Issues: Whether payment for rights confined to live telecast feed, without rights to record, preserve or re-telecast it beyond the relevant events, constitutes royalty under Section 9(1)(vi) of the Income-tax Act, 1961.

Analysis: Royalty presupposes an enduring benefit. The live-feed rights were restricted to telecast of matches in the relevant series and did not permit recording, preservation, or future re-telecast beyond those events. The payment therefore did not secure any enduring exploitation right in the feed.

Conclusion: Payment for the restricted live-feed rights is not royalty under Section 9(1)(vi) of the Income-tax Act, 1961 and is not chargeable to tax as royalty in the hands of the overseas rights holder.

Issues: Whether extraordinary writ jurisdiction could be exercised to condone delay beyond the statutory period for filing an appeal against cancellation of GST registration and require merits adjudication.

Analysis: Section 107 restricts the Appellate Authority's power to extend the appeal period, and the statutory appellate framework does not permit it to condone delay beyond the prescribed ceiling. However, Article 226 preserves constitutional power to grant appropriate relief where denial of merits consideration would cause grave prejudice. Cancellation of GST registration materially affects the taxpayer's ability to carry on business and livelihood; the GST framework also facilitates restoration of compliant taxpayers rather than imposing disproportionate and permanent exclusion for procedural default.

Conclusion: The delay of 452 days was condoned, the limitation order was set aside, and the taxpayer's appeal was required to be entertained and decided on merits.

Issues: Whether an assessment order passed for failure to file monthly GST returns under Section 62(1) can be revisited upon filing of the returns, and whether the assessee remains liable to pay interest and late fee under Section 62(2).

Analysis: The order records that the assessment was made because the monthly returns were not filed within time. It further records that, once the returns are uploaded, reassessment will follow in accordance with law. The fact that the assessee deals in exempt goods does not dispense with the statutory liability to pay interest and late fee arising from delayed compliance.

Conclusion: The petitioner was granted liberty to furnish the returns, and the matter was left to be considered by the appropriate authority in accordance with Section 62(2); the assessment order was not finally interfered with on merits.

Issues: Whether the petitioner was entitled to a direction for consideration of the claim for refund of the alleged excess GST amount arising from the transition from VAT to GST, and for a consequential refund, if found due.

Analysis: The petition sought mandamus for payment of the differential GST amount and a policy/circular to address similar claims. The petitioner stated that excess amounts had been paid during the change in tax regime and that earlier representations had not been considered. The Court disposed of the writ petition in terms of earlier coordinate bench orders and granted liberty to submit a detailed representation with supporting particulars to respondent No. 4. Upon such representation, respondent No. 4 was directed to consider the claim and refund any amount found due within eight weeks.

Conclusion: The petitioner obtained a limited relief of consideration of the refund claim, with a consequential direction to refund any amount due, if found payable.

Final Conclusion: The writ petition was disposed of with a direction for fresh consideration of the petitioner's refund claim by respondent No. 4 and consequential payment, if any amount was found due.

Issues: Whether the reduced demand and penalties sustained in de novo adjudication on the basis of the evidence on record and the earlier remand directions required interference in the revenue appeal.

Analysis: The adjudicating authority was found to have acted in accordance with the remand directions and restricted the demand on the basis of the available evidence. The revenue did not place any additional evidence to support the allegation of undervaluation beyond what had already been considered. In these circumstances, the impugned order was held to be sustainable. The reliance placed on a later decision concerning transaction value did not warrant interference on the facts of the present case.

Conclusion: The reduced duty demand and penalties were upheld, and the revenue challenge failed.

Ratio Decidendi: In the absence of additional evidence to substantiate undervaluation, an adjudication based on the available record and in conformity with remand directions will not be interfered with.

Issues: Whether the adjudicating authority failed to consider the petitioner's contention that the services were transportation services and that the tax liability, if any, rested on the recipient under the applicable notification, warranting setting aside of the order and remand.

Analysis: The order-in-original referred to the petitioner's plea based on the notification governing reverse charge on transportation services and also noticed the documents produced, but it recorded no finding on that contention. The reason for rejecting the petitioner's case that the activity related to transportation of goods was also not disclosed. In these circumstances, the adjudication was found to be incomplete. The petitioner expressed readiness to appear again and substantiate the transactions with the existing documents.

