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    Condonation of delay in export remittance requires a reasoned order and an opportunity to be heard; matter remitted for fresh decision.
    Anti profiteering: directory limitation, benefit not passed where prices rose; interest from notification date, penalty non retroactive.
    Location of Supplier determines registration state; movement across States triggers IGST while intra state supplies attract CGST and SGST.
    Release of seized property: CBDT timelines mandate prompt release on adequate security; ownership affidavits required before release.
    Block assessment: pending proceedings abate when an Assessment Year falls in the block period, subject to factual prerequisites.
    Certificate under Section 195: declaratory Nil rate certificate substituted for issued rate, with prompt amendment and future issuance rules.
    Withholding Tax Certificate: NIL rate granted for Matching Solution services; withholding maintained for Support services pending further decision.
    Tax treaty exemption for airline operations: reduced-rate certificate set aside and NIL-rate certificate directed.
    Reopening of assessment invalid where taxpayer fully disclosed capital reduction records and securities premium payments, so proviso criteria unmet.
    Condonation of Delay in Form 10B: short delay condoned so trust retains entitlement to Sections 11 and 12 benefits.
    Preponderance of probabilities: court remitted assessment, allowing petitioner an opportunity to obtain seized documents and file replies.
    Genuineness of Purchases: limit additions to embedded profit element; commission expenses upheld where primary evidence exists.
    Estimation of income from unsubstantiated purchases upheld; reasonable profit rate adopted and 40(a)(ia) TDS disallowance sustained.
    Fees for Included Services: consultancy and subscription receipts not FIS or royalty; TDS credit allowed if income is offered.
    Customs Broker Liability: broker duty to advise does not create strict liability where evidence shows advice given; revocation set aside.
    Classification of goods: technical composition and precedent negate CHA culpability, so customs penalty set aside.
    Import permissibility of J3 Grade stainless steel upheld; penalties and forfeiture claims quashed under controlling precedent.
    Commercial identity test affirms transformer parts classification; departmental knowledge bars extended limitation and demand is set aside.
    Natural justice: Cancellation of GST registration requires objective reasons and specific particulars; vague show-cause notices are invalidated.
    Videography of statements during GST summons allowed as limited humanitarian accommodation where cooperation and serious illness are shown.
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      Petitioner challenged confirmation of a show-cause proposal for...

      Input Tax Credit reversal: interest applies only to the cash tax component; remand ordered to decide interest and penalty.

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      GSTFebruary 25, 2026Case LawsHC
      Petitioner challenged confirmation of a show-cause proposal for reversal of erroneously availed Input Tax Credit; court noted petitioner purportedly reversed the ineligible credit and remitted the matter for fresh adjudication to determine whether interest and penalty are payable. The court directed the respondent to apply the post Finance Act 2022 amendment limiting interest under Section 50 to the cash component of tax and to reconsider penalty liability under the GST enactments (penalty provision invoked in the impugned order). Petitioner must file a reply with documents to the show-cause within 30 days; writ petition disposed accordingly.

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      ActsIncome Tax