Issues: (i) Whether the exempt-income disallowance was correctly restricted to Rs. 8,50,235; (ii) Whether the disallowance under Section 14A could be added to book profits under Section 115JB.

Issue (i): Whether the exempt-income disallowance was correctly restricted to Rs. 8,50,235.

Analysis: Under Section 14A and Rule 8D, Rs. 253.50 crore of the total expenditure of Rs. 314 crore related to specified purposes. Interest income of Rs. 59.58 crore was netted against the remaining interest expenditure of Rs. 60.99 crore. Only investments yielding exempt income during the year were considered, consistently with the approach adopted for earlier years.

Conclusion: The restriction of the disallowance to Rs. 8,50,235 was upheld in favour of the assessee.

Issue (ii): Whether the disallowance under Section 14A could be added to book profits under Section 115JB.

Analysis: Binding precedents addressed the computation of book profits under Section 115JB and the use of disallowances computed under Section 14A and Rule 8D for that purpose.

Conclusion: The Section 14A disallowance could not be added to book profits under Section 115JB. The issue was decided in favour of the assessee.

Final Conclusion: The exempt-income disallowance remains limited, and the separate book-profit adjustment does not survive.

Ratio Decidendi: A disallowance computed under Section 14A read with Rule 8D cannot be added to book profits under Section 115JB.

Issues: Whether cost allocations for group support services are taxable as fees for technical or included services under the applicable tax treaties.

Analysis: Article 13 of the India-United Kingdom treaty and Article 12 of the India-United States treaty require examination of the actual nature of the services and the applicable make available requirement. Professional expertise or commercial benefit alone does not establish that technical knowledge, skill or know-how has been made available for independent use. The precedent concerning business-support services applied subject to the services being of the nature claimed and not involving distinct technical services or transfers beyond its scope.

Conclusion: The additions treating the cost recharges as fees for technical or included services were deleted, in favour of the assessees.

Ratio Decidendi: Under the applicable make available treaty provisions, professional expertise or commercial benefit alone does not establish that technical knowledge has been made available for the recipient's independent use.

Issues: (i) Whether the delay in filing the appeal should be condoned; (ii) whether a pure question of law arising from facts on record could be raised for the first time before the Tribunal; (iii) whether the disallowance required fresh adjudication with an opportunity of hearing.

Issue (i): Whether the delay in filing the appeal should be condoned.

Analysis: The limitation provisions require sufficient cause for delay. The explanation referred to pandemic disruption, the managing director's ill health and the advice previously available; the supporting affidavit was not controverted. The substantial delay and lack of vigilance were balanced against the costs paid.

Conclusion: The delay was condoned, in favour of the appellant.

Issue (ii): Whether a pure question of law arising from facts on record could be raised for the first time before the Tribunal.

Analysis: The scope of adjustments under Section 143(1) is confined to those enumerated in the provision. The challenge to the adjustment's permissibility was a pure question of law arising from facts already on record, although it had not been specifically raised before the first appellate authority.

Conclusion: The legal ground could be raised before the Tribunal, in favour of the appellant.

Issue (iii): Whether the disallowance required fresh adjudication with an opportunity of hearing.

Analysis: The first appellate authority had sustained the disallowance on the basis of the retrospective character of the statutory amendments without examining the permissible scope of the adjustment or the effect of the subsequent Supreme Court decision. Its order was passed the day after the scheduled hearing without a further opportunity.

Conclusion: The disputed disallowance was set aside for fresh adjudication after a reasonable opportunity of hearing, in favour of the appellant.

Final Conclusion: The permissibility of the adjustment and the disputed deduction remain for fresh determination; the separate relief concerning bonus and gratuity remains undisturbed.

Ratio Decidendi: A pure question of law arising from facts already on record may be raised at the appellate stage even if it was not specifically raised before the first appellate authority.

Issues: Whether investments that did not yield exempt income during the relevant year could be included in the average investment value for computing the disallowance.

Analysis: Section 14A and Rule 8D govern the computation of expenditure relating to exempt income. The Tribunal relied on precedent distinguishing investments that yielded exempt income during the relevant year from the broader investment portfolio. The assessee's own computation used its income-yielding mutual fund investments.

