Issues: (i) Whether the special leave petition became infructuous on account of the petitioner's acquittal by the Trial Court; (ii) whether prolonged custody and delay in commencement or conclusion of trial justified bail; (iii) whether bail should be granted subject to conditions in view of the volume of prosecution evidence and anticipated delay.

Issue (i): Whether the special leave petition became infructuous on account of the petitioner's acquittal by the Trial Court.

Analysis: The petitioner's acquittal by the Trial Court eliminated the live controversy in the matter. Once the underlying criminal case no longer survived against the petitioner, no adjudication on merits remained necessary.

Conclusion: The petition became infructuous and stood disposed of as such.

Issue (ii): Whether prolonged custody and delay in commencement or conclusion of trial justified bail.

Analysis: The petitioner had remained in custody since October 2022, the trial had not formally commenced, the charge-framing stage was still continuing, and the prosecution case involved examination of a very large number of witnesses. The delay was treated as sufficiently inordinate to justify consideration of release on bail, though the matter was kept pending for further hearing to explore a special-court arrangement.

Conclusion: The prayer was not finally decided on that date and the matter was posted for further hearing.

Issue (iii): Whether bail should be granted subject to conditions in view of the volume of prosecution evidence and anticipated delay.

Analysis: The petitioner had spent a long period in custody, had no criminal antecedents, and the trial was likely to take a considerable time. The Court considered that release on bail could be ordered if suitable safeguards were imposed to ensure attendance, prevent delay, and avoid contact with witnesses or associates.

Conclusion: Bail was granted subject to stringent conditions and liberty to seek cancellation upon breach.

Final Conclusion: The common order disposed of one petition as infructuous, kept one matter pending for further hearing, and granted conditional bail in the other matter.

Issues: Whether the addition of Rs. 5,00,000 as unexplained investment on account of an alleged cash payment for purchase of shops was sustainable.

Analysis: The addition was made on the basis of material found during search and an Excel sheet said to record cash payments, together with statements of persons associated with the searched group. However, the assessee denied any cash payment during the relevant assessment year and relied upon the registered purchase documents and a confirmation letter from the seller stating that no cash was received from the assessee and that the shops were sold in the subsequent year through banking channels. No independent corroborative evidence was brought on record to substantiate the alleged cash transaction. In these circumstances, the presumption drawn by the Assessing Officer was found to be unsupported by reliable material.

Conclusion: The addition under section 69 was unsustainable and was deleted; the issue was decided in favour of the assessee.

Ratio Decidendi: An addition for unexplained investment cannot rest solely on uncorroborated third-party material or presumptive inference when the assessee's denial is supported by documentary evidence and the revenue fails to establish the alleged cash payment with independent proof.

Issues: (i) Whether interest income earned from investments/deposits with co-operative banks qualified for deduction under section 80P(2)(d) of the Income-tax Act, 1961. (ii) Whether disallowance of employees' provident fund contribution under section 36(1)(va) increased the business profits so as to permit further deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961.

Issue (i): Whether interest income earned from investments/deposits with co-operative banks qualified for deduction under section 80P(2)(d) of the Income-tax Act, 1961.

Analysis: The Revenue challenged the allowance of deduction on interest received from co-operative banks. The Tribunal followed the line of coordinate bench decisions and the Supreme Court's approval of the principle that a primary credit co-operative society is entitled to the benefit of section 80P(2), and that the character of a co-operative bank does not, by itself, justify denial of the deduction where the recipient is a co-operative society investing its funds with co-operative banks. The Tribunal held that the CIT(A) had correctly allowed deduction on interest earned from co-operative banks.

Conclusion: The issue was decided against the Revenue and in favour of the assessee.

Issue (ii): Whether disallowance of employees' provident fund contribution under section 36(1)(va) increased the business profits so as to permit further deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961.

Analysis: The Tribunal noted that the disallowance under section 36(1)(va) had the effect of enhancing the assessee's business profits. Relying on CBDT Circular No. 37/2016 dated 02.11.2016, it held that where a disallowance related to the eligible business increases the profits of that business, the corresponding Chapter VI-A deduction is admissible on the enhanced profits. On that basis, the assessee was entitled to further deduction under section 80P(2)(a)(i) on the amount disallowed under section 36(1)(va).

Conclusion: The issue was decided in favour of the assessee and against the Revenue.

Final Conclusion: The Revenue's challenge to the deduction on co-operative bank interest failed, and the assessee succeeded in obtaining further deduction on the enhanced profits arising from the provident fund disallowance, leaving the assessee partly successful overall.

