Issues: (i) Whether interest expenditure attributable to capital work in progress was liable to be capitalised where the assessee had sufficient interest-free funds and the building was already put to use; (ii) Whether disallowance computed under section 14A read with rule 8D could be added to book profit under section 115JB.

Issue (i): Whether interest expenditure attributable to capital work in progress was liable to be capitalised where the assessee had sufficient interest-free funds and the building was already put to use.

Analysis: The factual finding that interest-free funds exceeded the investments attracted the presumption that the investments were made from such funds. The expenditure also related to an existing building already put to use in earlier years; consequently, there was no basis to capitalise the interest expenditure.

Conclusion: The disallowance of interest expenditure was not sustainable. This issue was decided in favour of the assessee and against the Revenue.

Issue (ii): Whether disallowance computed under section 14A read with rule 8D could be added to book profit under section 115JB.

Analysis: Binding jurisdictional decisions established that an adjustment to book profit cannot be founded on the disallowance calculated under section 14A read with rule 8D. The concurrent findings of the appellate authorities deleting the corresponding book-profit adjustment were therefore upheld.

Conclusion: The section 14A disallowance computed under rule 8D could not be added to book profit under section 115JB. This issue was decided in favour of the assessee and against the Revenue.

Final Conclusion: Neither proposed question gave rise to a substantial question of law.

Ratio Decidendi: Where interest-free funds sufficient to cover the investments are available, investments are presumed to be made from those funds; further, a disallowance quantified under section 14A read with rule 8D cannot by itself be used to increase book profit under section 115JB.

Issues: Whether the challenges to the show-cause notices and the assessment order required adjudication in writ jurisdiction.

Outcome: The petitions were disposed of, leaving the petitioners to pursue the statutory appellate remedy against any final assessment order.

Issues: Whether penalty under section 271(1)(c) was leviable on an addition for alleged bogus purchases ultimately sustained on an ad hoc and estimated basis.

Analysis: The quantum addition was successively reduced from 25% of the alleged bogus purchases to 12.50% and finally to 6%, demonstrating that the sustained addition was estimated. Coordinate Bench decisions on materially identical facts had applied the settled principle that penalty for concealment or furnishing inaccurate particulars is not exigible merely on an ad hoc or estimated addition. No distinguishing factual feature or contrary subsequent authority was shown. Judicial discipline and consistency required adoption of that view.

Conclusion: Penalty under section 271(1)(c) was not leviable on the estimated addition; the penalty was deleted in favour of the assessee.

Issues: (i) Whether an integrated industrial shrimp-feed manufacturing plant is classifiable under CTH 8436 10 00 or CTH 8438 80 90, with consequential CVD liability; (ii) Whether rejection of the appeal as time-barred was sustainable without determining the status and finalisation of provisional assessments.

Issue (i): Whether an integrated industrial shrimp-feed manufacturing plant is classifiable under CTH 8436 10 00 or CTH 8438 80 90, with consequential CVD liability.

Analysis: Heading 8436, read contextually with its HSN Explanatory Notes, covers farm-level and allied husbandry machinery for preparing animal feed but excludes machinery clearly designed for industrial use. Heading 8438 applies to machinery for industrial preparation or manufacture of food, including food for animal consumption. The imported goods constituted an integrated, automated commercial production plant with mixing, conditioning, pelletising, cooling and conveying systems, intended for continuous large-scale manufacture of shrimp feed. HSN Notes were used as an interpretative aid to ascertain the scope of the competing tariff headings, not to override the tariff. The project-import approval did not determine the tariff classification.

Conclusion: The machinery is classifiable under CTH 8438 80 90, not CTH 8436 10 00; the reassessment and consequential CVD levy are valid, against the assessee.

Issue (ii): Whether rejection of the appeal as time-barred was sustainable without determining the status and finalisation of provisional assessments.

Analysis: The communication treated as the starting point for limitation neither finalised the assessments nor determined classification or differential duty. Where the Bills of Entry were treated as provisionally assessed, the foundational questions of finalisation under Section 18, the character of the communication as an appealable order, the requirement of a speaking order on disputed reassessment, the date from which limitation commenced, and the status of project-import finalisation required determination. The computation of delay was also unsupported by recorded particulars.

Conclusion: The time-bar rejection cannot be sustained; the matter must be reconsidered by the Commissioner (Appeals) on maintainability, provisional assessment, finalisation, limitation and merits, in favour of the assessee.

