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.

Best-judgment assessment may be used where books of account are not maintained and required information is not furnished, but business-profit estimation must remain fair, unbiased and rational. Profit rates cannot be adopted capriciously or without supporting facts; they should be based on the taxpayer's past history or comparable businesses in the same line of trade. Where the adopted rates lack such a disclosed basis, the profit estimation requires reconsideration. Net profit must be freshly determined with reference to relevant comparables or past results after affording the taxpayer an opportunity of hearing.

Contractual recruitment and training services provided to an insurer are business support activities, rather than insurance agency, commission, brokerage, or insurance-product canvassing. Training that uses knowledge or skill does not become a professional service unless it falls within a profession specified under section 44AA or constitutes technical consultancy. Receipts from such activities are therefore business receipts, not professional receipts, and may be computed under section 44AD if its statutory conditions are met; applying section 44ADA is inapposite and the related addition was deleted.

Management fees earned through a Cairo hotel permanent establishment were treated as business profits taxable in UAR and therefore exempt in India under the India-UAR DTAA, with inclusion permitted only for rate purposes. Consistent acceptance of the exemption in earlier and later years supported deletion of the related addition. Indirect common expenditure attributable to exempt dividends remained disallowable only to the extent computed under the consistently accepted income-distribution methodology. For MAT purposes, provision for wealth tax was not an adjustment to book profit because the applicable adjustment covers only income-tax. Reversal of provision for diminution in investment value also did not warrant a book-profit adjustment where the provision had already been added back when created.

Provisional attachment of immovable property was sustained where the property was acquired during the disclosed offence period and found to be directly derived from narcotics-related proceeds of crime. The absence of documentary proof of lawful income, unexplained banking transactions, and admissions concerning use of narcotics-sale proceeds supported the required nexus with the scheduled offence. Statements made under Section 50 of the Prevention of Money Laundering Act were treated as constitutionally valid and reliable where recorded under summons, written by the individuals concerned, and corroborated by investigative material. The allegation of duress was rejected, and the appeal challenging the attachment was dismissed.

Pre-arrest bail was considered unavailable for alleged misappropriation of funds entrusted for GST payments and alleged use of fabricated GST payment documents. Substantial sums received for GST payment were allegedly not deposited through the GST portal, while forged forms were allegedly produced to create a false appearance of payment. The seriousness of the alleged conduct, involving entrusted funds and fabricated GST records, was treated as sufficient to deny anticipatory protection.

Statutory GST appeals, including delayed appeals accompanied by condonation applications, require quasi-judicial consideration by the Appellate Authority. Mechanical rejection by an office or through a system-generated acknowledgement, without a hearing and a reasoned speaking order, is unsustainable. Reasons demonstrate application of mind, permit the aggrieved party to challenge the decision, and enable judicial review. Rejected appeals were restored for fresh consideration with any condonation applications after hearing, while the challenge to the circular remained open.

Section 107 confines the First Appellate Authority's power to condone delay in GST registration-cancellation appeals to the prescribed outer limit; condonation beyond that limit, and the resulting allowance of taxpayers' appeals, is without jurisdiction. Fact-specific relief granted by a High Court under Article 226 cannot enlarge the statutory appellate authority's jurisdiction. However, after the Department implemented the appellate orders by restoring GST registrations, it altered the taxpayers' legal and commercial position. As no effective or workable relief could then follow from annulling those orders, the departmental appeals were infructuous and not maintainable.

Assignment of user rights in intangible assets, without a lump-sum price, fixed term, fixed periodic payment, or reversion provision, was characterised as a licence rather than an ownership transfer; variable profit-linked payments were licence fees, and later consideration was capital sale proceeds. Sale proceeds of self-generated trade marks and brands were not taxable as long-term capital gains where the acquisition cost was unascertainable and no retrospective nil-cost deeming rule applied. An arbitral award remained binding between its parties absent an evidential basis to impugn it. Deletion of the underlying addition eliminated the basis for concealment penalty.

Foreign contribution registration under the Foreign Contribution (Regulation) Act, 2010 does not create a vested or absolute right to receive foreign contributions. Registration depends on the competent authority's discretionary assessment, reviewable for perversity, disregard of relevant material, or non-application of mind. Applicants must truthfully disclose their organisational character: an organisation professing Zen Buddhist philosophy is religious and cannot describe itself as non-religious. Religious organisations may apply, but must make full and accurate disclosures; organisations involved in conversion from one faith to another must be denied registration. Appeals from refusal of registration, being incapable of monetary valuation and treated as appeals from original decrees, fall for consideration by a Division Bench.

Section 127 transfers for centralised assessment require recorded and communicated reasons, and transfers between officers subordinate to different Commissioners require the prescribed inter-Commissioner agreement; an opportunity of hearing depends on feasibility. Taxpayers who requested centralisation, filed returns, responded to notices and participated before the transferee officer were treated as having acquiesced in the transferred jurisdiction, preventing a later technical challenge to the transfer. Challenges to consequential assessment orders were not entertained in writ jurisdiction where an effective statutory appellate remedy was available. The writ petitions challenging the transfers and assessments were dismissed.

Section 245H's first proviso denies Settlement Commission immunity where prosecution was instituted before receipt of the settlement application. Accordingly, a settlement order cannot extend immunity to an already filed complaint concerning false statements in an income-tax search, including undisclosed bank lockers. Inherent jurisdiction may nevertheless be invoked independently to examine whether continuing a long-pending prosecution after final settlement would abuse process. Where settlement remains unchallenged, payment directions have been complied with, and continued proceedings serve no practical purpose, the criminal complaint and consequential orders may be quashed.

Section 43B disallowance of interest liability converted into preference shares under a corporate debt restructuring arrangement was deleted. A High Court judgment affirming the relevant Tribunal approach retained its precedential value despite the Revenue's pending Special Leave Petition. Mere pendency of a challenge before the Supreme Court does not displace that judgment unless it is stayed, reversed, or modified. The Tribunal therefore sustained deletion of the disallowance and dismissed the Revenue's appeal.