Issues: Whether the land sold by the assessee was a capital asset liable to long term capital gains tax or was agricultural land outside the definition of capital asset under section 2(14)(iii)(b)(1) of the Income-tax Act, 1961.

Analysis: The Tribunal examined land revenue records and the location of the property, noting it was recorded as agricultural land and situated approximately 2-3 kilometres from the nearest municipality with population as per the cited census, placing it outside the non-agricultural limits specified in section 2(14)(iii)(b)(1) of the Income-tax Act, 1961. The Tribunal further observed that conversion or change of user effected by the purchaser several years after the date of sale does not alter the character of the land at the time of sale. The Tribunal relied on controlling judicial authority holding that sale to a non-agriculturist or subsequent conversion does not retrospectively convert agricultural land into a capital asset where no non-agricultural use or conversion had occurred prior to sale.

Conclusion: The sale proceeds do not attract long term capital gains; the land retained its character as agricultural land at the time of sale and is not a capital asset within section 2(14)(iii)(b)(1) of the Income-tax Act, 1961. The Revenue's appeal is dismissed and the deletion of the addition is upheld in favour of the assessee.

Issues: Whether the learned Single Judge erred in directing payment of salaries from amounts frozen under Section 17(1A) of the Prevention of Money Laundering Act, 2002 and in relegating the respondent to seek remedy before the Adjudicating Authority; and whether the appeal by the Authority should be allowed.

Analysis: The Court reviewed the scheme of the PMLA including the definitions of "proceeds of crime" and the statutory provisions governing provisional attachment, search, seizure and freezing of property (notably Sections 2(1)(u), 3, 5, 17, 20 and Section 8 procedure). The Apex Court's guidance that property can be regarded as "proceeds of crime" only if it is derived or obtained directly or indirectly as a result of criminal activity relating to a scheduled offence was applied. The Court noted that the Adjudicating Authority is the forum for adjudication of whether frozen property amounts to proceeds of crime and that the Adjudicating Authority has no power under Section 8 to grant interim directions for partial defreeze to make payments from frozen amounts. The Single Judge's order relegated the respondent to the statutory remedy before the Adjudicating Authority while directing limited payment of salaries; the High Court considered whether that exercise of judicial discretion was perverse in view of the statutory scheme and binding precedents and concluded it was not.

Conclusion: The appeal is dismissed and the exercise of discretion by the learned Single Judge in relegating the respondent to its statutory remedy and in the incidental direction regarding payment of salaries is upheld; the High Court's order stands.

Issues: Whether the petitioner may be permitted to prefer an appropriate statutory appeal before the Appellate Authority to challenge the final assessment orders dated 23-07-2024 and 08-08-2024 notwithstanding that the legality and validity of the Notifications extending time under Section 73(10) of the CGST Act, 2017 and RGST Act, 2017 are pending adjudication before this Court.

Analysis: The petitions sought substantive adjudication on the legality and validity of specified Central and State Notifications extending the time limit under Section 73(10) of the Central Goods and Services Tax Act, 2017 and the Rajasthan Goods and Services Tax Act, 2017. The High Court had not finally adjudicated the assessment challenges and had noted that related issues were pending consideration by this Court. The petitioner requested permission to prefer an appropriate statutory appeal against the final assessment orders; analogous relief had been granted in earlier similar matters by permitting assessees to file statutory appeals within a stipulated timeframe. Having regard to the pendency before this Court of the challenge to the Notifications, the Court limited its order to granting procedural relief to enable the petitioner to pursue the statutory appellate remedy in relation to the assessment orders, without prejudicing this Court's ultimate adjudication on the legality and validity of the Notifications.

Conclusion: The petitioner is permitted to prefer a statutory appeal before the Appellate Authority against the final assessment orders dated 23-07-2024 and 08-08-2024 within four weeks. The appellate authority's decision shall be subject to this Court's ultimate adjudication on the validity and legality of the Notifications.

Issues: Whether the deletion by the Tribunal and the Commissioner (Appeals) of the Assessing Officer's addition of Rs. 5,04,80,000 on account of alleged bogus purchases is sustainable; and whether any substantial question of law arises from the concurrent findings upholding deletion.

