Mandatory nationwide e-way bill compliance for inter-State movement of goods took effect only from 1 April 2018, despite rule 138 having provided the operational mechanism earlier. Non-production of an e-way bill for goods intercepted before that date therefore did not justify detention or penalty. Correspondence between the goods, invoice and transport documents, coupled with the absence of discrepancies or material indicating intent to evade tax, supported deletion of the detention proceedings and penalty. The Revenue's challenge against that deletion failed.

E-way bill validity requires Part B to state the actual vehicle used for movement; a concession for minor clerical errors does not cover entirely different vehicle particulars. Transport under an expired e-way bill bearing a wholly different vehicle number may support a rebuttable presumption of intent to evade tax. Mens rea is not required for a civil fiscal penalty unless the governing enactment makes it essential. The presumption remains rebuttable through surrounding facts, but failure to provide a satisfactory rebuttal supports penalty under the CGST/UPGST transport-of-goods provisions. On the stated facts, the penalty was sustained and the second appeal dismissed.

Inverted duty structure refund computation requires accurate determination of turnover of inverted-rated supplies and adjusted total turnover. The treatment of outward supplies allegedly taxable at a higher rate must be verified before deciding whether they form part of the relevant turnover figures. Where supporting invoices or other documents are unavailable and the relevant issue has not been examined, the admissible accumulated input tax credit refund cannot be correctly quantified. Refund computation requires fresh examination after production of relevant records and a reasonable opportunity for both sides to address the turnover treatment.

Pre-GST service tax paid on advances for flat bookings later cancelled after the appointed day does not qualify as input tax under the CGST/SGST Acts and cannot be carried as GST input tax credit. Where services are ultimately unprovided, the transitional provision requires the service-tax refund claim to be processed under the existing law and paid in cash. Taxpayers cannot adjust that claim through an electronic credit ledger without specific statutory authority. The claimed GST credit was therefore inadmissible.

Reasoned appellate orders are required by natural justice: common GST appellate orders confirming demands were invalid because they gave only a general conclusion without addressing material appeal grounds, cited judicial authorities, or each appellant's distinct contentions. The failure to give cogent reasons constituted a failure to exercise appellate jurisdiction. Objections concerning show cause notices, availability of relied-upon documents, and effective personal hearing in original proceedings also required consideration. The Tribunal set aside the appellate and original orders and remitted the matters for fresh adjudication after providing relied-upon documents, allowing replies and effective hearings, and issuing reasoned orders.

Leasing digital cinema equipment comprising a projector, server, UPS and VSAT for a single rental is classified as a mixed supply where the items are not naturally bundled in the ordinary course of business and can be supplied independently. The bundled lease therefore does not meet the requirements of a composite supply. GST is payable at the highest rate applicable to any constituent supply, which is the rate applicable to the projector: 28% up to 21 September 2025 and 18% thereafter. The bundled-lease treatment as a mixed supply is accordingly correct.

Psyllium seeds (Isabgol) are classified under tariff sub-heading 1211 9013, supported by the express tariff description and HSN coverage of Plantago psyllium herbs and seeds. GST exemption as fresh or chilled plant parts under Entry 87 was denied for supplies stored in godowns before onward sale. Eligibility depends on the goods' condition when supplied by the applicant, and godown storage was treated as giving the seeds a dried character. The supplies were consequently taxable at 5% under Entry 71 of Schedule I. The alternative exemption for goods of seed quality under Entry 77 was also denied.

Professional coaching supplied by an entity that does not itself deliver a recognised qualifying curriculum, conduct examinations or award qualifications is not exempt as education by an educational institution and is taxable. Examination, registration and related student fees remain within taxable value unless all pure-agent conditions, including student authorisation and separate invoice disclosure, are met. Coaching bundled for a single fee with study materials and digital resources is a composite supply whose principal supply is commercial training. Retained foreign-exchange differences unconnected with separate consideration are outside GST. Training-partner services to universities are taxable where no exempt service or educational-institution status is established; insufficient contractual material prevents precise six-digit classification.

Advance-ruling jurisdiction under section 97(2) does not extend to eligibility for refund of unutilised input tax credit arising from an inverted duty structure; that question is therefore not admissible. Heading 4504 covers agglomerated cork with or without a binding substance, without limits on the binder's quantity or nature. Cork sheets formed from agglomerated cork granules held together by a polymer system, rather than cork used merely as a rubber filler, fall under tariff item 4504 10 10 and qualify for the concessional GST entry. The bar applies only where the same question is pending or decided in proceedings concerning the applicant; absent such proceedings, classification and rate questions remain admissible.

Reassessment under Section 147 cannot be used to review conclusions reached in an original scrutiny assessment. Where the Assessing Officer had specifically examined depreciation claims, deductions, exempt-income expenditure and pre-production income, reopening based only on the same assessment record and a successor officer's different inference constitutes a change of opinion. In the absence of fresh tangible material, a false statement, or failure to make full and true disclosure of material facts, no jurisdictional reason to believe that income escaped assessment arises. The reassessment was therefore quashed and the revenue's appeal dismissed.

