Issues: (i) Whether an order under Section 73 issued within the prescribed limitation period becomes invalid merely because it is uploaded and served thereafter; (ii) whether limitation under Section 73(10) applies to issuance of the order or to its service; and (iii) whether signing and issuing the order are legally distinct from its subsequent communication to the taxpayer.

Issue (i): Whether an order under Section 73 issued within the prescribed limitation period becomes invalid merely because it is uploaded and served thereafter.

Analysis: Section 73(9) requires the proper officer to determine the tax, interest and penalty and issue an order, while Section 73(10) prescribes the limitation period for such issuance. Section 169 separately prescribes the modes of service, including making the order available on the common portal. Rule 142(5) requires the summary of the order to be uploaded in Form GST DRC-07 and does not make such uploading the date of issuance for limitation purposes. The order was digitally authenticated and issued on the last permissible date, and its uploading on the following day related to service and communication.

Conclusion: An order issued within the limitation period is not rendered void or time-barred merely because it is uploaded and served after that period.

Issue (ii): Whether limitation under Section 73(10) applies to issuance of the order or to its service.

Analysis: The statutory scheme deliberately uses the expressions "issue" and "service" distinctly. Section 73(10) attaches limitation to issuance of the order under Section 73(9), whereas Section 169 governs the manner and effect of service. The limitation provision contains no requirement that service of the order must also be completed within the same period. In interpreting the taxing statute, the separate statutory treatment of issuance and service cannot be disregarded.

Conclusion: The limitation under Section 73(10) applies to issuance of the order and not to its service.

Issue (iii): Whether signing and issuing the order are legally distinct from its subsequent communication to the taxpayer.

Analysis: Issuance involves the proper officer making and authenticating the adjudicatory order and setting it in motion for dispatch, including through the prescribed electronic mechanism. Service is the subsequent communication of that order through one of the modes specified in Section 169. Rule 26(3) governs electronic issuance and authentication, while Rule 142(5) governs uploading of the order summary. The statutory scheme therefore treats completion of the adjudicatory function and communication of the decision as distinct stages.

Conclusion: Issuance of the order is distinct from service, and the validity or completeness of issuance cannot be made dependent on service being completed within the limitation period.

Final Conclusion: The order issued within the prescribed period remained legally valid, and its subsequent uploading did not defeat the statutory limitation or the authority to enforce it after service.

Ratio Decidendi: Where the statute prescribes limitation for issuance of an adjudicatory order and separately regulates its service, timely issuance satisfies the limitation requirement; subsequent service need not occur within that limitation period.

Issues: Whether the assessment order was liable to be set aside for want of a fair and effective opportunity to respond to the proposed additions.

Analysis: The assessee's primary and secondary email addresses were registered on the income-tax portal, but the material notices were not sent to either address. Notices sent to the former auditor's email address were not effectively communicated after disputes arose and the auditor resigned. The assessment was consequently completed without an adequate opportunity for the assessee to submit its explanation and supporting documents, offending the principles of natural justice.

Conclusion: The assessment order and consequential demand notice were set aside in favour of the assessee, and the assessment was restored for fresh adjudication after affording an adequate opportunity and personal hearing. The issue concerning validity of service under Rule 127 was left open.

Issues: Whether the revision order and the ex parte assessment could be sustained when the documentary evidence filed during revision proceedings was not considered.

Analysis: The revision record contained a cash-transaction summary, appointment letter and delivery challans supporting the explanation for the cash deposits. The revision order merely stated that no reliable evidence had been furnished, without addressing those documents or recording adverse findings on them. As the assessment had been made ex parte and the material placed in revision had not been before the Assessing Officer, fresh consideration by the Assessing Officer was warranted with a reasonable opportunity of hearing.

Conclusion: The revision order and ex parte assessment, together with consequential demand, penalty notices and bank-account attachment notice, were set aside and the matter was remanded for de novo adjudication after considering the evidence and submissions. The issue was decided in favour of the assessee.

Issues: Whether an unsigned notice issued electronically under section 148 was validly authenticated and could confer jurisdiction for reassessment.

