Reassessment limitation under TOLA is a jurisdictional restraint. Transitional notices issued between 1 April 2021 and 30 June 2021 are treated as Section 148A(b) show-cause notices, but only the surviving time remaining until 30 June 2021 is available for completing the reassessment process. Periods for supply of material and the assessee's response are excluded, but the Section 148A(d) decision, statutory approval and final Section 148 notice must issue within the remaining period. For Assessment Year 2015-16, post-1 April 2021 notices are treated as time-barred.

Margin waiver for subsequent cash-segment buy or sell positions applies where a client has a net sell obligation and an Early Pay-In request for sold securities has been accepted. The clearing corporation shall not collect margin from the trading member or clearing member on subsequent client positions up to the accepted EPI amount. Available EPI value is the lower of the EPI completed and securities sold value. Squaring off an EPI-backed sale position removes the EPI value, with resulting margin shortfall blocked from proprietary collateral, except for trade-for-trade securities.

Comprehensive advertising services supplied on an agency's own account to a foreign client constitute principal-to-principal supplies rather than intermediary services, even where the agency procures media space from media owners. The foreign client remains the recipient; an Indian representative or target audience does not. As the services are not performance-based, the default place-of-supply rule applies, locating supply with the foreign recipient and allowing export treatment subject to applicable conditions. A mere agent facilitating a direct media-owner and foreign-client supply is an intermediary, with place of supply at the agency's location.

Cancelled service advances for which invoices were issued, and goods returned under tax invoices, require credit notes reported in the relevant return and tax-liability adjustment. Where no output liability exists, a refund claim may be filed through FORM GST RFD-01 under "Excess payment of tax, if any". Cancelled advances for which no invoice was issued require a refund voucher, and tax paid may be claimed through FORM GST RFD-01 under "Refund of excess payment of tax".

Provisional release of an unseized imported food consignment is not mechanically governed by Section 110A, which applies to goods seized under Section 110. Customs may examine, test, verify and reassess imports, but indefinite retention without a seizure memorandum or disclosed reasons connecting the goods with confiscation is not justified. Food sampling should follow the specialised food-safety process through an authorised officer. A valid food-safety report may support conditional clearance, while classification, duty liability, confiscation and adjudication remain open. Revenue may be protected through proportionate security.

GST transit-state jurisdiction permits interception, document verification and authorised physical inspection of inter-State consignments, but physical passage through an intermediate State does not itself establish a place of supply, tax liability or penalty jurisdiction. Section 129 detention and penalty require contravention linked to a taxable nexus; where documented origin and destination are outside the transit State and there is no diversion, local supply, false documentation or mismatch of goods, an e-invoice defect alone should be addressed by authorities connected with the supplier or recipient. Cross-empowerment under the CGST and IGST regimes facilitates administration but does not create independent territorial taxing authority. Discrepancies may be recorded and communicated to competent jurisdiction.

Shareholder ratification cannot retrospectively validate diversion of preferential-issue proceeds from the objects disclosed in the explanatory statement where the conduct breaches securities-market disclosure duties and constitutes fraud or an unfair trade practice. Issue-specific objects, rather than broad memorandum objects, govern whether proceeds were deployed as represented. Immediate use of funds for undisclosed loans or share investments, without a substantiated commercial explanation, may support an inference that the disclosed objects were never intended to be performed. Prospectus-based variation mechanisms do not apply to private placements or cure completed diversions. Continuing disclosure requirements promote transparency but do not authorise post-facto deviations, while later amendments to corporate objects remain prospective only.

Section 195 requires withholding on payments to non-residents only where the remittance contains income chargeable in India. Where a DTAA is more beneficial, treaty definitions govern royalty and fees for technical services. Software payments are not royalty where the recipient receives only a restricted right to use a copyrighted product, rather than rights to reproduce, exploit, distribute or otherwise exercise copyright. Services must be separately tested under any treaty make-available requirement. Amounts falling outside royalty and FTS may constitute business profits, taxable only under applicable permanent-establishment and profit-attribution rules. Composite arrangements require component-wise classification, with proportionate withholding available for genuinely mixed remittances.

Unpaid anti-dumping duty omitted during self-assessment may be pursued through the customs recovery procedure without prior appellate modification of the self-assessment. The recovery framework applies to anti-dumping duty through statutory incorporation of provisions concerning assessment, non-levy, short-levy, interest and recovery. Where anti-dumping duty is chargeable, it forms part of the aggregate value used to compute IGST on imports, potentially creating a consequential IGST short-payment. Recovery requires accurate assessment of notification coverage, product, origin, rate, valuation, limitation and procedural safeguards.

The six-year limitation for condoning delay in filing revised returns did not apply where the departmental intimation triggered representations, rectification proceedings and a rectification order. Treating the application as time-barred without accounting for that factual sequence was unsustainable. Delay in filing the revised returns was therefore to be condoned, and the related refund claim required consideration in accordance with law.

