Issues: Whether a charitable trust's exemption is wholly denied under section 11 upon loans or advances to trustees attracting section 13, or is restricted only to the income or benefit attributable to the violation.

Analysis: Section 13(1)(c), read with sections 13(2)(a) and 13(3), addresses application of trust income or property for the benefit of specified persons. The settled interpretation, reinforced by CBDT Circular No. 387 dated 06.07.1984, confines taxation at the maximum marginal rate to the portion of income that has enured for the benefit of such persons; the remaining income remains eligible for section 11 exemption. The subsequent statutory amendment was treated as recognising this established position. The contrary reliance on CBDT Circular No. 5P dated 19.06.1968 and the decision concerning Bharat Diamond Bourse was not accepted as requiring forfeiture of exemption over the entire charitable income.

Conclusion: Even if the trustee advances constitute a section 13 violation, denial of section 11 exemption is limited to the value of the benefit, if any, conferred on the trustees; exemption for the balance income remains available subject to other statutory conditions.

Issues: (i) Whether the difference between opening Capital Work-in-Progress and the amount capitalised could be assessed as revenue expenditure or taxable income; (ii) Whether the reduction in Pre-operative Expenses could be treated as amortisation and added to taxable income.

Issue (i): Whether the difference between opening Capital Work-in-Progress and the amount capitalised could be assessed as revenue expenditure or taxable income.

Analysis: The reconciliation established that the full opening Capital Work-in-Progress balance was accounted for through capitalisation into fixed-asset accounts and reversal of duplicate entries. Transfers from Capital Work-in-Progress to fixed assets were balance sheet reclassifications, while correction of duplicate entries neither created taxable income nor constituted allowable expenditure. No part of the disputed amount was debited to the Profit and Loss Account or claimed as a deduction, and the Revenue produced no contrary accounting material.

Conclusion: The difference did not represent revenue expenditure or taxable income; deletion of the addition was sustained in favour of the assessee.

Issue (ii): Whether the reduction in Pre-operative Expenses could be treated as amortisation and added to taxable income.

Analysis: The Pre-operative Expenses ledger reflected project-related capital expenditure transferred to fixed-asset accounts on capitalisation, along with reversals of duplicate entries. These were confined to balance sheet accounts and did not constitute amortisation charged to the Profit and Loss Account. A reduction in a balance sheet asset cannot itself justify an income addition unless it is shown to be an inadmissible expenditure, a deduction claimed, a taxable remission or cessation, or income under a charging or deeming provision. No such basis was established.

Conclusion: The adjustment was not amortisation of expenditure and did not give rise to taxable income; deletion of the addition was sustained in favour of the assessee.

Final Conclusion: Both disputed accounting adjustments were held to be non-taxable balance sheet entries, comprising capitalisation transfers and rectification of duplicate entries.

Ratio Decidendi: A balance sheet adjustment or reclassification cannot be assessed as income or revenue expenditure merely from a numerical movement in accounts, absent evidence of a Profit and Loss Account charge, a claimed deduction, or another statutory basis for taxation.

Issues: Whether penalty for underreporting of income could be sustained where deduction was claimed under a bona fide belief and had initially been accepted in assessment and rectification proceedings; and whether a penalty notice and order not specifying the applicable limb of the penalty provision could sustain the levy.

Issue (i): Whether penalty for underreporting of income could be sustained where deduction was claimed under a bona fide belief and had initially been accepted in assessment and rectification proceedings.

Analysis: The deduction claim had been accepted in the scrutiny assessment and again in an earlier rectification order. This supported the genuineness of the assessee's explanation and bona fide belief in making the claim. The statutory exclusion for a genuine explanation applied, and the discretionary nature of penalty required consideration of the particular facts rather than automatic imposition.

Conclusion: The income was not underreported income in the circumstances, and penalty was not leviable. This issue was decided in favour of the assessee.

Issue (ii): Whether a penalty notice and order not specifying the applicable limb of the penalty provision could sustain the levy.

Analysis: The notice and penalty order referred only to the general penalty provision without identifying the relevant sub-clause or limb under which the penalty was imposed. Such non-specification rendered the penalty unsustainable.

Conclusion: The penalty could not be sustained for failure to specify the applicable limb. This issue was decided in favour of the assessee.

Final Conclusion: The penalty imposed for alleged underreporting was deleted.

Ratio Decidendi: A penalty for underreporting cannot be imposed automatically where the assessee's claim rests on a genuine bona fide explanation accepted by the assessing authority in prior proceedings; the penalty notice and order must also specify the applicable statutory limb.