Search-assessment limitation requires court-ordered stay periods to be excluded within the single composite limitation period before testing whether TOLA extends that date. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge the period available for completing assessments. For years affected by the stay, the composite limitation date fell outside the TOLA window; for the remaining years, the extension operated only until 30 September 2021. The assessments, related notices and consequential penalty proceedings for all nine assessment years were time-barred and quashed, while the merits of the additions remained open.

Reopening of a completed scrutiny assessment is invalid where tax deducted at source on salary payments was not claimed as expenditure or as a statutory deduction, but was mistakenly treated as claimed through a misreading of the tax audit report. Where the deduction position and tax withholding had already been examined and accepted during original scrutiny, reopening on the same material without fresh tangible material constitutes an impermissible change of opinion and demonstrates non-application of mind. The reassessment notice and consequential order were quashed.

Fixed "refurbish and rebate" credit notes issued to distributors for defective products did not constitute consideration for contract work where the credit was uniformly calculated at 30% of the original price, regardless of repair cost or whether repairs occurred, and distributors were not obliged to repair. Consequently, tax was not required to be deducted at source and the related disallowance was deleted. Employees' welfare contributions require verification against statutory due dates using challans and supporting material where the tax audit report's payment dates are disputed. Contributions paid within the prescribed due dates must be allowed; the issue was remanded for limited verification.

For charitable trusts, bank fixed deposits made for six months or more from the net consideration received on transfer of trust property qualify as another capital asset for capital-gains exemption under section 11(1A). CBDT Instruction No. 883 extends the expression to such deposits. Form No. 10 is unnecessary where the consideration has already been invested rather than accumulated for later application. Unrecoverable tax deducted at source may be treated as application of income where no refund has been claimed and the amount has a direct nexus with the trust's income receipts.

Under the India-UK DTAA, telecommunication-service receipts are treated as business profits rather than royalty or fees for technical services where treaty characterisation remains unchanged by unilateral domestic-law amendments absent bilateral renegotiation. On that basis, the taxability challenge concerning those receipts succeeded on merits. Reopening and limitation issues remained open, while a remaining ground was not pressed.

Enhanced penalty for misreporting under section 270A requires identification of a specific statutory category of misreporting and factual findings establishing its ingredients. Mere omission of salary, interest or rental income from a return, followed by detection during reassessment, does not by itself establish misrepresentation, suppression, failure to record receipts, or another prescribed form of misreporting. Under-reporting and under-reporting resulting from misreporting are distinct defaults with different penalty consequences. Where proceedings were initiated solely on the aggravated misreporting charge, an appellate authority cannot recast the levy as a penalty for ordinary under-reporting after the misreporting charge fails.

Ad hoc disallowance of employee-benefit and business expenditure lacks basis where no expenditure is identified as non-genuine, excessive or non-business, and the books are not rejected; missing vouchers justify item-specific verification, not a blanket estimate. Cash deposits attributed to recorded multi-outlet sales cannot be reclassified as unexplained cash credits without evidence that they comprised Specified Bank Notes or that the underlying books, sales or stock records were defective; taxing recorded receipts again produces double taxation. Loan credits require verification of lender records, immediate source, and repayment or adjustment entries; confirmations, PAN details and banking entries require assessment alongside those records, while unsecured or interest-free terms alone do not justify an addition.

Corporate guarantees issued for an associated enterprise's borrowing fall within capital financing and constitute international transactions where they enhance the enterprise's creditworthiness and expose the guarantor to risk. Arm's-length pricing is therefore required. Where no pricing method or transfer-pricing study computation is provided, an annual 0.5% guarantee fee determined using the uncontrolled-price standard under Rule 10AB is sustained. Guarantee fee is not profit derived from SEZ development and is ineligible for the SEZ deduction. Tax deducted at source credit reflected in Form 26AS requires verification before eligible credit is granted.

Employee long-term reward insurance premiums do not qualify as wholly and exclusively incurred for business where policies on directors' lives are not Keyman Insurance Policies, policy proceeds vest in the directors or their nominees, and the company receives no ultimate benefit. Premium deductions were therefore denied for the relevant assessment years. Reassessment may rest on later scrutiny findings where earlier acceptance did not involve examination of policy terms; each assessment year is separate and res judicata does not strictly govern income-tax proceedings. A change-of-opinion objection fails absent prior scrutiny of the claim. A challenge alleging no statutory approval for a reassessment notice requires supporting material or evidence that approval was sought.

Transfer-pricing adjustment for operational-expense reimbursements to foreign associated enterprises was deleted because the Other Method was applied without identifying an uncontrolled price or comparable transaction, and transfer pricing cannot test expenditure allowability or genuineness where no mark-up, inflated pricing, or non-business spending is established. Unutilised foreign tax credit relating to income taxed in earlier years cannot be claimed later as a business deduction: Rule 128 confines credit to the year corresponding income is offered or assessed in India. Payments to non-resident recruitment, legal and tariff-publication providers did not attract withholding absent proof of Indian taxability; tariff publication did not make available technical knowledge. The related disallowance was deleted.