Ratio Decidendi: A primary credit co-operative society is entitled to deduction on qualifying income from co-operative bank investments under section 80P, and disallowances that merely enhance eligible business profits can support deduction under Chapter VI-A on the enhanced amount.

Issues: Whether an addition under section 68 of the Income-tax Act, 1961 could be sustained where the scrutiny was limited to examination of share premium under section 56(2)(viib) of the Income-tax Act, 1961 and no approval was shown for enlarging the scope of scrutiny.

Analysis: The scrutiny was initiated only for verification of share premium and the applicability of section 56(2)(viib) of the Income-tax Act, 1961. The assessee furnished documents relating to the subscribers, including bank statements, ledger confirmations, PAN details and valuation material, to establish identity, creditworthiness and genuineness. The revenue authorities did not place on record any material showing that the Assessing Officer had obtained the requisite approval for converting the limited scrutiny into a wider enquiry so as to invoke section 68 of the Income-tax Act, 1961. In the absence of such approval, the addition made beyond the limited scrutiny parameters was held to be legally unsustainable.

Conclusion: The addition under section 68 of the Income-tax Act, 1961 was deleted and the assessment was quashed on the legal issue, resulting in relief to the assessee.

Issues: (i) Whether additions under section 153A for completed assessment years were sustainable in the absence of incriminating material found during the search on the assessee and when the material relied upon was sourced from third-party searches without resort to section 153C; (ii) Whether the additions under section 69 and section 56 on account of alleged cash loans and notional interest were sustainable; (iii) Whether the addition under section 69A for jewellery in Assessment Year 2018-19 was sustainable.

Issue (i): Whether additions under section 153A for completed assessment years were sustainable in the absence of incriminating material found during the search on the assessee and when the material relied upon was sourced from third-party searches without resort to section 153C.

Analysis: For completed or unabated assessments, jurisdiction under section 153A is confined by the requirement that incriminating material must be found during the search conducted on the assessee. Material seized from a third party cannot be treated as incriminating material in the assessee's hands unless the statutory route under section 153C is followed. A statement recorded under section 132(4), by itself and without corroboration, does not constitute sufficient incriminating material. The record disclosed no document, paper, ledger, or asset seized from the assessee evidencing the alleged cash loans or interest, while the material relied upon belonged to searches conducted in other cases.

Conclusion: The jurisdictional basis for the section 153A additions in respect of the completed years failed, and the additions could not be sustained.

Issue (ii): Whether the additions under section 69 and section 56 on account of alleged cash loans and notional interest were sustainable.

Analysis: Section 69 requires proof that the assessee actually made the investment and failed to explain its nature and source. Here, the alleged cash loans rested on third-party loose papers, ledgers, and uncorroborated statements, none of which were seized from the assessee. The statements recorded during search were later retracted, remained uncontroverted, and were not supported by independent enquiry, tracing of cash flow, or any evidence of lending capacity. The notional interest addition was wholly derivative and depended on the existence of the principal loan transaction, which itself was not proved. Tax cannot be levied on conjectural or hypothetical income.

Conclusion: The additions under sections 69 and 56 were unsustainable and were directed to be deleted.

Issue (iii): Whether the addition under section 69A for jewellery in Assessment Year 2018-19 was sustainable.

Analysis: Section 69A requires the Revenue to establish ownership of the jewellery and to show that the assessee's explanation is unsatisfactory. The assessee explained that the jewellery belonged to family members and represented streedhan, gifts, and purchases from explained sources, and supporting material was filed. The addition was made without item-wise examination or a cogent basis for rejecting the explanation. In the absence of a finding that the assessee was the exclusive owner, the invocation of section 69A was not justified.

Conclusion: The jewellery addition under section 69A was unsustainable and was directed to be deleted.

Final Conclusion: All additions under sections 69, 56, and 69A for the years under appeal were deleted, and the assessee succeeded on the jurisdictional as well as merits-based challenges.

Ratio Decidendi: In completed assessments under section 153A, additions can be made only on the basis of incriminating material found during the search on the assessee, and third-party material or an uncorroborated statement cannot substitute for that jurisdictional requirement.

Issues: Whether the notice issued under section 148 of the Income-tax Act, 1961, after the expiry of three years from the end of the relevant assessment year, was invalid for want of approval from the proper authority under section 151 of the Income-tax Act, 1961.