Issues: Whether the period during which the Interim Board for Settlement lacked quorum and was incapable of exercising jurisdiction must be excluded in computing the time limit for disposal of settlement applications under Section 127C(8A), as extended under Section 127C(12), of the Customs Act, 1962.

Analysis: The statutory settlement framework and its timelines must be read as a whole, consistently with the object of expeditious and effective settlement. The prescribed period necessarily assumes the continued existence of a duly constituted Interim Board capable of performing its statutory adjudicatory functions. A distinction exists between delay despite a competent forum being available and inability to decide because the forum lacks the legally required quorum. Treating both situations alike would make the statutory remedy dependent on administrative contingencies beyond the applicant's control and produce an arbitrary, unworkable result. The applicant had completed all required steps and the proceedings had been heard and reserved before the Board became non-functional.

Conclusion: The period from 01.10.2025 until the date of judgment, during which the Interim Board lacked quorum, must be excluded from computation of the statutory period. The settlement proceedings did not abate, and the abatement communications were unsustainable. This conclusion is in favour of the assessee.

Issues: Whether the petitioner should be permitted to seek rectification of the impugned assessment order under the statutory rectification mechanism.

Outcome: The writ petition was disposed of with liberty to seek rectification before the Proper Officer.

Issues: Whether cancellation of GST registration for non-existence at the declared principal place of business should be restored where the address discrepancy resulted from a genuine mistake and no GST demand was outstanding.

Analysis: The registered-address discrepancy concerned different offices in the same building and was attributed to redevelopment of the earlier premises. No GST dues were outstanding. Restoration, conditional upon payment of applicable charges, late fees and penalty, would enable lawful business operations while protecting revenue interests.

Conclusion: The cancelled GST registration is to be restored upon payment of applicable charges, late fees and penalty.

Issues: Whether the petitioner could seek interest on the refund released pursuant to the appellate order.

Analysis: Section 56 provides interest where a refund ordered under Section 54(5) is not made within sixty days of receipt of the refund application. Its proviso also covers a refund arising from a final order of an adjudicating authority, appellate authority, appellate tribunal or court, where the consequential refund application is not processed within sixty days.

Conclusion: The petitioner may apply to the competent authority for interest under Section 56, which must decide the application in accordance with law.

Issues: Whether the writ petition challenging the GST demand and appellate order should be entertained despite the statutory appellate remedy before the GST Appellate Tribunal.

Analysis: The MGST/CGST statutory scheme provides a complete appellate mechanism. Exercise of jurisdiction under Article 226 is discretionary and ordinarily inappropriate where an efficacious statutory remedy exists, particularly where resolution requires detailed examination of evidence. No established denial of natural justice, jurisdictional defect, or material indicating bias arose merely because the officer authorising inspection later acted as appellate authority; authorisation of inspection was distinct from adjudicatory functioning. The controversies concerning whether seized records represented suppressed sales or estimates, the applicable tax rate, and reconciliation of bank deposits and returns with the seized material were disputed factual matters requiring evidentiary appreciation.

Conclusion: The writ petition was not maintainable in the absence of exceptional grounds warranting bypass of the statutory appellate remedy.

Issues: Whether proceeds from sale of flats held by the assessee were taxable as capital gains or as business income.

Analysis: The asset was acquired and consistently reflected in audited accounts as an investment; the memorandum indicated an object of holding and leasing the flats; a broker was engaged to locate tenants; and the first sale occurred after a substantial holding period. The isolated project, absence of other similar projects, staggered sales over several years, and absence of volume, frequency, continuity or regularity characteristic of real-estate trading supported the assessee's investment intent. Although book treatment is not conclusive, it is a relevant factor when evaluated with the overall conduct and duration of holding. Further, the Revenue had accepted capital-gains treatment in earlier assessments, which had attained finality, and no material change in facts or incriminating material justified a different treatment for the relevant year. The principles governing adventure in the nature of trade require assessment of intention and the totality of circumstances; the burden to establish a trading character rested on the Revenue.

Conclusion: The sale proceeds were assessable under the head capital gains and not as business income, in favour of the assessee.

Issues: (i) Whether revisionary jurisdiction could be exercised over purchase disallowances already forming the subject matter of a pending first appeal; (ii) Whether the assessment order was erroneous and prejudicial to the interests of the Revenue because the Assessing Officer estimated profit on disputed purchases rather than adding the entire amount as unexplained expenditure, and did not treat an outstanding supplier balance as ceased liability.