Conclusion: The impugned order was set aside and the matter was remitted for fresh consideration, with the petitioner's contentions kept open.

Issues: (i) Whether criminal proceedings for offences under the Companies Act, 2013 could be sustained against a former director when the complaint disclosed no specific role against him and he had already been dropped by two investigating agencies; (ii) Whether the look out circular issued against him could survive once the criminal proceedings were quashed.

Issue (i): Whether criminal proceedings for offences under the Companies Act, 2013 could be sustained against a former director when the complaint disclosed no specific role against him and he had already been dropped by two investigating agencies.

Analysis: The petitioner had ceased to be a director long before the company commenced commercial operations. The record showed that two investigating agencies had examined his explanation, found no incriminating material, and dropped him from the array of accused. The complaint under Sections 447 and 448 of the Companies Act, 2013 contained no concrete allegation attributing any fraudulent act or false statement to him and relied only on his past association as a former director. Criminal prosecution requires a clearly spelt out role, and a bald assertion that a person was a former director is insufficient to justify prosecution.

Conclusion: The criminal proceedings could not be sustained and were liable to be quashed in favour of the petitioner.

Issue (ii): Whether the look out circular issued against him could survive once the criminal proceedings were quashed.

Analysis: The look out circular was founded on the very proceedings that were challenged. Once the criminal case lacked a sustainable basis and stood quashed, the foundation for the look out circular disappeared. The consequential administrative restraint therefore could not continue.

Conclusion: The look out circular was liable to be quashed in favour of the petitioner.

Final Conclusion: The challenge succeeded in full, the criminal case and the connected travel restraint were set aside, and the observations were confined to the petitioner alone.

Ratio Decidendi: A former director cannot be subjected to criminal prosecution under the Companies Act on the basis of a bare reference to past office without specific allegations showing a prima facie role in the alleged offences, and any consequential restraint founded solely on such unsustainable proceedings must fall.

Issues: Whether a party unsuccessful in arbitral proceedings, having no enforceable award in its favour, may maintain an application for post-award interim measures under Section 9 of the Arbitration and Conciliation Act, 1996.

Analysis: Section 9, read with the definition of "party" in Section 2(h), plainly permits any party to an arbitration agreement to seek interim protection before, during, or after arbitral proceedings until enforcement of the award. The provision does not distinguish between successful and unsuccessful parties. Restricting post-award relief to an award-holder would impermissibly add a qualification absent from the statutory text and would narrow the statutory expressions "subject matter of arbitration" and "amount in dispute" to the "fruits" of an award. Sections 34 and 36 operate in distinct spheres: they concern challenge to, and stay of, an award, whereas Section 9 protects the subject matter or amount in dispute. The possibility of modification or severance of an award, recommencement of arbitration after setting aside, and preservation of limitation under Section 43(4) further demonstrate that an unsuccessful party may require protection pending challenge proceedings. Interim relief remains governed by prima facie case, balance of convenience, and irreparable injury; the threshold is higher for an unsuccessful party and relief is warranted only in rare and compelling cases.

Conclusion: Any party to an arbitration agreement, including a party unsuccessful in arbitration, may invoke Section 9 at the post-award stage before enforcement of the award; decisions denying such access do not state the correct law.

Issues: (i) Whether reassessment initiated beyond four years was valid in the absence of failure to disclose fully and truly all material facts; (ii) whether waiver of the principal amount of a loan was taxable under sections 28(iv) or 41(1) of the Income-tax Act, 1961.

Issue (i): Validity of reassessment proceedings initiated beyond four years.

Analysis: The first proviso to section 147 of the Income-tax Act, 1961 requires escapement of income by reason of the assessee's failure to disclose fully and truly all material facts where reopening is undertaken beyond four years. The recorded reasons relied on the balance sheet, Profit and Loss Account, computation and case records already available during the original scrutiny assessment. Disclosure of primary facts does not require the assessee to suggest the legal inference to be drawn from them. Mere non-discussion of an issue in the original assessment order does not establish failure of disclosure, and reopening on the same material amounts to an impermissible review or change of opinion.

Conclusion: The jurisdictional condition for reopening was not satisfied. The notice under section 148 and the reassessment under sections 143(3) read with 147 of the Income-tax Act, 1961 were invalid and liable to be quashed.

