Pre-1 April 2021 reassessment notices issued within four years, including under the applicable COVID-19 limitation extension, required sanction from the Joint Commissioner under section 151(2). Sanction by the Principal Commissioner, who was not the specified authority, created a jurisdictional defect because statutory approval requirements required strict compliance. The reassessment notice was therefore invalid, and the objection-disposal order, assessment order, demand notice, penalty-initiation notice and consequential proceedings were quashed.

GST registration cancellation based on a show-cause notice that cites Section 29(2)(e) without factual particulars, while relying on unavailable supporting enclosures, requires a fresh opportunity to respond. Following supply of the enclosures to counsel, the cancellation order was set aside. The taxpayer may file a reply within three weeks, and the competent authority must consider it according to law, grant a personal hearing, and communicate a written decision. The dispute over prior service of the enclosures remains unresolved.

Renewable Energy Certificates, Priority Sector Lending Certificates and similar documents are classifiable under heading 4907 and attract GST at 12%. The residual rate entry applies only to goods not covered under another specified schedule entry and cannot be used where a specific classification applies. The earlier residual-entry treatment of PSLCs is modified accordingly. Duty credit scrips classifiable under heading 4907 remain subject to Nil GST under the specified exemption entry.

Prior GST clarifications concerning the supply of Information Technology enabled Services (ITeS) are withdrawn ab initio following apprehensions about their implications. Statutory direction-making power is exercised to secure uniform implementation across field formations, discontinuing the earlier clarificatory framework for GST treatment of ITeS supplies.

GST treatment of catering services involving the supply of food or drink in a mess or canteen of an educational institution is clarified through incorporation of an earlier rate clarification into the relevant Tamil Nadu State tax rate entry. The relevant entry also incorporates the clarification that supplies of food or drinks by Indian Railways, IRCTC, or their licensees attract GST at 5% without input tax credit.

Combined trade estimates for April-September 2026-27 show exports of US$ 476.20 billion and imports of US$ 551.13 billion, resulting in a trade deficit of US$ 74.93 billion. Merchandise exports rose to US$ 259.89 billion, while merchandise imports reached US$ 437.53 billion. Estimated services exports were US$ 216.31 billion and services imports were US$ 113.60 billion, producing a services trade surplus of US$ 102.71 billion. September services figures are estimates, and specified earlier-period data were revised using quarterly balance-of-payments data.

Where premises form part of the corporate debtor's assets, Sections 18 and 25 of the Insolvency and Bankruptcy Code, 2016 require the resolution professional to take custody, control, preservation and protection measures. An occupant resisting recovery must prove a subsisting tenancy, leasehold interest or enforceable licence through reliable evidence of the parties' intended relationship and its essential terms. Permission to stock goods or conduct limited business activity, prolonged occupation, and business or utility records do not independently create rights in the premises. Section 60(5)(c) supports insolvency jurisdiction over asset-recovery measures connected with the insolvency estate.

Land consistently recorded as a fixed asset since 2007 and held for more than three years retains its character as a capital asset rather than stock-in-trade, notwithstanding separate land-trading activity. Taxpayers may maintain distinct investment and trading portfolios for immovable properties; classification of other land as trading assets does not, by itself, convert investment land into trading stock or an adventure in the nature of trade. Transfer of the Nikol land therefore gives rise to long-term capital gains, with deduction under section 54F available.

Supplies of short-term accommodation, conferencing, banqueting and similar services to a Special Economic Zone developer or unit are inter-State supplies. Supplies to such developers or units qualify as zero-rated only when received for authorised operations and supported by endorsement from the specified officer, enabling the supplier to claim applicable refund. Independent fabric processors supplying job work services may obtain refund of unutilised input tax credit from an inverted duty structure because their outward supply is a service, not fabric goods.

Tax determination for financial year 2024-25 onwards is governed by section 74A for unpaid or short-paid tax, erroneous refunds, and wrongly availed or utilised input tax credit. Notices must generally be issued within forty-two months, and orders within twelve months, subject to a limited extension. Penalties differ between ordinary defaults and fraud, wilful misstatement, or suppression. In ordinary cases, payment of tax and interest before notice prevents notice and penalty, while payment within sixty days after notice avoids penalty. Fraud cases permit conclusion on payment of tax, interest, and specified penalties at pre-notice, post-notice, or post-order stages.

Reasonable cause for delayed filing may be established where an authorised representative fails to communicate a first appellate dismissal, the assessee acts promptly after receiving a demand notice, and pandemic-related lockdowns explain the intervening period. An ex parte dismissal for non-prosecution, without examination of additions or disallowances on merits, requires restoration for merits-based adjudication when non-appearance is satisfactorily explained. Adequate opportunity of hearing must be afforded before determining the first appellate challenge in accordance with law.

