Issues: Whether a show cause notice under Section 74 of the Central Goods and Services Tax Act, 2017 can consolidate multiple financial years or tax periods, and whether the impugned notice and consequential order were liable to be set aside.

Analysis: The statutory scheme treats the tax liability under GST as referable to a defined tax period, and the limitation for demand and recovery under Sections 73(10) and 74(10) runs year-wise from the relevant due date. A single notice combining distinct financial years collapses separate periods having different due dates and separate limitation clocks, which is not permitted by the scheme of the Act. The Court applied its earlier view that consolidation of multiple financial years or tax periods in one notice under Section 74 is impermissible, and held that the contrary view of another High Court did not displace that binding position within its jurisdiction.

Conclusion: The impugned show cause notice and order, having clubbed multiple financial years, were quashed and set aside.

Final Conclusion: The proceedings were annulled to the extent they rested on a consolidated demand for multiple years, while leaving the revenue free to proceed afresh in accordance with the statutory framework.

Ratio Decidendi: Under the GST scheme, a demand under Section 74 must be issued with reference to the specific tax period or financial year to which the alleged short payment relates, and a consolidated notice covering multiple years is impermissible where the statute requires year-wise limitation and assessment.

Issues: Whether deduction under section 80IC of the Income-tax Act, 1961 could be denied merely because audit report in Form 10CCB was uploaded after the due date, though it was available before processing under section 143(1).

Analysis: The return was filed within the extended due date and the audit report in Form 10CCB had been obtained before the due date under section 44AB, though it was uploaded with the return. The denial was based only on belated electronic filing. The audit report was on record before processing under section 143(1), and the requirement to file the report along with the return was treated as directory rather than mandatory. On that basis, delay in upload did not defeat the substantive claim for deduction. The rectification rejection was therefore unsustainable.

Conclusion: The issue was decided in favour of the assessee, and the deduction under section 80IC was held allowable despite the delayed filing of Form 10CCB.

Ratio Decidendi: Where the statutory audit report is available before assessment or processing and the claim otherwise satisfies the substantive conditions, delayed filing of the report does not by itself nullify entitlement to deduction if the requirement is directory in nature.

Issues: Whether a writ petition can be entertained to challenge a show cause notice.

Analysis: The petitions directly assailed show cause notices. The governing principle applied was that a writ court ordinarily does not interfere at the stage of issuance of a show cause notice, leaving the affected party to raise objections before the competent authority. Since the challenge was directed against notices and no exceptional ground warranting interference was shown, the petitions were not maintainable.

Conclusion: The challenge to the show cause notices was rejected and the petitions were dismissed.

Final Conclusion: The petitioners were left to pursue all legal objections before the competent authority in the pending proceedings.

Issues: Whether the ex parte GST assessment order should be set aside and the matter remitted for fresh consideration after allowing the petitioner an opportunity to file reply and make the required pre-deposit.

Analysis: The writ petition was disposed of at the admission stage on consent. The petitioner stated that a substantial amount had already been paid and undertook to deposit 10% of the disputed tax if there was any shortfall. The respondent did not dispute the request for a fresh adjudication. The Court therefore accepted the proposal, directed the petitioner to file a reply to the show cause notice with supporting documents, and remitted the matter for de novo decision on merits. The order also provided for automatic vacation of bank attachment on compliance with the stipulated conditions.

Conclusion: The ex parte assessment was not finally sustained and the matter was sent back for fresh adjudication, subject to compliance with the directed deposit and reply.

Issues: Whether the High Court judgments quashing reassessment notices on the ground that the jurisdictional Assessing Officer lacked competence should be set aside and the matters remitted for fresh consideration in view of the subsequent amendments to the reassessment scheme.

Analysis: The statutory reassessment framework under the Income-tax Act, 1961 had been amended by the Finance Act, 2021, and the Central Board of Direct Taxes had introduced the e-Assessment of Income Escaping Assessment Scheme, 2022 under section 151A. The dispute concerned whether notices under sections 148 and orders under section 148A(d) could be issued by the jurisdictional Assessing Officer or only through the faceless mechanism. During the pendency of the appeals, Parliament introduced clarificatory amendments, including section 147A, with retrospective effect from 01.04.2021. In view of these amendments, the Court declined to decide the merits of the competing submissions and left the validity, scope, effect, retrospectivity and applicability of the amended provisions open for adjudication by the jurisdictional High Courts.

