Royalty and fees for technical services under the India-Germany DTAA are taxable on receipt rather than accrual basis. Consideration for restricted, non-exclusive standard software licences that do not transfer copyright rights is not royalty under the Act or treaty. Separate scopes of work, invoicing, consideration and no profit-and-loss sharing prevent consortium members from constituting an association of persons; joint and several liability and indemnities alone are insufficient. Offshore equipment-supply income is not taxable in India merely because it forms part of a composite project. Transfer-pricing adjustments require a prescribed method and cannot rest on an ad hoc mark-up where transaction differences are reconciled and benchmarking is undisputed.

Termination compensation under a distribution arrangement that is substantively an agency relationship is treated as business income rather than a capital receipt, and taxation is confined to the settlement actually received. A non-compete covenant integral to acquiring and protecting a trademark qualifies as a depreciable intangible asset. For section 80-IB, only costs directly connected with an eligible undertaking should reduce its profit; allocation of finance, research, travel, head-office and export-promotion costs depends on factual nexus. Section 80HHC excludes receipts lacking a direct export nexus, while concurrent 80-IB and 80HHC deductions remain subject to the gross-total-income ceiling. A purely legal additional ground based on the existing record may be considered.

Enhancement of declared customs value during reassessment under section 17(4) requires a speaking order under section 17(5) of the Customs Act, 1962. Failure to issue that order violates the statutory requirement and makes the reassessment unsustainable. The declared value must be accepted, with the assessments and appellate order set aside and consequential relief granted.

PMLA provisional attachment of an NBFC's bank balance requires material establishing that the property constitutes proceeds of crime connected with a scheduled offence. FIR allegations alone were insufficient where final chargesheets did not arraign the NBFC or its lending application, and no material showed that an unauthorised fintech operated under its licence or that the NBFC received identified criminal proceeds. Legitimate lending income and an outstanding contractual loan cannot be characterised as proceeds of crime without supporting evidence. As no nexus was identified between the attached balance and criminal proceeds, confirmation of the attachment was set aside.

Tax classification of GRD Powder and GRD Mix depends on the goods' identity and physical form at the time of supply, not on their subsequent use after mixing with milk or water. Strict construction of taxing statutes requires classification at the taxable event; a purchaser's use cannot convert a powder or biscuit-form product into a beverage. The entry for non-alcoholic drinks and beverages, read ejusdem generis with syrups, cordials, distilled juices, ark and essences, covers liquids or liquid preparations. GRD Powder and GRD Mix therefore fall under the residuary entry rather than the specific entry for non-alcoholic drinks and beverages.

Retrospective pay-fixation claims arising from a common pay-scale anomaly may involve a recurring cause of action, reducing the force of limitation and laches objections where corrective recommendations and comparable implementation occurred shortly before relief was sought. Similarly situated Customs and Central Excise officers should receive uniform correction where equivalent employees obtained revised scales and a common anomaly has been resolved. Denial solely because an employee did not participate in earlier proceedings conflicts with equality before law. Common pay-anomaly determinations are treated as judgments in rem, supporting notional revised-scale fixation from 1 January 1996 and actual benefits from 21 April 2004, with consequential arrears.

Proclamation under Section 82 of the Code of Criminal Procedure, 1973 does not impose an absolute bar on anticipatory bail. Availability of relief turns on the circumstances, the nature of the alleged offence, and the basis for issuing the proclamation. Where custodial interrogation is unnecessary and the accused is available to cooperate with investigation, anticipatory bail may be granted subject to Trial Court conditions.

Provisional release of imported food products, including areca nuts, was considered alongside verification of country of origin and protection of revenue while preferential tariff eligibility remained under examination. The writ petition concerning these matters became infructuous and was disposed of; the connected miscellaneous petition was closed without costs.

Validity of a reassessment notice depends on a duly signed approval from the prescribed authority under Section 151. Where the approval on record carries neither a visible physical signature nor a digital signature, and no duly signed approval is produced despite a specific direction, the statutory approval requirement remains unmet. The reassessment notice is consequently invalid, bad in law, and liable to be quashed.