Issue (ii): Taxability of waiver of the principal amount of a loan.

Analysis: Waiver of the principal loan amount results in a monetary benefit and therefore does not constitute a benefit or perquisite in a form other than money for purposes of section 28(iv) of the Income-tax Act, 1961. Section 41(1) requires an earlier allowance or deduction in respect of a loss, expenditure or trading liability. A principal borrowing does not become a trading liability merely because the borrowed funds were used for working capital or other business purposes. Book credit of the waived amount does not determine its taxability.

Conclusion: The waived principal amount was not chargeable to tax under section 28(iv) or section 41(1) of the Income-tax Act, 1961, and the addition was liable to be deleted.

Final Conclusion: The reassessment lacked jurisdiction and, independently, the substantive addition could not be sustained under the applicable provisions.

Ratio Decidendi: Reopening beyond four years on the basis of material already disclosed during the original scrutiny assessment is invalid absent failure to disclose fully and truly all material facts; waiver of a principal loan amount is neither a monetary benefit taxable under section 28(iv) nor remission of a trading liability taxable under section 41(1).

Issues: Whether the final assessment order passed under the faceless assessment regime was time-barred under section 144C(13) of the Income-tax Act, 1961 and consequently void ab initio.

Analysis: The assessment proceedings arose from a transfer pricing reference and culminated in draft assessment proceedings, objections before the Dispute Resolution Panel, and directions issued under section 144C(5). The decisive question was whether the final assessment order was passed within the statutory period prescribed under section 144C(13). The relevant DRP directions were uploaded on the ITBA portal on 08.10.2025, and the final order was digitally signed on 01.12.2025. The statutory deadline expired on 30.11.2025. Relying on the principle that the date of uploading in the ITBA portal is the relevant date for reckoning limitation, the delay beyond the prescribed period rendered the final order invalid.

Conclusion: The final assessment order was held to be barred by limitation and void ab initio, and the assessment was quashed. The appeal was allowed.

Issues: Whether a refund deficiency memo in Form GST RFD-03 could be sustained when the stated deficiency was that the supporting documents were incomplete and the reasons were found to be vague.

Analysis: The only deficiency communicated to the claimant was that the supporting documents attached to the refund application were incomplete and did not satisfy the requirements under the relevant circular. The reasons recorded in the deficiency memo were found to be too vague to enable the claimant to understand and meet the objection. In such circumstances, the memo could not be used to reject the refund claim without clearly specifying the actual deficiencies. The Court therefore directed the respondent to communicate the precise deficiencies, permit rectification, and thereafter pass a fresh speaking order on the refund claim.

Conclusion: The deficiency memo was held unsustainable for vagueness, and relief was granted to the petitioner with directions for specification of deficiencies, rectification, and fresh adjudication of the refund claim.

Final Conclusion: The petition succeeded, and the refund matter was remitted for reconsideration after issuance of a clear and speaking deficiency communication.

Ratio Decidendi: A refund deficiency memo must specify concrete and intelligible deficiencies; a vague communication cannot validly defeat a refund claim or substitute for a speaking order.

Issues: Whether the writ petition should be disposed of by remitting the matter for fresh adjudication on merits, subject to payment of a portion of the disputed tax and filing of a reply.

Analysis: The challenge arose from an adjudication order passed after the petitioner did not respond to the show cause notice or attend the personal hearings. The Court noted that the statutory appeal period had already expired, but recorded the petitioner's consent to deposit 25% of the disputed tax and to file a reply with supporting documents. On that basis, the matter was sent back for fresh consideration on merits, with a direction to treat the impugned order as an addendum to the show cause notice. The Court also directed that any bank attachment would stand lifted upon compliance with the stipulated conditions.

Conclusion: The matter was remitted to the respondent for fresh adjudication on merits, subject to the petitioner depositing 25% of the disputed tax and filing a reply within the prescribed time.

Issues: Whether accumulation of income under section 11(2) could be denied solely because Form-10 was filed belatedly, though it was on record during the assessment proceedings.

Analysis: The return was filed within the extended due date, and Form-10 was available before the Assessing Officer during the assessment proceedings. The Tribunal noted that High Court and Tribunal decisions had accepted belated filing of Form-10 where sufficient cause existed and the claim was otherwise supported on record. On the facts, the delay in furnishing Form-10 was treated as not fatal to the claim for accumulation under section 11(2).

