Reassessment for assessment year 2015-16 initiated by a notice issued on or after 1 April 2021 falls outside the limitation period under section 149, notwithstanding the relaxation provisions under the 2020 Act. Where the initial notice was issued on 7 April 2021 and later treated as a section 148A(b) notice, the consequential section 148A(d) order and section 148 notice are invalid as time-barred. The Revenue's recorded concession required such notices to be dropped.

Form 26A prevents a payer from being treated as an assessee in default for interest payments where the payee filed its return, included the income and paid tax; the corresponding disallowance is unavailable for substantiated payments. Payments characterised as purchases of spare materials do not by themselves attract tax deduction at source, but require verification of their factual nature. Machine-hire disallowance requires payment-wise proof that no tax deduction liability arose or that recipients discharged tax liability. For cash credits, creditor identity, creditworthiness and transaction genuineness, supported by financial records, banking trail, repayment and confirmation, negate an unexplained-credit addition.

Section 33(5) of the Insolvency and Bankruptcy Code bars institution of suits or other legal proceedings against a corporate debtor once a liquidation order is made. Income-tax assessment proceedings and consequential additions initiated or sustained against a company undergoing liquidation are therefore legally unsustainable under that statutory bar. Assessments and additions affirmed in appeal against the corporate debtor were treated as void ab initio and quashed.

Registration under Sections 12AB and approval under Section 80G for eligible charitable institutions cannot be qualified as tentative merely because a challenge to the governing jurisdictional High Court judgment is contemplated or pending. That judgment remains binding on authorities within its jurisdiction unless stayed, modified, or reversed by a competent forum. No statutory mechanism permits registration, approval, or their consequential benefits to be made conditional on speculative future proceedings. Caveats linked to a proposed Supreme Court challenge are legally unsustainable and must be deleted, leaving the registration and approval operative without qualification.

RELIEF Sub-Committee is constituted under the Export Promotion Mission to improve fund utilisation and uptake of the Support for Indian Exporters, Resilience & Logistics Intervention for Export Facilitation. It must review implementation of RELIEF's three components, including claims processed and available balances, examine factors affecting uptake and utilisation of approved funds, and recommend improvement measures. Recommendations are placed before the EPM Steering Committee for decisions concerning review of RELIEF, while the EPM Section acts as the Sub-Committee's secretariat.

GST rate rationalisation contemplates a simplified structure centred on 5% and 18%, with exempt supplies and a 40% special rate for identified luxury, sin and demerit supplies. The framework seeks to correct inverted duty structures, reduce classification disputes, align rates on akin goods and simplify compliance. The Council also accorded in-principle approval to a simplified GST registration framework for small suppliers selling goods inter-State through electronic commerce operators, subject to safeguards and detailed Law Committee recommendations. Compensation cess restructuring, individual life and health insurance exemptions, retail sale price-based tobacco valuation and improved IGST settlement processes were also addressed.

Section 194A(3)(v) separately addresses interest paid by a co-operative bank to a member and interest paid by a co-operative society to another co-operative society. The exclusion of co-operative banks is confined to the member-payment limb; a co-operative bank remains a co-operative society for the inter-co-operative society limb. Paragraph 42.7 of Circular No. 19/2015 preserves non-deduction, including time-deposit interest, where the depositor is a co-operative society. Section 80P does not determine this withholding obligation.

Export licensing conditions for agarwood permit export of agarwood oil, agarwood chips and allied products through Lokpriya Gopinath Bordoloi International Airport, Guwahati, subject to applicable statutory and regulatory requirements. The CITES export permit requirement for CITES species continues, as do the prescribed export ports. Exporters need not furnish additional information, no-objection certificates or documents beyond the prescribed documentation.

Input tax credit under Section 16(2)(c) remains conditional on actual payment of tax to Government, but supplier non-payment or retrospective cancellation cannot by itself justify reversal. The recipient must establish eligibility through transactional evidence, while the proper officer must investigate the particular supply, disclose supplier-default and recovery material, apply the law applicable to the relevant period, and issue a reasoned, notice-bound determination. Supplier recovery status and protection against duplicate collection are material considerations.

The first proviso to section 129A(1) excludes Appellate Tribunal jurisdiction over an order under section 128A relating to goods imported or exported as baggage. The decisive issue is the order's connection with baggage, not disputes concerning confiscation, declaration, duty, personal effects, concealment, concession, or penalty. Articles carried by an international passenger in luggage or on the person may constitute baggage. Section 129DD provides revision before the Central Government, ordinarily within three months, subject to a further period on sufficient cause.

