate that mere difference of opinion on weighment or valuation, without allegations such as absence of documents, forged documents, forged e-way bills, fake registration, or complete mismatch of goods, ordinarily do not justify confiscation. The respondents assert procedural compliance with Sections 129, 130 and 131. Considering the perishable nature of the consignment and absence of prima facie allegations of fraud or fabricated documents, interim security in the form of a bank guarantee to cover the tax demand is an appropriate mechanism to protect revenue while permitting release pending adjudication.

Conclusion: Interim relief granted in favour of the petitioner: on furnishing an adequate bank guarantee to cover the assessed short-paid tax demand of Rs. 4,52,076.00, the detained consignment of areca nut and the specified vehicles are to be released forthwith. Notice issued and matter listed for further hearing.

Issues: Whether the delay of approximately ten years in passing an order giving effect to the Income-tax Appellate Tribunal's remand order (dated 16.09.2016) is reasonable and whether the Revenue can be permitted to pass an order giving effect at this stage.

Analysis: The assessment for the relevant year was completed under Section 143(3) of the Income-tax Act, 1961 and the Tribunal directed a remand to the Assessing Officer on 16.09.2016 to exclude certain comparables. Section 153 of the Income-tax Act, 1961 was amended by the Finance Act, 2016 with effect from 01.06.2016; the parties advanced rival contentions on which version of Section 153 would govern limitation. The Court did not resolve the broader question of which version of Section 153 applies, keeping those rival contentions open for an appropriate case. The Court proceeded to assess whether, even assuming the pre-amendment position urged by the Revenue, a ten-year delay in giving effect to the Tribunal's directions could be regarded as reasonable.

Conclusion: The delay of ten years in passing an order giving effect to the Tribunal's remand is unreasonable. The Revenue has not made out grounds to entertain interference; the appeal is dismissed and the direction for refund (as ordered by the Single Judge) remains effective, with the time for compliance extended by eight weeks.

Issues: Whether the perpetual assignment of copyright in programmes independently produced by the appellant to broadcasters constituted taxable TV or Radio Programme Producer Service or a sale of goods liable to VAT.

Analysis: Programme Producer Service applies only where a programme is produced on behalf of another person. The programmes were independently produced by the appellant, with no material showing that they were produced for or on behalf of the broadcasters. Copyright, though intangible, possesses the attributes of goods where it is capable of transfer and commercial exploitation. The assignment granted broadcasters exclusive rights in the dubbed serials perpetually, leaving no rights with the appellant, and VAT had been paid on such transactions. A transaction constituting a sale of goods and properly subjected to VAT falls outside the scope of service tax.

Conclusion: The perpetual transfer of copyright in self-produced programmes was a sale of goods and not TV or Radio Programme Producer Service; no service tax, interest, or penalty was sustainable.

Issues: Whether revenue under the Percentage Completion Method could be recognised by including flats merely booked on token advances without legally enforceable agreements for sale, including flats not meeting the prescribed 10% realisation condition.

Analysis: Under Accounting Standard 9 read with the Guidance Note on Accounting for Real Estate Transactions, revenue recognition requires transfer of significant risks and rewards, determined with reference to legally enforceable agreements. Mere booking, identification of the buyer, ascertainment of area or consideration, and receipt of advances do not establish such transfer. The Guidance Note additionally requires realisation of at least 10% of the agreement value under legally enforceable documents at the reporting date. The undisputed material showed that certain flats were only booked, their agreements were executed in later years, and some included flats did not meet the 10% realisation threshold. The revenue included by the Assessing Officer had also been offered to tax in the subsequent year; taxing it again would amount to impermissible double taxation.

Conclusion: Revenue from merely booked flats and flats not satisfying the 10% realisation condition could not be included under the Percentage Completion Method. The related addition was deleted in favour of the assessee.

Issues: Whether deduction under Section 80JJAA is allowable where the return was filed after the due date under Section 139(1) but within the period prescribed under Section 139(4).

Analysis: The return was filed with the tax-audit report and Form 10DA after a 52-day delay from the due date under Section 139(1), following extension of the deadline for holding the annual general meeting. The deduction claimed in the return was not higher than that certified in Form 10DA. The applicable legal position was treated as permitting a Chapter VI-A deduction where the return is filed within the time available under Section 139(4), and as regarding the timing of the claim as directory. The delay was found bona fide and attributable to genuine hardship; consequently, the adjustment under Section 143(1)(a) was not sustainable.

Conclusion: Deduction under Section 80JJAA is allowable notwithstanding filing after the due date under Section 139(1), where the return was filed within the period under Section 139(4); the conclusion is in favour of the assessee.

Issues: (i) Whether the reassessment for AY 2014-15 was valid where the original scrutiny assessment had accepted the exemption claim; (ii) Whether the assessee was entitled to exemption for AY 2015-16 despite income from sale of books, notebooks and uniforms; (iii) Whether reassessment for AY 2017-18 could be initiated while the revised return remained pending for scrutiny; (iv) Whether exemption was allowable for AY 2018-19 on materially identical facts.

Issue (i): Whether the reassessment for AY 2014-15 was valid where the original scrutiny assessment had accepted the exemption claim.

