Net input tax credit verification must consider reversals reported in GSTR-3B; gross differences between GSTR-3B and GSTR-2A alone do not establish excess credit. Output-tax variances between GSTR-9 and GSTR-9C require examination of the reconciliation statement, sales ledgers, invoices and financial records, rather than a portal-field comparison. For Rules 42 and 43, proportional reversal relating to exempt supplies requires segregation of actual common credit from specific credit and application of the exempt-to-taxable turnover ratio only to that common-credit pool. The demands were set aside and remanded for fresh verification and de novo adjudication.

Post-supply discounts under section 15(3) regulate exclusion from the supplier's taxable value; they do not automatically permit a recipient to reduce its own outward taxable turnover or output tax liability. Their treatment requires examination of credit notes, invoice linkage, prior agreement, the supplier's return treatment, and the recipient's input tax credit position. Mere disclosure in GSTR-9C cannot alone support an output-tax demand without proof of an actual reduction in outward turnover or tax liability. Appellate and adjudication orders were set aside for fresh inquiry, confined to allegations in the existing show cause notice; a new claim that incentives were consideration for promotional services could not be introduced at the appellate stage.

Unchallenged advance rulings bind the applicant and jurisdictional officer unless appealed, rectified, or declared void; a belated jurisdictional objection cannot be used in appellate proceedings to examine the ruling where statutory challenge mechanisms were not invoked. A departmental circular cannot impose GST or fix an 18% rate contrary to the applicable rate notification, nor retrospectively displace a subsisting ruling. Recovery of refunds as erroneous solely on that circular was unsustainable. Refund demands also cannot rest on grounds outside the show cause notice; where the recipient bore the tax incidence, submitted the prescribed certificate, and reversed input tax credit, objections based on supplier-only entitlement and unjust enrichment failed. Recovery, interest, and penalty were set aside.

AAAR appellate jurisdiction over a GST advance ruling is confined to the ruling challenged and the factual matrix examined by the original advance-ruling authority. A subsequently presented soap product, revised packaging and a fresh test report could not support appellate determination where they lacked a documented link to the original product and materially differed in appearance, description and packaging. Classification of the later product would require an original examination of its composition, specifications, labelling, intended use and commercial identity. The appeal was rejected without deciding the merits of the original classification ruling, leaving the later product's classification and tax treatment to available legal remedies.

Section 127 transfer of assessment following a search centralises proceedings involving entities connected with the investigation; it does not finally determine tax liability. Where an assessee's name emerges in search material, coordinated investigation and centralised assessment may justify transfer to a Central Circle. The assessee remains entitled to receive relevant material during assessment and to contest the matter on merits. Transfer is not arbitrary or prejudicial merely because assessment is moved where centralisation is required for coordinated investigation.

Reassessment initiation requires a show-cause notice issued within the applicable limitation period and accompanied by transaction-specific information suggesting income escapement. The information must identify the transaction, the basis of proposed escapement and sufficient particulars to enable an effective response; merely stating an alleged escaped amount is insufficient. Later disclosure cannot cure an initiation lacking those foundational particulars within time. For proportionate rights-share allotments, fresh shares are distinct from pre-existing shares transferred by another person. Where an existing shareholder's percentage holding remains unchanged and no disproportionate benefit arises, the difference between subscription price and fair market value alone does not establish receipt of property for inadequate consideration under Section 56(2)(x).

Reassessment based solely on transfer-pricing material already examined in scrutiny proceedings is impermissible where the earlier assessment lapsed because no final order followed the draft assessment order within the prescribed period. Without fresh material, reopening would circumvent the statutory time limit for completing assessment and allow the Revenue to benefit from its own omission. The reassessment notices and the order under section 148A(3) were quashed, and the writ petition was allowed.

Common appellate remand orders must address year-specific findings where the record contains a reasoned appellate decision on the same issues. Restoring Assessment Years 2012-13 and 2013-14 solely by applying the finding for the earlier year, without examining the detailed reasoning for 2013-14, amounted to non-application of mind. Because the material, appeal grounds and cross-objections were before the Tribunal, merits required adjudication rather than a mechanical remand. The common remand order was quashed, and both appeals were returned for fresh determination on merits after hearing the parties.

Inadequate supporting evidence for a house property loss and deductions under sections 80C and 80D led to scrutiny of their substantiation. Where the documents were partly self-serving and unreliable, the aggregate disallowance was replaced with an ad hoc addition equal to 10% of the disputed claims. The addition was taxable at normal rates rather than under section 115BBE. The appeal was partly allowed by limiting the addition to that estimated amount.

Unsigned third-party excel sheets and ledger material, lacking purchaser or seller signatures and independent corroboration, cannot by themselves establish an alleged on-money payment for a commercial unit. Reliance on such material without allowing cross-examination of the third party breaches principles of natural justice. No change in facts or law, and no contrary material from Revenue, warranted departure from the coordinate decision; the addition for alleged on-money payment was deleted and the appeal allowed.

