Penalty under section 270A is invalid where the notice merely alleges under-reporting of income without identifying the applicable statutory circumstance. The specific charge must be communicated at initiation, and later identification in the penalty order does not cure the defect. Penalty under section 271AAB is unsustainable unless the amount satisfies the statutory definition of undisclosed income. An admission alone is insufficient where expenditure recorded in kaccha books during an unclosed financial year was subsequently entered in regular books and accounted for in the accepted return. Failure to specify the relevant penalty clause also leaves the charge unspecified.

Section 68 does not permit cash deposits during demonetisation to be treated as unexplained where audited books, cash and stock records, sales and purchase records, and VAT returns establish recorded bullion and jewellery sales and corresponding stock movement. An increase in cash sales before demonetisation, without evidence disproving sales, stock availability, or the records, does not negate the explained source. Where sale proceeds have already been credited to the trading account and included in returned income, a further cash-credit addition duplicates taxation. Suspicion or human-probability considerations cannot replace material evidence.

Section 273B precludes penalty under Section 271B where the assessee establishes reasonable cause for failure to furnish an audit report within the prescribed time. Viral fever was accepted as reasonable cause for the three-month delay because the Revenue produced no material to refute the explanation. Consequently, penalty for delayed furnishing of the audit report was not imposable.

Section 144B makes a show-cause notice mandatory before a faceless assessment introduces a variation prejudicial to the assessee. Disallowance of acquisition or construction cost without that notice breaches the prescribed assessment procedure and principles of natural justice. Where the Revenue concedes that no notice was issued, the resulting assessment order is non-est in law.

Voluntary ex gratia payments made under an employer's early-retirement scheme following unit closure were treated as outside profits in lieu of salary where they were not founded on an employer obligation under the service terms. The payment therefore did not constitute compensation for section 17(3) purposes and was not taxable; the related addition was deleted.

Delay of 735 days in challenging a revision order was not supported by sufficient cause. Reliance on professional assistance, failure to monitor communications, and a change of auditor did not explain the prolonged inaction. Professional representation in consequential assessment proceedings indicated that the revision order had not been timely challenged, while the appeal filed after consequential assessment was treated as an afterthought. Condonation of delay was therefore refused.

Revision of an assessment for alleged inadequate inquiry into accommodation-entry transactions is unsustainable where no material links the assessee to the intermediary or subsequent entity. Information alleging a payment to the intermediary, denied by the assessee, did not establish movement of funds from the assessee. As the Assessing Officer had conducted inquiry and the assessment was not shown to be both erroneous and prejudicial to Revenue interests, revision under Section 263 could not be sustained; no substantial question of law arose.

Section 148A(3) requires consideration of the taxpayer's response and supporting documents before forming an opinion that reassessment is warranted. Material explaining alleged undisclosed turnover as cash deposits, capital transactions, unsecured loans and land-sale advances must be examined to determine whether it represents business turnover. Mere reference to absent reconciliation or documentary evidence, without examining the explanation and recording cogent reasons, does not satisfy this requirement. The reassessment order and consequential notice were set aside for fresh consideration after due examination of the material furnished.

Section 148A requires disclosure of the definite information, computations and material proposed to support reassessment, together with a reasonable opportunity for the assessee to respond before a determination is made. Bank credits cannot automatically be treated as undisclosed turnover without disclosing the underlying computation and supporting material. Adverse allegations concerning fund parking, unsecured loans, expenses or accounting practices cannot be introduced in the determination if they were absent from the show-cause notice. Reassessment initiation based on undisclosed material or new propositions amounts to a roving enquiry and requires reconsideration after proper disclosure and opportunity.

Penalty for concealment under Section 271(1)(c) is not leviable where additional income disclosed in a return filed under Section 153A pursuant to a Section 153C notice is accepted without further addition. Under Section 271(1)(iii) and Explanation 4(c), the tax sought to be evaded is the difference between tax on assessed income and tax chargeable after excluding concealed income. Where assessed income equals returned income, no such tax difference arises. Explanation 5 does not apply to this position.