Analysis: Section 282A requires a notice issued by an income-tax authority to be signed; for electronic communication, authentication requires a digital signature. The statutory use of "shall" makes signature mandatory, not a procedural formality. The notice under section 148 bore neither a manual nor a digital signature. Such failure deprived the notice of legal validity and constituted a jurisdictional defect that could not be cured under sections 292B or 292BB.

Conclusion: The unsigned notice under section 148 was invalid; consequently, the reassessment proceedings and reassessment order were quashed.

Issues: (i) Allowability under section 37(1) of interest paid on delayed payment of statutory dues, including TDS, sales tax/VAT, service tax and provident-fund contributions; (ii) Validity and computation of disallowance under section 14A read with Rule 8D where exempt income was asserted not to have been earned.

Issue (i): Allowability under section 37(1) of interest paid on delayed payment of statutory dues, including TDS, sales tax/VAT, service tax and provident-fund contributions.

Analysis: Explanation 1 to section 37(1) excludes expenditure incurred for an offence or a purpose prohibited by law, while business expenditure must be wholly and exclusively for business. Interest on arrears of sales tax/VAT and service tax is compensatory because those levies are connected with business operations and are otherwise allowable on payment basis. Interest for delayed remittance of TDS is not deductible: TDS represents tax deducted from the payee and its remittance is not expenditure incurred for the assessee's business. Interest relating to delayed employees' provident-fund contribution is likewise not allowable; employer contribution requires factual segregation. The assessment requires verification whether the prior-period interest of Rs.10,93,356 was already included in the larger amount disallowed, so as to avoid double disallowance.

Conclusion: Interest on delayed deposit of VAT/sales tax, entry tax, service tax and employer's provident-fund contribution is allowable, subject to verification; interest on delayed TDS, employees' provident-fund contribution and other tax-related dues is not allowable. The alleged duplicate addition of Rs.10,93,356 must be deleted if verified. The issue is partly in favour of the assessee.

Issue (ii): Validity and computation of disallowance under section 14A read with Rule 8D where exempt income was asserted not to have been earned.

Analysis: A section 14A disallowance must be confined to investments that yield income not forming part of total income. National Savings Certificate investments cannot be included because their interest is taxable. Since the record did not contain the return computation despite the assertion that no exempt income was earned, verification by the Assessing Officer is necessary.

Conclusion: If no exempt income was earned, the additional section 14A disallowance must be deleted; absent evidence of any further exempt income, the disallowance is restricted to the amount voluntarily disallowed by the assessee. The issue is in favour of the assessee.

Final Conclusion: The disputed deductions and disallowance require recomputation after verification, with relief confined to compensatory business-related interest and to investments connected with exempt income.

Ratio Decidendi: Interest on delayed statutory payments is deductible only where it is compensatory and connected with the assessee's business expenditure; interest on delayed remittance of TDS or employees' contributions is not such business expenditure, and section 14A disallowance must relate to investments generating exempt income.

Issues: Whether penalty for failure to obtain a tax audit was sustainable where the assessee's futures and options turnover, computed under the applicable method, did not cross the tax-audit threshold.

Analysis: For futures and options transactions, turnover is determined from favourable and unfavourable differences, option premium received, and differences arising on reverse trades, with each buy-and-sell transaction treated independently. The assessment had treated the aggregate value of transactions as turnover, whereas the assessee's turnover computed on this basis was below the prescribed threshold for tax audit.

Conclusion: The penalty under Section 271B was unsustainable and was directed to be deleted, in favour of the assessee.

Issues: Whether a 5% ad hoc disallowance of business expenses, including foreign-exchange loss, could be sustained without identifying any specific defect, non-genuine expenditure, or inadequate supporting documentation.

Analysis: Acceptance of 95% of the expenditure indicated that the genuineness of the expenses was not in dispute. No finding established that any expense was bogus, not incurred for business purposes, or unsupported by deficient documentation; nor was any particular expense head or substantial transaction identified for further verification. If complete verification of documents was required in faceless assessment, the assessee had to be notified and afforded sufficient opportunity, which was not evident from the record. The foreign-exchange loss arose on year-end restatement of foreign-currency liabilities, and no finding showed that it was contrary to applicable accounting standards or capital in nature. The explanations and documents furnished also supported the remaining expenditure claims.

