Intra-court appellate interference with a Single Judge's order is confined to demonstrable error or perversity; the availability of another possible view does not suffice. In GST registration-cancellation matters, where a Single Judge relegates an appellant to the statutory appellate remedy for failing to invoke it, that direction should stand if supported by cogent reasons and free from perversity. Substantive contentions remain open before the appellate authority, and a timely statutory appeal must be considered on merits without treating it as delayed.

Composite show cause notices under Section 74 of the CGST Act cannot combine several financial years or tax periods with separate assessment, return, demand and limitation timelines. Each period must be assessed independently because aggregation obscures distinct due dates and statutory limitation requirements. In-limine dismissal of a special leave petition against a contrary High Court view does not trigger the doctrine of merger or displace later decisions binding on tax authorities. Non-compliant composite notices and consequential orders are subject to quashing, while fresh period-specific notices may be issued in accordance with law, subject to other legal impediments.

Project-specific anti-profiteering computation may compare pre-GST credit and post-GST input tax credit with corresponding project purchase values, rather than turnover, to quantify the benefit allocable per square foot to eligible homebuyers. Pre-GST purchase and credit data may remain relevant where records establish a project nexus, notwithstanding formal post-GST commencement of construction. Total project area and eligible sold area must support a reconciled allocation of the project-level benefit. GST collected on excess realisation arising from profiteering forms part of the amount to be passed on. Penalty may apply for contraventions occurring after the penal provision commenced, subject to statutory immunity where the profiteered amount is deposited within the prescribed period.

Delayed furnishing of Form No. 10 for charitable-income accumulation raises whether the filing requirement is directory and whether genuine hardship warrants condonation. Contemporaneous disclosure of the accumulation claim in the original return and audit report supports that the omission was inadvertent rather than an afterthought. Furnishing the form before an intimation may constitute substantial procedural compliance. Condonation addresses non-wilful default, particularly where the accumulated income was invested in a specified mode.

Assessment initiated under section 153C must proceed in accordance with section 153A, so pending returns under section 139(1) or section 139(4) cannot remain operative for determining concealment. Where an assessee discloses additional income in the section 153A return and the assessment accepts it without further addition, the tax assessed equals the tax payable on that return. The statutory computation therefore yields no tax sought to be evaded, precluding concealment penalty under section 271(1)(c). The penalty restoration was quashed and the appeal succeeded.

Reassessment proceedings under section 148A require the Assessing Officer to examine the taxpayer's explanation and supporting documents before deciding that a reassessment notice should issue. Where alleged undisclosed amounts are disputed as not constituting business turnover, the officer must determine their character and record cogent reasons. Non-consideration of the response and material invalidates the section 148A(3) order and consequential notice, requiring reconsideration; approval based on the quashed order does not survive.

Sufficient cause for delayed appeals against revision orders requires a credible explanation for the entire period of inaction under section 253(5). A consequential assessment order does not itself justify failure to challenge the underlying revision order within limitation. Reliance on professional assistance or a change of auditor is inadequate where it does not establish a bona fide reason for the delay, particularly if the assessee was represented in consequential reassessment proceedings. Failure to establish sufficient cause results in rejection of the delay-condonation request and dismissal of the appeal as time-barred without consideration on merits.

Voluntary ex gratia payments received under an employer's early retirement scheme are not compensation or profits in lieu of salary where no service-rule obligation requires the employer to make them. The payment's voluntary character prevents its assessment under the provision governing profits in lieu of salary. Applying that principle to employees of the same employer, the addition for amounts received under the early retirement scheme was deleted.

Section 144B requires service of a show-cause notice before a faceless assessment or reassessment makes a variation prejudicial to the assessee, so that an effective response can be given. A disallowance of cost of acquisition or construction made without notice proposing that variation breaches the mandatory faceless-assessment procedure and natural justice. Failure to disclose the grounds for proposed additions similarly denies a fair opportunity to respond. The resulting assessment is non-est, rendering other challenges academic and allowing the appeal.

Reasonable cause under section 273B precludes penalty for delayed furnishing of a tax audit report where the taxpayer establishes a justified explanation. Illness, specifically viral fever, was accepted as a reasonable cause for delay despite the absence of supporting medical evidence, because the Revenue produced no material rebutting the explanation. Consequently, penalty under section 271B was not leviable, the order confirming it was set aside, and the taxpayer's appeal succeeded.

Penalty notices for under-reporting and search-related penalties must specify the statutory circumstance or clause invoked, since a generic allegation does not disclose the precise charge or provide a reasonable opportunity to respond. Identifying the clause only in the final penalty order does not cure a defective initiation. Cash expenditure recorded in contemporaneous informal books during an unclosed financial year, later entered in regular books and reflected in an accepted return, does not constitute undisclosed income merely because it was absent from regular books on the search date or admitted in a search statement. On these grounds, the penalties for both assessment years were deleted.