Analysis: The appeal concerns an addition made by the Assessing Officer on the basis of information from the Investigation Wing alleging that purchases from M/s. Keshav Impex were bogus accommodation entries. The Commissioner (Appeals) deleted the addition on the ground that the AO did not discharge the onus of disproving the transactions. The Tribunal independently examined the record and accepted that no adverse material was placed on record to substantiate reopening or to controvert documents produced by the assessee; the AO did not refer to or rely upon statements or cogent evidence to rebut the assessee's evidence; books of account were not rejected or recast; VAT payments and completion of sales tax assessment were noted; and no contrary evidence was produced before the High Court to disturb the concurrent findings.

Conclusion: The Tribunal's and the Commissioner (Appeals)'s deletion of the addition of Rs. 5,04,80,000 is upheld; the concurrent factual findings favour the assessee and no substantial question of law is shown to arise. The appeal is dismissed.

Ratio Decidendi: Where the Assessing Officer fails to produce adverse material or otherwise discharge the onus of disproving the genuineness of claimed transactions, and books of account are not rejected with no cogent contrary evidence, an addition based on alleged bogus accommodation entries cannot be sustained.

Issues: (i) Whether customs duty and consequential interest could be demanded on imported marble blocks used by EOUs where excise equal to customs was paid on DTA sales; (ii) Whether extended period of limitation could be invoked; (iii) Whether mandatory penalty under section 114A was properly imposed; (iv) Whether imported marble blocks were liable to confiscation under sections 111(d) and 111(o) and whether redemption fine under section 125 could be imposed.

Issue (i): Whether customs duty with consequential interest could be confirmed on imported marble blocks where EOUs cleared finished slabs to DTA after paying excise equal to customs under the proviso to Section 3 of the Central Excise Act, 1944 and pursuant to High Court stay orders.

Analysis: The proviso to Section 3 of the Central Excise Act, 1944 mandates that excise on goods produced in a 100% EOU and cleared to DTA shall be equal to the customs duties leviable on like imported goods; the appellants paid such excise as directed by the High Court stay permitting DTA sales. The DGFT notification restricting DTA sales was the subject of litigation and stayed by the High Court; during the stay period clearances were made on payment of full excise equal to customs duties. The resulting receipt of revenue as excise on finished slabs, rather than as customs on raw marble, negates any revenue loss. Precedent where excise on finished products discharged equivalent customs demand applies.

Conclusion: Demand of customs duty and consequential interest on the imported marble blocks is unsustainable and is set aside in favour of the assessee.

Issue (ii): Whether the extended period of limitation could be invoked to sustain demands in these cases.

Analysis: Invocation of extended limitation depends on elements such as suppression, collusion or wilful misstatement. Having concluded that the duty demand itself is unsustainable on merits because excise equal to customs was paid under lawful stay orders and there was no concealment of material facts, it is unnecessary to sustain extended limitation. The factual matrix shows relevant clearances and payments were on record and subject to judicial stay.

Conclusion: Extended period of limitation was not required to be invoked; no basis for sustaining demands on limitation grounds in favour of the assessee.

Issue (iii): Whether penalties under Section 114A of the Customs Act, 1962 were correctly imposed.

Analysis: Section 114A mandates penalty where duty or interest was not levied by reason of collusion or wilful misstatement or suppression. Given that the primary demand of customs duty was unsustainable and that clearances were made pursuant to High Court stay orders with payment of excise equal to customs, the statutory threshold of collusion, suppression or wilful misstatement is not established.

Conclusion: Penalties under Section 114A are not sustainable and are set aside in favour of the assessee.

Issue (iv): Whether the imported marble blocks were liable to confiscation under Sections 111(d) and 111(o) of the Customs Act, 1962 and whether redemption fines under Section 125 could be validly imposed.

Analysis: Section 111(d) concerns import contrary to prohibition; Section 111(o) concerns breach of conditions attached to exemption unless sanctioned by the proper officer. The appellants had authorisation from the Development Commissioner and acted under High Court stay permitting DTA clearances on payment of duty; the proper officer had cleared imports at entry assessment. Further, the imported marble blocks had been processed into slabs and therefore were not available for physical confiscation; Section 126 requires the adjudicating authority to take possession upon confiscation. Section 125 provides redemption fine as an option to the owner except where provisional release on bond creates an obligation. Absent a sanctionable breach or availability of goods for confiscation, confiscation and consequent redemption fine cannot be sustained.