Share capital and share premium additions under Section 68 require the assessee to establish each subscriber's identity and creditworthiness and the genuineness of the transactions. Once supporting material discharges that initial burden, the Assessing Officer must scrutinise it and conduct an independent enquiry before disputing the credits. In the absence of identified deficiencies or evidence undermining those three elements, deletion of the unexplained cash-credit addition is justified.

Credit entries treated as unexplained money were restored to the notice-response stage, allowing the assessee to explain that deposits represented receipts from farmers and to substantiate its claimed deduction as a credit co-operative society. The assessment had been completed on available material because requested particulars were not furnished. No determination was made on the source of the deposits or eligibility for the deduction. The assessment, demand and consequential proceedings were set aside, and recovery attachment instructions were rescinded.

Rule 86A permits restriction on the utilisation of input tax credit only when mandatory safeguards are met. The authorised officer must give a pre-decisional hearing and independently form and record cogent reasons to believe that credit was fraudulently availed or otherwise ineligible. Mere reference to alleged fake invoices or reliance on enforcement reports, without independent application of mind and substantive recorded reasons, does not satisfy that threshold. Blocking orders issued without these safeguards are invalid and require consequential unblocking of the electronic credit ledger.

Identified pending Central Excise and Service Tax appeals filed on or after 1 July 2017, concerning acts or omissions preceding GST, are reassigned in partial modification of the prior allocation. The specified matters are divided between the Commissioner, Kolkata Appeal-II Commissionerate and the Commissioner, Howrah Commissionerate. Each recipient officer is assigned the relevant matters for passing Orders-in-Appeal under the applicable Central Excise or Service Tax appellate provision.

Banks were urged to expand brick-and-mortar branches and banking correspondent coverage in unbanked villages, strengthen digital outreach, and implement end-to-end digital loan processing. Working-capital lending for micro-enterprises through UPI-linked credit lines and credit cards was highlighted. Banks were also directed to increase awareness of insurance claim eligibility, exercise care in claim-related grievance handling, and enrol new PMJJBY and PMSBY beneficiaries through the Jan Suraksha portal.

Annual return filing deadline under the Arunachal Pradesh Goods and Services Tax framework is extended by substituting 31 March 2021 for 28 February 2021 in the earlier State Tax notification. The amendment is issued under the annual return provision read with the prescribed return-filing rule.

Table I is amended to revise the designated appellate officers for items 7.4.2 and 14.4.1. Table III inserts jurisdictional notes assigning Commissioner (Appeals I) Delhi jurisdiction over Delhi I and Delhi II for items 7.4.1 and 7.4.2, and Commissioner (Appeals II) Mumbai jurisdiction over Mumbai I and Mumbai II for items 14.4.1 and 14.4.2. The changes clarify territorial allocation of appellate functions.

Rule 59 is amended to restrict furnishing outward-supply details where required FORM GSTR-3B returns remain unfurnished. Registered persons cannot furnish FORM GSTR-1 after non-filing for the preceding two months. Quarterly return filers cannot furnish FORM GSTR-1 or use the invoice furnishing facility after non-filing for the preceding tax period. The restriction also applies to persons subject to electronic credit ledger utilisation restrictions who have not furnished FORM GSTR-3B for the preceding tax period.

Computer resources supporting UCO Bank's Core Banking Solution, Real Time Gross Settlement and Unified Payments Interface Switch, including associated dependencies, are declared protected systems as Critical Information Infrastructure. Access is limited to authorised UCO Bank employees, authorised managed service provider or third-party vendor personnel requiring need-based access, and consultants, regulators, government officials, auditors and stakeholders authorised on a case-to-case basis. The declaration takes effect upon publication in the Official Gazette.

Procedure for blocking websites is partially modified by deleting the Secretary, National Security Council Secretariat from paragraph 2(i) of G.S.R. 181(E). The remaining blocking procedure is unaffected by this limited amendment.

Reassessment beyond four years requires material that rationally links escaped income to the assessee's failure to make a full and true disclosure of material facts. Revised or subsequently obtained departmental valuation reports do not justify reopening where they identify no earlier suppression or nondisclosure; such reopening is invalid. Sanction for delayed reopening, although not expressly subject to a hearing requirement, carries adverse civil consequences and requires prior observance of natural justice. The assessee must receive a fair opportunity to place relevant material before the sanctioning authority, failing which the sanction is invalid and completed assessments retain finality.