Conclusion: The disallowance was not sustained, and the Assessing Officer was directed to examine Form-10 filed belatedly and allow the accumulation claim under section 11(2), in favour of the assessee.

Issues: Whether the assessee was entitled to the revised ceiling limit of Rs. 25,00,000 for exemption on leave encashment under section 10(10AA) of the Income-tax Act, 1961 for AY 2020-21, and whether the matter required recomputation by the Assessing Officer.

Analysis: The assessee, a retired employee, had received leave encashment and the lower authorities restricted exemption to Rs. 3,00,000 on the footing that he was a non-government employee. The Tribunal noted the CBDT notification dated 24.05.2023 enhancing the exemption ceiling to Rs. 25,00,000 and observed that coordinate bench decisions had already applied the revised limit to earlier assessment years, including AYs prior to the notification. Following those decisions, the Tribunal accepted that the assessee was entitled to the benefit of the revised ceiling for AY 2020-21. The issue was therefore sent back to the Assessing Officer only for recomputation of the exemption amount by applying the enhanced limit.

Conclusion: The assessee succeeded on the substantive issue to the extent that the revised limit of Rs. 25,00,000 was held applicable, and the addition was directed to be deleted upon recomputation.

Issues: Whether the appeal against the original assessment order survived after revision under section 263 of the Income-tax Act, 1961, and whether the doctrine of merger entitled the assessee to relief in the present appeal.

Analysis: The original assessment had already been revised under section 263, and consequential proceedings were also taken against the assessee. The appeal before the Tribunal was confined to the merger contention, while no specific ground was raised challenging the revision order itself. In these circumstances, the doctrine of merger was held to have no application for granting relief on the grounds urged. The assessee was found not entitled to any benefit on the factual and legal position presented in the appeal.

Conclusion: The appeal was not maintainable on the ground pressed and was dismissed.

Issues: Whether cash deposited in the bank during the demonetisation period was liable to be treated as unexplained money under section 69A of the Income-tax Act, 1961 and taxed accordingly.

Analysis: The assessee established that the disputed cash originated from RTGS compensation received on compulsory acquisition of agricultural land. The record showed immediate cash withdrawals from the same bank account after receipt of the compensation and no material was brought by the Revenue to show that the withdrawn cash was spent, invested, or otherwise diverted. In the absence of contrary evidence, the explanation that the cash was retained and later redeposited was found to be supported by a direct link between withdrawal and redeposit.

Conclusion: The cash deposit was accepted as explained and the addition made under section 69A did not survive; the assessee succeeded.

Issues: (i) whether reassessment initiated for the assessment year 2013-14 on the basis of third-party information was valid when the notice under section 148 of the Income-tax Act, 1961 was issued beyond six years from the end of the assessment year; (ii) whether the amount treated as accommodation entry could be added as unexplained money under section 69A of the Income-tax Act, 1961 and brought to tax under section 115BBE of the Income-tax Act, 1961 when it was already disclosed in the return and reflected in the books.

Issue (i): whether reassessment initiated for the assessment year 2013-14 on the basis of third-party information was valid when the notice under section 148 of the Income-tax Act, 1961 was issued beyond six years from the end of the assessment year

Analysis: The reopening rested solely on information received from a third party and there was no independent material showing failure by the assessee to disclose fully and truly all material facts necessary for assessment. The notice under section 148 was issued after the expiry of six years from the end of the relevant assessment year, and the jurisdictional requirement for reopening beyond that period was not satisfied.

Conclusion: The reassessment was invalid.

Issue (ii): whether the amount treated as accommodation entry could be added as unexplained money under section 69A of the Income-tax Act, 1961 and brought to tax under section 115BBE of the Income-tax Act, 1961 when it was already disclosed in the return and reflected in the books

Analysis: The amount in question had already been disclosed in the return of income, and the factual basis for treating it as unexplained money was not established. In the absence of sustainable reassessment and without a valid basis for characterising the amount as unexplained, the addition could not be upheld.

Conclusion: The addition under section 69A of the Income-tax Act, 1961 and the consequential application of section 115BBE of the Income-tax Act, 1961 were not sustained in favour of the Revenue.

Final Conclusion: The reassessment and the related addition were set aside, and the assessee obtained complete relief in the appeal.