New rule 164 creates an electronic process for waiver of interest or penalty, or both, under section 128A for qualifying tax demands. Applications against notices or statements are made in FORM GST SPL-01, while applications against demand orders are made in FORM GST SPL-02 after required payment adjustment in the Electronic Liability Register. Applicants must satisfy payment conditions and withdraw pending appeals or writ petitions. The process provides for notice in FORM GST SPL-03, reply in FORM GST SPL-04, acceptance in FORM GST SPL-05, rejection in FORM GST SPL-07, appellate acceptance in FORM GST SPL-06, and deemed approval if no order is issued within the prescribed period.

Eligible registered persons opting to pay State tax at 3% under the composition levy must file an intimation in FORM GST CMP-02, selecting the category "Any other supplier eligible for composition levy". The filing deadline is corrected to 31 July 2019. Such persons must also furnish the prescribed statement in FORM GST ITC-03 under the applicable composition-levy procedure.

Registered airport retail outlets beyond immigration counters may claim invoice-based refunds of applicable taxes paid on indigenous goods sold tax-free, against foreign exchange, to eligible outgoing international tourists. The outlets must reverse input tax credit on such goods, cannot claim refund of input-service taxes, and must maintain auditable electronic records linking inward supplies to passenger sales. Claims require prescribed passenger documentation, undertakings, return details and inward-supply statements, with invoices required where they are not reflected in the relevant statement. Improper refunds are recoverable with interest.

Under the pre-1994 Copyright Act, first ownership of copyright in a cinematograph film vested, absent a contrary agreement, in the person at whose instance and for valuable consideration it was made; the producer bore financial and commercial responsibility. A partnership that funded, produced, certified and commercially exploited the film could therefore hold copyright through its partners as joint owners and joint authors at completion. Retirement before completion and transfer of partnership interests undermined the plaintiff's claim. Absence of evidence of personal financing, contributor contracts, profit receipts or loan repayment, together with prolonged inaction, meant no prima facie authorship, ownership or Author's Special Rights were established.

IGST paid on exported goods and refunded to an exporter is not treated as contravening the export-refund restriction where the exporter initially imported inputs without IGST and compensation cess under the identified Customs notifications, later pays those levies with interest, and obtains reassessment of the relevant Bill of Entry by jurisdictional Customs authorities. Payment of IGST and compensation cess on inputs, with exemption confined to basic customs duty, means the specified notification benefit is treated as not availed for the restriction.

Post-sales discounts without further dealer obligations may be excluded from the supplier's value of supply where conditions for post-sale discount exclusion are met. Discounts linked to dealer promotional activities constitute consideration for services supplied by the dealer and attract GST, with corresponding input tax credit for the supplier. Discounts enabling reduced customer prices form part of the dealer's supply consideration. Where discounts are reflected through financial or commercial credit notes without a reduction in supplier tax liability, the dealer need not reverse input tax credit if the reduced supply value and original tax are paid.

Unstitched salwar suit sets and fabric pieces sold before stitching remain classified as fabrics rather than readymade apparel. Their classification depends on constituent material and carries the uniform 5% GST rate applicable to fabrics, without refund of unutilized input tax credit. Cutting fabric into different lengths and packing the pieces does not change their nature or tariff classification; the cut pieces retain the same GST treatment as the original fabric.

Suo motu revisional power cannot be used to set aside an appellate remand requiring the assessing authority to reconsider previously unexamined documents and issue a fresh order after hearing both sides. Such a remand is not prejudicial to revenue merely because it requires proper consideration of material. Revisional interference is improper where the authority refers to documents without deciding their merits and denies the assessee an opportunity of hearing. The appellate remand therefore remains operative.

Dual-energy solar cookers and all sprinklers, including fire water sprinklers, attract GST at 12%, while poultry-keeping machinery parts are expressly included in the relevant 12% rate entry. Agricultural farm produce in packages exceeding 25 kilograms or 25 litres falls outside "pre-packaged and labelled" goods and does not attract 5% GST. Past treatment of these issues is regularised on an "as is where is" basis. For qualifying welfare-scheme supplies of pulses and cereals, regularisation requires certification within 180 days and denial or reversal of input tax credit.

The Single All-India Multipurpose Electronic Bond offers importers and exporters a common electronic bond through ICEGATE instead of separate transaction-wise bonds at different customs ports. It may cover provisional assessment, export-promotion imports, concessional import or export, warehousing, and manufacture or other operations in private and special warehouses. Electronic execution includes online stamp-duty payment, e-stamping and electronic signatures through NeSL without notarisation. Electronic bank guarantees may be linked through ICEGATE, while supplementary bonds permit additional obligations or increased bond amounts.