Business deductions for motor vehicles registered in a director's name require records demonstrating exclusive company use; absent such evidence, a 25% disallowance for personal use applies, notwithstanding treatment in an earlier assessment. Interest on borrowings remains deductible where the borrowings are used for business purposes and no nexus is established with interest-free advances, particularly where those advances are funded from interest-free sources. Rent for director-provided accommodation may be commercially expedient and deductible, while the director's perquisite is separately taxable. Bank penal interest for delayed loan instalments is compensatory, rather than payment for an offence or prohibited purpose, and is allowable under section 37(1).

Section 14A permits Rule 8D computation only where recorded, account-based dissatisfaction establishes that a voluntary exempt-income expenditure disallowance is incorrect; a formula-only objection is insufficient. For assessment year 2020-21, depreciation is available on goodwill, brands and distribution networks identified and acquired for apportioned consideration in a demerger, even if absent from the demerged entity's asset block. Restrictions applicable to existing block assets do not cover these newly identified intangibles, and the later goodwill exclusion applies prospectively. Donation deductions disclosed in returns and audit records require consideration once assessment adjustments yield positive gross total income, notwithstanding losses in the returned computation.

Rule 27 allows a respondent that has neither appealed nor filed a cross-objection to defend an appellate order on a ground decided adversely, including a jurisdictional challenge to reassessment. Where alleged escaped income is based solely on search material and the year falls within the extended relevant assessment years under Section 153A, that provision's non obstante clause and mandatory language make it the exclusive assessment mechanism. If the extended-regime conditions, including the prescribed asset threshold, are met, recourse to Section 148 is without jurisdiction and the resulting reassessment is void ab initio.

Section 250 requires the first appellate authority to decide an income-tax appeal on merits by formulating points for determination and recording reasons. Dismissal solely because the assessee is absent or fails to file written submissions, including in an ex parte proceeding, does not meet that statutory duty. Where a prior direction requires merits-based reconsideration, compliance with these requirements is mandatory. An appellate order lacking points for determination and merits-based reasons is legally unsustainable and requires de novo reconsideration after reasonable opportunity of hearing.

Challenges to the legality, validity and propriety of a reassessment notice, including the statutory sanction for its issuance, were left open after connected reassessment matters were remanded. The petition was closed with liberty to initiate fresh proceedings on the same cause of action, including a challenge to the newly introduced statutory provision. Existing protection continued for 90 days but would cease if no fresh petition was filed within that period.

Section 275(1)(a) requires penalty proceedings under Section 270A to remain in abeyance while an appeal against the relevant assessment order is pending before the Appellate Tribunal. Where the appeal was filed and remained pending when the penalty order was issued, the order contravenes that requirement and cannot stand. The Assessing Officer's awareness or lack of intimation of the pending appeal does not affect this consequence.

Interest on requisitioned cash accrues under Section 132B(4) at simple interest of one-half per cent for every month or part of a month, from the day after expiry of 120 days following execution of the requisition until completion of assessment. Where assessment determines no tax liability, Section 132B(3) requires forthwith release of remaining seized assets. Continued post-assessment retention may attract compensatory interest on restitutionary principles despite no express statutory provision for that period. Compensation for deprivation of the use of money does not depend on whether the Revenue earned interest on the retained cash.

Effective cross-examination must be provided before completing a fresh assessment where prior directions require witnesses to be made available in accordance with principles of natural justice. An assessee's failure to attend an initially fixed hearing does not exhaust that right when the Assessing Officer subsequently issues fresh notices to the assessee and witnesses; those notices condone the earlier lapse. If the assessee attends the rescheduled hearing but witnesses do not, assessment without cross-examination is vitiated. Fresh assessment must follow cross-examination of both witnesses, subject to stipulated witness costs.

Cross-objections in High Court appeals under Section 260A of the Income-tax Act are maintainable through Section 260A(7), which incorporates compatible CPC appeal procedures. Order XLI Rule 22 permits a respondent to challenge an adverse part of the Tribunal's order by cross-objection, while Order XLII Rule 1 extends that procedure to second appeals, to which a Section 260A appeal is analogous. This procedural right does not expand the limited jurisdiction under Section 260A: the cross-objection must concern an adverse finding and raise a substantial question of law.

Suppression of material subsequent assessment orders may bar relief in income-tax appeals under section 260A. Orders passed after Tribunal-directed verification had determined tax and interest liability under sections 201(1) and 201(1A), pre-dated the appeals, and were neither disclosed in the appeal memoranda nor challenged. In the absence of a satisfactory explanation, their finality and the withholding of material facts left the appellants disentitled to appellate relief.

Excess tax deposited at the first appellate stage may be adjusted towards the Tribunal pre-deposit where it meets the cumulative requirement for the surviving tax dispute. The additional pre-deposit requirement applies to the tax remaining in dispute after excluding a separately remanded demand, and requires a total deposit of 20% when read with the first appellate pre-deposit. "In addition to" establishes the aggregate amount payable, not a requirement for a fresh payment through a separate challan. Pre-deposit remains an adjustable component of disputed tax, including amounts paid through FORM GST DRC-03, avoiding an unnecessary refund-and-redeposit cycle.