Conclusion: Confiscation under Sections 111(d) and 111(o) cannot be sustained and redemption fines under Section 125 cannot be validly imposed; disposition is in favour of the assessee.

Final Conclusion: The appeals are allowed and the impugned orders confirming customs duty with interest, penalties under Section 114A and courses of confiscation/redemption fines are set aside; consequential reliefs follow for the appellants.

Ratio Decidendi: Where EOUs cleared finished goods to DTA pursuant to judicial stay and paid excise equal to the customs duty payable on like imported goods under the proviso to Section 3 of the Central Excise Act, 1944, a subsequent demand for customs duty, mandatory penalty under Section 114A, or confiscation under Sections 111(d)/111(o) is not sustainable absent sanctionable breach, suppression or availability of goods for confiscation.

Issues: (i) Whether the confirmation of provisional attachment of properties under the Prevention of Money Laundering Act, 2002 is legally sustainable in the hands of the appellant.

Analysis: The Appellate Tribunal considered whether the attached properties represented proceeds of crime or the value thereof such that attachment under the PMLA could be sustained. The Tribunal reviewed statutory provisions including the scope of attachment and confiscation under Section 5(1) and the procedure under Section 8(1) and the related burden on a person served with notice to disclose sources of acquisition. The Tribunal applied settled law that attachment may be effected even where the person in whose name the property is held is not an accused in the scheduled offence, provided the property is shown to be derived from proceeds of crime or represents its value. The Tribunal evaluated the evidence on record, including statements recorded under Section 50 of the PMLA and admissions regarding receipt and use of funds, account credits into the appellant's bank account, and repayments of loans from amounts traced to the scheme. On the civil standard of preponderance of probabilities applicable to confirmation of provisional attachment, the Tribunal found that the material before the Adjudicating Authority supported the finding that the properties were linked to proceeds of crime and that the appellant had not discharged the statutory onus to demonstrate legitimate sources of acquisition.

Conclusion: The confirmation of the provisional attachment of the properties is upheld and the appeal is dismissed (decision in favour of the respondent).

Issues: Whether the Appellate Authority was justified in conditioning grant of stay of demand on payment of 20% of the outstanding demand, having regard to the Tribunal's order holding that tax deduction was not required and earlier orders holding the assessee not to be in default.

Analysis: The Tribunal's order dated 21.11.2025 in the assessee's own case on the same assessment year records a factual finding that the assessee was not required to deduct tax at source; earlier orders dated 31.03.2025 in the assessee's own case record the assessee as not in default. These findings are material to the question whether payment should be directed as a condition for stay, particularly where the demand arises under a provision that operates as a penalty. The Appellate Authority's order conditioning stay on deposit of 20% did not address or apply the Tribunal's finding or the earlier non-default determinations and therefore failed to take into account facts and authorities directly bearing on the necessity of a deposit during pendency of the appeal.

Conclusion: The condition requiring payment of 20% of the outstanding demand as a prerequisite to stay is set aside; the stay application is allowed and the assessee is not required to pay any part of the demand during the pendency of the appeal.

Issues: Whether the seizure of imported industrial oil under Section 110 of the Customs Act, 1962 was liable to be quashed and the goods released on the basis of the test reports and the decision in Gastrade International; whether the samples could be tested in more than one laboratory and whether the goods were in fact restricted Automotive Diesel Fuel / High Speed Diesel or only freely importable industrial oil.

Analysis: The imported goods were declared as industrial oil, but the laboratory reports recorded that the sample was mainly composed of diesel fraction, was adulterated with lighter hydrocarbons, and was most akin to HFHSD. The Court treated the CRCL report and the MRPL report as collectively covering the relevant parameters and found that, unlike in Gastrade International, there was a clear and unambiguous scientific opinion on the character of the goods. The Court also held that testing in different laboratories was not a ground to reject the reports, particularly when the samples were duly collected and the testing was directed at the technical parameters relevant to classification. On that basis, the Court concluded that the goods were restricted and that their seizure was justified. The Court further noted that the petitioners had not established any basis to discard the test results and that environmental considerations supported strict scrutiny of the consignment.

