Omission of Rule 96(10) of the CGST Rules, without a saving provision or legal fiction preserving pending proceedings, prevents continuation of recovery action for allegedly erroneous refunds founded on that omitted rule. Because the show-cause notice did not aver any enabling provision, the High Court quashed the demands under Issues 1 and 2. The writ petition was partly allowed, while the remaining issues were left for response and determination in accordance with law.

GST registration of a rented additional place of business must be assessed by verifying the premises, the applicant's business use or storage, and prescribed occupancy documents; ownership disputes, third-party complaints, and absence of a civil decree cannot be made conditions for registration. For rented premises, a rent or lease agreement and specified ownership-supporting documentation are required, but conclusive title proof or an original lease held by a civil court is unnecessary; deficiencies must be specifically notified. Reliance on undisclosed post-hearing third-party material and failure to address material documents breach natural justice and reasoned decision-making. Rejection and appellate action were set aside, with limited remand for fresh verification without deciding title or lease validity.

Input tax credit for genuine inward supplies from FY 2018-19, inadvertently omitted from corresponding returns, remained available when claimed in the April 2019 GSTR-3B within the then-permitted rectification period. At that time, GSTR-2A was facilitative; therefore, a GSTR-2A/GSTR-3B mismatch alone could not support reversal once the underlying supplies and credit were verified. Effective notice and a personal hearing were mandatory before an adverse GST decision. Notices placed only in a secondary portal tab, without hearing particulars, and orders issued on uncommunicated dates breached natural justice. Failure to consider appeal grounds and evidence or give reasons also invalidated the appellate decision. The demand and consequential orders were set aside.

Accumulated input tax credit on higher-taxed packaging materials, containers and printed flexible packaging used for packaged tea qualifies for inverted duty structure refund where those inputs bear a higher tax rate than the output supply. Equal tax treatment of bulk tea and packaged tea does not negate the refund where the packaging inputs themselves create the rate inversion. A departmental circular addressing reductions in tax rates on the same goods over time does not apply to this circumstance and cannot restrict a refund otherwise available under the Act. The sanctioned refund is consequently payable.

Credit notes issued within the prescribed period for rejected or returned supplies reduce taxable turnover because the returned goods no longer form part of the supply. Verified by a Chartered Accountant's certificate, GSTR-1 statements and voucher register, the notes were deductible from gross turnover in determining adjusted total turnover under Rule 89(5) for an inverted duty structure refund of accumulated input tax credit. The Tribunal upheld the deduction and dismissed the Revenue's appeal.

Refund of accumulated input tax credit under an inverted duty structure depends on whether input taxes exceed the tax rate on output supplies under Section 54(3)(ii). The comparison is not confined to the principal raw material and may include ancillary business inputs taxed at higher rates. Common HSN classification of raw materials and finished goods does not by itself establish that they are the same goods. CBIC circulars addressing rate reductions on identical goods at different times, including concessional supplies, do not restrict a statutory refund where those circumstances are absent.

GST registration cancellation must remain confined to the grounds stated in the show-cause notice. Where the notice alleges non-existence at the declared business premises, cancellation cannot instead rest on alleged wrongful availment of input tax credit; cancellation on that distinct, unstated ground is unsustainable and was revoked. Input tax credit liability also cannot be determined through appellate restoration conditions. Any proposed reversal or payment of disputed credit requires a prescribed notice, adjudication and meaningful opportunity to contest. A conditional cash-deposit requirement and automatic-void clause attached to restoration were unsustainable, while fresh proceedings for alleged wrongful credit remained available in accordance with law.

GST exemptions for sub-contracted manpower supply under Serial Nos. 3 and 3A require the supply to be made directly to a specified Government recipient. Supply to a private principal contractor does not meet that condition merely because the contractor executes a State water-supply project or the ultimate beneficiary is governmental. The recipient requirement applies independently; characterisation as a pure service connected with a constitutional function or as a qualifying composite supply cannot cure its absence. The claimed exemptions were denied, the advance ruling was upheld, and the supply remained taxable under the applicable classification and rate provisions.

Rule 10B does not prescribe a lower or upper turnover limit for transfer-pricing comparables in the software development services segment. Market conditions, assets employed and risks assumed remain material to comparability analysis. An upper turnover filter may therefore be applied where it rationally distinguishes companies with materially different scale and economic profiles. Its application is a factual determination and is not open to interference unless perversity is pleaded and demonstrated. The Tribunal's use of the filter consequently raised no substantial question of law, and the Revenue's appeal was dismissed.

Jewellery claimed as streedhan, customary family holdings and marriage gifts cannot be treated as unexplained solely through an ad hoc addition where family ownership is supported by affidavits and photographs, the family's status and past income are relevant, and no Revenue valuation exists. Jewellery accumulated in earlier years need not correlate with income declared for the relevant year, and married daughters may lawfully keep jewellery at their parental home. Cash found in a search is not unexplained where bank records establish sufficient withdrawals by the individual and family members. On these grounds, additions for jewellery and cash were deleted.

