Issues: (i) Whether the First Appellate Authority could condone delay beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could maintain appeals after implementing the impugned orders by restoring the taxpayers' registrations; (iii) Whether the taxpayers' inability to seek revocation within the period under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred their appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority could condone delay beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary period for appeal and Section 107(4) limits the further period for which delay may be condoned. The First Appellate Authority, being a statutory authority, could exercise jurisdiction only within those limits. Orders of a High Court under Article 226 of the Constitution of India, issued in the exercise of extraordinary constitutional jurisdiction on their particular facts, could not enlarge the statutory appellate jurisdiction. Equity follows the law; it cannot override an express statutory limitation. Condonation beyond the prescribed outer limit was ultra vires and coram non judice.

Conclusion: The First Appellate Authority lacked jurisdiction to condone the delays beyond the statutory outer limit. This issue is decided against the assessees.

Issue (ii): Whether the Department could maintain appeals after implementing the impugned orders by restoring the taxpayers' registrations.

Analysis: The Department acted upon the impugned orders by restoring the registrations, following which the taxpayers resumed business and discharged their obligations. This material subsequent development left no effective relief capable of being granted in the Department's challenge. The Department's inconsistent conduct engaged the principle that a party cannot approbate and reprobate by implementing an order and subsequently seeking its annulment without addressing the consequences of that implementation.

Conclusion: The Department could not maintain its challenge to the orders after implementing them through restoration of registrations. This issue is decided in favour of the assessees.

Issue (iii): Whether the taxpayers' inability to seek revocation within the period under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred their appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: The common portal did not permit applications for revocation after expiry of the prescribed period. The remedy of revocation under Section 30 and the appellate remedy under Section 107 operate as independent statutory remedies. The inability to pursue revocation under Rule 23 did not extinguish the right to challenge cancellation through appeal.

Conclusion: Non-compliance with Rule 23 did not bar the taxpayers from pursuing their statutory appeals. This issue is decided in favour of the assessees.

Final Conclusion: Although the statutory restriction on condonation of delay remains applicable, the restored registrations remain undisturbed because the Department's prior implementation of the impugned orders deprived its challenge of effective relief.

Ratio Decidendi: A revenue authority that has implemented an order restoring registration cannot subsequently pursue a challenge to annul that order where no effective relief can follow from such challenge.

Issues: Whether proceedings under Section 153C could be initiated where the satisfaction note did not link the alleged incriminating material to any particular assessment year.

Analysis: The satisfaction note merely recorded seizure of a hard disk and proposed initiation of proceedings for specified assessment years. It did not record how the seized material related to, or was relevant for, any particular assessment year. Such vague satisfaction was insufficient to assume jurisdiction under Section 153C.

Conclusion: Proceedings under Section 153C were invalid for want of a satisfaction note linking incriminating material to the relevant assessment years; the finding is in favour of the assessee.

Issues: Whether an ex parte GST demand order should be set aside to afford an effective opportunity of hearing where the proprietor's medically supported pregnancy prevented participation in the adjudication and the statutory appeal period had expired.

Analysis: The demand arose from adjudication under the Section 73 framework of the GST enactments. Medical records supported the proprietor's inability to participate during the relevant period due to pregnancy. As the order had been passed ex parte and the appellate remedy under Section 107 was no longer available owing to limitation, an effective opportunity to submit a reply and supporting documents was warranted.

Conclusion: The ex parte demand could not be sustained without affording the petitioner an opportunity to place her reply and relevant material before the adjudicating authority.

Issues: (i) Whether the First Appellate Authority could condone delay in filing an appeal beyond the outer limit prescribed by Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could maintain its appeals after implementing the impugned orders by restoring the registrations; (iii) Whether expiry of the period under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred recourse to the appellate remedy under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority could condone delay in filing an appeal beyond the outer limit prescribed by Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary limitation for an appeal, while Section 107(4) permits condonation only for the further statutorily limited period on sufficient cause. The First Appellate Authority, as a statutory authority, could exercise jurisdiction only within those limits. Orders of a High Court granting relief under Article 226 of the Constitution of India in the particular facts of writ proceedings could not enlarge the Authority's statutory power. Equitable considerations cannot override an express limitation provision.

