Issues: Whether, for Assessment Year 2013-14, exemption under Section 54EC was available up to Rs. 1 crore where Rs. 50 lakh was invested in specified bonds in each of two financial years within six months of transfer of the long-term capital asset.

Analysis: Section 54EC(1) prescribed a six-month period from transfer for investment in long-term specified assets. Its first proviso imposed a ceiling of Rs. 50 lakh on investments made during any financial year. The transfer occurred on 29.12.2012 and investments of Rs. 50 lakh each were made on 28.03.2013 and 28.06.2013, respectively, within the prescribed six-month period but in separate financial years. The subsequently inserted second proviso, effective from Assessment Year 2015-16, introduced an aggregate cap across the financial year of transfer and the following financial year; it did not govern the relevant assessment year.

Conclusion: The assessee was entitled to exemption under Section 54EC for the full investment of Rs. 1 crore; the disallowance of Rs. 50 lakh was deleted, in favour of the assessee.

Issues: Whether the impugned tax order and the rejection of the belated rectification application warranted interference and fresh adjudication.

Outcome: The impugned order was set aside and the matter was sent for fresh adjudication upon the petitioner making the stipulated tax deposit and filing a reply to the show-cause notice.

Issues: Whether the petitioner could be permitted to pursue the statutory appellate remedy against the assessment order notwithstanding limitation.

Analysis: The petitioner expressed willingness to clear the unpaid tax and interest and to make the prescribed deposit towards penalty. The writ jurisdiction was exercised to facilitate consideration of the statutory appeal on merits upon compliance with those requirements.

Outcome: The writ petition was disposed of with directions to make the stipulated payments and file an appeal, which shall be considered on merits without reference to limitation upon compliance.

Issues: Whether prolonged undertrial incarceration and the absence of a realistic prospect of an early trial justified regular bail notwithstanding the twin conditions under the Prevention of Money Laundering Act, 2002.

Analysis: The right to speedy trial is an integral component of personal liberty under Article 21 of the Constitution of India. Although Section 45 of the Prevention of Money Laundering Act, 2002 ordinarily governs bail on merits, its stringent requirements cannot operate to sustain unreasonably prolonged pre-trial detention where delay is not attributable to the accused and trial is unlikely to conclude within a reasonable time. The statutory custody thresholds under Section 436-A of the Code of Criminal Procedure, 1973 and Section 479 of the Bharatiya Nagarik Suraksha Sanhita, 2023 do not exhaust or restrict the constitutional power to protect liberty; whether custody has become constitutionally excessive depends on a contextual assessment of the sentence, the stage and likely duration of trial, the accused's role, and risks of absconding or interference with evidence.

Analysis: The investigation had concluded, the prosecution case depended predominantly on documentary evidence already held by the investigating agency, and the matter remained at the cognizance stage despite extensive proposed evidence. The duration of custody, the foreseeable delay arising from the volume of witnesses and documents, and the absence of tangible material showing flight risk, vulnerable witnesses, or likelihood of evidence tampering established that continued incarceration would be disproportionate. The statutory fetters on bail accordingly stood diluted by the Article 21 guarantee.

Conclusion: The petitioner was entitled to regular bail on the ground that continued custody amid a delayed trial would violate the constitutional right to personal liberty and speedy trial.

Ratio Decidendi: In proceedings under the Prevention of Money Laundering Act, 2002, the rigours of Section 45 must yield to Article 21 where undertrial custody is unduly prolonged, trial is unlikely to conclude within a reasonable time for reasons not attributable to the accused, and no concrete risk to the process of justice is shown.

Issues: Whether compound rubber manufactured by the industrial unit is excluded from sales-tax exemption under the negative list in clause (h) introduced into S.R.O. No. 1729/1993 by S.R.O. No. 38/1998.

Analysis: Clause (h) excludes treatment of raw rubber with chemicals to form a compound of rubber. Its wording is substantially similar to the exclusion previously considered under S.R.O. No. 1516/1990. The binding determination on the manufacturing process establishes that compound rubber is a finished rubber product, not merely rubber subjected to chemical mixing or a comparable processing activity. The comparable exclusion must therefore receive the same construction under S.R.O. No. 1729/1993.

Conclusion: Compound rubber is eligible for exemption under S.R.O. No. 1729/1993 and its claim cannot be curtailed by clause (h) introduced through S.R.O. No. 38/1998; the finding is in favour of the assessee.

Issues: Whether, for computing profits of the eligible cogeneration undertaking under section 80-IA(4), the low-pressure steam transferred to the paper division could be assigned nil cost and the entire common operating cost charged exclusively against electricity revenue.

