Issues: (i) Classification and applicable GST rate of "Turmeric Extract / Curcuma Elixir"; (ii) Whether its MRP of Rs. 4,990 has any bearing on the applicable GST rate.

Issue (i): Classification and applicable GST rate of "Turmeric Extract / Curcuma Elixir".

Analysis: Chapter 30 applies to products intended for therapeutic or prophylactic use in diagnosis, treatment or prevention of a specific disease; food supplements for general health and well-being are excluded. Heading 2106 covers food preparations, including plant-extract dietary supplements intended for general health maintenance. Tariff Classification depends on the Common Parlance Test, Essential Character and Primary Use. The product was licensed and marketed as a food supplement for wellness, immune support and nutritional use, without a specific disease-related therapeutic claim. Its predominantly water-based composition, absence of separated essential oil, and lack of aromatic, perfumery, cosmetic or flavouring use also excluded classification under Chapter 33. The applicable rate under Heading 2106 was 18% before the rate revision and became 5% with effect from 22 September 2025 under the amended rate notification.

Conclusion: The product is classifiable under Heading 2106 and not under Chapter 30 or Chapter 33. It was taxable at 18% before 22 September 2025 and at 5% from that date. This is partly in favour of the assessee.

Issue (ii): Whether its MRP of Rs. 4,990 has any bearing on the applicable GST rate.

Analysis: GST rate determination follows the tariff classification and the applicable rate notification. Price becomes relevant only where the relevant entry contains an express Value-Based Rate Condition, which was absent for goods under Heading 2106.

Conclusion: The MRP of Rs. 4,990 has no bearing on the classification or applicable GST rate. This is against the assessee.

Final Conclusion: The product is treated as a nutraceutical food preparation, with its GST liability governed by the applicable Heading 2106 rate notifications and not by its retail price.

Ratio Decidendi: Goods presented and understood as dietary supplements for general wellness, without a specific therapeutic purpose, are classifiable as food preparations, and their GST rate is determined by the applicable tariff entry rather than MRP unless an express value condition applies.

Issues: (i) Whether customer-supplied paper and content printed with the printer's consumables are classifiable under Heading 9988 and constitute job work; (ii) Whether such Heading 9988 printing qualifies for the 5% GST rate under Entry No. 26; (iii) Whether printing religious books using the printer's paper and consumables is a supply of goods eligible for NIL or concessional GST or a printing service.

Issue (i): Whether customer-supplied paper and content printed with the printer's consumables are classifiable under Heading 9988 and constitute job work.

Analysis: Section 2(68) requires a treatment or process on goods belonging to another registered person for the activity to be job work. Where the customer supplies the paper and content, ownership of the paper and printed output remains with the customer. The printing activity is a treatment or process on goods owned by another and falls under Heading 9988 irrespective of the recipient's registration status; registration determines whether it is termed job work.

Conclusion: The activity is classifiable under Heading 9988; it is job work only where the recipient is GST registered, and otherwise is a treatment or process on goods belonging to another person. In favour of Assessee to that extent.

Issue (ii): Whether such Heading 9988 printing qualifies for the 5% GST rate under Entry No. 26.

Analysis: Items (ii) and (v) of Entry No. 26 prescribe the concessional rate for printing newspapers, books, journals and periodicals, and for printing goods under Chapters 48 or 49 that themselves attract central tax at 2.5% or NIL. The benefit applies both to job work and to treatment or process not qualifying as job work. Items (iv) and (vii) are residual entries taxable at 18%.

Conclusion: The 5% rate applies only to printing covered by the specified concessional sub-entries; all other Heading 9988 printing is taxable at 18%. Partly in favour of Assessee.

Issue (iii): Whether printing religious books using the printer's paper and consumables is a supply of goods eligible for NIL or concessional GST or a printing service.

Analysis: Paper, consumables and printing are naturally bundled supplies. Under Sections 2(30), 2(90) and 8, printing is the principal supply where identified content is supplied by the customer or selected from the public domain for a customer-specific order, while physical inputs are ancillary. The nature of the religious content does not alter the classification. Circular No. 11/11/2017-GST treats such arrangements as printing services rather than an independent publication and sale of books.

