Issues: Whether the writ petition could be entertained to quash an attachment under the Prevention of Money Laundering Act, 2002 when the provisional attachment had already been confirmed and the petitioner had a statutory remedy before the Special Court.

Analysis: The attachment had been confirmed by the Adjudicating Authority under Section 8(3) of the Prevention of Money Laundering Act, 2002, and the trial under that Act was pending before the Special Court for PMLA cases. In that situation, the petitioner was required to seek relief before the Special Court under Section 8(7) of the Act for lifting of the attachment, rather than invoke writ jurisdiction to set aside the attachment directly.

Conclusion: The writ petition was not entertained on merits, and the petitioner was directed to pursue the statutory remedy before the Special Court under Section 8(7) of the Prevention of Money Laundering Act, 2002.

Issues: Whether the order cancelling GST registration was liable to be set aside for want of reasons and non-compliance with the prescribed procedure under the CGST Rules.

Analysis: Cancellation of registration under Section 29 of the Central Goods and Services Tax Act, 2017 read with Rule 22 of the Central Goods and Services Tax Rules, 2017 requires observance of the prescribed procedure, including issuance of notice, consideration of reply, and passing of a reasoned order in the prescribed form. A cancellation order affecting civil rights must be a speaking order and must disclose application of mind. The impugned order merely recorded that no reply had been filed and that returns were not furnished, without assigning any proper reason or setting out the basis for cancellation. The notice itself also lacked sufficient particulars of the alleged default. Such an order falls short of the statutory requirement and the principles of fair procedure.

Conclusion: The cancellation order was unsustainable and was set aside and quashed. The matter was remitted to the stage of the show-cause notice for fresh consideration in accordance with law.

Issues: (i) Whether the writ petition was entertainable despite the availability of the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017; (ii) whether the impugned order warranted interference on the ground of violation of natural justice and lack of sustainable findings for penalty under Section 122(1A) of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the writ petition was entertainable despite the availability of the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: The petitioners elected to seek a merits-based order instead of pursuing the appellate remedy. The Court nonetheless examined the matter on merits, but noted that the statutory appeal remained an efficacious remedy for factual and legal challenges.

Conclusion: The availability of appeal did not result in interference under writ jurisdiction, and the petition was not accepted on this ground.

Issue (ii): Whether the impugned order warranted interference on the ground of violation of natural justice and lack of sustainable findings for penalty under Section 122(1A) of the Central Goods and Services Tax Act, 2017.

Analysis: The investigation material, statements of the petitioners, electronic records, WhatsApp chats, and admissions regarding fake invoices, bogus e-way bills, and hawala routing were relied upon by the adjudicating authority. The findings recorded in the order showed the petitioners' knowledge, consent, and active participation, and the Court found that the order was a reasoned one and that no procedural unfairness or absence of findings was made out.

Conclusion: No violation of natural justice or infirmity in the findings was established, and the penalty under Section 122(1A) of the Central Goods and Services Tax Act, 2017 was not interfered with.

Final Conclusion: The writ challenge to the penalty order failed, and the impugned adjudication was left undisturbed.

Ratio Decidendi: A writ court will not interfere with a reasoned penalty order under the GST law where the record contains substantive findings based on statements, electronic evidence, and admissions showing participation in fraudulent availment of input tax credit, especially when an efficacious statutory appeal is available.

Issues: (i) Whether the addition of cash deposits as unexplained money under section 69A read with section 115BBE of the Income-tax Act was justified on the facts and evidence on record. (ii) Whether the assessment order suffered from violation of natural justice or mechanical acceptance of the show-cause notice without independent application of mind.

Issue (i): Whether the addition of cash deposits as unexplained money under section 69A read with section 115BBE of the Income-tax Act was justified on the facts and evidence on record.

Analysis: The assessee claimed that the cash deposits represented client receipts, reimbursements, service charges, and GST arising from travel business transactions. The record, however, showed substantial discrepancies between the cash deposits, the declared turnover, the GST returns, and the financial statements. The assessee did not maintain separate authentic accounts or furnish a reliable reconciliation supported by verifiable evidence to explain the source and nature of the deposits. In such circumstances, the onus to satisfactorily explain the cash credits was not discharged.

Conclusion: The addition under section 69A read with section 115BBE was upheld and was against the assessee.

Issue (ii): Whether the assessment order suffered from violation of natural justice or mechanical acceptance of the show-cause notice without independent application of mind.

Analysis: The record showed that the assessee had been given opportunity to file replies and supporting material, and the assessment order dealt with the explanations, ledger entries, bank statements, GST returns, and reconciliation offered. The finding of the authority below was based on inconsistencies in the material and the failure to reconcile deposits, rather than on a mere reproduction of the show-cause notice.

Conclusion: The plea of violation of natural justice and mechanical assessment was rejected and was against the assessee.

Final Conclusion: The assessed addition was sustained in full and the appeal did not succeed.

Ratio Decidendi: When an assessee fails to furnish credible and verifiable evidence satisfactorily explaining the source and nature of cash deposits, the deposits may be treated as unexplained income under section 69A and taxed accordingly.