Analysis: High-pressure and low-pressure steam were the same steam at different stages of an integrated extraction-condensing cogeneration process. The undertaking generated two commercially useful energy outputs-electricity and process steam-and extraction of steam for the paper division reduced the electricity that could otherwise have been generated. Absence of further fuel consumption after extraction did not eliminate the common fuel, boiler, water-treatment, labour, maintenance, depreciation and other costs embedded in the extracted steam. The steam was measurable, transferred to the paper division and used for paper drying; its meter readings, logbooks, reconciliations, audited accounts and professional certification disclosed no identified defect. The cost-reduction method adopted by the assessee and recognition of equivalent inter-unit steam revenue produced the same eligible profit. Under section 80-IA(8), the inter-unit transfer required examination at market value; assigning nil value to useful measurable steam without determining an alternative market value or establishing defects in the recorded value was impermissible. The materially identical earlier decision in the assessee's case was applicable, there being no demonstrated change in facts, law or binding contrary authority.

Conclusion: The nil-cost treatment of low-pressure steam and consequential recasting of the eligible undertaking's accounts were unsustainable. The disclosed profit of the eligible undertaking was required to be accepted and the claimed section 80-IA deduction allowed, in favour of the assessee.

Issues: Whether assignment by sale or transfer of long-term leasehold rights in land and building constitutes a taxable supply liable to GST.

Analysis: Assignment of leasehold rights by the original lessee to a third-party assignee transfers benefits arising from immovable property, with the assignee stepping into the position of the lessee. Such a transaction is outside the scope of supply under Section 7(1)(a) read with Clause 5(b) of Schedule II and Clause 5 of Schedule III, and is not chargeable to GST under Section 9. Consequently, no question arises of using input tax credit for discharging GST on that transaction.

Conclusion: Assignment of long-term leasehold rights in land and building is not subject to GST; the show-cause notice and demand order were unsustainable.

Issues: Whether a writ petition challenging the Tribunal's recall order remains maintainable after the Tribunal has passed a final order pursuant to the recall.

Analysis: The recall order merged into and ceased to exist independently upon the Tribunal's final order. The final order had separately been challenged through the statutory tax appeal remedy; hence, the challenge to the antecedent recall order could not be sustained.

Conclusion: The writ petition challenging the recall order was not maintainable after merger with the final order, against the assessee.

Issues: Whether an adjudication order passed without granting the requested personal hearing could be sustained.

Analysis: The requested personal hearing was admittedly not afforded. Such denial constituted a flagrant breach of the principles of natural justice. An adjudicating authority must independently consider the reply to the show-cause notice and provide reasons for accepting or rejecting the explanation; a reply cannot be treated as an empty formality.

Conclusion: The adjudication order was unsustainable for violation of principles of natural justice and was set aside, with the assessee entitled to a fresh merits adjudication after a reasonable opportunity of hearing.

Issues: Whether the six-month period prescribed by Notification No. 22/2024-Central Tax for seeking rectification to avail the benefit of retrospective Section 16(5) is valid, particularly in the absence of a provision for extension in extraordinary circumstances.

Analysis: Section 148 authorises the Government to notify classes of registered persons and special procedures concerning registration, returns, payment and administration. The power to prescribe a special procedure was provisionally recognised. The remaining question requiring consideration is whether the notification's six-month limitation incorporates the safeguards required by Section 148, including a mechanism to address extraordinary circumstances.

Outcome: Matter listed for further hearing.

Issues: Whether subletting charges paid to MIDC as a condition for subletting leasehold property are deductible in computing taxable rental income, notwithstanding the statutory deduction under Section 24(a).

Analysis: The payment of subletting charges was a mandatory condition under the lease for earning rental income from the sublet property. The charges constituted an integral cost of earning that income, and taxable rental income had to be computed on the net amount after their reduction. The statutory deduction under Section 24(a) did not preclude this computation. The revenue had also accepted the claim in an earlier assessment year, and the contrary reliance on principles governing exemption notifications was inapposite.

Conclusion: The subletting charges paid to MIDC are deductible from rental income while computing income from house property; the disallowance is not sustainable.

Issues: (i) Whether an advance ruling on classification of roasted areca nuts could be issued where the identical question had already been decided by a court; (ii) Whether roasted walnuts are classifiable under Customs Tariff Item 2008 19 91; (iii) Whether concessional-duty benefit under Notification No. 46/2011-Cus dated 01.06.2011 is available for the imported goods.

Issue (i): Whether an advance ruling on classification of roasted areca nuts could be issued where the identical question had already been decided by a court.

Analysis: The classification of roasted areca nuts as other roasted nuts and seeds had already been affirmed under the corresponding tariff entry. No distinguishing facts or new circumstances were shown. Section 28I(2)(b) bars an advance ruling where the question raised has already been decided by a court.