Conclusion: The ad hoc disallowance sustained in respect of the expenses was set aside in favour of the assessee.

Issues: (i) Whether the addition for excess share premium under section 56(2)(viib) could be sustained after rejection of the assessee's valuation report; (ii) Whether disallowance of expenses could be made in a limited-scrutiny assessment without conversion into complete scrutiny.

Issue (i): Whether the addition for excess share premium under section 56(2)(viib) could be sustained after rejection of the assessee's valuation report.

Analysis: The assessee furnished a chartered accountant's valuation report, supported by detailed workings, valuing the shares above the issue price. The Assessing Officer substituted that valuation with a self-computed net asset value without referring the matter to the valuation cell. The objections to the report rested on unverified doubts and lack of examination of the supporting workings, while the appellate finding accepting the report was reasoned and supported by the material.

Conclusion: The deletion of the addition for excess share premium was upheld, in favour of the assessee.

Issue (ii): Whether disallowance of expenses could be made in a limited-scrutiny assessment without conversion into complete scrutiny.

Analysis: The scrutiny selection was confined to advances, loans and share premium; expense disallowance was outside those selected issues. No satisfaction was recorded and no prior approval was obtained to convert the limited scrutiny into complete scrutiny. An addition on an issue beyond the prescribed scope was therefore beyond the Assessing Officer's jurisdiction.

Conclusion: The deletion of the expense disallowance was upheld, in favour of the assessee.

Final Conclusion: The assessed share-premium addition and expense disallowance were not legally sustainable.

Ratio Decidendi: A supported share-valuation report cannot be displaced by an Assessing Officer's unsupported substitute valuation, and additions outside limited-scrutiny issues require valid conversion to complete scrutiny.

Issues: Whether revision under section 263 on issues unrelated to the subject matter of reassessment was barred by limitation.

Analysis: The reassessment was initiated solely for alleged bogus purchases, whereas the proposed revision concerned gifts to doctors, disallowance of expenditure relating to exempt income, and deduction for CSR expenditure. Those matters arose from and had been examined in the original assessment. Where the subject matter of revision is distinct from the subject matter of reassessment, the limitation for revision runs from the original assessment order; it cannot be extended by treating the reassessment order as the relevant order. The audit objections were available during reassessment, but the reassessment was not enlarged to cover those matters.

Conclusion: The revisionary proceedings were time-barred and the order under section 263 was quashed, in favour of the assessee.

Issues: Whether cash deposits in specified bank notes during the demonetisation period, stated to be refunds of business advances from purchase agents, could be treated as unexplained cash credits.

Analysis: The assessee maintained audited regular books containing the advances, refunds, cash deposits and supporting particulars of 57 purchase agents. The books were neither rejected nor found incorrect, and the Revenue accepted the opening cash balance recorded therein. No enquiry was made with the agents and no material established that the advances, refunds or book entries were fictitious. There was also no abnormal increase in cash deposits compared with the preceding year. Receipt of specified bank notes before 31.12.2016 in voluntary lawful commercial transactions was not statutorily prohibited merely because the notes had ceased to be legal tender. The statutory conditions for invoking the unexplained-credit provision were therefore not established by suspicion alone.

Conclusion: The deposits stood explained as genuine refunds of business advances; the addition under Section 68 and consequential taxation under Section 115BBE were unsustainable.

Issues: Whether an addition based on estimated gross profit could be sustained where the books of account were accepted and no defects were found.

Analysis: The cash deposits during demonetisation were accepted as explained, and the books and records were properly maintained. The gross-profit estimate was derived by averaging results of three assessment years despite differences in turnover and business progression. The subsequent year's higher turnover and higher gross-profit rate did not support the adopted estimate. No defect was identified in the books and they were not rejected before estimating profit.

Conclusion: The estimated gross-profit addition was unsustainable and was deleted in favour of the assessee.

Issues: Whether the best judgment assessment levying tax on a works-contract dealer was sustainable when the dealer had opted for composition under the applicable VAT provision and submitted the records required under that scheme.

