Issues: Whether the Income Tax Appellate Tribunal could recall its detailed appellate order under its rectification power on the ground that relevant facts and merits required reconsideration.

Analysis: The rectification power is confined to correcting a mistake apparent from the record and is akin to the limited review jurisdiction under Order XLVII Rule 1 of the Code of Civil Procedure, 1908. The original appellate order had decided the validity of reassessment after detailed consideration of the factual record and statutory requirements. The Revenue's miscellaneous applications sought reconsideration of those merits on the basis that the Tribunal had not properly considered material concerning revision proceedings. Such reconsideration neither identified an apparent mistake nor remained within the confined rectification jurisdiction; an alleged error on merits could be challenged through a tax appeal.

Conclusion: The Tribunal could not recall its reasoned appellate order under Section 254(2) of the Income-tax Act, 1961 for a re-adjudication on merits; the recall orders were invalid and the original appellate order stood restored.

Issues: Whether an advance-ruling application on classification of roasted areca nuts is admissible where the identical question has already been decided by a High Court.

Analysis: Section 28-I(2) bars admission of an application where the question is the same as one already decided by the Appellate Tribunal or a Court. The classification question was squarely covered by an existing High Court decision. As a statutory authority subordinate to judicial precedent, the Authority could not re-adjudicate the settled question or issue a conflicting ruling.

Conclusion: The application was not admissible and no ruling on the classification question could be pronounced.

Issues: Whether delayed payment charges recovered by a stockbroker from clients for delayed settlement obligations or margin trading facility are taxable as consideration for agreeing to tolerate an act under Section 66E(e).

Analysis: Delayed payment charges arise only upon default in timely payment, after the stockbroker has discharged settlement obligations to the exchange. They are penal and compensatory charges for overdue amounts, not charges for stockbroking services or a separately agreed activity of tolerating delayed payment. The contractual penal clauses safeguard commercial interests and do not establish that the parties intended delay as the object of the arrangement. Departmental circulars under the service-tax and GST regimes also recognise that delayed payment charges are not consideration for taxable services.

Conclusion: Delayed payment charges are not taxable as a declared service under Section 66E(e); the issue is decided in favour of the assessee.

Issues: Whether a second show cause notice and consequential demand order concerning the same alleged wrongful availment of input tax credit from seven common suppliers could be sustained.

Analysis: The facts established that two proceedings covered the same alleged transactions involving seven common suppliers, and separate demand orders were passed on the same day. Multiple proceedings seeking to impose tax liability again on the same transactions were impermissible and contravened Section 6(2)(b) of the GST Act, 2017.

Conclusion: The second show cause notice and consequential order were quashed insofar as they concerned the seven common suppliers, in favour of the assessee. The proceedings relating to the remaining two suppliers survived, with liberty to pursue the statutory appeal.

Issues: Whether a show cause notice proposing cancellation of GST registration is valid when it merely cites Rule 21(b), (e) and (g) without disclosing the factual basis of the alleged violations.

Analysis: The notice did not specify the facts or manner constituting the alleged contraventions. A notice issued mechanically, without particulars of the proposed action, prevents the registered person from furnishing an effective reply and causes prejudice. Such absence of material particulars denies a meaningful opportunity of hearing and is inconsistent with principles of natural justice.

Conclusion: A show cause notice lacking the factual basis for alleged violations under Rule 21 is invalid; the authorities may initiate fresh proceedings through a notice containing the requisite particulars.

Issues: Whether Minimum Alternate Tax under Section 115JB applies to a statutory corporation constituted under a Central enactment but not incorporated as a company under the Companies Act, including after the amendment effective from 01.04.2013.

Analysis: Although the assessee is treated as an Indian company under the Income-tax Act, 1961, it is not a company incorporated under the Companies Act, 2013. The machinery for computation of book profit under Section 115JB is inapplicable where the statutory corporation is governed by its own enactment and does not prepare accounts in the manner contemplated for companies under the Companies Act. The amended Section 115JB(2)(b) does not alter this position. The binding precedent concerning an analogous statutory board was applied.

Conclusion: Section 115JB of the Income-tax Act, 1961 does not apply to the assessee; the issue is decided in favour of the assessee.