Analysis: The assessment year involved was 2017-18 and the notice under section 148 was issued beyond three years from the end of that year. In such a case, the approval required for reopening had to be obtained from the authority prescribed by section 151 for the extended time period. Since approval was taken only from the Principal Commissioner and not from the Principal Chief Commissioner, the reopening did not satisfy the statutory requirement. Following the binding jurisdictional precedent, the defect went to the root of jurisdiction and vitiated the reassessment proceedings.

Conclusion: The notice under section 148 was invalid and liable to be quashed, and the assessee succeeded on the jurisdictional challenge.

Issues: (i) Whether notice should be issued on the application for condonation of delay; (ii) Whether notice/formal service on the respondent may be accepted/waived.

Issue (i): Whether notice should be issued on the application for condonation of delay.

Analysis: Notice was directed to be issued on the delay condonation application and on the special leave petition, thereby putting the application and petition to be heard on merits following service.

Conclusion: Notice is issued on the application for condonation of delay and on the special leave petition.

Issue (ii): Whether notice/formal service on the respondent may be accepted/waived.

Analysis: The respondent's advocate-on-record accepted notice and formally waived service of formal notice.

Conclusion: Service of formal notice is accepted on behalf of the respondent and formal service is waived.

Final Conclusion: The proceedings are directed to proceed with notice issued on the delay condonation application and the special leave petition, and with service accepted and waived for the respondent.

Issues: Whether the long-term capital gains claimed under section 10(38) of the Income-tax Act, 1961 in respect of sale of listed shares (scrip SRK) are genuine or are to be treated as bogus/prearranged transactions such that additions under sections 68 and 69C are sustainable.

Analysis: The Tribunal examined the documentary record submitted by the assessee, including share certificates/contract notes, demat account statements, evidence of sale through a registered stockbroker, receipt of sale proceeds through banking channels and levy of securities transaction tax. The Tribunal noted that no direct, cogent or specific evidence was produced by the revenue to rebut these records or to show that the transactions were fabricated or that the assessee participated in price rigging. The Tribunal also considered that transactions in the identical scrip and the same assessment year were earlier examined by a Coordinate Bench which on facts held the transactions genuine and directed deletion of additions under sections 68 and 69C. Given identical facts and absence of independent inquiry or contrary evidence by revenue, the Tribunal followed the Coordinate Bench decision and accepted the documentary evidence as establishing genuineness of the LTCG claim.

Conclusion: The addition of the long-term capital gains and the alleged commission under sections 68 and 69C is deleted and the appeal is allowed in favour of the assessee.

Issues: (i) Whether the Assessing Officer can make an estimated addition of commission income by selectively accepting books of account and simultaneously estimating income without rejecting the books of account under Section 145(3) and without framing assessment under Section 144 of the Income-tax Act, 1961.

Analysis: The Court examined whether estimation of income by the Assessing Officer is permissible in the absence of a recorded rejection of the assessee's books of account under Section 145(3) and without proceeding to make a best judgment assessment under Section 144 of the Income-tax Act, 1961. The Court relied on settled precedents which establish that the power to estimate income and make a best judgment assessment arises only after the Assessing Officer is satisfied that the books of account are incorrect, incomplete or unreliable and has formally rejected them under Section 145(3); only thereafter can assessment be framed under Section 144. The judgments cited emphasize that partial acceptance of entries while rejecting others without rejecting the books as a whole results in arbitrary and unsustainable computation, and that estimation substituted for computation under Section 29 must follow the statutory safeguards in Sections 145(3) and 144. Applying these principles to the facts, the Court found that the Assessing Officer had accepted the purchases and sales in the books yet made an additional estimated commission income without rejecting the books or framing assessment under Section 144, rendering the addition legally impermissible.

Conclusion: The addition of estimated commission income made without rejecting the books of account under Section 145(3) and without framing assessment under Section 144 of the Income-tax Act, 1961 is unsustainable; the appeals are allowed and the impugned additions are directed to be deleted.

Issues: (i) Whether absolute confiscation could be ordered after the goods had been redeemed on payment of redemption fine; (ii) Whether enhancement of the penalties was sustainable.

Issue (i): Whether absolute confiscation could be ordered after the goods had been redeemed on payment of redemption fine.

Analysis: The finding on the merits of confiscability had attained finality because it was not challenged before the lower appellate authority. The goods had, however, already been redeemed upon payment of redemption fine and were no longer available. An order of absolute confiscation in respect of such unavailable goods was non est in law.

Conclusion: The direction for absolute confiscation was unsustainable and was set aside in favour of the assessee.