Issue (i): Whether revisionary jurisdiction could be exercised over purchase disallowances already forming the subject matter of a pending first appeal.

Analysis: The disallowance relating to purchases from the two suppliers, including the genuineness of such purchases and the estimation of profit embedded therein, was already under challenge before the first appellate authority. Clause (c) of Explanation 1 to Section 263 confines revisionary power, where an assessment is the subject of an appeal, to matters not considered and decided in that appeal. The subject of the revision was part of the larger purchase-disallowance issue pending in appeal; the authorities relied upon for the contrary position concerned matters not appealed or a period preceding the relevant statutory amendment.

Conclusion: Revision under Section 263 in respect of the disputed purchases was barred and the revisionary order was invalid to that extent, in favour of the assessee.

Issue (ii): Whether the assessment order was erroneous and prejudicial to the interests of the Revenue because the Assessing Officer estimated profit on disputed purchases rather than adding the entire amount as unexplained expenditure, and did not treat an outstanding supplier balance as ceased liability.

Analysis: The assessment record showed that the Assessing Officer had called for and considered invoices, ledger accounts, transport and e-way bill records, bank-payment details, confirmations, and GST-related material before estimating the profit element on the purchases. A detailed inquiry followed by adoption of a legally plausible view cannot be revised merely because the Principal Commissioner prefers addition of the entire purchase amount under Section 69C. The decision supporting full addition on different facts was distinguishable. Further, the alleged non-genuineness of the supplier did not by itself establish remission or cessation of the outstanding trading liability; no material showed a write-back, waiver, remission, or cessation during the relevant year.

Conclusion: The assessment was not amenable to revision on either the purchase addition or the outstanding liability; the Principal Commissioner could not substitute a different view under Section 263, and no addition under Section 41(1) was warranted, in favour of the assessee.

Final Conclusion: The revisionary action failed both because it intruded into an issue pending in first appeal and because the original assessment reflected inquiry and a sustainable view, with no factual basis for treating the creditor balance as ceased.

Ratio Decidendi: Revisionary power cannot be used to revisit an issue pending in appeal or to substitute the revisional authority's view for a plausible view adopted after inquiry; a trading liability cannot be taxed as ceased without material establishing remission or cessation.

Issues: Whether interim stay of the order declaring the earlier advance ruling void ab initio should be granted pending final adjudication of the appeal.

Analysis: The questions concerning the scope of the power to declare an advance ruling void ab initio, the alleged misrepresentation of material facts, and procedural fairness require detailed examination at the final hearing. At the interim stage, staying the impugned order would revive the earlier ruling despite the finding of misrepresentation recorded in the impugned order.

Outcome: The appeal was admitted for final hearing, and the interim-stay application was dismissed.

Issues: (i) Whether the imported powdered Pelargonium sidoides root extract containing Maltodextrin as a carrier is classifiable as a vegetable extract under Customs Tariff Item 1302 19 19 or as a medicament under Customs Tariff Item 3003 90 90; (ii) Whether the goods qualify for the exemption under Serial No. 37 of Notification No. 45/2025-Customs dated 24.10.2025.

Issue (i): Whether the imported powdered Pelargonium sidoides root extract containing Maltodextrin as a carrier is classifiable as a vegetable extract under Customs Tariff Item 1302 19 19 or as a medicament under Customs Tariff Item 3003 90 90.

Analysis: Classification is governed by Rule 1 of the General Rules for Interpretation, read with the relevant heading terms, Chapter Notes and HSN Explanatory Notes. Heading 1302 covers vegetable extracts, including solid extracts produced by removal of extraction solvent; the addition of an inert material for handling, drying or standardisation does not alter the extract's classification. The manufacturing process comprised hydro-ethanolic extraction, filtration, vacuum drying and addition of Maltodextrin, without chromatographic purification, ultrafiltration, additional extraction cycles or other high-refinement processes. Vacuum drying was merely removal of solvent and did not constitute concentration or purification.

Analysis: The product consisted of one botanical extract and Maltodextrin functioning as an inert carrier, rather than two or more active therapeutic constituents mixed for therapeutic or prophylactic use. It was imported in bulk as raw material, not in measured doses or retail packs. Its intended use in pharmaceutical manufacture could not determine classification where the tariff description at import governed. The prior finding that the extract underwent concentration was unsupported by the record and was an apparent error of fact.

Conclusion: The goods are classifiable under Customs Tariff Item 1302 19 19 as other vegetable extracts, and not under Customs Tariff Item 3003 90 90, in favour of the assessee.