Pending statutory amendment, GST field formations must not make further arrests. Transit conveyances may be intercepted only on specific intelligence authorised in writing by an officer of at least Joint Commissioner rank. Inspection and detention generally depend on jurisdiction over the supplier or recipient; where neither falls within that jurisdiction, the conveyance must proceed and information be sent to the jurisdictional officer. Absence of both an e-way bill and origin or destination documentation permits inspection, detention or seizure irrespective of jurisdiction. Transit confiscation is prohibited, and show-cause notices cannot be issued below the aggregate threshold of Rs. 10,000.

Rule 89(4) attributes the value of zero-rated goods to the refund period in which export invoices are issued and goods are removed under bond or LUT, rather than the later period of physical export. Sections 12 and 31 support invoice-and-removal recognition of supply, while actual export remains essential to establish export status and sustain the refund. Shipping bills and export records verify the later export event and must correlate with relevant invoices. Where export is delayed or does not occur within the stipulated period, Rule 96A governs extensions, tax and interest consequences; a mismatch in invoice and physical-export dates alone does not exclude the value from zero-rated turnover.

Under the pre-amendment Section 148 framework, an Assessing Officer must provide recorded reasons on request and dispose of reopening objections through a separate, reasoned speaking order before commencing merits scrutiny. A return filed in response to Section 148 is processed as a Section 139 return, but a Section 143(2) notice starts scrutiny and cannot precede disposal of jurisdictional objections. A Section 142(1) inquiry notice is likewise a merits-stage step. Following service of an adverse objection order, no further reassessment action may be taken for four weeks, preserving judicial-review rights. Breach may invalidate premature notices and consequential reassessment action.

Section 74 requires more than wrongful availment or utilisation of input tax credit: fraud, wilful misstatement, or suppression of facts with intent to evade tax must be alleged and proved. Under the former Explanation 2, suppression covered failure to declare legally required information or failure to provide information sought in writing, but did not remove the intent requirement. Disclosures in returns, annual reconciliations and portal filings materially weaken a non-declaration allegation. Mere audit detection or non-response to audit communications does not independently establish suppression, particularly where the notice did not plead that basis. Section 74 proceedings and enhanced penalties therefore require evidence of deliberate concealment, and appellate review cannot sustain a demand on a materially new allegation beyond the show cause notice.

Penalty for concealment of income or furnishing inaccurate particulars requires actual concealment or inaccurate particulars in the return of income. Where additional income detected during a survey is fully disclosed in a revised return and the assessed income matches the returned income, the disclosure is complete for tax purposes. Detection during survey alone does not establish the statutory conditions for penalty, and no penalty is leviable in those circumstances.

Section 154 confines rectification to a mistake apparent from the record and does not permit reconsideration of an unraised, debatable and complex claim of public-company status unsupported by Registrar of Companies records. A company's subsequent business losses do not discharge income-tax arrears for earlier years. Where arrears during directors' tenure remain unpaid, and findings show refunds received and income understated, Section 179 may impose joint and several liability on those directors for the company's tax arrears. The rectification refusal and declarations of directors' liability remain effective.

Free trade agreement utilisation is proposed through identification of leading export products, mapping of preferential markets and district-level FTA help desks for MSMEs, farmers and startups. GI-tagged products are to receive traceability, packaging and branding support for global exports. Pharmaceutical development is to focus on domestic key starting materials and active pharmaceutical ingredients, innovation, biosimilars and biotechnology. Ease-of-doing-business reforms include decriminalisation of minor offences, reduced compliance burdens, simplified procedures and time-bound single-window clearances.

Strategic restructuring of IDBI Bank is governed by a flexible bidding framework in which DIPAM's internal practices operate as indicative guidelines rather than rigid legal rules. No a-priori bidding benchmark applies: bidders undertake confidential valuation, while independently appointed agencies prepare contemporaneous fair valuations as comparators for assessing bid reasonableness. Where the highest financial bid is below the reserve price, the further course is left to the Government of India and QIPs cannot subsequently challenge that decision.

Prior approval scrutiny under section 153D turned on whether the approval record demonstrated a consolidated, mechanical, or reasoned approval. The available RTI statement confirmed that approval had been issued but did not include the approval letter or its terms, preventing a finding on application of mind or assessment validity. The additional legal ground was capable of consideration, with examination of the approval record directed before the appellate authority.

Separate assessment-year-specific notice under Section 143(2) is required for a regular assessment because each assessment year is an independent unit. A consolidated notice covering multiple years, including years subject to another assessment regime, does not confer jurisdiction for the relevant year and invalidates that assessment. A notice issued within six months from the end of the relevant financial year is timely, and a subsequent revised return does not itself require a fresh Section 143(2) notice where all revised returns are considered.