Recruitment to the Deputy Controller (Investigation) and Assistant Controller (Investigation) posts is through deputation, including short-term contract, or absorption. Eligible officers must meet prescribed analogous-post or lower-level regular-service requirements, technical degree qualifications, extensive Information Technology experience, and computer-forensic, incident-handling, investigation, Public Key Infrastructure, information-security, and certification requirements. The Deputy Controller post requires higher service and experience thresholds than the Assistant Controller post. Deputation is ordinarily limited to five years, while reservation, age-limit relaxation, and applicable concessions remain protected.

ITC availed in GSTR-3B for February to August 2020 had to be reconciled with the cumulative eligible credit relating to supplier-uploaded invoices and debit notes. The aggregate ITC availed for that period could not exceed 110% of the cumulative eligible credit supported by uploads made up to the specified September GSTR-1 due date. Excess ITC identified through cumulative reconciliation had to be reversed in Table 4(B)(2) of the September 2020 GSTR-3B.

Informer reward disbursement is under consideration following withdrawal of the assessee's appeal under the Sabka Vishwas Legacy Dispute Resolution Scheme, 2019, coupled with confirmation that no further appeal is pending. The earlier direction contemplated reward disbursement where an appeal was decided in favour of Revenue. A status report specifying the proposed disbursement timeframe was required within four weeks, while the informers could collect an interim reward without prejudice. Further consideration was scheduled after submission of the status report.

Railway container contractors leasing SLRs to transport goods fall within the statutory definition of dealer where prescribed conditions are met and must register for a taxable-goods business. They must maintain and preserve consignment records and declarations. A claim of non-taxability requires production of prescribed documentary evidence during regular assessment. Exoneration from dealer status and value added tax liability without verification of books of account or an assessment report, despite admitted SLR leasing and transport activity, is unsustainable.

Reward entitlement under the applicable customs scheme remains unresolved where the importer is asserted to have admitted customs-duty liability. Relevant documents must be placed on record before the entitlement can be determined, and the matter stands listed for final hearing. No final adjudication has been made on whether the petitioners qualify for a reward or on the effect of the asserted admission of duty liability.

Spectrum allocation services granted for a right to use spectrum are taxable under reverse charge and constitute continuous supply of services where payments are made periodically over more than three months. The Frequency Assignment Letter is a bid-acceptance and allotment instrument, not an invoice-equivalent document for the sixty-day reverse-charge rule. GST is payable on upfront payment when payment is made or due, whichever is earlier; for deferred payment, it is payable for each instalment when due or made, whichever is earlier.

Mandatory pre-show cause notice consultation was in issue in service-tax proceedings. The impugned adjudication order did not refer to any pre-consultation notice or consultation. Respondents were directed to file an affidavit, with relevant file notings, addressing whether consultation occurred. Further action or proceedings against the petitioner were restrained on an ad-interim basis pending further hearing.

Partition decrees bind parties and persons claiming through them, but cannot conclusively determine or defeat independent third-party title in execution. Under Order XXI Rules 97-101 CPC, an executing court may assess whether obstructionists show a prima facie bona fide independent claim, rather than finally adjudicating their title. Fraud cannot invalidate a preliminary decree without specific pleadings and evidence as required by Order VI Rule 4 CPC. Pattas, supporting revenue material, and presumptions applicable to ancient documents may support resistance to execution. Questions under inam, jagir abolition, land-reform and urban-land-ceiling regimes, including State claims, remain for appropriate proceedings where the State was not a party.

Appointments to Private Secretary, Personal Assistant, Assistant and Stenographer positions follow post-specific promotion, deputation or absorption, and direct-recruitment sequences. Private Secretary is promotion-led, while Personal Assistant permits direct recruitment after promotion and deputation or absorption options. Assistant and Stenographer rely on deputation or absorption before direct recruitment. Eligibility includes stipulated educational, skill, service and age requirements, with prescribed deputation tenure, age ceiling, promotion-service rules, and safeguards for reservation and age relaxation.

Designated customs formations, including Appraising Groups, processing sections, facilitation centres and import and export docks, remain functional during the Time Release Study Week. Appraising Groups and docks are also available on Sunday with skeleton staffing. The arrangements operate as standing directions for specified officers and staff, with supervisory officers required to ensure attendance.