Issues: Entitlement of the importer to nil countervailing duty under Notification No. 30/2004-C.E. dated 09.07.2004 on imported polyester woven fabrics, and whether the subsequent notifications affected that exemption.

Analysis: The imported goods were assessed to additional duty of customs on the footing that the conditions of the exemption notification were not fulfilled. The Tribunal held that the issue was already covered by earlier decisions, including the Tribunal's own decision on identical facts, and followed the settled position that conditions which cannot be complied with by the importer cannot be thrust upon imported goods for denying the exemption. It further held that the amendments introduced by Notification No. 34/2015-C.E. dated 17.07.2015 and Notification No. 37/2015-C.E. dated 21.07.2015 did not alter the legal position.

Conclusion: The importer was entitled to the benefit of nil CVD and the Revenue's challenge failed.

Issues: Whether notices issued under section 34(8A) of the Gujarat Value Added Tax Act, 2003 were valid in the absence of pending proceedings and recorded satisfaction.

Analysis: Section 34(8A) could be invoked only during the course of pending proceedings under the Act, and the prescribed authority had to be satisfied that tax had been evaded or incorrectly disclosed. The existence of pending proceedings was thus a jurisdictional precondition for exercise of the power. On the admitted facts, no proceedings were pending against the petitioner when the impugned notices were issued, and the notices did not record the requisite satisfaction on the basis of material found in the search.

Conclusion: The notices were without jurisdiction and liable to be quashed.

Issues: Whether interest was leviable under Section 50(3) of the Tamil Nadu Goods and Services Tax Act, 2017 read with Rule 88B(3) of the Tamil Nadu Goods and Services Tax Rules, 2017 on input tax credit that was held to have been wrongly availed and utilised on account of a discrepancy between GSTR-3B and GSTR-2A, and whether the writ court should interfere with the assessment order.

Analysis: Section 50(1) deals generally with delayed payment of tax, whereas Section 50(3) specifically governs cases where input tax credit is wrongly availed and utilised. The expression "wrongfully availed and utilised" is not confined to fraudulent or bad-faith cases; any availment and utilisation of credit when the assessee was not eligible to such credit falls within that expression. Rule 88B(3) prescribes the method for computing interest from the date of utilisation until reversal or payment. The assessing authority had applied this specific provision after finding that the credit had already been utilised against other dues before the date of actual set-off of the tax liability.

Conclusion: The levy of interest under Section 50(3) was upheld and no ground for interference under Article 226 of the Constitution of India was made out.

Issues: Whether the petitioner, arrested in connection with an offence under Section 132(5) of the Assam Goods and Services Tax Act, 2017, was entitled to bail pending investigation.

Analysis: The case was founded on documentary material, and the relevant documents and electronic records had already been seized by the investigating agency. The Court noted that the offence carried a maximum punishment of five years and that the petitioner had already remained in custody for more than fifteen days. In these circumstances, continued judicial custody was held to serve no useful purpose.

Conclusion: Bail was granted to the petitioner.

Ratio Decidendi: Where the prosecution case rests on seized documentary evidence and further custodial detention serves no useful investigative purpose, bail may be granted in an offence carrying a limited maximum sentence.

Issues: Whether the petitioner, accused of offences under the Central Goods and Services Tax Act, 2017, was entitled to bail.

Analysis: The petitioner was stated to be in custody since 11.02.2026, and the request for bail was pressed on the basis of parity with the principles applied in a comparable case, together with an undertaking to cooperate with the trial and not influence witnesses. The prayer was opposed by the opposite party, but the Court found the circumstances sufficient to exercise discretion in favour of release on bail.

Conclusion: Bail was granted to the petitioner on furnishing the stipulated bail bond and sureties, subject to conditions regarding cooperation with the trial, disclosure of mobile number and Aadhaar card, non-change of mobile number during trial, and non-interference with witnesses.

Outcome: The writ application was permitted to be withdrawn with liberty to pursue the appellate remedy within the time granted by the Court.

Outcome: The writ application was permitted to be withdrawn with liberty to the petitioner to avail the statutory remedy before the competent forum. No opinion was recorded on the merits of the dispute.

Issues: Whether the order in original passed under the Assam Goods and Services Tax Act, 2017 could be sustained when the statutory show cause notice was not issued in the prescribed manner and whether consequential directions could be issued regarding fresh proceedings and limitation.

Analysis: The impugned order in original was challenged on the ground that a summary of the show cause notice could not substitute the show cause notice required under Section 73(1) of the Assam Goods and Services Tax Act, 2017. The Court followed its earlier view that a statement or summary in GST DRC-01 does not amount to a valid show cause notice and that authentication by the proper officer is mandatory. It held that the notice, statement and order must bear proper authentication, and that failure to do so renders the proceedings ineffective. The Court therefore set aside the order in original while directing the proper officer to issue a fresh show cause notice under Section 73(1). It also directed that the fresh notice would relate back to the date of the summary notice and that the period from issuance of the summary notice till service of the certified copy of the order would be excluded while computing limitation under Section 73(10).