Conclusion: No. The additional disallowance of Rs. 2,14,98,928 was deleted, in favour of the assessee.

Ratio Decidendi: Only investments that actually yield exempt income during the relevant previous year are included in the average investment value for computing disallowance under Section 14A and Rule 8D.

Issues: Whether the assessee is entitled to deduction under section 54F for residential properties jointly allotted under a joint development agreement.

Analysis: Section 54F provides for deduction in respect of qualifying investment in residential property. Four properties were jointly allotted to the assessee and two co-owners, and one co-owner had been granted the deduction in respect of the same properties. Although entitlement must be assessed individually, no material factual or legal distinction was identified to justify different treatment.

Conclusion: The assessee is entitled to deduction under section 54F for his proportionate interest in the residential properties, computed according to the statutory formula.

Ratio Decidendi: Although deduction entitlement must be assessed individually, different treatment of co-owners on the same material facts requires a distinguishing factual or legal basis.

Issues: Whether the interim restraints on the applicant's property and bank accounts should be vacated or modified pending determination of the liquidator's application.

Analysis: The SFIO report and supporting documents indicated a prima facie role in the alleged fraudulent activities. The collateral money-laundering proceedings had not attained finality. Section 35 of the Companies Act, 2013 was considered in relation to potential personal liability despite the absence of proof that company assets had personally benefited the applicant. Allowing unrestricted dealings with property could prejudice recovery for creditors.

Conclusion: The property restraints remain in force. The applicant may operate the bank account subject to quarterly reporting of withdrawals and expenditure. The liquidator's principal application remains pending.

Ratio Decidendi: A prima facie case of personal liability for corporate fraud may justify interim protection of assets even without proof that company assets were received personally.

Issues: Whether the addition for unaccounted receipts based on an impounded document was sustainable despite the assessee's retraction and denial of the document, and whether a substantial question of law arose.

Analysis: Section 292C of the Income-tax Act, 1961 creates a rebuttable presumption concerning the ownership and truth of documents found during a survey. Part of the impounded document corresponded with recorded receipts. The retraction was treated as an afterthought, and no cogent material was produced to rebut the presumption. The addition rested on the document rather than the survey statement alone.

Conclusion: The addition of Rs. 4,06,360 was sustained against the assessee; no substantial question of law arose.

Ratio Decidendi: A corroborated document found during a survey may support an addition where the statutory presumption of its ownership and truth is not rebutted by cogent evidence.

Issues: Whether the assessment could be revised for failing to question the stamp duty valuation of properties sold.

Analysis: Section 43CA of the Income-tax Act, 1961 permits substitution of actual consideration with stamp duty value where the latter exceeds it. The valuation certificates covered the entire property, and no sale was identified where stamp duty value exceeded actual consideration. The revisional authority's objection concerned the correctness of the stamp duty authority's valuation certificate.

Conclusion: The assessment was not shown to be erroneous and prejudicial to Revenue; the revision was unsustainable. The issue was decided in favour of the assessee.

Ratio Decidendi: Revenue authorities cannot question a stamp duty authority's valuation certificate under Section 43CA as a basis for treating an assessment as erroneous in revision under Section 263.

Issues: Whether the share-sale gains were liable to be treated as unexplained cash credits and denied long-term capital gains exemption.

Analysis: Under the Income-tax Act, 1961, the assessee supplied contract notes, broker and demat account details, transaction statements, ledgers and bank records, and had paid securities transaction tax. The scrip and brokers had not been blacklisted during the relevant period. The assessing and appellate authorities recorded no findings connecting the assessee's transactions to the alleged market-price fluctuations.

Conclusion: The exemption and deletion of the addition were upheld. No substantial question of law arose.

Ratio Decidendi: General information about share-price manipulation, without findings linking it to the assessee's documented transactions, does not justify treating the gains as unexplained cash credits or denying the exemption.

Issues: (i) Whether the proprietor-subcontractor was liable for the full service tax on the works contract; (ii) whether the confirmed demand for the extended period was sustainable.

