Reciprocal transfers of developed plots under a pre-existing arrangement for consolidating fragmented ownership may constitute valid consideration in kind, notwithstanding deeds showing nil monetary consideration. Section 43CA applies only where consideration received or accrued is below stamp duty value. Where each transfer was matched by equivalent land transferred to the transferor's nominees and no shortfall against stamp duty value was found, the deeming fiction did not apply. The section 43CA addition was deleted because the conveyances represented reciprocal exchanges rather than understated consideration.

Project-import assessment under Heading 98.01 depends on registration of the relevant contract on or before importation and before clearance for home consumption; execution of a foreign-supplier purchase order is not importation. Accordingly, only goods imported after contract registration may receive project-import treatment, subject to all other regulatory conditions, while goods imported before registration do not qualify. Post-clearance revision of a qualifying Bill of Entry remains available under Section 18A notwithstanding the restriction in Section 149, but remains subject to prescribed requirements. Consequential refund processing may follow for qualifying post-registration consignments.

Pre-CIRP export-obligation defaults cannot support continued Denied Entry List restrictions after an approved, unchallenged resolution plan extinguishes the Government's operational-debt claim and attached performance obligations. Coercive administrative orders issued against the corporate debtor during the insolvency moratorium were void ab initio, and the impugned orders and listing were set aside, subject to fresh lawful action for an independent subsequent default. Inaction by the final decision-making authority constituted part of the cause of action, supporting territorial writ jurisdiction. Availability of an alternative remedy did not oust constitutional writ jurisdiction.

Material defects in the Information Memorandum, including overstated debt, omission of guarantor recovery, erroneous creditor ranking and undisclosed SEZ de-notification, distort voting, valuation and resolution-plan feasibility; commercial wisdom cannot cure those defects. A corporate guarantor that pays the financial creditor is subrogated to secured rights only to the amount paid and must be ranked as a secured financial creditor. The financial creditor's claim against the principal borrower must be recomputed from the finally adjudicated debt after crediting recovery from the guarantor. A plan requiring conversion or sub-leasing of SEZ leasehold land without statutory consent or completed approvals is neither feasible nor viable. The process must restart with a corrected Information Memorandum and fresh resolution invitation.

GST limitation under Section 74 turns on issuance of substantive show-cause notices and adjudication orders, while Rule 142 requires consequential electronic summaries in Forms GST DRC-01 and DRC-07. Later dates on those forms do not invalidate notices or Orders-in-Original issued within the applicable limitation period. Challenges involving fraud, suppression, supplier knowledge or collusion, input tax credit entitlement, and departmental evidence require statutory appellate scrutiny where no denial of hearing or patent jurisdictional defect exists. Merits remain open before the Appellate Authority.

Rule 138B permits physical verification of a conveyance by a proper officer authorised by the Commissioner; an authorisation-based challenge fails where the officer holds that authority and no jurisdictional defect is established. Writ jurisdiction despite an alternative statutory appeal remains confined to exceptional circumstances, including infringement of fundamental rights, breach of natural justice, lack of jurisdiction, or challenge to statutory validity. Where a fresh show-cause notice, personal hearing, consideration of the reply, and relevant detention, verification and registration-cancellation material are provided, complaints concerning relied-upon documents require appellate examination. The writ challenge to confiscation was dismissed, leaving the statutory appeal available.

Alternative statutory remedy under GST required disputes over reclassification of animal nutrition products from feed supplements to medicaments to be pursued through the appellate process. Alleged variance between the show cause notice and adjudication order, tariff classification, applicable notifications, and denial of hearing or cross-examination required factual examination and did not establish an apparent jurisdictional defect warranting writ intervention. The High Court dismissed the writ petition, holding that avoidance of the prescribed pre-deposit was not a basis to bypass appeal, while permitting the statutory appeal and excluding the writ period for limitation.

Writ jurisdiction against a common CGST penalty order is unavailable where alleged natural-justice breaches are unsupported by any specific denial of hearing or non-consideration of material. Challenges concerning limitation, the initiating officer's competence, and penalty liability require examination of the adjudication record and statutory provisions within the appellate process; the writ petitions were therefore not entertained. Pre-deposit relief available under an earlier High Court ruling may be claimed only where its factual conditions and stipulated requirements are satisfied.

Anticipatory bail under the CGST Act requires a communicated order authorising arrest. Summons issued during an inquiry into alleged ineligible input tax credit do not, by themselves, make the recipient an accused or establish a legally sustainable apprehension of arrest. The statutory foundation for pre-arrest protection is an arrest-authorisation order made after the required reasons to believe; pending investigation, searches, summons, and a contingent risk of arrest cannot replace that requirement. Petitions founded only on summons were premature where no such order had been passed and communicated, without addressing the underlying allegations or investigation.

