Retrospective upward price revisions for pre-GST clearances determine the goods' true value at original clearance. The transitional reporting mechanism for post-GST debit notes enables declaration and payment of differential tax but neither creates a new taxable event nor shifts the original time of supply. Interest attaches to delayed payment of differential tax from the original clearance period. Where contractual price escalation creates a bona fide transitional interpretative dispute and tax is voluntarily paid without fraud, wilful misstatement, suppression, or deliberate non-compliance, penal consequences are unwarranted.

Assignment of leasehold rights in an industrial plot and building for consideration transfers the benefits of immovable property to the assignee, who replaces the original lessee. Under section 7(1)(a), Schedule II clause 5(b), and Schedule III clause 5 of the CGST Act, the assignment is not taxable as a supply of services. Its classification as other miscellaneous services under Serial No. 35 of Notification No. 11/2017-Central Tax (Rate) is inapplicable. The jurisdictional ruling excluding these transactions from GST remains binding unless stayed or recalled; consequently, GST is not leviable.

For 2017-18, supplier credit notes did not themselves require recipients to reverse input tax credit: the statutory framework then governed reduction of the supplier's output liability, the matching mechanism was not operational, and Rule 37 applied only to non-payment of suppliers within 180 days. Past-period GSTR-3B errors could be corrected on a net basis. Excess IGST should ordinarily be refunded or adjusted against future IGST liability; a refund paid through the electronic credit ledger would be recredited as IGST input tax credit, then cross-utilisable against CGST and SGST. Direct cross-head adjustment bypassed that route but was a bona fide, revenue-neutral procedural lapse that did not support tax, interest, or penalty recovery.

Where GST registration was cancelled before issuance of a show-cause notice, portal-only service may not provide effective notice because the noticee may be unable or not required to access the Common Portal. Binding departmental instructions requiring physical service in those circumstances apply. Absence of physical service deprives the noticee of an effective opportunity to respond and renders an ex parte adjudication unsustainable. The matter requires fresh adjudication after permitting a reply, necessary requests for documents or cross-examination, and adequate prior notice of personal hearing.

Ex parte cancellation of GST registration without recorded reasons warranted writ intervention under Article 226. The cancellation order was quashed and set aside, with fifteen days granted for filing pending returns and depositing outstanding dues. Absence of reasons in the cancellation order was the central legal defect requiring corrective relief.

Article 226 writ jurisdiction remains available despite an alternative statutory remedy where adjudication breaches procedural fairness and audi alteram partem. Section 74(9) requires consideration of the taxpayer's representation before liability is determined. Rule 142(4) requires a reply in Form GST DRC-06 but does not make electronic filing the exclusive mode: an acknowledged manually filed reply cannot be disregarded solely because it was not uploaded on the portal. Failure to consider that reply, objections, and documents permitted for submission before the allowed time expires violates natural justice, vitiates the adjudication, and requires reconsideration after an effective hearing.

Where GST registration has been cancelled and business operations have ceased, solely uploading a show-cause notice on the GST portal does not constitute adequate service for proceedings under Section 74 of the Uttar Pradesh GST Act. Notice must be issued through an alternative mode consistent with principles of natural justice. Failure to provide effective notice invalidates the resulting Section 74 order and warrants its setting aside for breach of natural justice.

Statutory appellate remedy was permitted despite expiry of the prescribed limitation period and the period capable of condonation. The petitioner received liberty to file an appeal within two weeks. The appeal was to be entertained without any objection based on limitation, enabling recourse to the statutory appellate process notwithstanding the expired time limits.

Excise-duty demand requiring cash payment under Rule 8(3A) of the Central Excise Rules, 2002 was unsustainable because that rule had been declared ultra vires and unconstitutional. Jurisdictional High Court and Tribunal decisions followed that position. Judicial discipline required adherence to those binding decisions, preventing enforcement of the cash-payment requirement through the demand.

Mobile-phone parts classification under Rule 1 of the General Rules for Interpretation and Section XVI Note 2(b) covers specially designed aluminium plates, magnesium alloy sheets, thermal-management materials, antennae, tape and dust-proof paper where they are solely or principally used in mobile-phone manufacture. Further machining, stamping or lamination does not alter that character. These goods qualify for the manufacture-linked customs exemption where their prescribed end use in intermediary or finished mobile phones is established and verified. Low-viscosity polymer granules introduced after filing fall outside the advance-ruling scope because they were not identified in the original application.