Issue (i): Whether the proprietor-subcontractor was liable for the full service tax on the works contract.

Analysis: The services were supplied by a proprietary firm as subcontractor. Notification No. 30/2012-S.T. provided for partial reverse charge, with the recipient responsible for half the tax. The calculation also accounted for tax already deposited by the subcontractor.

Conclusion: The subcontractor was liable for only 50% of the service tax, with the balance payable by the recipient, in favour of the assessee.

Issue (ii): Whether the confirmed demand for the extended period was sustainable.

Analysis: Conflicting tribunal decisions on subcontractors' liability preceded resolution by a larger bench, making the issue interpretational. The demand was substantially reduced after valuation and consideration of partial reverse charge, and there was no evidence that the subcontractor had charged service tax to the main contractor.

Conclusion: The confirmed demand for the extended period was time-barred, in favour of the assessee.

Final Conclusion: The confirmed service-tax demand cannot be recovered.

Ratio Decidendi: Where a subcontractor's non-payment arises from a bona fide belief supported by conflicting tribunal decisions and suppression is not established, the extended limitation period cannot be invoked.

Issues: Whether the delay in filing the statutory appeal should be condoned.

Analysis: The appeal was filed 28 days after the three-month filing period, within the additional month contemplated by Section 107(4) of the Central Goods and Services Tax Act, 2017. Although supporting documents had not been produced before the appellate authority, the explanation for the delay appeared genuine.

Conclusion: The delay was condoned and the rejection of the appeal was set aside. The appeal was directed to be re-presented for determination on merits after a hearing.

Issues: Whether cancellation of GST registration for non-filing of returns should be revoked and the registration restored.

Analysis: The petitioner had not filed returns from July 2025 and had not responded to the show-cause notice, leading to cancellation of registration. Financial difficulties were accepted as a genuine explanation for the default. Revocation and restoration were made conditional upon enabling portal access, filing all pending returns, and payment of tax dues, interest, and belated-filing fees without adjustment against unutilised or unclaimed input tax credit. Any input tax credit may be utilised only after departmental scrutiny and approval.

Conclusion: The cancellation order was revoked and GST registration was directed to be restored, subject to the stipulated compliance conditions, in favour of the assessee.

Issues: Whether the assessee's appeal, filed 29 days after the ordinary appeal period but within the statutory condonable period, could be rejected solely for delay.

Analysis: Section 107(4) of the Central Goods and Services Tax Act, 2017 permits extension of the appeal period by one month on sufficient cause. The appeal was filed on 09.10.2026, within the one-month condonable period following expiry of the three-month period on 10.09.2026. The stated reason for delay, namely the director's maternity leave, was found genuine.

Conclusion: The rejection of the appeal for delay was set aside, and the 29-day delay was condoned.

Issues: Whether an ex parte GST order based solely on notices uploaded to the GST portal, despite repeated non-response, constituted effective service and satisfied the principles of natural justice.

Analysis: Section 169(1) of the Central Goods and Services Tax Act, 2017 recognises portal uploading as a valid mode of service, but also provides other modes. Where repeated portal notices elicit no response, the issuing officer must make a genuine effort to serve the taxpayer through other prescribed modes, preferably registered post, rather than merely complete a formal requirement. Exclusive reliance on portal uploading in such circumstances does not amount to effective service.

Conclusion: The service adopted was ineffective in the circumstances and the ex parte order violated the principles of natural justice.

Issues: Whether an ex parte GST assessment based solely on notices uploaded on the online portal, despite no response to repeated notices, violated principles of natural justice.

Analysis: Uploading a notice on the GST portal is a valid mode of service. However, where repeated notices elicit no response, Section 169(1) of the Central Goods and Services Tax Act, 2017 requires the officer to explore other prescribed modes of service, preferably registered post with acknowledgment due, to secure effective service. Mere portal upload in such circumstances amounts to an empty formality and does not afford a meaningful opportunity to reply or be heard.

Conclusion: The ex parte assessment was vitiated by breach of principles of natural justice and was set aside for fresh adjudication after receipt of objections and grant of a clear personal-hearing notice. The bank-account attachment could not survive the setting aside of the assessment.

