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    Personal hearing in GST adjudication remains mandatory; inadequate notice and an unreasoned adverse order require fresh determination.
    Adequate hearing before ex parte tax assessment requires fresh assessment after consequential demand and bank-account attachment are set aside.
    Garnishee recovery requires prior adjudication, consideration of taxpayer replies, and a personal hearing before coercive recovery proceeds.
    GST portal-only service of notices and orders is invalid when rules do not prescribe it as a service mode.
    Show cause notice limits GST demand grounds; wrong-head IGST payment may be appropriated against CGST and SGST liabilities.
    Transitional GST credit must be examined by GST authorities, while VAT authorities cannot recover tax, interest or penalties.
    Section 73 notice timing does not require a three-month notice-to-order gap; inconsistent tax assessments require fresh consideration.
    Blocked input tax credit applies to GST on industrial-land lease premiums used to construct a taxpayer's factory building.
    Passenger carriage under presumptive shipping taxation includes round cruises despite ancillary on-board hospitality and entertainment services.
    Fixed place permanent establishment dispute remained undecided as the Special Leave Petition failed for unexplained filing delay.
    Wilful tax evasion requires conscious intent, not delayed payment where bona fide instalments and full settlement negate mens rea.
    General public utility status can extend to trade-promotion bodies where charitable purpose predominates over incidental member benefit.
    Deemed dividend rules exclude public Trusts from "concern" status, so shareholder-trustee loans ordinarily remain outside the provision.
    Section 153C limitation begins on transfer of records, and a later satisfaction note cannot defer assessment timelines.
    Scientific warranty estimation, grossed-up royalty tax and eligible in-house research expenditure deductions were accepted; notice-format challenge fa...
    Timeliness of Black Money Act notices: CBDT guideline breach invalidates delayed foreign asset assessment proceedings.
    CSR donations to approved institutions remain deductible, while advance-tax and refund interest computations require factual verification.
    Accrual-based consultancy income cannot be taxed twice merely because Form 26AS reflects tax credit in a later year.
    Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
    Year-specific evidence for chit investments and actual interest payments required; averaging uncorroborated statements cannot support additions.
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      Interest on the refund amount of pre-deposit - the amount...

      Interest Granted on Pre-Deposit Refund Made Under Protest; Refund with Interest Due in 45 Days.

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      CustomsJanuary 27, 2023Case LawsAT
      Interest on the refund amount of pre-deposit - the amount remained with the revenue unadjusted by way of pre-deposit. - It is further found under the facts and circumstances, that such pre-deposit was made under protest - Such interest on refund should be granted within a period of 45 days from the date of receipt of copy of this order. - AT

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      ActsIncome Tax