Testing, research and development, and demonstration samples may be imported without quantity restriction. Highly Specialised Equipment meeting defined criteria need not be supported by a NoC, subject to Customs seeking technical clarification where necessary, while direct end-user imports for personal use are unrestricted. For these categories, a declaration from the importer, exporter, local representative or end user is sufficient for Customs clearance and forms the basis for non-application of BIS provisions.

FORM GSTR-3B due dates for February, March and April 2020 remain unchanged. Registered persons with aggregate turnover above Rs. 5 Crore receive nil interest for the first 15 days after the due date and interest at 9% per annum thereafter only if returns are furnished by 24 June 2020; otherwise, interest at 18% per annum applies from the original due date, with regular late fee and penalty liability. Registered persons with turnover up to Rs. 5 Crore receive nil interest if filing by prescribed dates, but otherwise face interest at 18% per annum, regular late fee and penalty liability.

The enhanced tolerance band for differences between purchase consideration and stamp-duty value under Section 56(2)(x)(b)(B) was treated as a curative measure removing hardship and therefore applicable retrospectively to assessment year 2018-19. A 6.56% difference fell within the enhanced 10% band, so no addition arose on that basis. Computing an addition by applying 5% to the total consideration was inconsistent with the provision. Consequently, additions based on the stamp-duty valuation difference were deleted.

Cash bonus paid to identified regular employees is not disallowable merely because it was paid in cash where the employees' identities and the genuineness of payment are undisputed. Section 40A(3), read with Rule 6DD, targets tax evasion and the use of unaccounted money rather than genuine, bona fide business expenditure. Bonus paid within the statutory payment period is deductible on actual payment under Section 43B. Accordingly, genuine cash bonus payments satisfying these conditions remain allowable business deductions.

Penalty proceedings under Section 271(1)(c) cannot stand where notices under Section 274 invoke both concealment of income and furnishing inaccurate particulars without identifying the precise charge. Specific notice is necessary to give the taxpayer a meaningful opportunity to respond. An objection raised in the penalty appeal was distinguishable from a substantially delayed challenge. Failure to specify the applicable statutory limb invalidated the notices and resulted in quashing of the penalty.

Estimated additions for undisclosed trading receipts require a proportionate basis where incomplete cold-storage withdrawal records do not justify treating a substantial share of withdrawals as the assessee's own trading activity. The estimated addition was restricted to Rs. 10 lakh, with the balance deleted. Loading and unloading expenses and interest on advances to farmers, initially disallowed on the same estimated trading basis, required corresponding reduction. The disallowance was recomputed at 5%, resulting in consequential recomputation of income.

Section 80P deduction cannot be denied merely because a return was filed after the original due date where it was filed within the extended due date. Return processing under section 143(1) is confined to prima facie adjustments; after the stated basis for an adjustment fails, the deduction's substantive merits cannot be examined through that process. Interest derived from members qualifies for deduction under section 80P(2)(a)(i). Income must therefore be recomputed after giving effect to the section 80P claim without the delayed-filing denial.

Extrapolation of annual business receipts and profit from survey material covering only three months requires supporting material for the remaining period. Without such material, taxable income must reflect real income rather than presumptive annualisation, making the extrapolation-based addition unsustainable. Bank credits already included in business receipts used to compute business income cannot be separately added, as this duplicates the same income. Business income must therefore be confined to the supported computation without a duplicative bank-credit addition.

Share capital and share premium received from a shareholder were subjected to an addition as unexplained cash credit under the Income-tax Act. The shareholder's bank-account transactions had been accepted by another person in the assessee group and settled before the Income Tax Settlement Commission. As the shareholder's own assessment contained no corresponding addition, the addition relating to the share capital and premium was treated as unsustainable and deleted.

Interest earned by a co-operative credit society on term deposits with a State co-operative bank falls within the deduction for income from investments with another co-operative society where both entities qualify as co-operative societies under the Income-tax Act. The exclusion for co-operative banks applies where the claimant itself is a co-operative bank under the Banking Regulation Act; it does not deny the deduction merely because the payer is a co-operative bank. Qualifying interest on such deposits is therefore deductible under Section 80P(2)(d).