Issues: Whether an ex parte GST assessment based solely on portal-uploaded notices, without resort to other statutory modes of service after repeated non-response, violates principles of natural justice.

Analysis: Section 169(1) of the Central Goods and Services Tax Act, 2017 provides multiple valid modes for service of notices. Though uploading notices on the GST portal is a valid mode, repeated non-response requires the officer to make a genuine effort to effect effective service through other prescribed modes, preferably registered post. Reliance solely on portal uploads in such circumstances amounts to an empty formality and denies a meaningful opportunity to reply and be heard.

Conclusion: The ex parte assessment, having been made without effective service and a meaningful opportunity of hearing, violated the principles of natural justice.

Issues: Whether the petitioner should be permitted to pursue the statutory appellate remedy despite delay in challenging the assessment order.

Outcome: Liberty was granted to file an appeal before the appellate authority, which was directed not to raise limitation.

Issues: (i) Eligibility of a Government-controlled university for exemption under section 10(23C)(iiiab) where UGC grants and capital grants in kind are included in Government funding under Rule 2BBB; (ii) Sustainability of penalty for under-reporting or misreporting where the underlying addition is deleted.

Issue (i): Eligibility of a Government-controlled university for exemption under section 10(23C)(iiiab) where UGC grants and capital grants in kind are included in Government funding under Rule 2BBB.

Analysis: Exemption requires the institution to be a university or educational institution existing solely for education and not profit, and to be wholly or substantially financed by Government. Rule 2BBB treats this financing condition as fulfilled where Government grants exceed 50% of total receipts in the relevant previous year. Statutory control over the university's finances, expenditure, staffing and immovable property established Government control over its affairs.

Analysis: UGC funds originate from Central Government allocations and are distributed to universities through the statutory commission; they consequently form part of Government grants. Capital assistance in the form of Government-granted land was also includible for the financing computation. On including the UGC grant and the value attributable to the land grant, Government funding constituted 50.76% of total receipts, exceeding the prescribed threshold.

Conclusion: The exemption under section 10(23C)(iiiab) is allowable and this issue is decided in favour of the assessee.

Issue (ii): Sustainability of penalty for under-reporting or misreporting where the underlying addition is deleted.

Analysis: The penalty was founded solely on the addition resulting from denial of the exemption. Once that addition ceased to survive, there remained no basis for penalty.

Conclusion: The penalty is unsustainable and is deleted, in favour of the assessee.

Final Conclusion: The income is to be computed after giving effect to the statutory exemption, and the penalty founded exclusively on the resultant addition has no subsisting basis.

Ratio Decidendi: For the Government-financing test, funds routed through a statutory Government intermediary and Government capital grants in kind may be included in Government funding; where such funding exceeds the prescribed threshold, the educational institution is entitled to exemption.

Issues: Whether an adjudicating authority may confirm a tax demand exceeding the demand proposed in the show-cause notice, contrary to Section 75(7) of the Uttar Pradesh Goods and Services Tax Act, 2017.

Analysis: Section 75(7) prohibits confirmation of a demand exceeding that proposed in the show-cause notice. The notice proposed a substantially lower tax demand, interest and penalty than those confirmed in the adjudication order. Breach of this mandatory restriction rendered the excess confirmation jurisdictionally invalid.

Conclusion: An adjudicating authority cannot confirm a demand beyond that proposed in the show-cause notice; the impugned excess demand was invalid, in favour of the assessee.

Issues: Whether service of GST notices solely through portal uploads, despite repeated non-response and without recourse to other statutory modes of service, rendered the ex parte assessment and appellate rejection violative of principles of natural justice.

Analysis: Uploading notices on the GST portal is a valid mode of service. However, where repeated notices elicit no response, the proper officer must apply their mind and explore other modes available under Section 169(1) of the Central Goods and Services Tax Act, 2017, preferably registered post with acknowledgement due. Mere portal uploads in such circumstances amount to an empty formality rather than effective service, particularly where no meaningful opportunity of hearing is afforded.

Conclusion: In favour of the assessee, the ex parte assessment and appellate rejection were vitiated by breach of the principles of natural justice.