Conclusion: The First Appellate Authority lacked jurisdiction to condone delay beyond the outer statutory limit; this issue was decided in favour of Revenue and against the assessees.

Issue (ii): Whether the Department could maintain its appeals after implementing the impugned orders by restoring the registrations.

Analysis: The Department had acted upon the impugned orders, restored the registrations, and thereby enabled the assessees to resume business and undertake transactions. That implementation was a material subsequent event which crystallised the parties' position. The Department could not seek annulment of the same orders without addressing the consequences of the restoration, and no effective relief could be granted through the appeals.

Conclusion: The Department could not maintain the challenges in the circumstances after implementing the impugned orders; this issue was decided in favour of the assessees.

Issue (iii): Whether expiry of the period under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred recourse to the appellate remedy under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: Since the common portal did not permit an application for revocation after expiry of the prescribed period, compliance with Rule 23 was not practically available. The remedy of appeal under Section 107 operated independently, and non-availment of revocation under Rule 23 did not extinguish the right to challenge cancellation through an appeal.

Conclusion: Expiry of the Rule 23 period did not bar the assessees from pursuing the appellate remedy; this issue was decided in favour of the assessees.

Final Conclusion: Although the condonation of delay beyond the statutory limit was declared jurisdictionally impermissible, the restored registrations and the legal position resulting from their implementation were not unsettled.

Ratio Decidendi: A statutory appellate authority cannot extend an expressly prescribed outer limit for condonation of delay by relying on equitable relief granted by a High Court in exercise of jurisdiction under Article 226 of the Constitution of India.

Issues: (i) Whether the First Appellate Authority could condone delay beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could maintain its challenge after implementing the appellate orders and restoring the registrations; and (iii) Whether failure to pursue revocation under Rule 23(1) of the Central Goods and Services Tax Rules, 2017 barred the taxpayers from pursuing the statutory appellate remedy.

Issue (i): Whether the First Appellate Authority could condone delay beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary limitation for an appeal, while Section 107(4) permits condonation only within the additional period expressly stipulated. A statutory appellate authority has no inherent or equitable power to extend this outer limit. Relief moulded by a High Court in exercise of Article 226 of the Constitution of India does not enlarge the statutory appellate jurisdiction of the First Appellate Authority. Equity follows the law; condonation beyond the legislatively prescribed limit is coram non judice and ultra vires.

Conclusion: The First Appellate Authority lacked jurisdiction to condone delay beyond the statutory outer limit; this issue is decided in favour of the Revenue.

Issue (ii): Whether the Department could maintain its challenge after implementing the appellate orders and restoring the registrations.

Analysis: The Department restored the registrations pursuant to the impugned appellate orders, enabling the taxpayers to continue business and undertake subsequent transactions. This material subsequent development altered the parties' legal and commercial position. Having implemented the orders, the Department could not seek their invalidation without addressing the consequences of restoration, and no effective relief could result from the challenge.

Conclusion: The Department could not maintain its challenge to orders that it had already implemented; this issue is decided in favour of the Assessee.

Issue (iii): Whether failure to pursue revocation under Rule 23(1) of the Central Goods and Services Tax Rules, 2017 barred the taxpayers from pursuing the statutory appellate remedy.

Analysis: The common portal did not practically permit an application for revocation after expiry of the prescribed period. The revocation mechanism under Section 30 of the Central Goods and Services Tax Act, 2017 and the appeal under Section 107 operate as independent statutory remedies. Inability to invoke the former does not extinguish the right to pursue the latter.

Conclusion: The taxpayers were not barred from pursuing the appellate remedy because they had not obtained revocation under Rule 23(1); this issue is decided against the Revenue.

Final Conclusion: Although the First Appellate Authority exceeded its statutory jurisdiction in condoning the delay, the Department's prior implementation of the orders and restoration of registrations prevented it from reopening the settled position through these proceedings.

Ratio Decidendi: A statutory appellate authority cannot condone delay beyond an express outer limit prescribed by legislation, and equitable relief granted by a constitutional court under Article 226 cannot enlarge that authority's statutory jurisdiction.