GST portal service is a statutory method under Section 169, but its use in an ex parte demand proceeding depends on effective accessibility and a meaningful opportunity to reply and be heard. Rule 142 requires electronic DRC-01 and DRC-07 summaries to operate alongside the underlying show-cause notice and reasoned order. Portal placement, complete communication, e-mail transmission, technical reliability and proof of actual access may determine whether service is effective, whether waiver applies, and whether appellate limitation begins.

TNMM requires consistent computation of operating profit and operating cost for the tested party and comparables. A provision for doubtful debts connected with sales and trade receivables may be an operating expense, as may routine business levies; income-tax on profits remains excluded. A search matrix is a disciplined evidentiary tool, not a statutory bar to an out-of-matrix comparable. Inclusion requires proof of functional fit, filter satisfaction and reasons for its absence, while rejection cannot rest solely on matrix absence. FAR analysis, segmental reliability and material scale differences govern comparability.

Disallowance of a political-donation deduction does not, without more, establish misreporting for enhanced penalty purposes. A valid misreporting charge requires proof that the taxpayer's conduct falls within a specified statutory category, such as suppression of facts, false entries, or an evidentially unsupported claim; an adverse finding on the deduction's genuineness is insufficient by itself. Transparent disclosure and a bona fide, fully supported explanation remain relevant to ordinary under-reporting. Notices and penalty orders must clearly distinguish under-reporting from misreporting, identify the precise allegation, and provide a meaningful opportunity to respond. Acceptance of a disallowance is not an admission of misreporting.

Section 12AB requires the Commissioner to grant or reject charitable-registration applications after examining objects, genuineness of activities and material legal compliance. It does not create a category of registration whose effectiveness or tax benefits are suspended pending future litigation. Conditions may operate only where they reflect statutory requirements; prescribed forms, rules and administrative circulars cannot enlarge substantive powers. Post-registration concerns must be addressed through the separate cancellation process, including inquiry and hearing safeguards. A binding jurisdictional ruling remains applicable unless stayed, modified or reversed. The absence of an express irrevocability clause does not itself establish that a public charitable trust is revocable where no power of revocation is reserved.

Written acceptance of customs reassessment under Section 17(5) may dispense with a speaking order but does not, by itself, waive an importer's statutory right to challenge enhanced valuation. Consent letters must be read with the surrounding correspondence; payment under protest or requests for provisional clearance may negate unconditional acceptance. Transaction value remains the primary basis for valuation. Declared value may be rejected only where objectively grounded reasonable doubt exists under Rule 12, with written disclosure of grounds and a hearing on request. Any redetermination must follow the sequential valuation rules and rely on demonstrably comparable import data; generic NIDB references are insufficient. Challenges to an unchanged assessment must proceed through the statutory appeal route, not refund proceedings.

Gold seizure under Section 110 requires the proper officer to hold, before seizure, objectively supportable reasons to believe that goods are liable to confiscation. For gold, Section 123 shifts the burden of disproving smuggling only after a lawful seizure made in reasonable belief that the gold is smuggled. A general panchnama recital, foreign markings, high purity, or an uncorroborated retracted statement cannot alone establish that foundation. Reasons must exist contemporaneously and cannot be supplied retrospectively through later investigation.

GST treatment of leasehold transfers depends on whether the transaction is an original grant, sub-lease, or complete assignment. An original grant of a lease, tenancy, easement or licence to occupy land is classified as a supply of services; qualifying long-term industrial leases may receive the stated exemption for upfront amounts. A complete assignment, where the outgoing lessee transfers the whole residual term, possession, building and associated benefits and retains no reversionary or possessory interest, may constitute transfer of an immovable-property interest rather than a taxable service. Consideration labels are not decisive; the deed, lessor consent, assignee substitution and future rent obligations determine characterisation. Sub-leases or continuing occupation arrangements remain susceptible to GST.

Section 10(10AA)(ii) governs retirement leave encashment received by employees other than Central or State Government employees. Exemption remains subject to the ten-month earned-leave limit, average-salary calculation, thirty-days-per-year leave entitlement restriction, aggregate limits for multiple employers, and adjustment for earlier exempt receipts. Notification No. 31/2023 raises the notified ceiling to Rs. 25,00,000 and states retrospective effect from 1 April 2023 without adverse effect. Tribunal authorities discussed apply the enhanced ceiling to eligible pending claims for earlier assessment years, while maintaining that public sector undertaking and bank employees do not qualify as government employees under Section 10(10AA)(i).

Free-of-cost moulds and dies provided by an original equipment manufacturer to an unrelated component manufacturer in the course of business do not constitute supply, require no input tax credit reversal, and are excluded from the component value where the component manufacturer did not bear their cost. If the contract required the component manufacturer to use its own moulds and dies, the amortised cost of moulds and dies supplied free of cost is included in component value and input tax credit must be reversed. E-way bill requirements depend on inter-State movement of goods, while railway delivery requires production of the e-way bill.