Conclusion: The order in original was quashed, fresh proceedings under Section 73 were permitted, and limitation was ordered to be excluded for the specified period, thereby granting relief to the petitioner in part.

Final Conclusion: The writ petition was disposed of by invalidating the impugned adjudication, preserving the revenue's right to proceed afresh in accordance with law, and protecting the petitioner from prejudice on limitation for the excluded period.

Ratio Decidendi: A show cause notice and adjudication order under the GST framework must be issued and authenticated by the proper officer as mandated by the statute, and a mere summary cannot substitute for the statutory notice.

Issues: Whether the interest income was governed by the principle of mutuality; whether deduction under Section 57(iii) of the Income-tax Act, 1961 could be restricted to 7.5%; and whether the appropriate portion of deduction under Section 57(iii) should be allowed.

Analysis: The first question was treated as covered by binding Supreme Court authority and was not entertained. The Court found arguable questions on the remaining two questions and admitted the appeal only on those questions.

Outcome: The appeal was not entertained on the first question and was admitted only on the second and third questions.

Issues: Whether the Tribunal was justified in upholding the restriction of the addition to 25% of the alleged bogus purchase amount and whether any substantial question of law arose.

Analysis: The purchases were found, on the material accepted by the first appellate authority and the Tribunal, to be partly genuine, supported by transportation receipts, octroi receipts and other documents. On that factual basis, the addition was confined to 25% of the purchase amount instead of disallowing the entire claim. The concurrent factual findings that the entire purchase was not bogus did not disclose any perversity or legal error warranting interference in appeal under the substantial question of law standard.

Conclusion: The restriction of the addition to 25% was upheld and no substantial question of law arose.

Issues: Whether the assessee was entitled to deduction under section 54B of the Income-tax Act, 1961 on sale of agricultural land, in view of the additional evidence accepted in remand proceedings.

Analysis: The Assessing Officer, in remand proceedings under Rule 46A of the Income-tax Rules, 1962, verified the affidavit of the agriculturist cultivating the land and the bills for seeds, fertilizers, pesticides and urea. On that verification, the Assessing Officer recorded that agricultural and farming activities had been carried out on the land in the years immediately preceding the transfer and that the assessee had purchased another agricultural land after sale. The Tribunal found no contrary material to dislodge the remand findings and held that the conditions for deduction under section 54B stood satisfied. The contention regarding limited scrutiny was treated as academic in view of the decision on merits.

Conclusion: The assessee was entitled to deduction under section 54B, and the disallowance sustained by the first appellate authority was deleted.

Issues: Whether the addition under section 68 of the Income-tax Act, 1961 could be sustained solely on information from the Investigation Wing without independent enquiry or corroborative material linking the assessee to the alleged accommodation entries.

Analysis: The addition was founded only on departmental information arising from a search on third parties and on the assessee's non-compliance. The factual finding recorded below was that no independent enquiry, bank verification, or other corroborative evidence was undertaken to trace the flow of funds or establish a direct nexus between the assessee and the alleged entry providers. The assessee denied the transactions, and the Revenue did not place any material to controvert those findings. In the absence of transaction-specific proof, the alleged accommodation entry remained a matter of suspicion, and suspicion alone could not justify an addition under section 68.

Conclusion: The deletion of the addition was upheld and the Revenue's challenge failed.

Issues: Whether penalty under Section 271(1)(c) of the Income-tax Act, 1961 could be sustained where the quantum addition in respect of bogus purchases was restricted to 12.5% on an estimate basis.

Analysis: The penalty arose from reassessment and best-judgment assessment proceedings under Sections 147, 148 and 144 of the Income-tax Act, 1961. The quantum addition had already been upheld only to the extent of 12.5% of the alleged bogus purchases, and the penalty was set aside by the Tribunal on the footing that the addition was purely estimated. A penalty for concealment or furnishing inaccurate particulars cannot be imposed when the sustaining of income is founded on estimation or guesswork rather than on a definite finding of concealed income.

Conclusion: Penalty under Section 271(1)(c) was not leviable on the estimated addition, and the Tribunal was correct in deleting the penalty.

Outcome: The revenue's appeal was admitted on selected substantial questions of law, and notice of admission was directed to be served on the respondent.

Outcome: The interim application seeking amendment of the writ petition to challenge the vires of Section 147-A of the Income-tax Act, 1961 was allowed, and the matter was disposed of accordingly.

Issues: Whether the show cause notices issued under the repealed Foreign Exchange Regulation Act, 1973 by an officer appointed under the Foreign Exchange Management Act, 1999 were without jurisdiction for want of valid empowerment.

Analysis: The governing provisions concerning repeal and savings were examined together with the requirement under Section 50 of the Foreign Exchange Regulation Act, 1973 that an adjudicating officer must be specifically empowered by the Central Government. The prior Division Bench view on the very same officer was followed, holding that a deemed or general appointment under the Foreign Exchange Management Act, 1999 could not substitute the specific empowerment required to initiate proceedings under the repealed enactment. No distinguishing feature or stay of the earlier decision was shown.

Conclusion: The show cause notices were held to be without jurisdiction and liable to be quashed and set aside; the writ petition was allowed.