Conclusion: The activity is a composite supply whose principal supply is printing service, classifiable under Heading 9989 and taxable at 18%; it is not a supply of Chapter 49 goods and is not eligible for NIL or concessional GST as such. Against Assessee.

Final Conclusion: Customer-owned material printing is taxable under Heading 9988 at the rate determined by the applicable specific or residual entry, whereas religious-book orders using the printer's own paper and consumables are taxable as printing services.

Issues: (i) Whether a suit for employment-related salary, increments and claimed commission is a "commercial dispute" under Section 2(1)(c) of the Commercial Courts Act, 2015; (ii) Whether, if it is not a commercial dispute, the plaint must be returned rather than the suit being dismissed.

Issue (i): Whether a suit for employment-related salary, increments and claimed commission is a "commercial dispute" under Section 2(1)(c) of the Commercial Courts Act, 2015.

Analysis: Section 2(1)(c) of the Commercial Courts Act, 2015 is directed at genuine mercantile and commercial disputes and requires strict construction. An employment agreement is fundamentally a contract of personal service; claims for salary, increments, remuneration or employment-related dues do not acquire a commercial character merely because payment obligations or sales-related claims are involved.

Conclusion: An employer-employee dispute arising from an employment agreement is not a commercial dispute under the Commercial Courts Act, 2015. The issue is answered against the appellant.

Issue (ii): Whether, if it is not a commercial dispute, the plaint must be returned rather than the suit being dismissed.

Analysis: Where the forum lacks commercial jurisdiction, outright dismissal unnecessarily compels fresh expenditure and proceedings. The appropriate jurisdictional consequence is return of the plaint for presentation before the competent court.

Conclusion: The plaint must be returned for presentation before the appropriate court rather than the suit being dismissed. The issue is answered in favour of the appellant.

Final Conclusion: Employment-related monetary claims remain outside commercial-court jurisdiction, but the claimant is entitled to pursue the existing plaint before the competent non-commercial forum.

Ratio Decidendi: A dispute arising from a contract of personal service is outside the statutory definition of a commercial dispute, and a plaint filed before a forum lacking such jurisdiction must be returned for presentation before the competent court.

Issues: Whether the final assessment order was barred by limitation under section 144C(13) of the Income-tax Act, 1961.

Analysis: Section 144C(13) requires completion of assessment within one month from the end of the month in which the Dispute Resolution Panel directions are received. In the faceless electronic process, upload of the directions on the designated portal determines their receipt, and any subsequent internal transmission or availability to the Assessing Officer cannot extend the statutory period. As the directions were uploaded on 30.12.2025, the assessment was required to be completed by 31.01.2026; the order dated 19.02.2026 was beyond that period.

Conclusion: The final assessment order was time-barred and null and void; the issue was decided in favour of the assessee.

Issues: Whether an adverse GST order passed without affording the assessee a personal hearing is sustainable.

Analysis: A personal hearing is required where an adverse determination is contemplated. The Revenue could not establish that the assessee had been afforded such an opportunity. The absence of a hearing constituted a breach of the principles of natural justice.

Conclusion: The adverse order is unsustainable for denial of a personal hearing, and the assessee is entitled to a fresh determination after being heard.

Issues: Whether recovery of the outstanding demand should be stayed pending disposal of the appeal.

Analysis: The assessee consistently applied the Transaction Net Margin Method for benchmarking the arm's length price, which had been accepted in earlier years, whereas the adjustment for the relevant year was based on the Comparable Uncontrolled Price Method despite no demonstrated change in facts. This established a prima facie case and balance of convenience for interim protection. The statutory payment requirement under the second proviso to Section 254 of the Income-tax Act, 1961 was applied.

Conclusion: Stay of recovery was granted in favour of the assessee upon payment of 20% of the outstanding demand, with stay of the balance for 180 days or until disposal of the appeal, whichever is earlier.