Analysis: The original scrutiny proceedings had specifically sought and received the trust's objects, books of account, income-and-expenditure details, accumulation particulars and details showing receipts from books, uniforms and related items. The survey statement did not provide new tangible material because it merely corroborated facts already disclosed. The notice issued after four years was therefore barred by the first proviso to Section 147. Further, only a gist, rather than the actual recorded reasons, was supplied to the assessee; the actual reasons placed before the Tribunal materially differed from that gist. Reopening also amounted to a review of a claim already examined and accepted in scrutiny assessment.

Conclusion: The reassessment for AY 2014-15 was time-barred, invalid for non-supply of the actual recorded reasons, and based on a mere change of opinion; it was quashed in favour of the assessee.

Issue (ii): Whether the assessee was entitled to exemption for AY 2015-16 despite income from sale of books, notebooks and uniforms.

Analysis: As there had been no original scrutiny assessment for this year, the challenge based on change of opinion failed. On merits, however, the trust's educational objects remained unchanged. Following discontinuance of its teacher-education college, it acquired land and pursued approvals to establish a school. The surplus from sale of books and uniforms was set apart and invested for acquiring land and constructing the school, with no finding of diversion to non-charitable purposes. The revenue-generating activity was consequently incidental to attainment of the educational objects within Section 11(4A), rather than a standalone non-charitable commercial activity.

Conclusion: The assessee was entitled to exemption under Section 11 for AY 2015-16 because the sale activity and resulting surplus were incidental to its educational objects; the merits claim was decided in favour of the assessee.

Issue (iii): Whether reassessment for AY 2017-18 could be initiated while the revised return remained pending for scrutiny.

Analysis: The assessee filed a revised return under Section 139(5), and the statutory time to issue scrutiny notice under Section 143(2) had not expired when notice under Section 148 was issued. The assessment proceedings founded on the revised return were therefore pending and had not been terminated. Reassessment jurisdiction could not be invoked during such pendency.

Conclusion: The notice under Section 148 and reassessment for AY 2017-18 were invalid and were quashed in favour of the assessee.

Issue (iv): Whether exemption was allowable for AY 2018-19 on materially identical facts.

Analysis: The parties accepted that the facts were identical to those for AY 2015-16. The surplus generated from sale of books and uniforms was directed towards the trust's continuing educational objective of establishing a school, making the activity incidental to attainment of that object.

Conclusion: The assessee was entitled to exemption under Section 11 for AY 2018-19; the addition of excess income over expenditure was deleted in favour of the assessee.

Final Conclusion: The reassessments for AYs 2014-15 and 2017-18 could not stand, while the exemption claims for AYs 2015-16 and 2018-19 were sustained on the basis that the income-generating activity was incidental to the trust's educational purpose.

Ratio Decidendi: Reassessment cannot be founded on facts fully disclosed and examined in original scrutiny, cannot proceed without supplying the actual recorded reasons, and cannot be initiated while assessment on a pending return remains open; business income of a charitable trust is exempt where it is incidental to, and applied towards, its charitable objects.

Issues: (i) Whether the non-refundable security received for transfer of development rights was taxable in the relevant assessment year notwithstanding recognition of project revenue under the Percentage of Completion Method; (ii) Whether non-deduction of tax on payment for acquisition of development rights attracted Section 194IA and consequential disallowance under Section 40(a)(ia) of the Income-tax Act, 1961.

Issue (i): Whether the non-refundable security received for transfer of development rights was taxable in the relevant assessment year notwithstanding recognition of project revenue under the Percentage of Completion Method.

Analysis: The assessee consistently followed the Percentage of Completion Method for its real-estate project. In subsequent scrutiny assessments, the Department accepted the project-revenue computation in which the security amount was adjusted against revenue and offered to tax. Taxing the same amount again in the year of receipt would result in double addition. As the record did not establish whether the entire security had been adjusted in subsequent years, verification was required.

Conclusion: The security amount cannot be taxed again to the extent already adjusted and offered under the Percentage of Completion Method; the Assessing Officer shall verify any unadjusted portion, which alone may be treated as income for the relevant year. This issue is in favour of the assessee subject to verification.

Issue (ii): Whether non-deduction of tax on payment for acquisition of development rights attracted Section 194IA and consequential disallowance under Section 40(a)(ia) of the Income-tax Act, 1961.

Analysis: The payment was made before Section 194IA came into force on 01.06.2013. Further, the expansion of Section 40(a)(ia) to encompass payments covered by Section 194IA applied only from assessment year 2015-16, whereas the relevant assessment year was 2014-15.

Conclusion: Section 194IA was inapplicable to the payment, and no disallowance under Section 40(a)(ia) could be made for non-deduction of tax. This issue is in favour of the assessee.

Final Conclusion: Recognition of the project receipt must conform to the accepted Percentage of Completion Method, subject to verification of any unrecognised balance, and the proposed tax-deduction-based denial of cost is unsustainable.

Ratio Decidendi: Where project revenue is consistently recognised under an accepted Percentage of Completion Method and the receipt has been brought to tax in subsequent accepted assessments, it cannot be taxed again in the year of receipt; a tax-deduction obligation cannot be imposed under a provision not in force when the payment was made.