Issues: (i) Whether the First Appellate Authority could condone delay in filing appeals beyond the outer condonable period under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department's appeals remained maintainable after it had implemented the impugned orders and restored the respondents' registrations; and (iii) Whether the taxpayers' inability or failure to pursue revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred their statutory appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority could condone delay in filing appeals beyond the outer condonable period under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary limitation for an appeal and Section 107(4) permits condonation only within the further period expressly stipulated. The First Appellate Authority, being a statutory authority, possesses no inherent or equitable power to extend that outer limit. Relief granted by a High Court under Article 226 of the Constitution of India in the peculiar facts of a writ proceeding cannot enlarge the statutory appellate jurisdiction. Equity follows the law, and a statutory limitation cannot be overridden through reliance on constitutional-court directions.

Conclusion: The First Appellate Authority lacked jurisdiction to condone delay beyond the outer statutory limit; this issue is decided in favour of the Revenue.

Issue (ii): Whether the Department's appeals remained maintainable after it had implemented the impugned orders and restored the respondents' registrations.

Analysis: The Department implemented the impugned orders by revoking the registration cancellations, following which the taxpayers resumed business and their registrations remained active. This subsequent development materially altered the parties' legal and commercial position. The Department could not seek annulment of orders whose consequences it had voluntarily implemented, particularly where no effective or workable relief could thereafter be granted without unsettling intervening genuine transactions.

Conclusion: The Department could not maintain its challenge after implementing the impugned orders; this issue is decided against the Revenue and in favour of the assessees.

Issue (iii): Whether the taxpayers' inability or failure to pursue revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred their statutory appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: Once the prescribed period had elapsed, the common portal did not permit applications for revocation under Rule 23. The statutory remedy of revocation under Section 30 and the appellate remedy under Section 107 operate independently. Inability to avail revocation therefore did not extinguish or prejudice the taxpayers' right to challenge cancellation through an appeal.

Conclusion: Non-availment of the revocation route did not bar the taxpayers' appeals; this issue is decided against the Revenue and in favour of the assessees.

Final Conclusion: Although the First Appellate Authority's condonation beyond the statutory limit was jurisdictionally defective, the Department's implementation of the resulting restoration of registrations precluded it from unsettling that relief in the circumstances of these matters.

Ratio Decidendi: A statutory appellate authority cannot condone delay beyond an expressly prescribed outer limit by relying on relief moulded by a constitutional court in exercise of writ jurisdiction.

Issues: Whether, under the faceless reassessment framework, a jurisdictional assessing officer could issue a reassessment notice under Section 148 of the Income-tax Act.

Analysis: The questions raised were governed by a recent decision of the Court which had answered the same questions against the Revenue.

Conclusion: A jurisdictional assessing officer could not sustain issuance of the impugned reassessment notice under the faceless reassessment framework; the issue was decided in favour of the assessee.

Issues: Whether execution of the joint development agreement constituted a taxable transfer under Section 2(47)(ii), (v) and (vi) of the Income-tax Act, 1961, read with Section 53A of the Transfer of Property Act, 1882, so as to give rise to capital gains for the relevant assessment year.

Analysis: The appeal arose from the same joint development agreement and involved the identical controversy resolved by the binding decision referred to in the order. The findings in that decision on the legal effect of the agreement, the character of possession delivered to the developer, and the applicability of the statutory provisions governing transfer were adopted without fresh examination.

Conclusion: Execution of the joint development agreement did not result in taxable capital gains on the basis adopted in the assessment for the relevant assessment year.

Issues: (i) Whether compulsorily convertible debentures retained the character of debt until actual conversion, making the stipulated interest payment arm's length; (ii) Whether a separate notional-interest adjustment on delayed associated-enterprise receivables was sustainable despite working-capital adjustment and a uniform credit policy towards unrelated customers; (iii) Whether interest on compulsorily convertible debentures was alternatively disallowable as interest not paid on capital borrowed or as non-business expenditure.

Issue (i): Whether compulsorily convertible debentures retained the character of debt until actual conversion, making the stipulated interest payment arm's length.

Analysis: The transfer-pricing analysis required the actual pre-conversion instrument to be tested rather than replaced with an equity transaction merely because conversion was compulsory. The debenture holders had no voting or dividend rights before conversion, the instrument carried contractually stipulated interest, and the rate of 12% fell within the comparable uncontrolled price range of 12% to 14%. No defect in the interest-rate comparables was demonstrated. The prior acceptance of the same arrangement also supported the absence of a reasoned basis for a changed characterisation without any material change in facts or contractual terms.

