Refund of accumulated Compensation Cess input tax credit on coal used to manufacture leather products for domestic supply under an inverted tax structure depends independently on the conditions in Section 54(3); credit standing in the electronic credit ledger does not itself create a cash-refund right. Availability of credit, including the absence of a blocked-credit restriction, concerns credit availment rather than refund eligibility. Inability to use cess credit against other liabilities and the absence of cess on domestic output supplies do not establish inverted tax structure eligibility. Clarifications and export-related decisions concerning zero-rated supplies do not support the domestic refund claim. The refund-granting appellate order was set aside, restoring the original rejections.

Refund of accumulated Compensation Cess input tax credit on coal used to manufacture domestically supplied leather products is limited to the statutory categories for unutilised credit. A cess burden on inputs, where domestic outward supplies do not attract the cess, does not by itself meet the inverted tax structure requirement. Eligibility to avail credit, including the absence of a blocked-credit restriction, is distinct from entitlement to a cash refund. Restrictions on credit utilisation neither bar every refund nor create an independent refund right. Clarifications and authorities concerning zero-rated supplies or exports do not establish eligibility for domestic supplies.

Section 129(1)(a) of the GST Act treats transportation in contravention of the Act or Rules, including movement after expiry of an e-way bill, as attracting civil penalty without requiring proof of intent to evade tax. A claimed vehicle breakdown must be established by reliable material. GPS data concerning another vehicle, repair records lacking evidentiary value, and an explanation not contemporaneously disclosed do not substantiate the claim. Guidance that does not address movement with an expired e-way bill provides no justification; on these facts, the penalty was upheld.

Road-restoration charges paid for planned restoration following road cutting for a business pipeline constitute consideration for a taxable service where the work is specifically requested and involves bilateral reciprocity, rather than compensatory damages. Targeted restoration undertaken for a commercial entity does not qualify as a general governmental public-function service or non-supply, and recipient-side reverse-charge liability applies where forward-charge payment is unproven. Refund sanctions for parallel registrations in other jurisdictions neither bind an independent appellate authority nor override statutory conditions. Electronic GST proceedings remain valid without a physical Document Identification Number where authenticated portal records establish source and integrity, the notice identifies the factual and legal basis, and no prejudice is shown.

Refund adjustment against a disputed penalty demand pending first appeal is ordinarily limited to 20% under CBDT stay guidelines. The guidelines do not distinguish assessment demands from penalty demands, so full adjustment before pending stay applications are decided conflicts with those instructions. Recovery should therefore be confined to 20% of the disputed penalty demand, with excess adjustment reversed and refunded with applicable interest and the balance demand stayed pending disposal of the first appeal.

Revisional limitation for a Debenture Redemption Reserve adjustment to book profit runs from the original assessment where reassessment was initiated on unrelated financial transactions. The High Court held that the original assessment continues to govern matters not forming part of reassessment, while the reassessment order supersedes it only for reassessed items. Although Explanation 3 permits assessment of another escaped-income issue noticed during reassessment, the DRR issue was not shown to have arisen then. The revisional order was therefore time-barred and set aside; the merits of the DRR adjustment remained open.

Functional comparability under TNMM requires selection or exclusion of comparables to conform to Rule 10B through a factual, data-driven analysis. A standard departmental comparable set cannot replace appropriately matched companies. Software product, product-development, licence and subscription businesses with significant intangibles may be functionally dissimilar to a software development service provider and therefore unsuitable as comparables.

CBDT stay instructions limit recovery of a tax demand disputed before the First Appellate Authority to 20% as a pre-condition for stay. Refunds for later assessment years may not be adjusted against the disputed demand where prior payments and such adjustments have already recovered more than that threshold. Adjustment beyond 20% is impermissible, and the excess recovery must be refunded within four weeks while the first appeal remains pending.

Information indicating income escaping assessment must relate to the same assessment year proposed for reopening. Reassessment for AY 2020-21 could not rest on agricultural-land sale information from FY 2020-21, which related to AY 2021-22 rather than FY 2019-20. Because the transaction had no bearing on income for AY 2020-21, it could not establish escapement for that year. The reassessment notices, initiating order and consequential proceedings were quashed.

Final-instalment payment under the Income Declaration Scheme depends on verifying that the cheque was tendered by the due date and that the amount was subsequently credited to the Income Tax Department's account. Applicability of the relevant circular was not determined on the available facts. The payment and credit were to be re-examined; where verified facts brought the declarant within the circular, Scheme benefits were to be granted.