Issue (ii): Whether the goods qualify for the exemption under Serial No. 37 of Notification No. 45/2025-Customs dated 24.10.2025.

Analysis: Upon classification under Customs Tariff Item 1302 19 19, the goods fell within the relevant exemption entry. Availability of the concession remains dependent upon compliance with the notification conditions and assessment-stage verification.

Conclusion: The goods are eligible for the exemption under Serial No. 37 of Notification No. 45/2025-Customs dated 24.10.2025, in favour of the assessee.

Final Conclusion: The earlier advance ruling was modified by correcting the erroneous factual premise concerning concentration and by recognising the product as a simple vegetable extract with an inert carrier.

Ratio Decidendi: A single botanical extract remains classifiable as a vegetable extract where solvent removal and addition of an inert carrier do not amount to purification or create a medicinal mixture; downstream pharmaceutical use does not itself render it a medicament.

Issues: Whether the security-service provider could pursue its unpaid service claim in the ongoing corporate insolvency proceedings before the NCLT.

Analysis: The company is now undergoing the Corporate Insolvency Resolution Process before the NCLT. The claim for payment for security services may therefore be placed before that forum for consideration in the insolvency proceedings.

Conclusion: The petitioner may join the NCLT proceedings and submit its claim for unpaid security-service charges.

Issues: Whether dismissal of the applications seeking replacement of the interim resolution professional and consequential restraint on further Committee of Creditors proceedings warranted appellate interference.

Analysis: Appointment, continuation, or replacement of an interim resolution professional or resolution professional is governed by the statutory process under Sections 22 and 27 of the Insolvency and Bankruptcy Code, 2016, which entrusts the decision primarily to the requisite voting majority of the Committee of Creditors. The interim resolution professional is required to receive, verify and collate claims and maintain the creditor list; admission of claims of homebuyers resulting in reduction of other creditors' voting share, or admission of a claim for less than the amount claimed, does not by itself establish lack of integrity or justify removal. The professional entity's appointment and fees had been approved by the Committee of Creditors, and the resolution concerning the contract terms had not been acted upon pursuant to the earlier protective direction.

Analysis: Although conflict existed among creditor groups, the creditors in a class holding the majority voting share supported the interim resolution professional. The subsequent appointment of the interim resolution professional as resolution professional was not adjudicated because it arose after the impugned order, leaving parties to pursue available remedies before the appropriate forum. Replacement of the insolvency professional remains a Committee of Creditors-controlled process, and tribunal intervention is warranted only in exceptional circumstances; such circumstances were not established.

Conclusion: No ground was made out to interfere with rejection of the applications for replacement of the interim resolution professional or the consequential interim restraint.

Issues: Whether an adjudication order could be sustained where, after cancellation of registration, the show-cause notice was served only through the common portal and the assessee consequently remained unaware of the proceedings.

Analysis: The registration had been cancelled before issuance of the show-cause notice, which was uploaded solely through electronic mode more than three years later. The applicable departmental circular required physical service of notices where adjudication proceedings are initiated after cancellation of registration. Electronic portal service alone in those circumstances did not afford the assessee an effective opportunity to respond. A fresh opportunity was required to submit a reply, seek relied-upon documents or cross-examination, and participate in a personal hearing.

Conclusion: The ex parte adjudication order was unsustainable for want of effective service and adequate opportunity of hearing, in favour of the assessee.

Issues: Challenge to prohibition orders sealing the petitioner's premises pending GST search proceedings.

Outcome: The writ petition was disposed of by consent, without adjudicating the merits; the premises were directed to be de-sealed in the petitioner's presence and any search was to proceed in accordance with the applicable statutory procedure.

Outcome: Delay condoned and the Special Leave Petition dismissed; pending applications disposed of.

Issues: Whether the classification and duty consequences of imported sorbitol under the Advance Authorisation Scheme require fresh adjudication in light of the asserted fulfilment of export obligation and subsequently cited decisions.

Analysis: The appellant stated that sorbitol, imported for providing moisture to paste, was claimed under Chapter 2905, while certain import documents reflected Heading 382460 because of an admitted supplier error. The appellant relied on decisions said to establish that, where goods are imported under the Advance Authorisation Scheme and the export obligation is fulfilled, the department cannot dispute the goods imported. The Revenue did not oppose reconsideration of the matter in light of those decisions. Fresh examination by the adjudicating authority was therefore considered necessary.

Conclusion: The classification and consequential duty dispute is remitted for fresh adjudication after considering the cited decisions and further submissions of the appellant.