Conclusion: The seizure was upheld and the challenge to the detention of the consignments failed; the goods were treated as restricted Automotive Diesel Fuel / HFHSD rather than freely importable industrial oil.

Final Conclusion: The writ petitions were not made out, since the combined laboratory evidence supported the revenue's classification of the consignments as restricted goods and justified the impugned seizure.

Ratio Decidendi: Where scientific test reports, read together, clearly establish that imported goods are most akin to a restricted commodity and the opinion is unambiguous on the decisive parameters, the seizure of the goods will not be quashed merely because the samples were examined in more than one laboratory or because the importer relies on a contrary classification.

Issues: (i) Whether the Special Leave Petition filed by the assessee is maintainable despite a gross delay of 369 days in filing; (ii) Whether there are grounds to interfere with the impugned High Court order on merits.

Issue (i): Maintainability of the Special Leave Petition in view of the unexplained delay of 369 days.

Analysis: The Court recorded that there was a gross delay of 369 days in filing the Special Leave Petition and that the delay had not been satisfactorily explained by the petitioner. The Court considered the question of condonation of delay and noted the absence of satisfactory justification for the delay.

Conclusion: The Special Leave Petition is dismissed on the ground of delay (in favour of the revenue).

Issue (ii): Whether interference with the impugned High Court order is warranted on merits.

Analysis: The Court examined the impugned order and found no good ground to interfere with the High Court's decision, concluding that interference on merits was not justified.

Conclusion: The Special Leave Petition is dismissed on merits (in favour of the revenue).

Final Conclusion: The Special Leave Petition is dismissed both on the ground of unexplained delay and for lack of merit; the petition is restored to file and dismissed accordingly, while any question of law is kept open.

Ratio Decidendi: An SLP may be dismissed where there is a gross unexplained delay justifying non-condonation and where there is no sufficient ground to interfere with the impugned High Court order on merits.

Outcome: Special Leave Petitions dismissed after the Court declined to interfere with the impugned High Court order.

Issues: (i) Whether the Principal Commissioner of Income Tax rightly exercised revisionary jurisdiction under section 263 of the Income-tax Act, 1961 to interfere with the Assessing Officer's acceptance of depreciation claimed on opening written down value of goodwill for A.Y. 2018-19; (ii) Whether the Principal Commissioner of Income Tax rightly exercised revisionary jurisdiction under section 263 of the Income-tax Act, 1961 to interfere with the Assessing Officer's allowance of actual warranty expenses where the assessee had itself disallowed the warranty provision.

Issue (i): Whether revision under section 263 could be sustained in respect of depreciation claimed on opening written down value of goodwill.

Analysis: Goodwill was created and depreciation on the goodwill was earlier accepted by revenue in the relevant earlier year; the assessee claimed depreciation on the opening written down value in the year under consideration supported by audited accounts and tax audit report; no impairment or inconsistency in books of account was shown for the year under consideration; if revenue had concerns about creation of goodwill, the appropriate course was reopening the assessment for the year in which goodwill was created rather than invoking section 263 for the later year; reliance on a factual distinction with the cited precedent where goodwill was impaired to nil was noted.

Conclusion: Revision under section 263 is not sustainable in respect of the depreciation claimed on goodwill; the Assessing Officer's order on this issue is not erroneous and prejudicial to the interests of revenue. (In favour of assessee)

Issue (ii): Whether revision under section 263 could be sustained in respect of warranty expenses where the assessee had itself added back the provision and claimed only actual expenses.

Analysis: The assessee had suo motu disallowed the warranty provision in the computation and claimed only the actual warranty expenses incurred during the year; the Assessing Officer accepted the computation; there was no material to show that the acceptance of actual warranty expense was erroneous or prejudicial to revenue; no further inquiry was shown to be necessary for the year under consideration.

Conclusion: Revision under section 263 is not sustainable in respect of warranty expenses; the Assessing Officer's order on this issue is not erroneous and prejudicial to the interests of revenue. (In favour of assessee)

Final Conclusion: The revisionary order passed by the Principal Commissioner of Income Tax under section 263 of the Income-tax Act, 1961 is quashed and the assessment order dated 30.06.2022 is restored, resulting in allowance of the assessee's appeal.