Completion of the block assessment, absence of any outstanding tax demand, and absence of an operative attachment over the bank locker supported release of the jewellery. The assessee could operate the locker in accordance with the bank's procedure, while the Revenue's lack of objection and undertaking to release the jewellery enabled its handover to the assessee.

Delay in furnishing Form No. 10 for accumulation under Section 11(2) may be condoned under Section 119(2)(b) where the original timely return and audit report disclose the claim, demonstrating that the omission was not an afterthought. Filing the form before issuance of the intimation constitutes substantial compliance with a directory procedural requirement. Condonation is appropriate where inadvertence is supported by contemporaneous records, accumulated funds are invested in prescribed Section 11(5) modes, and denial would cause undue hardship to the charitable trust's corpus and activities.

Real-estate anti-profiteering calculations may quantify additional input tax credit by comparing actual pre-GST credit and post-GST ITC with corresponding project purchase values, rather than turnover, where buyer receipts, construction activity and credit accrual do not align. The resulting project-level savings may be allocated across eligible sold area as a per-square-foot benefit and passed to buyers through commensurate price reductions. Pre-GST purchases and credits remain relevant despite a post-GST commencement certificate if certified records establish project nexus. GST collected on excess realisation forms part of the profiteered amount. Penalty exposure applies for conduct within the provision's effective period, subject to timely-deposit exemption.

Section 74 CGST proceedings must be initiated separately for each financial year or tax period. GST liability, assessment, recovery, annual-return obligations, and limitation periods operate independently year-wise; consequently, a consolidated show-cause notice aggregating periods with different due dates and separately running limitation periods conflicts with the statutory scheme. Binding jurisdictional High Court decisions prohibiting such consolidation govern authorities within the State. Dismissal in limine of a challenge to a contrary High Court ruling neither triggers the doctrine of merger nor displaces the binding local precedent. Consolidated Section 74 notices and consequential adjudication orders spanning multiple years or tax periods are therefore impermissible.

Separate assessment proceedings are required for each tax period under the statutory scheme governing GST assessments. Sections 73 and 74 preclude a single show-cause notice or assessment order covering multiple tax periods. Composite proceedings may restrict access to statutory benefits and impair the statutory right of appeal. Consequently, a composite assessment order spanning more than one tax period is legally unsustainable, while separate proceedings for each relevant period may be initiated in accordance with law.

Cancellation of GST registration should be challenged through the statutory appellate forum under section 107 of the CGST Act, which can address factual and legal objections. Intra-court writ appellate jurisdiction under Article 226 permits interference with a Single Judge's direction to use that remedy only where demonstrable legal error or perversity is shown. Where the direction is plausible and no such defect is established, recourse to the statutory appeal remains required.

Requested personal hearing under section 75(4) of the Maharashtra Goods and Services Tax Act, 2017 must be afforded where the taxpayer seeks it to explain factual matters and supporting documents. Proceeding with adjudication on the basis that no representative attended, without evidence that a hearing date was notified after the request, denies a fair opportunity of hearing. Such denial vitiates the adjudication, requiring the issue to be resolved in favour of the assessee.

Under section 75(4), a written request for a personal hearing in response to a show-cause notice must be assessed holistically. An inadvertent "No" selection in Form GST DRC-06 does not amount to an express waiver where the reply expressly seeks a hearing. Denial of the hearing breaches principles of natural justice and requires fresh adjudication after hearing the assessee.

Transfer of leasehold rights in an industrial plot is treated as a transfer of benefits arising from immovable property rather than a taxable supply. Consequently, input tax credit on acquiring those rights cannot be characterised as blocked credit under the construction-related restriction, which applies only to lawfully taxable inward supplies of goods or services received for construction of immovable property. No construction occurs merely through a transfer of leasehold rights. Fraud-based recovery cannot be invoked where the underlying transaction is non-taxable and the credit is not ineligible. Tax collected on a subsequent transfer was deposited with the Government.

Adjudication of an input tax credit demand must address an objection that central GST proceedings cover the same period and credit and trigger the statutory bar on parallel proceedings. Confirming tax, interest and penalty without determining the asserted overlap fails to provide reasoned adjudication. The overlap and statutory bar require fresh determination in accordance with law, while the substantive eligibility of the input tax credit remains open.