Reassessment under Sections 147 and 148 requires a reason to believe, based on tangible material with a live nexus to income escaping assessment; estimated foreign-travel expenditure where the return did not require separate disclosure amounts only to suspicion. For a notice issued beyond four years, the recorded reasons must also identify the assessee's failure to disclose fully and truly all material facts. Absence of those requirements renders the notice and consequential assessment void ab initio. A concealment penalty under Section 271(1)(c) founded exclusively on additions in that invalid reassessment has no surviving basis.

External development charge payments attract tax deduction at source as contract payments rather than rent payments. Revisionary jurisdiction may correct the applicable withholding provision from rent-payment treatment to contract-payment treatment where the revision precedes first appellate adjudication and the issue has not been considered and decided on appeal. Explanation 1(c) does not bar revision in those circumstances, and the corrected TDS treatment remains operative.

Validity of search authorisation under Section 132 cannot be challenged through an assessment appeal. For seized cash, a taxpayer's unsupported explanation of customer collections may fail the test of human probabilities and justify treatment as unexplained money under Sections 69A and 115BBE. However, the established nature of a milk and dairy-products business operating in an unorganised sector may make it inappropriate to treat the entire seized cash as unexplained. A fact-specific lump-sum addition was consequently considered appropriate, without creating a precedent.

Reassessment for AY 2015-16 required notice within the limitation applicable under the earlier regime; the first proviso to section 149 barred a notice issued after that period had expired. For the extended reassessment period under section 149(1)(b), escaped income in a capital-gains transaction must be the taxable capital gain, if any, rather than the gross sale consideration received on transfer. Reliance on gross sale consideration without determining taxable capital gain does not meet the jurisdictional condition that income represented in the form of an asset has escaped assessment. Timely notice and legally determined escaped income are independent requirements for reassessment jurisdiction.

Eligible freight payments to sub-contractors covered by verified Form 15-I declarations remain exempt from tax deduction at source. The contractor is not responsible for verifying declarations furnished by sub-contractors, and filing Form 15-J with a non-jurisdictional Commissioner is a procedural defect that does not revive a tax-deduction obligation or support disallowance for non-deduction. Where transport-business receipts and books of account are accepted, corresponding freight expenditure cannot be wholly disallowed merely because declaration-related doubts arise. A wholesale expense disallowance requires rejection of accounts and a reasoned estimation of profits.

State tax measures include amendment of Finance Department Notification No. 15313-CTA-19/2005 and reconstitution of the Odisha State Authority for Advance Ruling. The measures were circulated to CT & GST territorial and enforcement formations, circles, assessment units, and first appellate authorities for information and necessary action, and remain accessible on Finance Department and CTD websites.

Explanation-II under the Odisha Value Added Tax framework is amended by replacing the earlier reference to item No. 3 with serial numbers 4A, 4B and 5, covering motor spirit commonly known as petrol, high speed diesel and aviation turbine fuel. The Note is also expanded to include Reliance Industries Limited, Nayara Energy Limited, and any other registered oil company operating in the State.

Form GST DRC-28 prescribes the order on an objection in Form GST DRC-27 against a restriction on debit from the electronic credit ledger imposed through Form GST DRC-26. Following consideration of the objection, supporting material, and a reasonable opportunity of being heard, the application may be allowed and debit restored from a specified date. If the objection is not in order, reasons are recorded, the application is rejected, and the debit restriction continues.

GST DRC-27 provides for objections to GST DRC-26 orders restricting debit from an electronic credit ledger. The applicant must identify the restrictive order and submit the objection to the proper officer having jurisdiction. The objection must state relevant facts and circumstances, may include supporting documents, and requires a verified declaration that the information is true, correct and not concealing any material fact.

Form GST DRC-26 enables restriction of debit from the electronic credit ledger where input tax credit appears to have been fraudulently availed or is ineligible. The proper officer may restrict debit up to the equivalent credit amount after recording the reasons. The restriction ends on the earlier of one year from issuance or a subsequent order allowing debit when the disallowance grounds no longer exist. Objections may be filed through Form GST DRC-27.