Issues: Whether the stay of recovery of disputed income-tax demand should be extended pending disposal of the appeal and acceptance of the Advance Pricing Agreement.

Analysis: Non-disposal of the appeal was not attributable to the assessee. The assessment year was covered by the pending Advance Pricing Agreement, and the assessee had complied with the earlier stay condition by furnishing a bank guarantee. The existing prima facie case, balance of convenience and relative hardship continued to support protection against recovery.

Outcome: Stay of recovery of the disputed demand was extended for 180 days, or until disposal of the appeal or acceptance of the Advance Pricing Agreement by the assessee, whichever occurred earlier.

Issues: (i) Whether working capital adjustment must be granted for differences in inventory, trade receivables and trade payables while benchmarking the trading segment; (ii) Whether an alternative deduction claim under section 80G for CSR contribution to the PM CARES Fund can be entertained and allowed despite not having been made in the return of income.

Issue (i): Whether working capital adjustment must be granted for differences in inventory, trade receivables and trade payables while benchmarking the trading segment.

Analysis: Rule 10B(3) permits adjustment where differences between the tested party and comparables materially affect price, cost or profit and the effect can be eliminated through a reasonably accurate computation. Working capital differences may affect operating margins because funds remain blocked in inventory or receivables, or are available through trade credit. The adjustment cannot be rejected in principle, but its grant depends on verification of reliable data and the accuracy of the computation. The working-capital computation and supporting material furnished by the assessee had not been examined.

Conclusion: In favour of the assessee: the working capital adjustment claim shall be verified and appropriate adjustment granted if factually correct and capable of reasonably accurate computation.

Issue (ii): Whether an alternative deduction claim under section 80G for CSR contribution to the PM CARES Fund can be entertained and allowed despite not having been made in the return of income.

Analysis: The alternative claim arose from the same CSR payment already forming part of the assessment proceedings and disallowed in computing business income. An appellate authority has jurisdiction to entertain a claim not made in the return where it arises from facts on record. Disallowance of CSR expenditure as a business deduction does not itself bar an otherwise admissible deduction under section 80G. Eligibility depends upon verification of the payment, eligible donee, prescribed receipt, mode of payment and statutory limits.

Conclusion: In favour of the assessee: the alternative section 80G claim is maintainable and shall be allowed if the statutory conditions are verified to be fulfilled.

Final Conclusion: Both claims require fresh factual verification under the applicable statutory conditions, with consequential relief available on satisfaction of those conditions.

Ratio Decidendi: A tax adjustment or deduction claim arising from facts already on record cannot be declined merely in principle or solely because it was not claimed in the return; it must be considered upon verification where the governing statutory conditions permit relief.

Issues: Whether a woman accused of money laundering is exempt from the twin conditions for bail under the first proviso to Section 45(1) of the Prevention of Money Laundering Act, 2002, and whether regular bail should be granted on the facts of the case.

Analysis: The first proviso to Section 45(1) exempts every woman accused from the statutory twin conditions without permitting sub-classification based on education, status, or professional standing. The expression "may be" makes the proviso enabling and discretionary, not an automatic entitlement to bail. The exemption is confined to the twin conditions; ordinary bail considerations, including the prima facie case, gravity, attributed role, likelihood of absconding, and possibility of witness or evidence tampering, continue to apply. The protective dispensation is consistent with substantive equality and the protection available to women under Article 15(3) of the Constitution of India.

Analysis: The petitioner had undergone more than seven months of custody; the prosecution complaint had been filed and no further custodial interrogation was shown to be necessary. With 73 proposed witnesses and voluminous documentary material, the trial at the pre-cognizance stage was unlikely to conclude soon. The record did not disclose tangible material establishing flight risk, vulnerable witnesses, or a likelihood of interference with evidence, which was substantially documentary and electronic and already in the investigating agency's custody.

Conclusion: The statutory discretion under the first proviso to Section 45(1) was exercisable in favour of the petitioner, and regular bail was warranted subject to protective conditions.