Conclusion: The compulsorily convertible debentures remained debt until conversion, and the interest payment was at arm's length. The transfer-pricing adjustment on interest is deleted, in favour of the assessee.

Issue (ii): Whether a separate notional-interest adjustment on delayed associated-enterprise receivables was sustainable despite working-capital adjustment and a uniform credit policy towards unrelated customers.

Analysis: Although receivables may fall within the statutory ambit of an international transaction, the outstanding amount could not be isolated from the principal transaction where its funding effect had already been addressed through working-capital adjustment. The assessee's adjusted margin exceeded comparable margins, and substantially longer delays from unrelated customers were also allowed without charging interest. The minor delay from the associated enterprise therefore did not establish a separately benchmarkable financing arrangement.

Conclusion: No separate notional-interest adjustment on the delayed receivable was warranted. The adjustment is deleted, in favour of the assessee.

Issue (iii): Whether interest on compulsorily convertible debentures was alternatively disallowable as interest not paid on capital borrowed or as non-business expenditure.

Analysis: The alternate disallowance rested on the same rejected premise that the compulsorily convertible debentures were equity. Once the instrument was recognised as debt until conversion, the interest represented the contractual cost of borrowed funds. There was no finding that the expenditure was fictitious or that the funds were used for a non-business purpose; the absence of services rendered by the lender was immaterial to interest on borrowing.

Conclusion: The interest was deductible as interest on borrowed capital and could not be disallowed as non-business expenditure. The alternate disallowance is deleted, in favour of the assessee.

Final Conclusion: The assessment must exclude the transfer-pricing additions and the alternate interest disallowance arising from the pre-conversion compulsorily convertible debentures, with consequential computation being made in accordance with law.

Issues: Whether the arm's length price of electricity transferred from eligible captive power plants to the non-eligible cement unit for deduction under section 80IA should be determined at the tariff charged by the distribution licensee to that cement unit or at rates derived from supplies by generating companies to State distribution utilities.

Analysis: For a specified domestic transaction, clause (iii) of the Explanation to section 80A(6) requires market value to be determined as the arm's length price under section 92F(ii), namely a price applied in uncontrolled conditions. Under the Comparable Uncontrolled Price method in Rule 10B(1)(a), the rates at which independent generating companies supplied electricity to State distribution utilities could not qualify as uncontrolled comparables because those supplies and tariffs were regulated. The non-eligible cement unit was the appropriate tested party, and its purchase of electricity from the distribution licensee constituted a reliable internal comparable uncontrolled transaction. Differences between the suppliers did not impair comparability between the two purchases by the same consumer. Further, adding a 10% mark-up to an average of comparable prices impermissibly introduced an element of the cost plus method into the Comparable Uncontrolled Price method.

Conclusion: The arm's length price is Rs. 7.35 per unit, being the rate charged by the distribution licensee to the cement unit; the transfer-pricing adjustment is deleted and the deduction claimed under section 80IA is allowable.

Issues: (i) Validity of revisional jurisdiction under Section 263 of the Income-tax Act, 1961 on the alleged absence of enquiry into unsecured loans, trade payables and work-in-progress; (ii) Validity of revision on revenue-recognition and fixed-asset matters not proposed in the show-cause notice.

Issue (i): Validity of revisional jurisdiction under Section 263 of the Income-tax Act, 1961 on the alleged absence of enquiry into unsecured loans, trade payables and work-in-progress.

Analysis: Revision under Section 263 requires the assessment order to be both erroneous and prejudicial to Revenue interests. Explanation 2(a) applies where requisite enquiries have not been made, but does not permit revision merely because further or more elaborate verification was possible. The assessment record contained loan particulars, confirmations, return acknowledgments, lender responses to notices under Section 133(6), banking material, creditor ledgers, work-in-progress details, invoices and supplier ledgers. No particular lender, liability, expenditure or document was identified as non-genuine, false or unexplained. Financial and banking records furnished during revision were also not analysed to establish any specific defect. The material showed enquiry rather than a complete lack of enquiry; revision for an exploratory or roving enquiry was therefore impermissible.