Issues: Whether the Tribunal's quashing of reassessment and deletion of the addition for alleged unexplained cash credit gave rise to a substantial question of law.

Analysis: The recorded basis for reopening alleged entries involving long-term capital gain, short-term capital loss or business loss exceeding the monetary threshold. The assessee's transaction was, however, an intraday share-trading transaction yielding business profit of Rs. 49,792, which had been offered to tax, and did not contain any of the alleged entry characteristics. The Tribunal therefore found that the basis for reopening failed. The High Court found these to be factual findings and, having regard also to the small amount involved, found no substantial question of law warranting interference.

Conclusion: The reassessment was unsustainable and no substantial question of law arose from the Tribunal's decision; the issue was decided in favour of the assessee.

Issues: (i) Whether interest expenditure attributable to capital work in progress was liable to be capitalised where the assessee had sufficient interest-free funds and the building was already put to use; (ii) Whether disallowance computed under section 14A read with rule 8D could be added to book profit under section 115JB.

Issue (i): Whether interest expenditure attributable to capital work in progress was liable to be capitalised where the assessee had sufficient interest-free funds and the building was already put to use.

Analysis: The factual finding that interest-free funds exceeded the investments attracted the presumption that the investments were made from such funds. The expenditure also related to an existing building already put to use in earlier years; consequently, there was no basis to capitalise the interest expenditure.

Conclusion: The disallowance of interest expenditure was not sustainable. This issue was decided in favour of the assessee and against the Revenue.

Issue (ii): Whether disallowance computed under section 14A read with rule 8D could be added to book profit under section 115JB.

Analysis: Binding jurisdictional decisions established that an adjustment to book profit cannot be founded on the disallowance calculated under section 14A read with rule 8D. The concurrent findings of the appellate authorities deleting the corresponding book-profit adjustment were therefore upheld.

Conclusion: The section 14A disallowance computed under rule 8D could not be added to book profit under section 115JB. This issue was decided in favour of the assessee and against the Revenue.

Final Conclusion: Neither proposed question gave rise to a substantial question of law.

Ratio Decidendi: Where interest-free funds sufficient to cover the investments are available, investments are presumed to be made from those funds; further, a disallowance quantified under section 14A read with rule 8D cannot by itself be used to increase book profit under section 115JB.

Issues: Whether the challenges to the show-cause notices and the assessment order required adjudication in writ jurisdiction.

Outcome: The petitions were disposed of, leaving the petitioners to pursue the statutory appellate remedy against any final assessment order.

Issues: Whether penalty under section 271(1)(c) was leviable on an addition for alleged bogus purchases ultimately sustained on an ad hoc and estimated basis.

Analysis: The quantum addition was successively reduced from 25% of the alleged bogus purchases to 12.50% and finally to 6%, demonstrating that the sustained addition was estimated. Coordinate Bench decisions on materially identical facts had applied the settled principle that penalty for concealment or furnishing inaccurate particulars is not exigible merely on an ad hoc or estimated addition. No distinguishing factual feature or contrary subsequent authority was shown. Judicial discipline and consistency required adoption of that view.

Conclusion: Penalty under section 271(1)(c) was not leviable on the estimated addition; the penalty was deleted in favour of the assessee.

Issues: (i) Whether an integrated industrial shrimp-feed manufacturing plant is classifiable under CTH 8436 10 00 or CTH 8438 80 90, with consequential CVD liability; (ii) Whether rejection of the appeal as time-barred was sustainable without determining the status and finalisation of provisional assessments.

Issue (i): Whether an integrated industrial shrimp-feed manufacturing plant is classifiable under CTH 8436 10 00 or CTH 8438 80 90, with consequential CVD liability.

Analysis: Heading 8436, read contextually with its HSN Explanatory Notes, covers farm-level and allied husbandry machinery for preparing animal feed but excludes machinery clearly designed for industrial use. Heading 8438 applies to machinery for industrial preparation or manufacture of food, including food for animal consumption. The imported goods constituted an integrated, automated commercial production plant with mixing, conditioning, pelletising, cooling and conveying systems, intended for continuous large-scale manufacture of shrimp feed. HSN Notes were used as an interpretative aid to ascertain the scope of the competing tariff headings, not to override the tariff. The project-import approval did not determine the tariff classification.

