Ex parte reassessments under Sections 147, 144 and 144B, coupled with dismissal of first appeals in limine for delayed filing, warrant a further opportunity to substantiate disputed transactions where additions have not been examined on merits. The assessee may present its case and supporting evidence before the Assessing Officer. If it fails to comply, the assessment may be completed on the material available in accordance with law.

Orders under section 201 issued in the name of an amalgamating company after it has ceased to exist under an approved amalgamation scheme are jurisdictionally invalid where the Revenue received timely notice of the amalgamation. Issuing a show-cause notice to the amalgamated company does not cure a final order addressed to, carrying the tax-deduction account number of, and served on the non-existent entity. The defect is not merely procedural: an order against the ceased entity is void ab initio. Principles concerning curable notice defects or delayed intimation do not apply where prior intimation was given.

Cash-deposit explanations based on agricultural income must reflect net income available after agricultural expenses, not gross receipts. Accordingly, only the net agricultural income supported the deposits, while the excess agricultural claim remained unexplained. Gift-based explanations require reliable evidence of donor identity, relationship and financial capacity. In the absence of confirmations, identity proof and evidence of capacity, only the accepted portion of gifts could explain the deposits; the remaining amount was treated as unexplained money under Section 69A.

Jewellery purchased from a company's disclosed income and held by its managing director for safe custody does not, by itself, establish that the managing director accepted a cash loan or deposit. Characterising the value of such jewellery as a cash loan requires evidence of an actual loan or deposit transaction; assumptions, presumptions and surmises are insufficient. On these facts, the alleged contravention of the cash-loan restriction was not established, and the related penalty was unsustainable.

Section 151 sanction for reopening may rest on available material indicating escaped income where no return was filed, provided the approval reflects application of mind rather than mechanical consent. Section 69 applies to investments not recorded in the books; a loan or advance recorded in the books and received through banking channels cannot be characterised as unexplained investment merely because the creditor's creditworthiness is doubted. Documentary support must be addressed, and an adverse creditworthiness finding requires enquiry from the creditor or other rebutting evidence; recourse to Section 68 does not cure an unsupported addition.

Breach of prescribed investment conditions by a charitable trust triggers forfeiture of exemption only for the income connected with the non-conforming investment. Under Section 13(1)(d), the proviso to Section 164(2), and Circular No. 387, eligibility for exemption under Section 11 remains distinct from the extent of exemption forfeited because of a statutory contravention. The maximum marginal rate applies only to the affected portion of income, while the trust retains Section 11 exemption for its remaining qualifying income.

Revisionary jurisdiction cannot be invoked over cash deposits merely because the Principal Commissioner adopts a different view after assessment. Where the Assessing Officer examined the deposits in detail during assessment, the assessment order is not erroneous or prejudicial to the interests of the Revenue on that issue. Revision is therefore impermissible where the existing assessment record establishes adequate inquiry.

Under the faceless reassessment framework, a jurisdictional assessing officer cannot validly issue a reassessment notice under Section 148 of the Income-tax Act. Issuance must conform to the prescribed faceless mechanism rather than the conventional jurisdictional-officer process. The legal position is presented as settled by an earlier ruling against the Revenue, rendering the impugned reassessment notice unsustainable and supporting the assessee's position.

Notional rental income under Section 23(1)(a) is not chargeable on unsold flats for the period before an occupancy certificate is issued. A property without an occupancy certificate is legally incapable of occupation; where it was neither legally occupiable nor actually occupied, no annual letting value can be attributed on a notional basis under income from house property. A completion certificate alone does not establish legal occupiability without an occupancy certificate.

Section 107(4) of the CGST Act confines condonation of delayed appeals to its express outer period; a statutory appellate authority has no inherent or equitable power to extend that limit, and writ relief cannot enlarge appellate jurisdiction. Departmental implementation of orders restoring cancelled GST registrations can preclude a challenge to that restoration where taxpayers have resumed business and reversal would disturb intervening transactions. The revocation remedy under Section 30 and Rule 23 operates independently of the appellate remedy under Section 107; expiry of the portal-based revocation period does not bar an appeal against registration cancellation.