Internal Review Cell scrutiny treats orders passed during the quarter ending March 2025 as the opening balance, with subsequent monthly orders added as accrual. Refund sanction orders and orders where the final demand is lower than the show-cause liability require compulsory scrutiny. High-stake orders may be reviewed for omitted issues. First appeal is preferred against erroneous orders, while suo motu revision is reserved for orders erroneous and prejudicial to revenue. A monthly progress report records scrutiny, discrepancies, pending cases, and statutory remedies.

Three centrally issued GST circulars are adapted for application under the Odisha Goods and Services Tax Act, 2017, to promote uniform implementation. They clarify regularisation of GST on apportioned co-insurance premiums and reinsurance commission, GST applicability to certain services, and late fee applicability for delayed furnishing of FORM GSTR-9C. The clarifications are characterised as clarificatory.

Article 13 of the India-Mauritius tax treaty governs the claimed exemption of current-year long-term capital gains, while Section 74 governs set-off and carry-forward of long-term capital losses. Where those gains are exempt from Indian taxation under the treaty, no taxable capital gain exists for adjustment of brought-forward long-term capital losses; the losses therefore remain available for carry-forward in accordance with law. Treaty-exemption entitlement requires factual verification, with an opportunity of hearing, before this treatment applies.

GST exemption is considered for upfront consideration determined upfront but paid or payable in instalments for long-term leases of industrial or financial-infrastructure plots. Seed testing, inspection, certification and issuance of seed tags together form a composite exempt supply where the certification is legally required for consumer and public safety. Seed tags separately supplied by external departments or manufacturers are taxable goods, classified according to their predominant material.

GST registration is deemed cancelled upon submission of a cancellation application, from the application date or the requested cancellation date. Registration obtained under rule 14B is also deemed cancelled following specified changes involving an electronic commerce operator, the declared principal place of business, or cancellation of the underlying home-State registration, where required amendments are not filed within thirty days. Cancellation does not remove liability for tax, other dues, or GST obligations relating to periods before cancellation.

Change in the effective date of GST registration cancellation may be ordered after a show cause notice, with reasons recorded and the revised cancellation date specified. The available record, any reply, and written or oral hearing submissions may be examined according to the person's response and attendance. The registered person must file pending returns and, where furnishing returns under section 39(1), file FORM GSTR-10 within three months of the order. Earlier tax liabilities and statutory obligations remain unaffected by cancellation.

GST REG-36 provides for dropping proceedings commenced to change the effective date of registration cancellation. Following consideration of the taxpayer's reply to a show cause notice or submissions at a hearing, the proceedings may be vacated with recorded reasons. Proceedings are deemed dropped where no order is issued within sixty days of the show cause notice. A deemed-dropping order is system-generated and does not require the issuing authority's signature.

Existing registered persons electing the concessional tax option must submit FORM GST CMP-02 under the indicated supplier category by 30 April 2019 and furnish FORM GST ITC-03. Eligible applicants for new registration may select the option in FORM GST REG-01. Election for one place of business extends to all registrations under the same Permanent Account Number and operates from the financial year's beginning or, for new registrations, the registration date.

Form GST REG-35 prescribes replies to show cause notices concerning a change in the effective date of cancellation. It requires notice particulars, GSTIN/UIN, legal and trade names, the reply, and a list of uploaded supporting documents. An authorised signatory must verify by solemn declaration that the information is true and correct to the best of knowledge and belief and that nothing has been concealed, and provide signature, name, designation or status, place, and date.

GST REG-34 requires a show cause notice before changing the effective date of cancellation of GST registration. Grounds include fraudulent registration, failure to conduct business from the declared place, issuing invoices without supply, and failure by a voluntarily registered person to commence business within six months. The person is allowed thirty days to reply and an opportunity of personal hearing. Failure to respond or attend may result in an ex parte determination on available records and merits.