Conclusion: The machinery is classifiable under CTH 8438 80 90, not CTH 8436 10 00; the reassessment and consequential CVD levy are valid, against the assessee.

Issue (ii): Whether rejection of the appeal as time-barred was sustainable without determining the status and finalisation of provisional assessments.

Analysis: The communication treated as the starting point for limitation neither finalised the assessments nor determined classification or differential duty. Where the Bills of Entry were treated as provisionally assessed, the foundational questions of finalisation under Section 18, the character of the communication as an appealable order, the requirement of a speaking order on disputed reassessment, the date from which limitation commenced, and the status of project-import finalisation required determination. The computation of delay was also unsupported by recorded particulars.

Conclusion: The time-bar rejection cannot be sustained; the matter must be reconsidered by the Commissioner (Appeals) on maintainability, provisional assessment, finalisation, limitation and merits, in favour of the assessee.

Final Conclusion: The classification and CVD demand remain upheld, while the separate limitation dispute is restored for fresh appellate determination.

Ratio Decidendi: Machinery forming an integrated industrial plant for large-scale commercial manufacture of animal feed falls under the tariff heading for industrial food-manufacturing machinery where the farm-feed machinery heading excludes industrial-use machinery; limitation cannot be invoked against a provisional assessment without determining whether a legally appealable final assessment or order exists.

Issues: (i) Whether registered secured creditors' dues take priority over State tax dues and statutory charges; (ii) Whether State attachment orders issued before enforcement of the secured-creditor priority provisions can defeat that priority without a lawful public proclamation and consequential recovery steps; (iii) Whether an auction purchaser of a secured asset may be subjected to a State boja/encumbrance after completion of the secured sale.

Issue (i): Whether registered secured creditors' dues take priority over State tax dues and statutory charges.

Analysis: Section 26E of the SARFAESI Act and Section 31B of the RDDB Act confer priority upon secured creditors in distribution of sale proceeds over all debts, revenues, taxes, cesses and rates payable to governmental authorities. The State provisions creating a first charge, including Section 82 of the MGST Act and amended Section 37 of the MVAT Act, do not displace that statutory priority. The secured interests in the cases were registered before the State departments' charges, or the State charges were not registered.

Conclusion: The secured creditors' registered dues have priority over the State tax dues, in favour of the secured creditors.

Issue (ii): Whether State attachment orders issued before enforcement of the secured-creditor priority provisions can defeat that priority without a lawful public proclamation and consequential recovery steps.

Analysis: A mere attachment order is insufficient. For a pre-enforcement attachment to resist the secured creditor's priority, the State must establish attachment and public proclamation in accordance with the applicable revenue-recovery procedure, along with the required consequential steps. The State did not establish compliance with those requirements in any of the relevant petitions.

Conclusion: The unproclaimed and incompletely enforced State attachments cannot defeat the secured creditors' statutory priority, in favour of the secured creditors.

Issue (iii): Whether an auction purchaser of a secured asset may be subjected to a State boja/encumbrance after completion of the secured sale.

Analysis: Upon payment of consideration and issuance of the sale certificate in a secured sale, the auction purchaser is entitled to enjoy the asset free from a State encumbrance that cannot prevail over the secured creditor's priority. An "as is where is" sale condition does not permit the State to pursue the same asset or retain a revenue-record boja after enforcement of the security interest.

Conclusion: The State cannot retain or enforce a boja/encumbrance against the auction purchasers' secured-sale assets, in favour of the auction purchasers.

Final Conclusion: The impugned State attachment orders, notices, communications and revenue-record encumbrances were invalidated, and consequential removal of the encumbrances was required.

Ratio Decidendi: Statutory priority of a duly registered secured creditor under the central recovery regime prevails over State tax charges unless a pre-existing State attachment was lawfully completed through the prescribed public-proclamation and recovery process.

Issues: Whether the petitioner should be granted regular bail pending investigation into alleged clandestine manufacture and clearance of pan masala without registration and payment of cess.