Consideration for supplying standard software to Indian customers, directly or through an Indian subsidiary, is characterised under the India-USA DTAA as business income rather than royalty where the relevant facts, transaction terms, and legal position remain unchanged. In the absence of a permanent establishment in India, Article 7 prevents taxation of that business income in India. The corresponding addition that treated the software receipts as royalty is deleted.

Transfer-pricing treatment limited corporate-guarantee commission to 0.5% and associated-enterprise loan interest to 9% by applying earlier-year benchmarks. Withholding-tax disallowances were removed for overseas legal fees and export commission paid to non-resident agents for services outside India, whereas non-withholding on payments to an offshore branch of an Indian bank was sustained for professional or technical services. Annual GDR listing and maintenance fees, foreign travel expenditure, and the section 80-IA captive-power deduction were allowed. Carbon-credit sale proceeds were treated as capital receipts. Mining-development expenditure capitalised in the accounts was not deductible as revenue expenditure, but qualified for applicable depreciation.

Additional legal grounds raising pure questions of law may be admitted for the first time on appeal where all material facts are on record and no further inquiry is required. Rectification of a consequential assessment order must be confined to the mistake identified in the rectification notice and must arise from that order itself. Interest under section 234B, having merged with the appellate order, could not be rectified in the consequential order; any section 234C omission lay in the original assessment. Further, a debatable advance-tax interest levy under the statutory proviso is not a mistake apparent from record. The rectification and its appellate confirmation were invalid.

Realised foreign exchange loss arising on settlement of a foreign-currency liability may be capitalised into the actual cost of the related capital asset under section 43A. Where the taxpayer records assets at the prevailing exchange rate, capitalises the exchange difference only upon final settlement, and does not claim that loss separately as revenue expenditure, the enhanced asset cost forms the basis for depreciation. Depreciation on the capitalised realised loss is therefore allowable, and a disallowance of such depreciation is not sustainable.

Appellate jurisdiction over non-transfer-pricing assessment issues covers interest-expenditure and exempt-income disallowances where no transfer-pricing adjustment or arm's-length-price determination is examined. Interest deductions require identification of interest linked to earlier and current advances and taxable interest income; where no direct nexus is established, proportional examination applies. Claims disallowed for tax-deduction-at-source non-compliance require verification of payment under the statutory proviso before determination. Exempt-income disallowance cannot exceed exempt income earned, while the Finance Act 2022 amendment operates prospectively. The additional disallowance beyond the voluntary disallowance was deleted, and the Revenue's appeal was dismissed.

Prolonged pre-trial incarceration in a money-laundering prosecution may violate the right to speedy trial under Article 21 where charges remain unframed and the predicate offence has no charge-sheet. The High Court considered early commencement and completion of both trials unlikely, particularly because the money-laundering trial could not be finally decided before the scheduled-offence trial concluded. Continued detention for an indeterminate period would therefore become punitive rather than preventive. Bail was granted subject to conditions requiring investigative cooperation, restricting travel, and safeguarding prosecution witnesses.

Under the PMLA, a stay of predicate-offence proceedings does not extinguish the underlying offence; unlike quashing, it only temporarily suspends proceedings. An ECIR-based inquiry may therefore continue where the predicate FIR pre-dated the ECIR and remains unquashed. Summons should ordinarily state their purpose, identify information or documents bearing a nexus to the ECIR or PMLA inquiry, and specify consequences of non-compliance; vague or omnibus demands are generally unsustainable. However, lack of full particulars does not automatically invalidate a summons in a complex inquiry if grounds can be justified without compromising the inquiry. Recipients may furnish available material and seek reasonable time for further compliance.

Bank-account freezing under the Prevention of Money-Laundering Act requires strict compliance with search-and-seizure safeguards, including the authorised officer's written reasons to believe based on information in possession. The High Court found that the freezing order appeared not to record those reasons and stated that later forwarding of records or proceedings before the Adjudicating Authority could not cure that foundational defect. Because the challenge alleged infringement of fundamental rights and procedural illegality, the alternative statutory remedy did not preclude writ jurisdiction. The writ petition was maintainable, and notice was issued for further consideration.

Contractual allocation of DVAT liability and reimbursement under a works contract may be resolved through arbitration. The relevant tax inquiry is whether imported or inter-State procured goods have an integral contractual nexus with their supply: project-specific procurement to employer specifications, approved suppliers, prescribed inspection and employer consignee status may preserve that nexus despite intermediary procurement and incorporation into works. Such transactions attract exemption for sales in the course of import or inter-State trade, making DVAT and contractual reimbursement inapplicable. Review under Section 34 is confined: courts do not re-appreciate evidence or substitute a plausible arbitral view absent patent illegality going to the root of the matter.