Conclusion: The impugned High Court judgments were set aside on the limited ground of the subsequent legislative amendments and the matters were remitted to the High Courts for fresh consideration.

Issues: (i) whether the assessee was rightly treated as an assessee in default for failure to deduct tax at source on the balance consideration paid for purchase of immovable property; (ii) whether the other TDS disallowances on provisions and expenses required fresh examination by the Assessing Officer.

Issue (i): whether the assessee was rightly treated as an assessee in default for failure to deduct tax at source on the balance consideration paid for purchase of immovable property.

Analysis: The assessee purchased immovable property for the full consideration but deducted tax only on a part of the amount. The explanation that the balance was debited in the profit and loss account was not accepted. On the facts, the obligation to deduct tax under section 194IA arose on the entire consideration for transfer of the property. Non-deduction on the balance amount attracted treatment under section 201.

Conclusion: The assessee was rightly treated as an assessee in default on this issue, and the finding was against the assessee.

Issue (ii): whether the other TDS disallowances on provisions and expenses required fresh examination by the Assessing Officer.

Analysis: The assessee produced additional material, including details of payments, remittances, and Form 16A, and contended that in some cases tax had been deducted and remitted in later years or that the liability had not crystallised. These materials had not been examined fully at the earlier stage. The matter therefore required verification of the documents and a fresh determination on whether tax was deductible and whether the assessee could be treated as an assessee in default.

Conclusion: The issue was remitted to the Assessing Officer for de novo consideration, and the assessee obtained partial relief on this issue.

Final Conclusion: The determination on TDS for purchase of immovable property was sustained, while the remaining TDS-related disallowances were sent back for fresh examination, resulting in a partial success for the assessee.

Ratio Decidendi: Tax was required to be deducted on the entire consideration for transfer of immovable property under section 194IA, whereas disputed TDS liabilities on other items could be re-examined where the record showed unresolved factual questions and additional evidence.

Issues: Whether the challenge to the orders admitting personal insolvency proceedings under Section 95 of the Insolvency and Bankruptcy Code, 2016 survived after liquidation of the corporate debtor had already been ordered and affirmed.

Outcome: The appeals were held to have lost their cause and were dismissed as infructuous, with all pending interlocutory applications closed. No adjudication on the merits of admission under Section 95 was undertaken.

Issues: Whether the sale proceeds from shares of GCM Securities Ltd. could be treated as bogus long-term capital gains and taxed as unexplained cash credit, with consequential disallowance of alleged unexplained expenditure, despite the assessee producing share allotment documents, demat statements, contract notes, broker ledger and banking evidence.

Analysis: The assessee supported the purchase and sale of shares with contemporaneous documentary material showing allotment, demat credit and debit, sale through a registered broker on the stock exchange, payment of securities transaction tax, and receipt of consideration through banking channels. The additions were founded mainly on general investigation material, surrounding circumstances and the theory of human probabilities, without any specific material linking the assessee to price manipulation, accommodation entries or any defect in the documentary evidence. The absence of tangible evidence and the lack of any proved expenditure to sustain the section 69C addition meant that the Revenue had not discharged the burden of showing that the apparent transaction was not real.

Conclusion: The long-term capital gain was rightly accepted as genuine, the exemption claim was upheld, and the additions under sections 68 and 69C were unsustainable.

Issues: Whether the petitioner was required to comply with the mandatory pre-deposit requirement before obtaining appellate relief, and whether interference with the impugned order was warranted.

Analysis: The petitioner had not complied with the pre-deposit condition under Section 35F of the Central Excise Act, 1944 read with Section 83 of the Finance Act, 1994. The Court found no ground to interfere with the impugned order, but granted two months' time to make the pre-deposit in accordance with law.

Conclusion: The pre-deposit requirement was held to be mandatory, and interference with the impugned order was declined.

Issues: Whether the ex parte order-in-original passed in service tax proceedings, without effective participation of the petitioner, required to be set aside and the matter remitted to the stage of reply to the show-cause notice.