Analysis: A dealer executing works contracts may opt for composition under Section 4(7)(b) of the Andhra Pradesh Value Added Tax Act, 2005, subject to the prescribed conditions and record-keeping requirements. The petitioner had exercised that option and submitted the available tax-collection certificates, returns and other prescribed records. The assessing authority failed to consider these materials and did not address the petitioner's specific statutory contentions. The assessment was therefore vitiated both by non-compliance with the composition scheme and by failure to give reasons.

Conclusion: The best judgment assessment was unsustainable in law and was quashed.

Issues: Whether the ex parte Order-in-Original could stand where the petitioner had earlier reported fraudulent use of his identity for obtaining a GST registration, the authorities failed to investigate the complaint, and the subsequent notices were not received by him.

Analysis: The petitioner had informed the GST authorities in 2022 that his identity had been fraudulently used to create the concerned firm and had denied any connection with it. Despite receipt of that complaint, no investigation was undertaken. The subsequent show cause notices were not received by the petitioner, and the Order-in-Original was passed without his participation. The principles of natural justice, including a meaningful opportunity of hearing, required fresh adjudication in the peculiar circumstances.

Conclusion: The Order-in-Original dated 18.03.2026 was quashed and set aside, and the matter was remanded to the competent Commissioner for fresh adjudication after giving the petitioner an opportunity of hearing.

Outcome: Special Leave Petition dismissed. The question of law was kept open.

Outcome: Delay condoned. The Special Leave Petitions were dismissed and the accompanying interlocutory applications, if any, were disposed of.

Issues: Whether delayed filing of Form 10DA, otherwise available before processing of the return or completion of assessment, rendered the deduction under Section 80JJAA inadmissible and justified revision under Section 263 of the Income-tax Act, 1961.

Analysis: The delay in filing Form 10DA or the tax audit report does not by itself defeat the deduction under Section 80JJAA where the prescribed form was available to the Assessing Officer before processing the return or framing the assessment. The Assessing Officer's allowance of the deduction therefore could not be regarded as erroneous and prejudicial to the interests of the Revenue so as to invoke revisionary jurisdiction under Section 263.

Conclusion: Delayed filing of Form 10DA did not render the deduction under Section 80JJAA inadmissible, and the revision under Section 263 was invalid.

Issues: Whether the respondents wilfully and deliberately disobeyed the Court's earlier order so as to constitute civil contempt.

Analysis: Contempt jurisdiction under the Contempt of Courts Act, 1971 is limited and requires clear proof of deliberate or wilful disobedience. The earlier order required the customs authorities to accept a baggage declaration made under Section 77 of the Customs Act, 1962, while preserving their statutory power to take appropriate action regarding baggage. The introductory reproduction of the prayer did not constitute an operative direction. The material on record did not establish non-compliance, much less intentional disobedience, and bare averments were insufficient to initiate contempt action.

Conclusion: No case of civil contempt or wilful disobedience was established against the respondents.

Ratio Decidendi: Civil contempt requires satisfactory proof of deliberate and wilful disobedience of a specific court direction; an interpretation of the order unsupported by material evidence is insufficient.

Issues: Whether late filing fee under Section 46(3) of the Customs Act, 1962 read with Regulation 4 of the Bill of Entry (Electronic Integrated Declaration and Paperless Processing) Regulations, 2018 was leviable on supplementary Bills of Entry filed for excess bulk coal arising from natural cargo variations.

Analysis: The original Bills of Entry covering the manifested quantity were filed within time and the applicable customs duty was paid. The supplementary Bills of Entry were filed after the excess quantity was identified through the prescribed procedure and arose from inherent and unavoidable variations in bulk cargo, including moisture, physical weighment and draught survey differences. There was no suppression, misdeclaration, revenue loss, deliberate delay or mala fide conduct. Section 46(3), read with Regulation 4, does not require late fee to be imposed mechanically where sufficient cause for delayed filing is established and permits waiver in deserving cases. The levy was therefore inconsistent with the appellant's bona fide conduct and the circumstances of the import.

Conclusion: The late filing fee imposed on the appellant was legally unsustainable and was set aside.