Issues: (i) Whether the assessee and its overseas counterparty were associated enterprises under section 92A; (ii) Whether the overseas counterparty could be selected as the tested party using foreign comparables; (iii) Whether regulatory affairs services could be re-characterised as knowledge process outsourcing services and benchmarked using the selected comparables.

Issue (i): Whether the assessee and its overseas counterparty were associated enterprises under section 92A.

Analysis: Section 92A(1) addresses participation in management, control or capital, while section 92A(2) specifies circumstances in which enterprises are deemed associated. The business of the overseas entity was wholly dependent upon the regulatory affairs and compliance processes performed by the assessee, attracting section 92A(2)(g). The associated-enterprise relationship had also been reported in the transfer-pricing study and Form 3CEB.

Conclusion: The entities were associated enterprises under section 92A(2)(g), against the assessee.

Issue (ii): Whether the overseas counterparty could be selected as the tested party using foreign comparables.

Analysis: Tested party selection requires reliable comparable data. Where the tested party and all proposed comparables are outside India and their data cannot be readily accessed and verified, their geographical and economic circumstances cannot reliably establish the arm's length price for the Indian transaction. The selection of the assessee as the tested party was therefore justified.

Conclusion: The overseas counterparty could not be accepted as the tested party on the facts, against the assessee.

Issue (iii): Whether regulatory affairs services could be re-characterised as knowledge process outsourcing services and benchmarked using the selected comparables.

Analysis: Rule 10TA(g) contains an exhaustive definition of knowledge process outsourcing services and does not specifically cover the domain-specific regulatory affairs services rendered. The selected companies were engaged in materially different activities, including research and development, engineering, information technology, information technology enabled services, advertising and gaming. Their selection based on isolated descriptions in annual reports was inconsistent with a proper Functional, Asset and Risk Analysis and comparability analysis.

Conclusion: The re-characterisation as knowledge process outsourcing services and the selected comparables were unsustainable, in favour of the assessee; fresh benchmarking with appropriate comparable companies is required.

Final Conclusion: The associated-enterprise relationship and selection of the assessee as tested party remain valid, but the arm's length price must be freshly determined by benchmarking the actual regulatory affairs services against functionally comparable entities after providing opportunity to furnish relevant material.

Ratio Decidendi: A transfer-pricing comparability analysis must reflect the actual functional profile of the services; domain-specific regulatory affairs services cannot be treated as knowledge process outsourcing services unless they fall within the applicable statutory definition.

Issues: Whether the petitioner was required to make a further statutory pre-deposit for filing an appeal before the GST Appellate Tribunal where the disputed tax had already been paid under the Integrated Goods and Services Tax regime.

Analysis: The dispute concerned the classification of supplies as inter-State or intra-State supplies and consequent liability under CGST and SGST instead of IGST. Since the demand did not concern excess availment of input tax credit and the corresponding tax had already been deposited under the IGST regime, a further deposit was not warranted for pursuing the statutory appellate remedy under Section 112.

Conclusion: The petitioner may file an appeal before the GST Appellate Tribunal within one week without making the statutory 10% pre-deposit; all questions on the merits remain open.

Issues: Whether closure of the criminal case was sustainable when the tax liability had not attained finality at the time of the closure order.

Analysis: The closure order proceeded on the premise that the purpose of prosecution had been satisfied, although the assessment and appellate orders had been set aside in part and remitted for fresh consideration. The tax liability was determined and discharged only after the closure order. The closure order therefore did not record a sustainable basis for treating the liability as fully satisfied. Subsequent developments require consideration by the Trial Court.

Conclusion: The closure order was unsustainable and the Trial Court must reconsider the matter in accordance with law after considering subsequent developments.

Issues: Whether a Mauritius resident assessee may claim set-off and carry forward of capital losses arising from shares acquired before 1 April 2017, by electing the more beneficial provisions of the Income-tax Act over the India-Mauritius tax treaty.