Analysis: The proceedings were founded on information received from the tax department and the order-in-original was passed without the benefit of a reply from the petitioner. The Court noted that in earlier connected matters involving the same class of disputes, similar orders had been relegated for reconsideration, and that the authorities had themselves indicated a mechanism for post show-cause notice adjudication by designated officers. The Court also recorded that the petitioner's substantive objections, including whether the activity fell within the charging provisions, whether any exemption or negative-list treatment applied, and whether limitation barred the demand, had not been finally adjudicated and required consideration by the proper authority. In these circumstances, the ex parte adjudication could not be allowed to stand and the matter had to be restored for fresh consideration at the reply stage.

Conclusion: The order-in-original was set aside and the matter was remitted to the stage of reply to the show-cause notice, with all contentions kept open.

Issues: Whether the ex parte order-in-original and the consequential recovery notice were liable to be set aside and the matter remitted to the stage of reply to the show-cause notice.

Analysis: The order-in-original was found to be ex parte. The Court noted the reliance placed on earlier writ proceedings in an identical factual matrix, where similar matters had been sent back for reconsideration from the stage of the show-cause notice. In view of that approach and the need to permit the petitioner to submit a fresh reply, the impugned adjudication and consequential recovery action were not sustained.

Conclusion: The ex parte order-in-original and the recovery notice were set aside and the matter was remitted to the stage of reply to the show-cause notice in favour of the petitioner.

Final Conclusion: The dispute was restored for fresh adjudication by the authorities from the pre-adjudication stage, with all contentions left open.

Ratio Decidendi: An ex parte adjudication that does not afford an effective opportunity to reply may be set aside and remitted to the show-cause stage, with consequential recovery proceedings also falling.

Issues: (i) Whether the writ petition was entertainable despite availability of an appellate remedy, and whether denial of unrelied documents and cross-examination vitiated the adjudication. (ii) Whether the earlier order in the connected matter was binding on the other noticees and whether the impugned adjudication could be sustained. (iii) Whether WP No. 17609 of 2025 disclosed any ground for interference.

Issue (i): Whether the writ petition was entertainable despite availability of an appellate remedy, and whether denial of unrelied documents and cross-examination vitiated the adjudication.

Analysis: The availability of an appeal did not create an absolute bar to writ jurisdiction where there was a violation of natural justice. The adjudication proceeded on statements and documents without furnishing the unrelied material and without granting cross-examination, despite such relief having been recognised in the connected matter. The denial of these procedural safeguards went to the fairness of the adjudication and attracted writ interference.

Conclusion: The petition was maintainable and the adjudication was vitiated by breach of natural justice.

Issue (ii): Whether the earlier order in the connected matter was binding on the other noticees and whether the impugned adjudication could be sustained.

Analysis: The earlier order was treated as laying down a procedural entitlement concerning return of unrelied documents and cross-examination. The distinction sought to be drawn between a judgment in rem and a judgment in personam was rejected in the context of a common notice and identical procedural grievance. Judicial discipline required the quasi-judicial authority to follow the same course for similarly placed noticees, and the contrary view taken in the impugned order was not sustained.

Conclusion: The impugned adjudication could not be sustained insofar as it denied the benefit of the earlier procedural directions to similarly placed noticees.

Issue (iii): Whether WP No. 17609 of 2025 disclosed any ground for interference.

Analysis: No material was shown that the petitioner in that petition had appeared before the adjudicating authority or sought return of unrelied documents or cross-examination. In the absence of such foundational steps, no separate ground for interference was made out.

Conclusion: WP No. 17609 of 2025 was dismissed.

Final Conclusion: The common adjudication was set aside for the petitioners who had demonstrated denial of procedural fairness, while one petition failed for want of factual foundation; the matters were otherwise concluded by remand or dismissal as the case may be.

Ratio Decidendi: Where a tax adjudication rests on third-party statements and seized material, denial of unrelied documents and denial of cross-examination amounts to breach of natural justice, and a quasi-judicial authority must follow binding procedural directions in similarly situated cases in observance of judicial discipline.

Issues: Whether an order issued under the GST law is invalid for want of the label "DIN" when it bears a verifiable Reference Number, is uploaded on the common portal, and is also communicated through registered post and e-mail.