Final Conclusion: The classification and CVD demand remain upheld, while the separate limitation dispute is restored for fresh appellate determination.

Ratio Decidendi: Machinery forming an integrated industrial plant for large-scale commercial manufacture of animal feed falls under the tariff heading for industrial food-manufacturing machinery where the farm-feed machinery heading excludes industrial-use machinery; limitation cannot be invoked against a provisional assessment without determining whether a legally appealable final assessment or order exists.

Issues: (i) Whether registered secured creditors' dues take priority over State tax dues and statutory charges; (ii) Whether State attachment orders issued before enforcement of the secured-creditor priority provisions can defeat that priority without a lawful public proclamation and consequential recovery steps; (iii) Whether an auction purchaser of a secured asset may be subjected to a State boja/encumbrance after completion of the secured sale.

Issue (i): Whether registered secured creditors' dues take priority over State tax dues and statutory charges.

Analysis: Section 26E of the SARFAESI Act and Section 31B of the RDDB Act confer priority upon secured creditors in distribution of sale proceeds over all debts, revenues, taxes, cesses and rates payable to governmental authorities. The State provisions creating a first charge, including Section 82 of the MGST Act and amended Section 37 of the MVAT Act, do not displace that statutory priority. The secured interests in the cases were registered before the State departments' charges, or the State charges were not registered.

Conclusion: The secured creditors' registered dues have priority over the State tax dues, in favour of the secured creditors.

Issue (ii): Whether State attachment orders issued before enforcement of the secured-creditor priority provisions can defeat that priority without a lawful public proclamation and consequential recovery steps.

Analysis: A mere attachment order is insufficient. For a pre-enforcement attachment to resist the secured creditor's priority, the State must establish attachment and public proclamation in accordance with the applicable revenue-recovery procedure, along with the required consequential steps. The State did not establish compliance with those requirements in any of the relevant petitions.

Conclusion: The unproclaimed and incompletely enforced State attachments cannot defeat the secured creditors' statutory priority, in favour of the secured creditors.

Issue (iii): Whether an auction purchaser of a secured asset may be subjected to a State boja/encumbrance after completion of the secured sale.

Analysis: Upon payment of consideration and issuance of the sale certificate in a secured sale, the auction purchaser is entitled to enjoy the asset free from a State encumbrance that cannot prevail over the secured creditor's priority. An "as is where is" sale condition does not permit the State to pursue the same asset or retain a revenue-record boja after enforcement of the security interest.

Conclusion: The State cannot retain or enforce a boja/encumbrance against the auction purchasers' secured-sale assets, in favour of the auction purchasers.

Final Conclusion: The impugned State attachment orders, notices, communications and revenue-record encumbrances were invalidated, and consequential removal of the encumbrances was required.

Ratio Decidendi: Statutory priority of a duly registered secured creditor under the central recovery regime prevails over State tax charges unless a pre-existing State attachment was lawfully completed through the prescribed public-proclamation and recovery process.

Issues: Whether the petitioner should be granted regular bail pending investigation into alleged clandestine manufacture and clearance of pan masala without registration and payment of cess.

Analysis: The alleged offences were punishable with imprisonment of less than five years. The petitioner had remained in custody since 18.06.2026; investigation was still pending, but no custody petition had been filed. These circumstances warranted release on bail subject to stringent safeguards for investigation and compliance with statutory bail conditions.

Conclusion: Regular bail was granted to the petitioner, subject to execution of bond and sureties, weekly appearance before the investigating officer for the stipulated period or until filing of the charge sheet, and compliance with applicable bail conditions.

Issues: Whether the writ petition challenging rejection of a consequential GST refund should be entertained despite the availability of a statutory appeal.

Analysis: The appellate order had set aside the earlier rejection on specified grounds but had neither directed unconditional release of the refund nor precluded fresh examination on other legally permissible grounds. The subsequent rejection order independently examined the refund claim and recorded reasons concerning turnover reconciliation and refund computation. The legality of those reasons and the scope and effect of the appellate order could be comprehensively examined in an appeal under Section 107 of the Central Goods and Services Tax Act, 2017. The rejection order was therefore not shown to be non est or wholly without jurisdiction so as to justify writ interference.

Conclusion: The writ petition was not maintainable for interference in the circumstances, and the petitioner was required to pursue the statutory appellate remedy.

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.