Entitlement to input tax credit not reflected in FORM GSTR-2A requires interpretation of the recipient-payment condition, Rule 36(4), and relevant departmental circulars. The issue extends beyond verification of returns or supporting documents because the provisions' scope and interrelation directly affect credit eligibility. It therefore raises a question of law under Section 109(8) of the Central Goods and Services Tax Act, 2017, requiring consideration by a Division Bench comprising a Judicial Member and a Technical Member.

Request-specific road restoration performed by a government authority for a business entity's commercial pipeline project constitutes a taxable supply for consideration, with GST payable by the recipient under reverse charge. Targeted restoration differs from routine public road maintenance and does not qualify as a sovereign public-function activity, non-supply, or exemption linked to constitutional local-government functions. Refund sanctions in other jurisdictions do not create binding precedent or res judicata, and an unsupported assertion that tax was already paid does not displace reverse-charge liability. Electronic GST portal records can establish the authenticity of refund proceedings despite the absence of a physical DIN, where the notice adequately discloses the grounds and causes no prejudice.

Request-specific road restoration undertaken by a government authority for a business entity's commercial pipeline activity constitutes a taxable supply when separately quantified charges are paid in direct exchange for the restoration service. Such charges differ from compensatory damages because they involve reciprocal performance. The service does not receive non-supply treatment as a public-welfare function under Articles 243G or 243W and is not covered by the general governmental-function exemption. Under reverse charge, the business recipient bears GST liability where forward-charge payment is unproven. Refund orders for separate State registrations do not govern independent adjudication, while authenticated electronic notices remain valid despite the absence of a physical DIN where adequate notice and response are established.

Customised road-restoration services performed by a government authority at a business entity's request, following road excavation for pipeline operations, constitute a taxable supply for consideration rather than compensatory damages. Targeted commercial restoration differs from general public-road maintenance and does not qualify as a non-supply governmental function or a public-function exemption. The business recipient bears GST under reverse charge. Refund orders from other jurisdictions do not establish binding precedent or res judicata, and unproven forward-charge payment does not displace reverse-charge liability. Electronically authenticated GST proceedings remain valid where the notice identifies the grounds, the recipient can respond, and no prejudice arises from the absence of a physical DIN.

Targeted restoration of public roads at a business entity's request is treated as a taxable supply for consideration rather than compensatory damages or a sovereign public-road function. Recipient liability therefore arises under the applicable reverse-charge mechanism, while exclusions and exemptions are construed strictly. Refund sanctions by tax officers in other State jurisdictions are administrative determinations, not binding precedents or res judicata. Electronic GST-portal proceedings remain valid where notices identify the factual and legal basis of the claim and the taxpayer suffers no prejudice; absence of a physical Document Identification Number alone does not compromise authenticity or natural justice. These principles support denial of refund where reverse-charge tax remains unpaid.

Customised road-restoration work undertaken by a government authority at a business entity's request, following road cutting for a commercial pipeline project, constitutes a taxable supply for consideration rather than compensatory damages. Routine public-road functions do not extend non-supply or sovereign-function exemptions to request-driven repairs supplied to business entities. The recipient business entity bears GST under the reverse-charge mechanism for taxable services received from government or local authorities, absent transaction-specific proof that tax was paid under forward charge, and cannot claim refund merely by alleging double taxation. Refund sanctions in other jurisdictions neither create res judicata nor govern separate GST determinations. Authenticated portal-based notices and orders can satisfy natural justice despite no physical DIN where adequate particulars and opportunity to respond exist.

Section 120 of the Uttar Pradesh GST Act authorises monetary-limit instructions for departmental appeals. For Tribunal appeals, the applicable instruction requires aggregation of disputed tax alone, excluding interest and penalty where tax is disputed, and sets a threshold of Rs. 20,00,000. Commissioner authorisation under Section 112(3) does not override that policy. An appeal below the threshold requires a specifically pleaded and supported recognised exception; reliance on interests of justice or revenue requires a case-specific, reasoned opinion of the Commissioner. Without such material, the departmental appeal is not maintainable and cannot proceed to merits adjudication.

Departmental GST appeals before GSTAT are subject to the prescribed monetary-limit policy under the Uttar Pradesh GST Act. Where only penalty is disputed and the amount falls below the applicable threshold, the appeal requires a specifically pleaded and supported exception. Statutory authorisation to file an appeal does not independently satisfy that requirement. A recurring legal issue, another specified exception, or a reasoned case-specific exercise of residual power must be established to depart from the policy. In the absence of such material, the departmental appeal is not maintainable.

Bill-to/Ship-to supplies are legally permissible where an original supplier dispatches goods directly to the ultimate consignee on an intermediate buyer's direction, provided the transactions are genuine, documented, accounted for and taxed. Valid e-invoices should identify the Bill-to and Ship-to parties, while e-way bills must correspond to the movement and may be generated by the person causing it, including the applicable consignor or consignee. Where those requirements are met before interception, detention and penalty cannot rest solely on the original supplier's failure to generate an e-way bill.