Ratio Decidendi: Section 263 cannot be invoked to revise an assessment unless the Assessing Officer's order is shown to be erroneous in a manner that is prejudicial to the interests of revenue; where the Assessing Officer has accepted claims supported by books of account and prior acceptance in earlier years or where the assessee has itself adjusted provisions in the computation, the Commissioner's revisionary power is not properly exercisable.

Issues: (i) Whether the appellant's investment in Bharathi Cements and the subsequent sale proceeds could be treated as proceeds of crime. (ii) Whether profits attributed to the Kadapa limestone mining activity could be treated as proceeds of crime and whether the attachment needed to be confined to the revised quantification. (iii) Whether sufficient reason to believe existed for provisional attachment under the PMLA. (iv) Whether substitution of the attached properties by alternate security could be permitted.

Issue (i): Whether the appellant's investment in Bharathi Cements and the subsequent sale proceeds could be treated as proceeds of crime.

Analysis: The investment in shares was treated as a genuine commercial transaction and the later sale was made to a third-party foreign company that was not shown to be involved in any criminal activity. The share purchase was an outgo by the appellant, not property derived or obtained from criminal activity, and there was no material to show that the consideration used for the purchase came from tainted sources. The reasoning adopted in the earlier connected matter was held applicable.

Conclusion: The investment and the share-sale proceeds could not be treated as proceeds of crime in the hands of the appellant.

Issue (ii): Whether profits attributed to the Kadapa limestone mining activity could be treated as proceeds of crime and whether the attachment needed to be confined to the revised quantification.

Analysis: The sequence of mining approvals and the transfer of the lease were viewed as showing a coordinated and collusive arrangement at the stage of provisional attachment. On that basis, attachment of equivalent value was justified under the PMLA. At the same time, the revised computation reducing the mining component after deduction of extraction costs was accepted, and the share-sale component was excluded from the quantified proceeds of crime. The remaining mining-linked amount was therefore much lower than the figure adopted in the provisional attachment order.

Conclusion: The mining-linked profits were liable to be treated as proceeds of crime at this stage, but the quantified amount stood reduced to the revised figure accepted in the order.

Issue (iii): Whether sufficient reason to believe existed for provisional attachment under the PMLA.

Analysis: The recorded reasons showed material suggesting generation and dissipation of proceeds of crime and the need to attach equivalent value property because the direct proceeds were stated to have been intermingled and were no longer traceable. The standard at the attachment stage was held to require reason to believe, not conclusive proof.

Conclusion: Sufficient reason to believe existed for invoking provisional attachment.

Issue (iv): Whether substitution of the attached properties by alternate security could be permitted.

Analysis: The Tribunal held that the PMLA and the rules framed thereunder do not confer an express power on the Appellate Tribunal to order substitution of attached property. However, it noted that the Enforcement Directorate was not averse to a substitution arrangement and observed that such a course would not be obstructed by the order if otherwise agreed and secured.

Conclusion: No independent power to direct substitution was recognised, though the order did not stand in the way of an agreed substitution by the Directorate.

Final Conclusion: The appeal was disposed of with partial relief, the share-investment component being excluded from proceeds of crime, the mining-linked attachment substantially scaled down, and the provisional attachment otherwise sustained to the extent justified under the PMLA.

Ratio Decidendi: Property cannot be treated as proceeds of crime unless it bears a legally supportable causal nexus with the scheduled offence, while at the provisional attachment stage equivalent value attachment may be sustained on recorded reason to believe where the direct proceeds are no longer traceable.

Issues: (i) Whether the services rendered by the appellant are classifiable as 'business auxiliary service' or as 'air travel agent service'; (ii) Whether the demand of service tax under the head 'travel agent service' for charges such as visa and passport processing is sustainable; (iii) Whether the demands relating to short payment and excess collection under 'air travel agent service' are correctly determined and need further verification; (iv) Whether the invocation of extended period of limitation and imposition of penalty is sustainable.

Issue (i): Whether the services rendered by the appellant are classifiable as 'business auxiliary service' or as 'air travel agent service'.