Section 107 confines condonation of delay in statutory appeals to its express additional period; a first appellate authority has no inherent or equitable power to extend that outer limit. Constitutional relief under Article 226 does not expand that statutory appellate jurisdiction. Registration revocation and appeal operate as independent remedies, so inability to seek revocation through the portal after the prescribed period does not extinguish the right of appeal. Where appellate orders have been implemented by restoring registrations and enabling subsequent business transactions, reopening those orders without addressing the consequences may yield no effective relief; the implemented restoration prevents reopening the settled position in these proceedings.

Section 107 confines an appellate authority's power to condone delay to the prescribed outer period; equitable considerations or writ relief under Article 226 cannot enlarge that statutory jurisdiction. Failure to seek registration revocation within the Rule 23 period does not remove the independent appellate remedy against cancellation where portal functionality prevents timely revocation. Restoration of registrations pursuant to appellate orders enables resumption of business and renders subsequent departmental challenges ineffective unless the consequences of implementation are addressed. Statutory limitation therefore governs condonation, while implemented registration restoration remains unaffected.

Compulsory acquisition of land and buildings is a statutory exercise of eminent domain, not a voluntary supply of goods or services by the owner. Land and structures attached to or embedded in land constitute immovable property. Surrender of such property under compulsory acquisition does not amount to a sale of goods or provision of services, and the compensation payable cannot be treated as consideration for a taxable supply. GST deduction from acquisition compensation therefore lacked statutory authority; the deducted amount was required to be refunded with interest.

Rule 86A blocking of an electronic credit ledger is a provisional measure that requires recorded reasons and cannot continue beyond one year. Filing a GST appeal with the prescribed pre-deposit creates a deemed stay of recovery for the balance demand, preventing appropriation from the electronic cash ledger or blocked credit ledger. That stay does not automatically lift a subsisting Rule 86A blocking order. Unblocking remains subject to the separate Rule 86A mechanism, under which the affected person may seek consideration of an unblocking request.

Regular bail was warranted under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, after weighing the allegations, the petitioner's willingness to provide a voice sample, and parity arising from bail granted to 34 of 37 accused. Although the allegations concerned an organised tax-evasion arrangement and forensic examination of voice samples remained pending, those considerations did not require continued custody on the stated facts. The petitioner therefore met the threshold for regular bail.

Ex parte GST demand orders issued under the Section 73 adjudication framework require an effective opportunity to submit a reply and supporting material where medically supported pregnancy prevented the proprietor from participating. Expiry of the statutory appellate remedy under Section 107 because of limitation may leave the affected person without recourse to challenge the demand. The demand cannot be sustained without permitting the proprietor to place relevant documents and submissions before the adjudicating authority.

Omission of Rule 96(10) without a savings or sunset clause prevents its continued application to pending refund proceedings. The governing principle for omitted subordinate legislation requires express transitional preservation before an omitted rule can sustain pending action. A recommendation that the omission operate prospectively was advisory and did not retain the refund restriction. Refund claims therefore cannot be denied by keeping Rule 96(10) alive after its omission.

Service of a GST show-cause notice under Section 73(1), read with Rule 142(1)(a), must comply with the recognised modes under Section 169. Where records do not establish service through the GST portal, registered post, or e-mail, an ex parte demand and consequential appellate order cannot be sustained because the registered person was denied the opportunity to file objections and be heard. The registered person must receive the notice and be afforded an opportunity of hearing before fresh adjudication.

Input tax credit supported prima facie by available GSTR-2A/2B portal data, GSTR-3B returns and the annual return requires verification before an assessment can be sustained for non-production of return copies. The assessment was set aside for fresh consideration after verifying the asserted recovery of part of the tax demand and providing a reasonable opportunity. Bank attachment was to be lifted consequentially upon verification of the asserted recovery.

Anticipatory-bail jurisdiction under the CGST Act may be invoked before any formal arrest authorisation where circumstances objectively establish a real and reasonable apprehension of arrest. A Section 70 summons, requiring evidence or production of material, neither itself establishes arrest nor makes a pre-arrest application premature; Section 69 separately governs arrest. Pre-arrest protection remains exceptional and requires balancing personal liberty against investigative needs. Alleged organised tax evasion, material obtained in searches, links to an arrested person, non-cooperation, and the need to trace operational, financial and electronic evidence may justify further interrogation and refusal of protection despite an undertaking to cooperate.