Analysis: Section 90(2) permits the assessee to apply the Act or the applicable treaty, whichever is more beneficial. The treaty cannot be compulsorily imposed upon the assessee. The co-ordinate-bench rulings applied recognise that exempt capital gains under Article 13 do not enter computation of total income, and that capital-loss claims determined or claimed under the Act may be carried forward in accordance with the Act. The earlier acceptance of brought-forward losses also supported their continued availability.

Conclusion: The assessee is entitled to the claimed set-off and carry-forward treatment of its current-year and brought-forward long-term capital losses; the Assessing Officer shall recompute taxable income accordingly.

Issues: Whether the service-tax demand order could stand when the relevant work contracts and agreements were subsequently placed on record for consideration.

Analysis: The relevant contractual materials were available for examination, and the Department agreed that the matter required fresh consideration on the basis of the complete record. A fresh decision was also required after permitting production of any further relevant documents and affording an opportunity of hearing.

Conclusion: The impugned demand order was set aside and the matter was directed to be decided afresh by the competent Commissioner on the available and further relevant materials.

Issues: Whether an adjudicating authority may confirm tax and penalty beyond the amounts proposed in the show cause notice.

Analysis: Section 75(7) prohibits confirmation of a demand exceeding that specified in the show cause notice. The notice proposed tax of Rs. 96,000 and penalty of Rs. 20,000, whereas the adjudication order confirmed tax of Rs. 96,000 and penalty of Rs. 96,000. The excess confirmation violated the mandatory statutory limitation and was without jurisdiction.

Conclusion: The adjudication order confirming penalty beyond the show cause notice was invalid and was set aside in favour of the assessee.

Issues: (i) Entitlement to credit for tax deducted at source where the deductor failed to deposit the deducted tax with the Central Government. (ii) Enforceability of a demand arising from an intimation under Section 143(1) where proof of service of the intimation was unavailable.

Issue (i): Entitlement to credit for tax deducted at source where the deductor failed to deposit the deducted tax with the Central Government.

Analysis: Section 205 of the Income-tax Act, 1961 protects an assessee against recovery of tax deducted at source from its income. The applicable directions governing verification of a claim for credit where deduction is established but remittance by the deductor has failed were adopted. The admitted insolvency claim against the deductor related to unpaid receivables and did not preclude the assessee from seeking TDS credit.

Conclusion: In favour of the assessee: upon verification of deduction, TDS credit and consequential relief must be granted notwithstanding the deductor's non-deposit of the tax.

Issue (ii): Enforceability of a demand arising from an intimation under Section 143(1) where proof of service of the intimation was unavailable.

Analysis: An intimation under Section 143(1) determining a payable sum is deemed to be a notice of demand under Section 156(1), and its service upon the assessee is mandatory. As no proof of service of the relevant intimation was available, the asserted demand could not be enforced. Consequently, recovery and adjustment of refunds under Section 245 could not rest on that demand.

Conclusion: In favour of the assessee: the demand for Assessment Year 2011-12 was quashed, and no recovery or refund adjustment could be made against it.

Final Conclusion: The assessee is entitled to verification-based TDS credit for Assessment Year 2010-11, while the unenforceable demand for Assessment Year 2011-12 cannot support recovery or adjustment of refunds.

Issues: (i) Whether contemporaneous additional evidence concerning intra-group support-service payments should be admitted and the transfer-pricing adjustment be reconsidered; (ii) Whether Reserve for Unexpired Risks, not debited to the statement of profit and loss, can be added to book profit under clause (b) of Explanation 1 to section 115JB of the Income-tax Act, 1961.

Issue (i): Whether contemporaneous additional evidence concerning intra-group support-service payments should be admitted and the transfer-pricing adjustment be reconsidered.

Analysis: The evidence comprised primary contemporaneous material directly bearing on the rendition and receipt of services, benefit derived, underlying costs and arm's-length character of the payments. The short time allowed to respond to the show-cause notice and the explanation for non-production constituted sufficient cause. Since the material had not been verified by the lower authorities, its probative value required examination at the assessment stage with opportunity to both sides.

Conclusion: The additional evidence was admitted and the transfer-pricing issues were restored for fresh determination. This is in favour of the assessee.