Issue (ii): Whether enhancement of the penalties was sustainable.

Analysis: The penalties originally imposed were proportionate to the gravity of the offence. The market value and consequent profit margin had not been ascertained so as to justify enhancement.

Conclusion: The enhanced penalties were unsustainable and were set aside in favour of the assessee.

Final Conclusion: The original adjudication permitting redemption and imposing the original penalties remained sustainable.

Ratio Decidendi: Absolute confiscation cannot validly be ordered where goods have already been redeemed and are unavailable, and enhancement of penalty requires a demonstrated basis proportionate to the offence.

Issues: (i) Whether CSR expenditure paid to institutions eligible under section 80G qualifies for deduction under that provision; (ii) Whether, in computing the written down value of a continuing block of building assets, actual sale consideration may be replaced with stamp-duty value under section 50C.

Issue (i): Whether CSR expenditure paid to institutions eligible under section 80G qualifies for deduction under that provision.

Analysis: Explanation 2 to section 37(1) excludes CSR expenditure from business-expenditure deduction, but section 80G contains no corresponding exclusion for CSR payments. The statutory restriction on deduction under section 80G applies to specified funds and does not exclude otherwise qualifying CSR donations. Where the donee institutions satisfy the conditions prescribed by section 80G, the mandatory character of CSR spending does not by itself disentitle the donor from deduction under that provision.

Conclusion: Deduction under section 80G for the qualifying CSR donations is allowable in favour of the assessee.

Issue (ii): Whether, in computing the written down value of a continuing block of building assets, actual sale consideration may be replaced with stamp-duty value under section 50C.

Analysis: Section 43(6)(c) requires reduction of the moneys payable, namely the price for which the asset was sold, from the block's written down value. The deeming fiction in section 50C is confined to computation of capital gains and cannot be extended to depreciation computation where the block continues and section 50 does not result in capital gains. The statute creates no corresponding fiction for substituting stamp-duty value while determining written down value of a block of assets.

Conclusion: Stamp-duty value under section 50C cannot replace actual sale consideration for reducing the written down value of the continuing block; the adjustment is deleted in favour of the assessee.

Final Conclusion: The assessee is entitled to the claimed section 80G deduction and to computation of the building block's written down value after reduction of actual, rather than deemed, sale consideration.

Ratio Decidendi: A statutory deeming fiction for stamp-duty valuation in capital-gains computation cannot be extended to depreciation and written-down-value computation absent an express legislative mandate; CSR payments otherwise meeting section 80G conditions remain deductible thereunder despite exclusion from business-expenditure deduction.

Issues: Whether the Tribunal could direct refund of tax recovered during pendency of a rectification application where the rectification order established that no tax demand survived.

Analysis: The rectification order granted the claimed tax deducted at source credit and computed a refund after accounting for the amount already recovered. Excluding that recovery, a refund still remained payable, demonstrating that the original demand had been extinguished and that the recovery resulted in duplicate collection. The Tribunal's powers over the subject matter of the pending appeal extend, in exceptional circumstances, to directing refund of an unlawful recovery so that the statutory appellate process is not frustrated by arbitrary revenue action.

Conclusion: The recovery constituted double recovery of tax; the Assessing Officer was directed to refund Rs. 25,40,43,714 to the assessee.

Ratio Decidendi: Where rectification establishes that no demand is payable, the Tribunal may exercise its inherent appellate powers to order refund of tax unlawfully recovered during pendency of the rectification proceedings.

Issues: Whether interest earned on statutory deposits placed with co-operative banks is business income eligible for deduction under section 80P(2)(a)(i).

Analysis: The deposits were made pursuant to the mandatory investment requirements under the Karnataka Souharda Sahakari Act, 1997. Interest arising from such compulsory deposits was attributable to the assessee's business of providing credit facilities to its members. The governing Supreme Court and jurisdictional High Court decisions treated interest on compulsory statutory investments as eligible business income, and the contrary treatment as income from other sources was inconsistent with those principles.

Conclusion: Interest earned from statutory deposits with co-operative banks is eligible for deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961, in favour of the assessee.

Issues: Whether rejection of the applications for registration under section 12AB and approval under section 80G, owing to non-furnishing of material for verification of the genuineness of activities, warranted restoration for fresh adjudication.