Section 129 transit penalties may operate on a strict-liability basis, but still require proof of a statutory breach attracting the penalty. Where invoices, e-way bills and bilty documents matched the goods, the buyer was identifiable, and historical records supported use of its former address, a repeated consignee-address entry was treated as a bona fide documentary error. In the absence of evidence of a fictitious purchaser, diversion, clandestine unloading, value suppression, or tax evasion, the discrepancy did not establish a substantive transit violation. The transit penalty and consequential recovery were annulled, while tax lawfully payable on the supply remained unaffected.

Rule 138(3)'s third proviso permits Part B conveyance details to remain unfilled during the specified initial intrastate movement from a consignor's business premises to a transporter's premises for further transportation. The exception covers movement to a transporter's warehouse for consolidation before onward dispatch, rather than every short-distance journey. A permitted omission does not constitute an actual contravention attracting a Section 129 penalty, despite its overriding language. Appeals below the statutory monetary threshold may be admitted where a substantive issue concerning this exception and the resulting penalty warrants consideration on merits.

GST interest on self-assessed return liabilities is discharged only when the Electronic Cash Ledger is debited towards the identified liability; a sufficient unappropriated cash balance does not stop interest until belated GSTR-3B filing. The later Rule 88B(1) proviso excluding amounts credited by the due date and continuously retained in that ledger operates prospectively, not for earlier periods. Notice proceedings remain valid where the taxpayer received the demand basis and computation, gave detailed replies, and established no actual prejudice. Denial of a requested personal hearing breached section 75(4), but did not require remand where the record was complete, the remaining issue was legal, and no lost substantive opportunity was identified. Interest demands were sustained, subject to reconciliation to prevent double recovery; substantive refund claims failed.

Prescription of a timeframe for deciding applications to cancel or surrender duplicate PANs was referred to CBDT for initial consideration because no prior representation had stated the grounds for such a timeframe. The petitioner may submit a detailed representation; CBDT must decide it in accordance with law within eight weeks of receipt and communicate the decision.

Upper turnover filter of Rs. 200 crore for selecting software-development comparables in transfer-pricing analysis was treated as valid under precedent. The Revenue's challenge failed because the issue was already covered in favour of the taxpayer, resulting in dismissal of its appeal for the relevant assessment year.

GST refund disclosure in a tax audit report does not, by itself, establish taxable income. GST is a statutory levy collected and paid on behalf of the Government, and its refund represents a return of tax paid rather than income. Where refunded GST or IGST was not claimed as expenditure in the profit and loss account, it cannot be taxed solely because of its disclosure in the tax audit report. Allowability of the refund remains subject to examination of supporting records and applicable law.

Omission of the provision defining related-party purchases as specified domestic transactions, without a saving clause, removed the statutory foundation for penalties for failure to furnish Form 3CEB. Omission is distinguished from repeal: absent a saving provision, it does not preserve a right to initiate or continue proceedings based on the omitted provision. Penalties imposed for the relevant assessment years were therefore unsustainable.

Recovery of the balance disputed tax demand arising from transfer-pricing adjustments was stayed pending appeal, conditional on deposit of 20% of the outstanding demand after excluding proportionate demand relating to services claimed to have been rendered to an associated enterprise. The stay operates for 180 days or until appeal disposal, whichever occurs first, subject to meeting the deposit condition and cooperating in early appeal disposal. No merits determination was made on the transfer-pricing additions.

Section 144C requires a draft assessment order before a final reassessment order imposes a prejudicial variation on a non-resident eligible assessee. Following the amendment to the definition of eligible assessee, non-residents other than companies are expressly covered. The draft procedure allows the assessee to accept the variation or seek directions from the Dispute Resolution Panel. Direct issuance of a final reassessment order without a draft order deprives the assessee of that statutory remedy. Such non-compliance is a jurisdictional defect rather than a curable procedural irregularity, rendering the final reassessment order invalid.

Extended limitation for recovering wrongly exempted Special Additional Duty was sustained where, following amendment of the relevant Schedule, the exemption was unavailable and RMS-facilitated imports were cleared on the importer's declaration. The Special Additional Duty demand and its appropriation consequently remained valid. Interest under Section 28AA and penalty under Section 114A on the confirmed duty demand were unsustainable under affirmed precedent and subsequent consistent Tribunal decisions, and were set aside. The modified order retained duty recovery while removing interest and penalty, with consequential relief in accordance with law.

Cross-segment derivatives trading was treated prima facie as manipulative where connected companies moved futures prices through aggressive orders while holding larger, sentimentally opposite options positions and pre-positioned options orders. Artificial futures-price movements enabled favourable options execution, while cancelled, inexecutable futures orders added deceptive order-book depth. Repeated deliberate futures losses coupled with greater options gains were considered inconsistent with legitimate hedging, arbitrage, speculation, or rational profit-maximising conduct. Company directors responsible for business conduct faced a rebuttable presumption of vicarious liability and joint-and-several impounding of gains attributable to their companies. Interim directions restricted market access, preserved assets and gains, and required asset disclosures pending investigation.