Section 148A reassessment procedure requires the Assessing Officer to identify the income alleged to have escaped assessment in the notice, consider the taxpayer's response, pass a reasoned order, and obtain prescribed approval. A reassessment addition for alleged loan-repayment cash deposits is unsustainable where those deposits were not identified in the section 148A proceedings or approved as escaped income. Where the originally proposed cash deposits were dropped after accepting the taxpayer's explanation, distinct deposits cannot subsequently be introduced through reassessment. The loan-repayment addition was therefore deleted, without adjudicating the remaining merits grounds.

Reassessment requires the Assessing Officer to assess or reassess the income forming the recorded basis for reopening before making additions for any other escaped income identified during the proceedings. The provision allowing assessment of other escaped income permits consideration of a new issue but does not remove this prerequisite. Where no addition or adverse finding was made regarding the recorded underpricing of a share transfer, an addition for unexplained credit arising from a separate share-sale transaction could not be made independently. A fresh reopening notice was required. The reassessment was therefore without jurisdiction and non est, while the merits of the addition remained unadjudicated.

Pre-CIRP statutory income-tax claims not forming part of an approved resolution plan are treated as extinguished, preventing continuation of proceedings concerning those claims. This principle applies where a corporate debtor's successor entered the corporate insolvency resolution process, an approved resolution plan was not implemented, and liquidation followed. No material established admission of the Department's claims for the relevant assessment years in the resolution or liquidation proceedings; the connected Departmental appeals, assessee appeal, and cross-objection therefore did not survive.

Appeals from Tribunal orders determining customs classification, the rate of customs duty, or the value of goods for assessment fall outside High Court appellate jurisdiction under section 130. The prescribed appellate remedy for such disputes is an appeal to the Supreme Court under section 130E. Consequently, a High Court appeal challenging imported-goods classification and consequential customs duty liability is not maintainable and must be pursued before the Supreme Court.

Limitation for an appeal under the Insolvency and Bankruptcy Code against an NCLAT order runs from pronouncement of the order. The prescribed 45-day period, with a maximum 15-day condonable extension, establishes an absolute 60-day limit. Section 12(2) of the Limitation Act excludes only the time from applying for a certified copy until it becomes available; delay in applying remains countable. Obtaining a copy cannot defer limitation, and delay beyond the outer limit cannot be condoned.

Section 19(2) of the PMLA requires the arrest order and supporting material to reach the Adjudicating Authority immediately, meaning expeditiously and substantially simultaneously, subject only to time strictly necessary to compile extensive records and complete administrative requirements. No fixed forwarding period applies; a five-day delay in the stated circumstances does not invalidate arrest. Article 21 prevents the PMLA's twin bail conditions from operating as punishment where investigation is complete and a document-heavy trial cannot finish within reasonable time. Continued prolonged custody in those circumstances warrants regular bail, subject to conditions protecting evidence and witnesses.

Compromise-based quashing of a predicate FIR does not by itself eliminate proceeds of crime for money-laundering proceedings; the relevant inquiry concerns the underlying crime that generated those proceeds. Bail granted after treating the compromise quashing as conclusive was set aside. Serious allegations, an undetermined extent of alleged money laundering, and an incomplete investigation attracted the statutory rigour governing bail under the Prevention of Money Laundering Act. Bail for the other accused was refused, while both accused may seek regular bail after completion of the investigation.

Revisional jurisdiction cannot serve as a substitute for filing a revised return after the statutory deadline. A fresh claim may be considered only where it raises a new question of law on foundational facts already before the Assessing Officer; claims requiring facts not placed before that authority fall outside revisional jurisdiction. The Tribunal's plenary appellate power to entertain a legal point does not expand the revisional authority's powers. This framework confines revision to the existing factual record and prevents its use to introduce a new fact-based tax claim.

Faceless reassessment under the e-Assessment of Income Escaping Assessment Scheme, 2022 requires automated allocation for notices and all connected reassessment proceedings. Pre-notice enquiry and orders are inseparable from notice issuance and reassessment; concurrent-jurisdiction notifications cannot preserve a Jurisdictional Assessing Officer's authority where automated allocation was not used. Proceedings initiated under sections 148A and 148 by such officers were therefore set aside. Retrospective validating legislation must cure the statutory defect underlying prior judicial decisions and cannot merely override them; section 147A was unconstitutional because it left section 151A and the Scheme unchanged. Its insertion after repeal of .....

Automated airline reservation and operational software subscription services, delivered through overseas-hosted software without human intervention as a standard facility, are not treated as fees for technical services under the India-Netherlands DTAA. Technical services, when distinguished from mere use of a standard facility, require human interface or application of the human mind. Training and support for use of the systems do not satisfy the treaty's make available requirement where customers cannot independently apply the underlying technology and the provider retains the relevant intellectual-property rights. The consideration is therefore not taxable as fees for technical services under the treaty or the Act.