Analysis: The earlier remand required fresh examination of the applications and did not mandate grant of registration merely upon self-attested copies already on record. The applicant did not supply the information and documents sought through successive notices for verifying its educational activities, approvals, accounts, staff payments, fee structure and donations; hence, the inability to ascertain the genuineness of its activities was justified. However, the non-compliance proceeded on the mistaken belief that no further documents were required after the prior remand. Self-attested or self-certified copies of relevant material could be furnished for verification.

Conclusion: The applications are restored for fresh decision after affording the applicant a further opportunity to submit relevant self-attested or self-certified documents.

Issues: (i) Whether export incentive and miscellaneous expenses were to be treated as operating items for transfer pricing margin computation and whether the margins of the assessee and comparables were to be recomputed under Rule 10CA of the Income-tax Rules, 1962; (ii) Whether the rejection and inclusion of comparables on the basis of the related party transactions filter and functional comparability required reconsideration; (iii) Whether notional interest on overdue receivables from associated enterprises was warranted.

Issue (i): Whether export incentive and miscellaneous expenses were to be treated as operating items for transfer pricing margin computation and whether the margins of the assessee and comparables were to be recomputed under Rule 10CA of the Income-tax Rules, 1962.

Analysis: The treatment of export incentive and miscellaneous expenses was held to follow the Tribunal's earlier view that export incentive forms part of operating income and miscellaneous expenses constitute operating expenses, both for the assessee and for the comparables wherever relevant data is available. The margin working was also directed to be considered in terms of Rule 10CA, and the transfer pricing margin of the comparables was required to be redetermined on that basis.

Conclusion: The issue was decided in favour of the assessee, with directions to recompute the margins accordingly.

Issue (ii): Whether the rejection and inclusion of comparables on the basis of the related party transactions filter and functional comparability required reconsideration.

Analysis: The basis of computation of the 25% related party transactions filter was not shown for the exclusion of the disputed comparables, and one newly included comparable was said to be functionally dissimilar. The matter was therefore required to be revisited by the Transfer Pricing Officer after furnishing the basis of computation and reconsidering functional similarity in the light of the assessee's objections. The margin of one comparable was also required to be recomputed after treating miscellaneous expenses as operating in nature.

Conclusion: The issue was partly decided in favour of the assessee and remitted for reconsideration.

Issue (iii): Whether notional interest on overdue receivables from associated enterprises was warranted.

Analysis: The adjustment on account of overdue receivables was held to be covered by the Tribunal's earlier ruling that, in the case of a debt-free assessee which does not charge interest from non-associated enterprises as well, no separate transfer pricing adjustment for notional interest on overdue receivables is warranted.

Conclusion: The issue was decided in favour of the assessee and the adjustment was deleted.

Final Conclusion: The transfer pricing adjustments were sustained only to the limited extent requiring reconsideration and recomputation on certain comparables, while the notional interest adjustment was deleted, resulting in a partial success for the assessee.

Ratio Decidendi: For transfer pricing under TNMM, export incentive is operating income, miscellaneous expenses are operating expenses where relevant data exists, and notional interest on overdue receivables is not separately warranted for a debt-free assessee that does not charge such interest from non-associated enterprises.

Issues: Whether licence fee or royalty paid for transfer of manufacturing rights and technology in relation to aircraft engines was taxable as Intellectual Property Rights Service under the Finance Act, 1994.

Analysis: The Tribunal held that the dispute was already settled in the appellant's own case. It noted that, for taxability under the relevant service category, the intellectual property had to be one recognised under Indian law and capable of registration or protection in India. The transferred technology and manufacturing rights were treated as confidential know-how and undisclosed information, not as a registered intellectual property right exigible to service tax. The Tribunal therefore found no basis to sustain the demand, interest, or the penalties imposed under the impugned orders.

Conclusion: The royalty and licence fee were not taxable as Intellectual Property Rights Service, and the demand and penalties could not be sustained. The issue was decided in favour of the assessee.

Issues: Whether the transfer pricing adjustment on interest-free loan transactions was sustainable when the assessee had not commenced business and had no taxable income during the year.

Analysis: The assessee had not commenced business and had capitalised all expenditure to capital work-in-progress, so no business profit arose during the year. On these facts, the premise of profit shifting to associated enterprises did not survive. The adjustment was sought on interest-free lending and benchmarking of related-party financing, but the foundational requirement of taxable income or distributable profit was absent. The reasoning also recognised that the concessional regime under section 115BAB has relevance only where income exists for computation, and in the absence of income there was no basis to sustain an adjustment of this nature. Following the coordinate bench decision in the group case on materially similar facts, the transfer pricing addition was held unsustainable.