Penalty notice expressly stating that underreporting resulted from misreporting discloses the Assessing Officer's satisfaction and is not vague. Income omitted from the return despite being admitted during a survey may constitute underreported income when assessed income exceeds income processed under section 143(1). Enhanced penalty for misreporting requires proof that the conduct falls within a specified instance of misreporting under section 270A(9); merely applying the enhanced rate is insufficient. The penalty was therefore confined to 50% of tax on underreported income.

Limitation for filing an appeal may be relaxed only upon a bona fide and reasonable explanation establishing sufficient cause. After allowing the COVID-19 extension of limitation, expectations of a favourable consequential assessment, later professional advice, and family circumstances did not explain the remaining delay. Continued representation through qualified professionals and participation in consequential proceedings indicated a later change of position following an adverse consequential assessment. The delay was therefore not condoned.

Gross principal cash movements routed through an Angadia network were not taxable as the assessee's unexplained money where the accepted business model showed only a facilitation role and no material established ownership of the funds or corresponding asset accretion. Applying the real-income principle, taxability was confined to embedded commission income, resulting in rejection of the Revenue's challenge to deletion of principal additions. Commission on unaccounted turnover was estimated at 0.30%, rather than 2%, after credit for commission already assessed, because of the business's low-margin nature. The commission income was taxable at normal rates rather than under section 115BBE.

Carried-forward loss from scientific research expenditure remains examinable in the year in which set-off is claimed, and its earlier computation does not conclusively determine its character or eligibility. Where concessional corporate taxation is elected and the additional weighted deduction is forgone, the underlying actual scientific research expenditure may still be considered under otherwise applicable provisions. Restrictions on specified incentives and exemptions do not, without an express prohibition, deny actual expenditure independently allowable under law. Allowance of the corresponding carried-forward loss requires verification of the underlying expenditure and consequential recomputation, without granting the additional weighted deduction.

Eligibility for India-Mauritius DTAA capital-gains benefit on redemption of equity-oriented mutual fund units requires factual verification of commercial substance and surrounding circumstances; documents need not be accepted at face value where their apparent position may not reflect reality. Information relating to a management shareholder's licence and regulatory action involving a sister concern requires fresh examination after an effective and adequate opportunity to explain. Taxability of the gains was restored for fresh determination of treaty-benefit eligibility, without a merits determination.

Foreign tax credit under section 90 for United States tax paid on salary and interest income requires timely filing of the income-tax return and Form 67, supported by proof of foreign tax payment. Compliance with these prescribed formalities supports entitlement to treaty-based credit and grant of the claim where the required conditions are met.

Related-party transaction filtering for Ideavate Solutions excludes key managerial personnel remuneration; it therefore qualifies for inclusion among software development comparables. Toxsl Technologies is functionally comparable on annual-report analysis and is included. The functional comparability of Great Software Laboratory, Consilient Technologies, Systango Technologies and Ksolves India requires reassessment against prior Tribunal decisions, with exclusion where the taxpayer's claim is substantiated. Working-capital-adjusted margins require verification, and appropriate transfer-pricing relief may follow where warranted.

Rupee-denominated non-convertible debentures are treated as debt instruments for the concessional interest-tax treatment contemplated by section 194LD, because statutory definitions encompass interest on money borrowed, debt incurred, debentures and other securities. The bond-debenture distinction does not affect eligibility where the instruments are rupee denominated and the investor satisfies the prescribed foreign portfolio investor and other conditions. A separate claim under section 194LC requires express consideration: where an objection is left unaddressed in the final assessment, a denial attributable to that claim cannot be sustained.

Written acceptance of reassessed customs value does not waive an importer's statutory right to challenge the valuation opinion or reassessment; it only removes the proper officer's obligation to issue a speaking order. Declared transaction value may be rejected only after reasonable doubt is formed and the grounds are communicated in writing under Rule 12(2). Undisclosed contemporaneous-import particulars and NIDB data, without independent cogent material, cannot sustain value enhancement. The enhanced valuation and the order affirming it were set aside, with consequential relief in accordance with law.

Boiler-specific fabricated support steel structures imported in CKD condition are classified as other boiler parts under CTI 84029090 where their design, drilling, tagging and configured placement objectively establish sole or principal use with a particular boiler. Their load-bearing role and boiler-specific access, inspection and maintenance arrangements support application of Section XVI Note 2(b), while identifiable machinery parts are excluded from Heading 7308. CKD importation does not change the goods' identity. Heading 9406 does not apply because structures supporting and suspending boiler equipment, with operational access, neither constitute nor have the essential character of prefabricated buildings.