Analysis: Section 169 of the Central Goods and Services Tax Act, 2017 recognises service of a decision or order through multiple prescribed modes, including by making it available on the common portal, by registered post, and by e-mail. The order in question carried a verifiable Reference Number capable of online retrieval on the GST portal, and the record also showed communication through the recognised statutory modes. The later CBIC circular clarified that where a portal-generated communication already bears a verifiable RFN, a separate DIN is not required and the communication remains valid. In these circumstances, absence of the word "DIN" by itself does not invalidate the communication.

Conclusion: The challenge based solely on absence of DIN fails, and the order is not liable to be set aside on that ground.

Ratio Decidendi: A GST communication that is verifiable through the common portal and is served through prescribed statutory modes is not rendered invalid merely because it does not expressly mention DIN.

Issues: (i) Whether the assignment to initiate proceedings under the GST law was valid when the empowering order had expired, and whether the consequential proceedings were without jurisdiction; (ii) whether the impugned notice, demand proceedings and order could be quashed.

Issue (i): Whether the assignment to initiate proceedings under the GST law was valid when the empowering order had expired, and whether the consequential proceedings were without jurisdiction.

Analysis: The authority to assign proceedings flowed from an order dated 30 January 2023, which was stated to be operative only up to 31 December 2023. Proceedings were initiated for the 2021-2022 tax period after the expiry of that empowering order. Once the authorising order ceased to operate, the officer lacked authority to make the assignment, and proceedings founded on such an assignment could not stand.

Conclusion: The assignment and the consequential proceedings were without jurisdiction and non-est.

Issue (ii): Whether the impugned notice, demand proceedings and order could be quashed.

Analysis: Since the foundation of the proceedings was held to be invalid, the pre-intimation notice, show cause notice and order in original, along with the summary of demand, were liable to be set aside. The writ jurisdiction was therefore invoked to annul the consequential actions.

Conclusion: The impugned notice, demand proceedings and order were quashed.

Final Conclusion: The proceedings under the GST law failed for want of authority, and the writ petition succeeded with ancillary relief relating to de-freezing of the bank accounts.

Ratio Decidendi: Proceedings initiated by an authority after the expiry of the empowering order are without jurisdiction, and all consequential actions founded on such unauthorised initiation are liable to be quashed.

Issues: (i) Whether the amendment of the prayer portion of the writ petition, to correct the date of the impugned adjudication order, should be allowed. (ii) Whether the impugned adjudication order could be sustained in law in view of the earlier proceedings initiated by the State GST Authority on the same allegations and against substantially the same suppliers.

Issue (i): Whether the amendment of the prayer portion of the writ petition, to correct the date of the impugned adjudication order, should be allowed.

Analysis: The incorrect mention of the date was found to be a bona fide error. The amendment was sought only to correct the date of the impugned order in the prayer portion, and no prejudice was shown that would justify insistence on procedural formalities or technical requirements.

Conclusion: The amendment application was allowed.

Issue (ii): Whether the impugned adjudication order could be sustained in law in view of the earlier proceedings initiated by the State GST Authority on the same allegations and against substantially the same suppliers.

Analysis: The Court relied on the law governing overlapping inquiries and parallel proceedings under the GST regime. It noted that where the same taxable liability, contravention, and suppliers are already the subject of proceedings by one authority, a subsequent show-cause notice or adjudication on the same subject matter cannot stand. The materials showed substantial overlap between the State proceedings and the Central adjudication, with common suppliers and common allegations. In the absence of proof that the prior State proceedings and orders had been furnished to the Central authority, the impugned order was nevertheless held unsustainable once the overlap was established.

Conclusion: The impugned adjudication order was set aside.

Final Conclusion: The writ petition succeeded, the challenged adjudication was quashed, and the connected applications were disposed of in consequence.

Ratio Decidendi: A subsequent GST proceeding cannot be sustained where it duplicates an earlier proceeding on the same subject matter and against the same liability, since overlapping jurisdiction must not result in parallel adjudication of the same contravention.

Issues: Whether the petitioner was entitled to opt out of the QRMP Scheme and be migrated to monthly filing of GSTR-1 and GSTR-3B through backend correction on the GST Common Portal.