Conclusion: The transfer pricing adjustment was deleted and the issue was decided in favour of the assessee.

Final Conclusion: The appeal was allowed and the impugned addition did not survive.

Ratio Decidendi: Where a company has not commenced business, has incurred no taxable income, and has capitalised expenditure to work-in-progress, a transfer pricing adjustment premised on profit shifting from interest-free or related-party financing is not sustainable.

Issues: Whether a writ petition should be entertained against an ex parte adjudication order when a statutory appeal lies under the GST law, and whether the petitioner should be relegated to the appellate remedy with the appeal authority considering limitation and merits.

Analysis: The impugned adjudication order was appealable under the GST Act. In taxation matters, the existence of an effective statutory appellate remedy ordinarily weighs against exercise of extraordinary writ jurisdiction under Article 226 of the Constitution of India. The limitation issue was also addressed by directing that the period for appeal be computed from the date of communication of the order sought to be challenged. The order further safeguarded access to the appellate forum by requiring the appeal authority to register the appeal once the date of communication is disclosed, without the portal preventing filing on the basis of upload or alert dates. It was also clarified that limitation, the ex parte character of the adjudication, and other challenge grounds would remain open before the appellate authority.

Conclusion: The writ petition was not entertained and the petitioner was relegated to the statutory appellate remedy, with the appeal authority to consider limitation and the merits of the challenge.

Final Conclusion: The dispute was relegated to the statutory appeal route, and the extraordinary writ jurisdiction was declined in view of the available appellate remedy.

Ratio Decidendi: Where an effective statutory appeal is available in a taxation matter, writ jurisdiction under Article 226 should ordinarily not be invoked, and the appellate forum must be enabled to consider both limitation and the merits of the challenge.

Issues: (i) Whether the plaintiff was entitled to vacant possession and rent arrears on the basis of the lease agreement and termination notice; (ii) Whether the defendant was liable to pay damages, GST, future interest and mesne profits for continued occupation after termination; (iii) Whether costs and any further reliefs were payable.

Issue (i): Whether the plaintiff was entitled to vacant possession and rent arrears on the basis of the lease agreement and termination notice.

Analysis: The lease was for a fixed term commencing on 07.03.2019 and ending on 07.03.2025. The defendant admitted default in payment of rent from August 2021, and there was no reliable material to establish payment of arrears. The termination notice was held to have been duly served, and the defendant's challenge to the claim of arrears was rejected. The objection based on the unregistered agreement was not accepted as barring relief on the facts proved.

Conclusion: The issue was answered in favour of the plaintiff.

Issue (ii): Whether the defendant was liable to pay damages, GST, future interest and mesne profits for continued occupation after termination.

Analysis: After termination of the tenancy, the defendant continued in occupation and carried on business without clearing arrears or handing over possession. The continued occupation was treated as unlawful, justifying liability for arrears, damages, GST and interest. The claim for future mesne profits at the specified monthly rate was, however, found to have no basis and was rejected.

Conclusion: The issue was answered in favour of the plaintiff, except that the claim for future mesne profits was rejected.

Issue (iii): Whether costs and any further reliefs were payable.

Analysis: In view of the partial rejection of the claim and the overall circumstances, the Court declined to grant costs and held that no further relief was warranted.

Conclusion: The issue was answered against the plaintiff as to costs and further reliefs.

Final Conclusion: The suit was decreed with directions for delivery of vacant possession and payment of arrears, damages, GST and interest, but the claim for future mesne profits and costs was declined.

Ratio Decidendi: A tenant who remains in occupation after valid termination of tenancy and fails to prove payment of rent is liable for arrears and damages for unlawful occupation, while an unregistered lease objection does not by itself defeat such relief where the tenancy and default are otherwise proved.

Issues: Whether the impugned giving-effect order, passed after the Tribunal directed reconsideration of working capital adjustment, required interference and a fresh decision on merits.

Analysis: The Tribunal had directed the Transfer Pricing Officer to reconsider working capital adjustment in light of the assessee's averments and evidence. The petitioner did not furnish the requisite working capital details and supporting material sought in the subsequent communication, and had only placed calculations without proper authentication or substantiation. In view of the incomplete compliance, the Court found that the giving-effect order had been passed on the material available, but also considered it appropriate that the issue be reconsidered after the petitioner supplies the required particulars.

Conclusion: The matter was remitted to the first respondent to pass a fresh order on merits after the petitioner uploads the required details and supporting documents, and after hearing the petitioner.