Issues: Whether reassessment under section 147 read with section 143(3) could be sustained where the notice under section 148 was issued by an officer lacking pecuniary jurisdiction under CBDT Instruction No. 1/2011.

Analysis: The returned income was below the monetary threshold assigned to an Assistant Commissioner/Deputy Commissioner for a corporate assessee in Delhi under CBDT Instruction No. 1/2011. The instruction, being binding upon departmental authorities, allocated jurisdiction to the Income-tax Officer. The reassessment was initiated through a section 148 notice issued by the ACIT, who lacked the prescribed pecuniary jurisdiction. Such defect concerned the inherent authority to assume jurisdiction and invalidated the reassessment proceedings.

Conclusion: The reassessment was void for want of valid assumption of jurisdiction and was quashed in favour of the assessee.

Issues: Whether the addition of Rs. 77,00,000 based on stamp-duty valuation under section 50C could be sustained without affording the assessee an opportunity to contest the Departmental Valuation Officer's valuation.

Analysis: The assessment was completed before receipt of the valuation report despite the assessee's objection to the stamp-duty valuation and reference to the Departmental Valuation Officer. The assessee had no opportunity to address the valuation findings, including the asserted lack of road access to the land and discrepancies in the sale instances and rate adopted for valuation. A fresh determination after considering the assessee's objections and any registered valuer's report was therefore required.

Conclusion: The section 50C addition was restored for fresh adjudication after granting the assessee an effective opportunity to challenge the valuation; the issue was decided in favour of the assessee.

Issues: (i) Whether the COVID-19 limitation extension applied to the statutory due dates for furnishing quarterly TDS statements and the resulting fee under section 234E; (ii) Whether the extended due date for the final quarter of financial year 2020-21 under Circular No. 12/2021 required exclusion of default up to 15.07.2021; (iii) Whether interest under sections 201(1A) and 220(2) was sustainable.

Issue (i): Whether the COVID-19 limitation extension applied to the statutory due dates for furnishing quarterly TDS statements and the resulting fee under section 234E.

Analysis: The Supreme Court's COVID-19 directions excluded time for instituting and pursuing judicial or quasi-judicial proceedings and specified statutory limitation periods. They did not extend the statutory time prescribed for filing TDS statements. The general COVID-related relaxation under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 extended the TDS-return due date only for the quarter ending 31.03.2020 and not for the relevant subsequent quarters. Section 234E contains no exception based on reasonable cause for delayed furnishing of TDS statements.

Conclusion: The COVID-19 limitation extension did not excuse delayed filing of the relevant TDS statements, and fee under section 234E was sustainable, except to the extent of the specific final-quarter relaxation.

Issue (ii): Whether the extended due date for the final quarter of financial year 2020-21 under Circular No. 12/2021 required exclusion of default up to 15.07.2021.

Analysis: Circular No. 12/2021 permitted furnishing the TDS statement for the last quarter of financial year 2020-21 on or before 15.07.2021. This specific relaxation applied to the appeal for assessment year 2021-22; it did not apply to the appeal for assessment year 2022-23.

Conclusion: For assessment year 2021-22, the assessee could not be treated as in default for delay in furnishing the final-quarter TDS statement up to 15.07.2021; no corresponding relief was available for assessment year 2022-23.

Issue (iii): Whether interest under sections 201(1A) and 220(2) was sustainable.

Analysis: The assessee neither established payment of the relevant tax into the Government Treasury nor fulfilled the conditions for protection from being treated as an assessee in default. Interest under section 220(2) follows non-payment of the demand specified in the notice under section 156 within the prescribed period; any waiver remedy lies before the prescribed authority under section 220(2A).

Conclusion: Interest under sections 201(1A) and 220(2) was sustainable against the assessee.

Final Conclusion: The final-quarter TDS-statement delay for financial year 2020-21 is to be recalculated by giving effect to the extended date of 15.07.2021, while the remaining levies and the corresponding claims for assessment year 2022-23 remain undisturbed.

Ratio Decidendi: A COVID-19 exclusion of limitation for judicial or quasi-judicial proceedings does not extend statutory due dates for TDS statements; relief from late-filing consequences is available only where a specific statutory or administrative extension covers the relevant statement.

Issues: Whether the delay in filing the customs appeal could be condoned despite the statutory limitation, so that the petitioner is not left without an effective remedy against the confiscation order.

Analysis: The appeal was filed beyond the ordinary period and beyond the appellate authority's condonable extension under the Customs Act. However, the Court noted that the delay was not inordinate on the facts of the case and that refusal to condone it would leave the petitioner remediless against the confiscation order. Emphasis was placed on the statutory right of appeal and on the need to avoid denial of appellate review in the peculiar circumstances of the case.

Conclusion: The delay was condoned in the facts of the case and the order dismissing the appeal as time-barred was set aside.

Ratio Decidendi: Where refusal to condone delay would extinguish the only appellate remedy and the delay is not exorbitant on the facts, the delay may be condoned in the interests of justice notwithstanding the appellate authority's limited statutory power.