Conclusion: The assessment was not shown to be both erroneous and prejudicial to the interests of Revenue in respect of unsecured loans, trade payables or work-in-progress; invocation of Section 263 on these matters was unsustainable, in favour of the assessee.

Issue (ii): Validity of revision on revenue-recognition and fixed-asset matters not proposed in the show-cause notice.

Analysis: The show-cause notice concerned verification of the source and composition of work-in-progress, whereas the revision order introduced a distinct revenue-recognition objection by proposing proportionate income instead of the consistently followed project-completion method. No examination was undertaken of project completion, contractual terms, accrual of enforceable rights or distortion of profits. Receipt of customer advances and substantial work-in-progress alone did not establish taxable accrual. The fixed-asset source issue was not included in the show-cause notice, and no unexplained source, incorrect capitalisation, inadmissible depreciation or Revenue prejudice was identified.

Conclusion: Revision could not be sustained on the revenue-recognition or fixed-asset matters, as they were either outside the show-cause notice or unsupported by a demonstrated error causing Revenue prejudice, in favour of the assessee.

Final Conclusion: Section 263 does not authorise an exploratory re-examination where the assessment record evidences actual enquiry and supporting material, nor may revision be enlarged beyond the stated show-cause grounds without establishing the statutory conditions.

Ratio Decidendi: Revision under Section 263 is unavailable merely because further enquiry may be possible; where the assessment record demonstrates enquiry, the revisional authority must identify a specific error causing prejudice to Revenue and cannot direct a roving re-enquiry.

Issues: (i) Whether the transport of coal in tipping trucks with loading by contractor's pay loaders is cargo handling service; and (ii) whether a service-tax demand could be sustained where the show-cause notice invoked a deleted charging provision and omitted the then applicable provision.

Issue (i): Whether the transport of coal in tipping trucks with loading by contractor's pay loaders is cargo handling service.

Analysis: Under the definitions of cargo handling service and goods transport agency service, cargo handling requires that the commodity has become cargo and that loading, unloading, packing or unpacking is independently undertaken as a service. Transporting coal through tipping trucks, with loading by pay loaders, constituted shifting of coal and did not satisfy the essential requirements of an independent cargo handling service.

Conclusion: The activity is not cargo handling service. This finding is in favour of the assessee.

Issue (ii): Whether a service-tax demand could be sustained where the show-cause notice invoked a deleted charging provision and omitted the then applicable provision.

Analysis: The applicable statutory provisions are those in force when the show-cause notice is issued. Reliance on an earlier provision that had ceased to operate could not validate the demand merely by reference to Section 66BA of the Finance Act, 1994.

Conclusion: The demand could not be sustained on the basis of the deleted provision. This finding is in favour of the assessee.

Final Conclusion: The proposed levy was not legally sustainable because the underlying activity was outside the taxable category invoked and the notice relied on an inapplicable charging provision.

Issues: Whether anticipatory bail should be granted in an alleged GST-fraud case where the applicant had six other similar criminal cases.

Analysis: The alleged offence involved fraudulent GST transactions resulting in substantial loss to the public exchequer. The applicant was also associated with six other cases of a similar nature. The gravity of the economic offence and the criminal antecedents weighed against extending pre-arrest protection.

Conclusion: The applicant was not entitled to anticipatory bail.

Issues: Whether the challenge to the GST demand should be pursued before the statutory appellate authority.

Analysis: The challenge required factual substantiation of the asserted exemption for fuelwood and charcoal. A substantial part of the confirmed demand had already been recovered, and the reference to Form GSTR-8A in the impugned order appeared to require clarification on the record. These matters were considered appropriate for appellate examination.

Outcome: Liberty was granted to file a statutory appeal within 30 days, to be decided without reference to limitation.

Issues: Whether an ex parte tax demand confirmed under Section 73 could be reconsidered upon a conditional opportunity to submit a reply and participate in adjudication.

Analysis: The demand had been confirmed without a reply to the show-cause notice. Although no basis existed to entertain the challenge or permit recourse to the appellate remedy, the ex parte nature of the adjudication warranted a limited opportunity consistent with principles of natural justice. That opportunity was made conditional upon filing a reply within the stipulated period and making a pre-deposit of the disputed tax.