Conclusion: No advance ruling was issued on classification of roasted areca nuts because the question was barred by Section 28I(2)(b) of the Customs Act, 1962.

Issue (ii): Whether roasted walnuts are classifiable under Customs Tariff Item 2008 19 91.

Analysis: High-temperature roasting changes the flavour, colour and texture of walnuts and makes them suitable for immediate consumption. Roasting exceeds the preservation treatments contemplated for fresh or dried nuts under Chapter 8. Heading 2008 specifically covers dry-roasted or fat-roasted nuts, so the specific Chapter 20 entry governs.

Conclusion: Roasted walnuts are classifiable under Customs Tariff Item 2008 19 91, in favour of the assessee.

Issue (iii): Whether concessional-duty benefit under Notification No. 46/2011-Cus dated 01.06.2011 is available for the imported goods.

Analysis: Eligibility for exemption must be established strictly under the applicable notification, tariff entry and prevailing conditions on the date of import. The importer must establish the originating status of the goods under the applicable origin requirements.

Conclusion: The concessional-duty benefit is available only upon proof of the prescribed country of origin to the satisfaction of the competent customs officer.

Final Conclusion: The application received a binding classification ruling for roasted walnuts, while the request concerning roasted areca nuts could not be entertained because the identical classification issue stood previously decided; exemption entitlement remains dependent on proof of origin.

Ratio Decidendi: Roasted nuts, being prepared products specifically covered by Heading 2008, are not classifiable as fresh or dried nuts under Chapter 8; an advance ruling is barred where the identical question has already been decided by a court.

Issues: Whether an assessee that replied to a show-cause notice may invoke the applicable remedy of appeal where the order-in-original was served only by uploading it on the common portal.

Analysis: The petitioner's reply to the show-cause notice established knowledge of the notice. The governing principle for an order passed after contest and served solely through the common portal is that such portal upload does not trigger the limitation period for appeal; the assessee may avail the appellate remedy within the period prescribed by the applicable directions. The challenge to the State notifications was not pressed, while the challenge to the Central notifications remained subject to the Supreme Court's eventual decision.

Conclusion: The petitioner may avail the statutory appellate remedy in accordance with the governing directions; the issue is decided in favour of the assessee.

Issues: Whether interest is payable on the refund of IGST collected on ocean freight from the date of its original payment.

Analysis: The claim was accepted as identical to the precedent governing refund of IGST levied on ocean freight. That precedent treats the declaration invalidating the levy as operative from inception, absent an express prospective limitation, and recognises that interest compensates the taxpayer for being deprived of the refunded amount during its retention by the authorities.

Conclusion: The assessee is entitled to interest on the refunded IGST in the manner specified in the governing precedent.

Issues: Whether rejection of condonation of an 18-day delay in furnishing Form 10B for claiming exemption was sustainable.

Analysis: The audit report was delayed by only 18 days during the continuing Covid-19 pandemic. The requirement of furnishing the audit report is procedural, and the report may be produced before the assessment or appellate authority upon sufficient cause. The pandemic-related inability to file the report was accepted as genuine, establishing genuine hardship. The delegated discretion under Section 119(2)(b) required a pragmatic application favouring substantial justice over technicality; the refusal did not reflect proper application of that discretion.

Conclusion: The rejection of condonation was invalid. The delayed Form 10B must be treated as having been filed within the prescribed period and taken into account for the exemption claim.

Issues: Whether the accused was entitled to regular bail in a prosecution alleging GST evasion through transportation of goods without invoices and e-way bills.

Analysis: The application was considered under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023. The record indicated that the accused was a transporter rather than a manufacturer or supplier, no computation or determination of GST liability attributable to him had been made, the charge sheet had been filed, he had remained in custody since 12.04.2026, and the trial was likely to take time. The assessment was made without commenting on the merits of the prosecution.

Conclusion: The accused was entitled to regular bail.

Issues: Whether the Revenue established sufficient cause for condonation of 156 days' delay in filing an appeal.

Analysis: Section 5 of the Limitation Act, 1963 permits condonation where sufficient cause is shown. The explanation disclosed the departmental process of scrutiny, obtaining opinions and approvals, collection of documents, settlement of the appeal memorandum and final approval for filing. A justice-oriented and pragmatic approach applies to bona fide administrative delays, and the decisive consideration is the sufficiency of the cause rather than the length of delay. The explanation was not shown to be mala fide or factually incorrect. Handwritten insertion of dates in the application did not, by itself, establish that it was mechanical or stereotyped.

Conclusion: The delay was sufficiently and bona fide explained and was condoned in favour of the Revenue.