Analysis: The alleged offences were punishable with imprisonment of less than five years. The petitioner had remained in custody since 18.06.2026; investigation was still pending, but no custody petition had been filed. These circumstances warranted release on bail subject to stringent safeguards for investigation and compliance with statutory bail conditions.

Conclusion: Regular bail was granted to the petitioner, subject to execution of bond and sureties, weekly appearance before the investigating officer for the stipulated period or until filing of the charge sheet, and compliance with applicable bail conditions.

Issues: Whether the writ petition challenging rejection of a consequential GST refund should be entertained despite the availability of a statutory appeal.

Analysis: The appellate order had set aside the earlier rejection on specified grounds but had neither directed unconditional release of the refund nor precluded fresh examination on other legally permissible grounds. The subsequent rejection order independently examined the refund claim and recorded reasons concerning turnover reconciliation and refund computation. The legality of those reasons and the scope and effect of the appellate order could be comprehensively examined in an appeal under Section 107 of the Central Goods and Services Tax Act, 2017. The rejection order was therefore not shown to be non est or wholly without jurisdiction so as to justify writ interference.

Conclusion: The writ petition was not maintainable for interference in the circumstances, and the petitioner was required to pursue the statutory appellate remedy.

Issues: (i) Whether an order under Section 73 issued within the prescribed limitation period becomes invalid merely because it is uploaded and served thereafter; (ii) whether limitation under Section 73(10) applies to issuance of the order or to its service; and (iii) whether signing and issuing the order are legally distinct from its subsequent communication to the taxpayer.

Issue (i): Whether an order under Section 73 issued within the prescribed limitation period becomes invalid merely because it is uploaded and served thereafter.

Analysis: Section 73(9) requires the proper officer to determine the tax, interest and penalty and issue an order, while Section 73(10) prescribes the limitation period for such issuance. Section 169 separately prescribes the modes of service, including making the order available on the common portal. Rule 142(5) requires the summary of the order to be uploaded in Form GST DRC-07 and does not make such uploading the date of issuance for limitation purposes. The order was digitally authenticated and issued on the last permissible date, and its uploading on the following day related to service and communication.

Conclusion: An order issued within the limitation period is not rendered void or time-barred merely because it is uploaded and served after that period.

Issue (ii): Whether limitation under Section 73(10) applies to issuance of the order or to its service.

Analysis: The statutory scheme deliberately uses the expressions "issue" and "service" distinctly. Section 73(10) attaches limitation to issuance of the order under Section 73(9), whereas Section 169 governs the manner and effect of service. The limitation provision contains no requirement that service of the order must also be completed within the same period. In interpreting the taxing statute, the separate statutory treatment of issuance and service cannot be disregarded.

Conclusion: The limitation under Section 73(10) applies to issuance of the order and not to its service.

Issue (iii): Whether signing and issuing the order are legally distinct from its subsequent communication to the taxpayer.

Analysis: Issuance involves the proper officer making and authenticating the adjudicatory order and setting it in motion for dispatch, including through the prescribed electronic mechanism. Service is the subsequent communication of that order through one of the modes specified in Section 169. Rule 26(3) governs electronic issuance and authentication, while Rule 142(5) governs uploading of the order summary. The statutory scheme therefore treats completion of the adjudicatory function and communication of the decision as distinct stages.

Conclusion: Issuance of the order is distinct from service, and the validity or completeness of issuance cannot be made dependent on service being completed within the limitation period.

Final Conclusion: The order issued within the prescribed period remained legally valid, and its subsequent uploading did not defeat the statutory limitation or the authority to enforce it after service.

Ratio Decidendi: Where the statute prescribes limitation for issuance of an adjudicatory order and separately regulates its service, timely issuance satisfies the limitation requirement; subsequent service need not occur within that limitation period.

Issues: Whether the assessment order was liable to be set aside for want of a fair and effective opportunity to respond to the proposed additions.

Analysis: The assessee's primary and secondary email addresses were registered on the income-tax portal, but the material notices were not sent to either address. Notices sent to the former auditor's email address were not effectively communicated after disputes arose and the auditor resigned. The assessment was consequently completed without an adequate opportunity for the assessee to submit its explanation and supporting documents, offending the principles of natural justice.