Issue (ii): Whether Reserve for Unexpired Risks, not debited to the statement of profit and loss, can be added to book profit under clause (b) of Explanation 1 to section 115JB of the Income-tax Act, 1961.

Analysis: The identical issue had already been decided in the assessee's earlier assessment years. A reserve not debited to the statement of profit and loss does not satisfy the condition for adjustment under clause (b) of Explanation 1 to section 115JB. The basis of the contrary adjustment did not survive in light of the earlier coordinate-bench determination.

Conclusion: Reserve for Unexpired Risks not debited to the statement of profit and loss cannot be added to book profit under clause (b) of Explanation 1 to section 115JB. This is in favour of the assessee.

Final Conclusion: The transfer-pricing matters require de novo consideration on the admitted record, and the consequential book-profit computation must conform to the settled position on Reserve for Unexpired Risks.

Ratio Decidendi: An amount carried to a reserve that has not been debited to the statement of profit and loss cannot be added to book profit under clause (b) of Explanation 1 to section 115JB.

Issues: Whether input tax credit for Financial Year 2018-19 could be denied where the return was filed on 23.10.2019 in light of Section 16(5).

Analysis: Section 16(5) overrides the limitation in Section 16(4) and permits a registered person to avail input tax credit relating to Financial Years 2017-18 to 2020-21 through a return filed up to 30.11.2021. The return for Financial Year 2018-19 was filed on 23.10.2019, within the period preserved by that provision.

Conclusion: The claimed input tax credit could not be denied under Section 16(5), in favour of the assessee.

Issues: (i) Whether cash receipts in Specified Bank Notes towards repayment of existing micro-finance loans could be assessed as unexplained cash credits; (ii) Whether the separate addition of interest income embedded in the loan repayments could be sustained.

Issue (i): Whether cash receipts in Specified Bank Notes towards repayment of existing micro-finance loans could be assessed as unexplained cash credits.

Analysis: Section 68 requires a satisfactory explanation of the nature and source of a sum credited in the books. The receipts were supported by audited financial-statement disclosures, regular cash-book entries, cash-flow details, deposit particulars and borrower confirmations. Repayment of loans already advanced and recorded as receivables reduces the outstanding receivable and does not constitute a fresh unexplained credit. The books and underlying loan portfolio were not rejected or shown to be non-genuine. Receipt in demonetised currency, or non-service of certain third-party notices, without contrary material disproving the repayments, did not establish undisclosed income.

Conclusion: The cash repayments were explained recoveries of existing loan receivables and could not be added as unexplained cash credits. This issue is decided in favour of the assessee.

Issue (ii): Whether the separate addition of interest income embedded in the loan repayments could be sustained.

Analysis: The interest component of the instalments had been credited in the books and offered to tax. As the principal receipts were not liable to treatment as unexplained cash credits, the consequential addition concerning the same receipts had no independent basis and would result in taxation of income already offered.

Conclusion: The separate interest addition could not survive and was deleted. This issue is decided in favour of the assessee.

Final Conclusion: The additions founded on the characterisation of documented loan recoveries as unexplained credits, including the consequential interest addition, do not stand.

Ratio Decidendi: Repayment of an existing and recorded loan receivable, supported by regular books and corroborative evidence, cannot be treated as an unexplained cash credit merely because it was received in demonetised currency.

Issues: Whether writ jurisdiction should be exercised to adjudicate disputed facts concerning service of the show cause notice, hearing notice and order-in-original despite an available statutory appeal.

Analysis: The alleged non-service and denial of hearing were disputed, with the respondents asserting service through speed post, e-mail and the web portal. These factual controversies could appropriately be examined by the statutory appellate authority. As an efficacious appeal was available, and denial of hearing could not conclusively be established at this stage, extraordinary jurisdiction under Article 226 was not invoked. The appellate authority was directed to consider, on merits and in accordance with law, any application for exclusion of the time spent pursuing the writ petition.

Conclusion: The petitioner was relegated to the statutory appellate remedy; the writ court declined to adjudicate the disputed service-related facts.