Analysis: The definition of 'business auxiliary service' under Section 65(19) of the Finance Act, 1994 lists promotional, marketing, customer care, procurement, production/processing, provision of service on behalf of client and incidental/auxiliary services, including commission agent activities. The definition of 'air travel agent' under Section 65(4) of the Finance Act, 1994 covers services connected with booking of passage for travel by air. The activities of the appellant consist of providing services to end users as IATA agents, with commission built into flight tickets and service tax charged on tickets. The services do not involve promotion or marketing of the IATA agents/airlines, nor do they fall within the seven categories specified for business auxiliary services.

Conclusion: The services rendered by the appellant are not 'business auxiliary service' and are classifiable as 'air travel agent service'. The demand confirmed under 'business auxiliary service' is set aside in favour of the appellant.

Issue (ii): Whether the demand of service tax under the heading 'travel agent service' for passport, visa processing, insurance and similar charges is sustainable.

Analysis: The charges such as passport fees, visa processing, NOC charges and insurance collected from customers do not fall within the definition of service connected with booking of passage for travel and are not covered within the four corners of the definition of travel agent service as pleaded by the department.

Conclusion: The demand of service tax under the heading 'travel agent service' to the extent confirmed is not sustainable and is set aside in favour of the appellant.

Issue (iii): Whether the demands relating to short payment (Rs. 2,44,774) and excess collection (Rs. 9,33,670) under 'air travel agent service' are correctly determined and require verification.

Analysis: The appellant has charged and deposited service tax on air travel agent services and contends that amounts alleged as excess collection were deposited with the government. The record shows both a demand for short payment and a separate demand for excess collection under the same category. The correctness of the appellant's claim of deposit and the computation requires factual verification by the adjudicating authority.

Conclusion: The issues of short payment and excess collection under 'air travel agent service' are remanded to the adjudicating authority for verification of the appellant's claim that the collected amounts were deposited; no final finding on these amounts is made in this order.

Issue (iv): Whether invocation of the extended period of limitation and imposition of penalty is sustainable.

Analysis: The classification of the service itself was in dispute and the details for raising demands were derived from the appellant's books of account. There is no satisfactory basis for suppression with intent to evade tax where classification is contested and source material was available to the department.

Conclusion: Invocation of the extended period of limitation and imposition of penalty are not sustainable; demands on these grounds are set aside in favour of the appellant.

Final Conclusion: The appeal is partly allowed - demands confirmed under 'business auxiliary service' and 'travel agent service' are set aside, demands relating to 'air travel agent service' for short payment and excess collection are remanded for verification, and interest and penalty demands are set aside.

Ratio Decidendi: Where the factual activities of a provider fall within the statutory definition of 'air travel agent service' under Section 65(4) of the Finance Act, 1994 and do not meet the specific categories listed under Section 65(19) of the Finance Act, 1994 for 'business auxiliary service', the classification must be as 'air travel agent service' and demands premised on classification as 'business auxiliary service' cannot be sustained.

Issues: Whether the appellant was entitled to anticipatory bail in the facts and circumstances of the case.

Analysis: The appellant faced apprehension of arrest in connection with offences under the Indian Penal Code, 1860 and the Goods and Services Tax Act, 2017. The record showed that the appellant had appeared before the Investigating Officer and cooperated with the investigation. The co-accused had already been granted bail at different stages. The Court also noted that the earlier bail applications had been withdrawn and that the question relating to forged documents was a matter for trial, and no opinion on merits was expressed so as to avoid prejudice.

Conclusion: The appellant was held entitled to anticipatory bail and was ordered to be enlarged on such terms and conditions as the Investigating Officer deemed fit.

Ratio Decidendi: Anticipatory bail may be granted where the accused has cooperated with the investigation, similar co-accused have been enlarged on bail, and the merits of disputed facts are best left to trial without causing prejudice.

Issues: Whether the petitioner should be permitted to prefer an appropriate statutory appeal before the appellate authority against the final order of assessment and, if so, the period within which the appeal may be filed and the manner in which the appellate authority should decide the appeal.

Analysis: The High Court directed that a statutory appeal may be filed and considered without reference to limitation if filed within a specified period and that the appellate authority should consider all grounds and documents and afford an opportunity of personal hearing before passing a reasoned order on merits. The present order grants the petitioner additional time to file an appeal against the final order of assessment and clarifies that any appeal so filed shall be entertained and decided on merits. The appellate authority is directed to take up and decide the appeal expeditiously, to consider all contentions and relevant documents (including specific documentary requests such as Fastag details), and not to be influenced by earlier observations made in the writ proceedings.