Ratio Decidendi: Reassessment beyond the prescribed limitation period cannot be sustained on the basis of third-party information alone unless the statutory preconditions for reopening are independently met, and an amount already disclosed cannot be treated as unexplained without a legally sustainable basis.

Issues: (i) Whether the addition made by treating cash deposits as unexplained under section 69A read with section 115BBE could be sustained in respect of receipts from coaching classes and hostel activity; (ii) whether the deposits claimed to represent agricultural income and amounts received from Lala Ram required verification and could be finally accepted on the existing record.

Issue (i): Whether the addition made by treating cash deposits as unexplained under section 69A read with section 115BBE could be sustained in respect of receipts from coaching classes and hostel activity.

Analysis: The assessee had consistently disclosed coaching and hostel income over the years and placed bank statements, cash flow details and return material on record. The record showed cash withdrawals and deposits, and the explanation that part of the deposits represented student and advance received in cash was found supported by the surrounding facts. The available material established that the assessee was running a coaching centre and hostel and had a direct source for the impugned deposits from students.

Conclusion: The addition was deleted to the extent of advance fees received from students of Rs. 9.75 lakh and fees received of Rs. 33.75 lakh, in favour of the assessee.

Issue (ii): Whether the deposits claimed to represent agricultural income and amounts received from Lala Ram required verification and could be finally accepted on the existing record.

Analysis: The assessee relied on agricultural receipts and an amount stated to have been received from Lala Ram, but the supporting material was not considered sufficient for final acceptance on the record before the Tribunal. These claims needed factual verification by the Assessing Officer before any conclusive relief could be granted.

Conclusion: The issues relating to agricultural income and the amount received from Lala Ram were remanded to the Assessing Officer for verification, partly in favour of the assessee.

Final Conclusion: The addition was sustained only to the extent requiring fresh verification, while the explained coaching and hostel receipts were accepted and granted relief. The appeal was, therefore, allowed in part.

Ratio Decidendi: Where cash deposits are supported by consistent business history, cash flow material and corroborative bank transactions showing a direct source, they cannot be treated as unexplained; claims lacking adequate supporting evidence may be remanded for verification.

Issues: Whether, where the declared sales were not disturbed and the purchases were alleged to be unverified or from unaccounted sources, the entire purchase amount of Rs. 22,50,000 could be added under section 69C of the Income-tax Act, 1961, or only the profit element embedded in such purchases was liable to tax; and whether denial of cross-examination of persons whose statements were relied upon vitiated the addition.

Analysis: The assessee was engaged in trading activity and the Revenue had not rejected the sales declared by the assessee. On that footing, the purchases corresponding to such sales could not be treated as wholly non-existent for tax purposes. Where sales are accepted and only purchases are doubted, the settled approach is to tax only the profit element embedded in such purchases and not the entire purchase value, since taxing the gross amount would be inconsistent with the computation of real income. The documentary material seized during search was treated as primary evidence, while the statements recorded under section 132(4) of the Income-tax Act, 1961 were only corroborative. In those circumstances, the absence of cross-examination did not invalidate the addition, but the quantum of addition still had to be restricted to a reasonable estimate of profit.

Conclusion: The entire alleged purchases could not be brought to tax under section 69C of the Income-tax Act, 1961, and the addition was to be restricted to the profit element embedded in the purchases.

Issues: Whether the addition made under section 69A on the basis of alleged accommodation entries and bogus capital gains was sustainable in the absence of specific material linking the assessee to the alleged entry provider and corroborative evidence of unexplained money.

Analysis: The addition rested on general investigation information alleging a stock market accommodation-entry racket, but no live nexus was established between the assessee and the alleged operator. The assessment order did not identify the exact transactions, the specific scrips giving rise to the alleged amounts, the dates or manner of the supposed routing of funds, or any corresponding credit entries in the assessee's bank statements. The assessed share transactions disclosed only a nominal short-term capital gain already offered to tax, and no independent inquiry or corroborative material was brought on record to show that the assessee introduced unaccounted money in the guise of capital gains. An addition under section 69A requires cogent material showing ownership of unrecorded money and the absence of a satisfactory explanation.

Conclusion: The addition under section 69A was held unsustainable and the deletion of the addition was upheld, in favour of the assessee.