Conclusion: The assessment order and consequential demand notice were set aside in favour of the assessee, and the assessment was restored for fresh adjudication after affording an adequate opportunity and personal hearing. The issue concerning validity of service under Rule 127 was left open.

Issues: Whether the revision order and the ex parte assessment could be sustained when the documentary evidence filed during revision proceedings was not considered.

Analysis: The revision record contained a cash-transaction summary, appointment letter and delivery challans supporting the explanation for the cash deposits. The revision order merely stated that no reliable evidence had been furnished, without addressing those documents or recording adverse findings on them. As the assessment had been made ex parte and the material placed in revision had not been before the Assessing Officer, fresh consideration by the Assessing Officer was warranted with a reasonable opportunity of hearing.

Conclusion: The revision order and ex parte assessment, together with consequential demand, penalty notices and bank-account attachment notice, were set aside and the matter was remanded for de novo adjudication after considering the evidence and submissions. The issue was decided in favour of the assessee.

Issues: Whether an unsigned notice issued electronically under section 148 was validly authenticated and could confer jurisdiction for reassessment.

Analysis: Section 282A requires a notice issued by an income-tax authority to be signed; for electronic communication, authentication requires a digital signature. The statutory use of "shall" makes signature mandatory, not a procedural formality. The notice under section 148 bore neither a manual nor a digital signature. Such failure deprived the notice of legal validity and constituted a jurisdictional defect that could not be cured under sections 292B or 292BB.

Conclusion: The unsigned notice under section 148 was invalid; consequently, the reassessment proceedings and reassessment order were quashed.

Issues: (i) Allowability under section 37(1) of interest paid on delayed payment of statutory dues, including TDS, sales tax/VAT, service tax and provident-fund contributions; (ii) Validity and computation of disallowance under section 14A read with Rule 8D where exempt income was asserted not to have been earned.

Issue (i): Allowability under section 37(1) of interest paid on delayed payment of statutory dues, including TDS, sales tax/VAT, service tax and provident-fund contributions.

Analysis: Explanation 1 to section 37(1) excludes expenditure incurred for an offence or a purpose prohibited by law, while business expenditure must be wholly and exclusively for business. Interest on arrears of sales tax/VAT and service tax is compensatory because those levies are connected with business operations and are otherwise allowable on payment basis. Interest for delayed remittance of TDS is not deductible: TDS represents tax deducted from the payee and its remittance is not expenditure incurred for the assessee's business. Interest relating to delayed employees' provident-fund contribution is likewise not allowable; employer contribution requires factual segregation. The assessment requires verification whether the prior-period interest of Rs.10,93,356 was already included in the larger amount disallowed, so as to avoid double disallowance.

Conclusion: Interest on delayed deposit of VAT/sales tax, entry tax, service tax and employer's provident-fund contribution is allowable, subject to verification; interest on delayed TDS, employees' provident-fund contribution and other tax-related dues is not allowable. The alleged duplicate addition of Rs.10,93,356 must be deleted if verified. The issue is partly in favour of the assessee.

Issue (ii): Validity and computation of disallowance under section 14A read with Rule 8D where exempt income was asserted not to have been earned.

Analysis: A section 14A disallowance must be confined to investments that yield income not forming part of total income. National Savings Certificate investments cannot be included because their interest is taxable. Since the record did not contain the return computation despite the assertion that no exempt income was earned, verification by the Assessing Officer is necessary.

Conclusion: If no exempt income was earned, the additional section 14A disallowance must be deleted; absent evidence of any further exempt income, the disallowance is restricted to the amount voluntarily disallowed by the assessee. The issue is in favour of the assessee.

Final Conclusion: The disputed deductions and disallowance require recomputation after verification, with relief confined to compensatory business-related interest and to investments connected with exempt income.

Ratio Decidendi: Interest on delayed statutory payments is deductible only where it is compensatory and connected with the assessee's business expenditure; interest on delayed remittance of TDS or employees' contributions is not such business expenditure, and section 14A disallowance must relate to investments generating exempt income.