Interest-free advances to wholly owned subsidiaries, used for overseas business expansion as owners' quasi-equity and not funded by domestic borrowings, were not benchmarked as ordinary loans for a notional-interest transfer-pricing adjustment; the adjustment was deleted. Corporate-guarantee pricing was restricted to 0.5%, reflecting an arm's-length rate materially lower than a bank-guarantee rate. A creditor's write-off supported an addition for remission or cessation of the related trading liability, while a separate alleged liability required verification of whether it remained outstanding in the taxpayer's books. Only the established write-off addition survived, subject to verification of the other liability.

Section 69A treatment of demonetisation-period cash deposits must consider whether the claimed source-realisation of business receivables and sales-was accepted on materially identical facts in an earlier assessment year. Although res judicata does not strictly govern income-tax assessments, the rule of consistency supports uniform treatment where the fundamental facts and source explanation remain unchanged. Without a material distinguishing change, the same business-receipt explanation should not be rejected; the addition requires fresh determination after considering the earlier assessment, supporting material, and providing a reasonable hearing opportunity.

Closing-stock valuation under the mercantile system must be assessed as part of an integrated going-concern exercise. A reduced closing-stock value that also lowers opening stock in the succeeding year increases that year's profit; where the Department does not establish distortion of profits for the relevant year, the adjustment is revenue-neutral. The resulting tax effect concerns only the timing of taxability, not the accrual of real income, so an addition based solely on that reduced valuation is unsustainable.

Unsigned electronic notices issued under Section 148 to initiate income-tax reassessment must comply with the CBDT requirement that notices issued through the e-proceedings facility bear the Assessing Officer's digital signature. Where a reassessment notice was neither digitally nor manually signed, it was invalid and could not confer jurisdiction to reassess income. The resulting reopening proceedings and consequential assessment were quashed.

Dividend income of a recognised staff provident fund is exempt under Section 10(25). Misreporting that income in the return under Section 10(35) does not change its exempt character or justify its disallowance under Section 115BBDA. Delayed employees' provident-fund and ESI contributions concern a separate issue and cannot support disallowance of the fund's dividend income. The dividend disallowance under Section 115BBDA was deleted.

Reassessment beyond four years after scrutiny requires recorded failure to make full and true disclosure linked to escaped income; absent that requirement, reopening is void. Within four years, tangible material not examined originally can support reopening without change of opinion. Dealer-service payments not shown to be prohibited by law, actuarially valued IBNR and IBNER claims, and amortised premium on mandated Government securities qualify as deductible expenditure. Foreign reinsurance premiums require withholding where the payee's Indian business connection or permanent establishment makes income chargeable; default can trigger disallowance. Special insurance computation rules prevent exempt-income expenditure disallowance and book-profit add-back of reserve for unexpired risk, while qualifying investment-sale gains remain exempt.

Section 144C(13) requires a final assessment conforming to Dispute Resolution Panel directions to be completed within one month from the end of the month in which the directions are received. Digitally signed directions uploaded to the ITBA portal are treated as accessible to the Faceless Assessing Officer on the upload date. Internal system processing, asserted non-receipt, or differing user functions do not defer limitation; an assessment made without the directions cannot satisfy the conformity requirement.

Reassessment was sustained where a search-related inquiry identified an assessee's political donation and the assessee acknowledged it during assessment inquiry. A deduction for political contribution cannot be determined on merits without verifying bank records for possible prior cash receipt or subsequent return of donated funds. The deduction issue requires fresh adjudication after verification of donation evidence and an opportunity of hearing, consistent with principles of natural justice.

CBDT's extended-relaxation circular permits the admission and processing as pending applications of settlement applications filed after 31 January 2021 and before 30 September 2021, provided the assessee was otherwise eligible and relevant assessment proceedings remained pending. Applications filed within that period require consideration by the Interim Board in accordance with the circular and applicable law. Eligibility to apply for settlement under section 245C remains subject to separate examination and is not determined merely by filing within the extended period.

GST process reforms propose automated registration, registration amendments and cancellation, return reconciliation, input tax credit correction, and phased system-based refund processing. Standardised demand notices and adjudication safeguards are proposed alongside lower penalties, capped penalty-only appeal pre-deposits, withdrawal of arrest powers and narrowed prosecution provisions. Input tax credit reforms would expand refunds and remove specified blocked-credit restrictions, while export measures would broaden zero-rated and export-of-services eligibility. Goods interception would be intelligence-based and authorised, with further compliance relief for small taxpayers and targeted classification, exemption and reverse-charge measures.