Conclusion: The petitioner is permitted to prefer an appropriate statutory appeal within six weeks from the date of this order; any such appeal shall be heard expeditiously by the appellate authority and decided on its own merits after affording opportunity of personal hearing and considering all grounds and documents. The Special Leave Petition stands disposed of.

Outcome: Delay condoned. No interference was called for in the impugned order. The special leave petition was dismissed and pending applications were disposed of.

Issues: (i) Whether donations made to the Prime Minister's Relief Fund and the Maharashtra Chief Minister's Relief Fund, though incurred in discharge of corporate social responsibility, were eligible for deduction under section 80G; (ii) Whether the assessment issue relating to computation of income under the intimation process required restoration for verification.

Issue (i): Whether donations made to the Prime Minister's Relief Fund and the Maharashtra Chief Minister's Relief Fund, though incurred in discharge of corporate social responsibility, were eligible for deduction under section 80G.

Analysis: The statutory scheme of section 80G permits deduction for specified donations and contains express prohibitions only where the Legislature has so provided. The prohibition inserted for certain CSR-linked contributions to Swachh Bharat Kosh and Clean Ganga Fund showed that CSR-linked donations are not universally barred under section 80G. Explanation 2 to section 37(1) of the Income-tax Act disentitles CSR expenditure as business expenditure, but does not create a wider embargo against deduction under other provisions such as section 80G. The contribution was treated as a donation to approved funds, and the absence of any express bar under section 80G for these funds was .

Conclusion: The claim for deduction under section 80G was allowed in favour of the assessee.

Issue (ii): Whether the assessment issue relating to computation of income under the intimation process required restoration for verification.

Analysis: The grievance was confined to verification of the return income and the computation reflected in the intimation. Since the limited prayer was for factual verification and the Revenue raised no objection, the matter was restored to the jurisdictional Assessing Officer for examination in accordance with law.

Conclusion: The issue was remitted for verification and consequential fresh decision, in favour of the assessee for statistical purposes.

Final Conclusion: The appeal succeeded on the principal deduction issue and the remaining income-computation issue was sent back for verification, leaving the assessee with only partial substantive relief.

Ratio Decidendi: A donation made in discharge of CSR obligation remains eligible for deduction under section 80G unless the statute expressly excludes that category of contribution.

Issues: (i) Whether the order dated 30.09.2025 passed under Section 74 of the CGST Act confirming demand for wrongful availment of input tax credit is amenable to writ jurisdiction; (ii) Whether pre-deposit mandated for preferring the statutory appeal can be waived and the petitioner permitted to file appeal without the mandatory pre-deposit.

Issue (i): Whether the impugned demand order under Section 74 (wrongful availment of input tax credit) is liable to be quashed in writ proceedings.

Analysis: The impugned order records reasons including findings of misstatement and suppression connected with submission of fake invoices and absence of e-way bills. In exercise of certiorari jurisdiction, adequacy and sufficiency of reasons are not to be re-examined unless reasons are perverse or tainted by mala fides. No such perversity or mala fide is shown on the record.

Conclusion: The challenge to the order dated 30.09.2025 under Section 74 is rejected; the writ does not succeed on merits.

Issue (ii): Whether the statutory pre-deposit for filing the appeal may be dispensed with and the appeal be entertained without the mandatory pre-deposit.

Analysis: The requirement of pre-deposit is statutory. No extraordinary circumstance has been demonstrated that would justify dispensing with the statutory pre-deposit obligation or directing reduced deposit/security. The petitioner's interim offer to furnish security does not suffice to override the statutory requirement in the absence of exceptional justification.

Conclusion: Prayer to waive or dispense with the mandatory pre-deposit is refused; the petitioner is not permitted to file the statutory appeal without complying with the pre-deposit requirement.

Final Conclusion: The writ petition is dismissed; the impugned tax demand remains subject to the statutory appellate remedy which requires compliance with the pre-deposit condition.

Ratio Decidendi: A statutory pre-deposit requirement for preferring an appeal under the CGST framework cannot be waived in writ jurisdiction absent demonstration of extraordinary circumstances, and certiorari will not be granted to reappraise reasoned tax orders unless shown to be perverse or mala fide.