Conclusion: Conditional fresh adjudication on merits after hearing the petitioner was directed upon compliance with the stipulated reply and pre-deposit requirements.

Issues: Whether the appellate order rejecting the GST appeal as time-barred under Section 107 should be set aside and the matter restored for merits consideration.

Analysis: The existing 10% pre-deposit and the petitioner's status as a government enterprise formed the basis for granting restoration upon a further 15% pre-deposit and submission of a detailed reply to the show-cause notice. Fresh consideration was directed without objection on statutory limitation. No final finding was made on the alleged excess input tax credit.

Conclusion: The appellate rejection was set aside and the matter was remitted for fresh adjudication on merits after compliance with the stipulated pre-deposit and reply requirements.

Issues: Whether the petitioner should be allowed to invoke the statutory appellate remedy despite expiry of limitation where the adjudication order had allegedly remained unserved.

Analysis: The factual basis for permitting the appeal was that 25% of the disputed tax had already been deposited pursuant to an earlier order, exceeding the pre-deposit required for an appeal, and that the petitioner claimed to have acquired knowledge of the adjudication order only upon initiation of recovery proceedings after changing its place of business.

Conclusion: The petitioner was permitted to file an appeal within 30 days, and the Appellate Authority was directed to entertain and decide it on merits without reference to limitation.

Issues: Whether approval for reassessment under Section 151 was valid where the sanctioning authority recorded that no response to the notice under Section 148A(b) had been filed, although the assessee had filed a response.

Analysis: The record established that the assessee had responded to the notice under Section 148A(b). The sanction recorded that no response had been filed and did not reflect consideration of that response. Approval based only on the Assessing Officer's proposal and materials, without demonstrable consideration of the assessee's response, was mechanical and lacked due application of mind. Since the order under Section 148A(d) rested on that approval, it could not be sustained.

Conclusion: The approval under Section 151 was invalid for non-application of mind; consequently, the order under Section 148A(d) and the notice under Section 148 were set aside, without precluding fresh proceedings in accordance with law.

Issues: (i) Whether rejection of the initial application for registration under section 12AB for alleged non-submission of information was justified and whether the subsequently granted registration should operate from the date of that initial application; (ii) Whether registration under section 12AB could be made subject to a condition concerning commercial receipts from sale of teaching-learning material and updating of returns; (iii) Whether rejection of approval under section 80G was sustainable.

Issue (i): Whether rejection of the initial application for registration under section 12AB for alleged non-submission of information was justified and whether the subsequently granted registration should operate from the date of that initial application.

Analysis: The assessee had existed since 1982, had earlier obtained registration, and its charitable character had been upheld in prior appellate proceedings. In these circumstances, rejection of the initial application without proper opportunity to furnish the required material was not justified, particularly when fresh registration was subsequently granted.

Conclusion: The initial rejection was unsustainable, and the registration was directed to take effect from 23.09.2025, the date of the initial application, in favour of the assessee.

Issue (ii): Whether registration under section 12AB could be made subject to a condition concerning commercial receipts from sale of teaching-learning material and updating of returns.

Analysis: Registration had been granted after satisfaction regarding the objects and activities, and no material established that the activities were contrary to the stated objects. A condition making continued registration dependent on subsequent return updating, based on the stated commercial-receipt concern, was inconsistent with the finding of genuine charitable objects and activities. Any cancellation of registration must follow due process of law.

Conclusion: The condition attached to registration, particularly the condition concerning commercial receipts and return updating, was unjustified; registration was directed to be granted without conditions, in favour of the assessee.

Issue (iii): Whether rejection of approval under section 80G was sustainable.

Analysis: In view of the direction for registration under section 12AB and the prior grant of section 80G approval, the application required reconsideration on the relevant material after providing a proper opportunity of hearing.

Conclusion: The section 80G application was restored for fresh consideration and grant in accordance with law.

Final Conclusion: Registration under section 12AB must operate from the original application date and remain unconditional, while eligibility for approval under section 80G requires fresh determination on the material placed before the competent authority.

Ratio Decidendi: Once genuine charitable objects and activities are accepted, registration cannot be burdened with conditions imposing prospective compliance requirements; any cancellation must be undertaken only through the prescribed legal process.