Analysis: The petitioner had crossed the turnover threshold and sought to exit the QRMP Scheme for monthly filing from March 2026. The GST authorities also indicated that backend changes on the Common Portal could be made to facilitate migration to monthly filing, though they insisted that returns be filed with applicable late fee and interest, leaving refund claims to be pursued separately. In the facts and circumstances, the request for migration was found justified.

Conclusion: The petitioner was permitted to opt out of the QRMP Scheme and to file monthly returns in Forms GSTR-1 and GSTR-3B, with backend corrections directed to be carried out by the GSTN and the GST authorities.

Issues: Whether the appeal survives after the appellant company was ordered to be liquidated, and whether the absence of an application for continuance by the liquidator under the Tribunal procedure rules results in abatement.

Analysis: The appellant company was stated to have been ordered to be liquidated. No application for continuance of the proceedings by the official liquidator or other successor-in-interest was made within the framework of Rule 22 of the CESTAT (Procedure) Rules, 1982. In such circumstances, the appeal does not survive. The Tribunal also relied on the principle that, upon liquidation and in the absence of a proper application for continuance, the proceedings abate.

Conclusion: The appeal abated and could not be continued.

Final Conclusion: The miscellaneous application was disposed of and the appeal stood abated for want of continuation after liquidation.

Ratio Decidendi: Where a company in appeal is liquidated and no timely application for continuance is made by the liquidator or successor-in-interest under the applicable Tribunal procedure rules, the appeal abates.

Issues: (i) Whether the disputed services qualified as input services under Rule 2(l) of Cenvat Credit Rules, 2004. (ii) Whether the post 01.04.2011 exclusion clause applied to the services in question. (iii) Whether interest and penalty were sustainable.

Issue (i): Whether the disputed services qualified as input services under Rule 2(l) of Cenvat Credit Rules, 2004.

Analysis: For the period prior to 01.04.2011, the definition of input service had wide amplitude and covered services having nexus with business activity. Services such as manpower, insurance, cleaning, catering and repairs were found to be connected with the business operations and therefore eligible for credit.

Conclusion: Credit on the disputed services for the period prior to 01.04.2011 was admissible.

Issue (ii): Whether the post 01.04.2011 exclusion clause applied to the services in question.

Analysis: From 01.04.2011, the definition was amended to introduce specific exclusions, including construction services, works contract services and services used for construction of building or civil structures. Credit relating to civil works, structural works, construction works, painting and similar activities fell within the exclusion, while manpower, insurance, cleaning, pest control and repairs and maintenance not amounting to new construction remained eligible.

Conclusion: Credit attributable to construction and civil works was inadmissible after 01.04.2011, while credit on other eligible services remained admissible.

Issue (iii): Whether interest and penalty were sustainable.

Analysis: Interest was held payable only on the portion of credit finally found inadmissible. Penalty was not sustained because the dispute turned on interpretation of law and the credit had to be re-quantified after segregation of eligible and ineligible services.

Conclusion: Interest survived only to the extent of inadmissible credit and penalty was set aside.

Final Conclusion: The credit dispute was allowed only in part, the disallowance was confined to post-amendment construction-related services, and the matter required limited re-quantification by the adjudicating authority.

Issues: Whether the services rendered under the intra-group services agreement constituted fees for technical services under Article 13 of the India-UK Double Taxation Avoidance Agreement on the basis that technical knowledge, experience, skill, know-how or processes were made available to the Indian entity and an enduring benefit arose.

Analysis: The services were examined as routine commercial and administrative support within a group arrangement. It was found that the parent company retained ultimate control and supervision, including over marketing and scientific know-how, and that the Indian entity did not receive any transfer of technical skill or scientific know-how in the sense required by the treaty. Any incidental advantage or skill acquired by employees of the Indian entity during execution of instructions was held insufficient to satisfy the make available requirement. The conclusion that no technical knowledge or skill was imparted was treated as a factual finding, and no perversity in that finding was shown.

Conclusion: The make available condition was not satisfied and the receipts did not amount to fees for technical services; the appeal failed.

Ratio Decidendi: For treaty taxation of technical services, routine managerial or support services do not become fees for technical services unless they actually and specifically make available technical knowledge, experience, skill, know-how or processes to the recipient.

Outcome: Delay in filing the special leave petition was not condoned and the special leave petition was dismissed with costs.