Condonation of inordinate delay requires a pleaded and substantiated sufficient cause; filing before a court without territorial jurisdiction and subsequent administrative movement of papers, without a pleaded pandemic-related impediment, do not establish it. Gross negligence, deliberate inaction and unexplained delay undermine finality and certainty under limitation law, while delay may prejudice the opposing side. On these principles, the revenue's condonation request was rejected and its appeal was treated as barred by limitation.

Angadia cash-transit entries representing clients' funds do not constitute the operator's unexplained money where the operator acts only as a facilitator and no evidence establishes ownership or accrual of the principal. Only the embedded profit or commission is taxable, not gross cash-transit receipts. Commission embedded in unaccounted turnover was estimated at 0.30 per cent after credit for commission already assessed, reflecting the low-margin nature of the business, operating margins, scale of operations and comparable Angadia decisions. Such commission is taxable at normal rates rather than under section 115BBE, and additions for gross principal cash transactions were deleted.

Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.

Section 56(2)(x) was treated as inapplicable where land was acquired solely through purchase of leasehold rights rather than ownership rights in land. The interpretation followed co-ordinate Tribunal decisions that compared the provision with Section 50C and adopted the view favourable to the assessee amid conflicting High Court views. Characterising the transaction as a sale of land did not change its legal character as a transfer of leasehold rights. The related addition was deleted.

Revision under section 263 cannot rest solely on an Assessing Officer's failure to record satisfaction or initiate penalty for alleged cash-transaction violations of section 269SS. It requires both an erroneous assessment order and prejudice to Revenue. Penalty under section 271D is independent of assessment proceedings and, under the applicable statutory scheme, falls within the Joint Commissioner's competence. The limitation governing that penalty cannot be bypassed by setting aside a completed assessment to create a fresh penalty foundation, particularly where the underlying transactions admit two plausible views.

The first proviso to section 149(1)(b) preserves the reassessment limitation available under the pre-amendment regime for assessment years commencing on or before 1 April 2021. The fifth and sixth provisos regulate computation under the amended three-year or ten-year framework but cannot extend that preserved limitation. Consequently, a reassessment notice for assessment year 2015-16 issued after expiry of six years from the end of the relevant assessment year was time-barred, and the consequential reassessment order was invalidated.

Cash deposits claimed to arise from cash sales require documentary verification linking the sales to the specific deposits. Matching aggregate turnover with VAT returns and establishing a cash-sales business do not alone prove that nexus; cash books, sales and stock registers, and date-wise or period-wise reconciliation must establish cash availability and rule out circulation through multiple accounts. Verification of the claimed source was remitted to the Assessing Officer with reasonable opportunity. A reassessment notice allowing less than seven days in its stated response date remained valid where the order followed only after twelve days and no inability or attempt to respond was shown; the cross-objection failed.

Where a draft assessment order is issued within the prescribed period, final assessment timing pursuant to DRP directions follows the specific statutory limits rather than the general assessment limitation. Tax computation must give effect to allowed brought-forward losses and unabsorbed depreciation, subject to verification against duplicate relief. RPM is appropriate for unaltered goods resold to independent customers where reliable gross-profit data and functional comparability exist; operating profit or loss alone does not disqualify a trading comparable. The other method can combine justified NAV and DCF valuations, and a deemed international transaction does not establish associated-enterprise status for secondary adjustment, which requires the actual relationship.

Functional comparability under the CUP method requires comparison of functions performed, assets employed and risks assumed; third-party guarantee data must be disclosed for effective rebuttal. In the absence of reliable comparable uncontrolled transactions or a proper FAR analysis, the transfer-pricing adjustment for counter-guarantee support was deleted. Lending income could not be equally allocated where the overseas entity funded loans and assumed substantive lending risks, and no reliable comparable or prescribed method disproved the attribution. An arm's length price cannot be determined ad hoc after rejecting TNMM without a comparable or prescribed method. Regional support expenditure was supported by evidence of services, business n.....

Unsecured loans alleged to be accommodation entries require evaluation of lender identity, creditworthiness and transaction genuineness. Confirmations, bank statements, ledger accounts, receipt through banking channels, and repayment with interest support those requirements; generic third-party search information or allegations of entry providers do not, without contrary material, displace such evidence. Interest expenditure connected with a supported loan requires evidence of actual incurrence or payment, rather than presumption or estimation based merely on an alleged consequential liability.