Section 250(6) requires an appellate authority to identify the points for determination and give a reasoned decision on each ground. An ex parte order that merely confirms a reassessment because the assessee did not respond to notices, without deciding the grounds on merits or recording reasons, does not meet that requirement and is invalid. The appellate authority's powers are co-terminous with those of the Assessing Officer and permit further enquiry where necessary. Fresh adjudication after giving both sides an opportunity is required.

Pre-scheme self-assessment tax paid for the relevant assessment year must be credited against tax, surcharge and penalty under the Income Disclosure Scheme where it is demonstrably linked to the disclosed income, remains unadjusted against another liability, and is consistently reported in prescribed declaration and proof-of-payment forms. The Scheme contains no express bar on credit for such prepaid tax. Its recognition of credit for tax deducted at source supports comparable adjustment of directly relatable pre-scheme payments. Such payment is treated as Scheme payment, completing the required liability and entitling declarants to Form No. 4.

Income-tax notices under Section 143(2) may be issued by either the Assessing Officer or a duly prescribed income-tax authority. Centralisation of a case with a designated Assessing Officer does not, by itself, remove the prescribed authority's competence to issue such a notice. Notices under Section 142(1) are information-gathering measures that do not finally determine liability or prejudice rights. Jurisdictional and factual objections may be raised during assessment and through statutory appeals; writ jurisdiction generally does not intervene at this preliminary show-cause stage while effective remedies remain available.

Provisional attachment and lien over fixed-deposit receipts are to be lifted once security equal to 25% of the aggregate outstanding and anticipated tax demand is furnished through a post-dated cheque. This level of security exceeds the CBDT benchmark of 20% payment for stay of demand and adequately protects Revenue interests. Release remains conditional on an undertaking not to transfer the assets or create third-party rights in them.

Reassessment beyond three years requires books of account, documents or evidence showing income escapement; an audit objection alone, particularly one reappraising material examined in scrutiny, cannot satisfy this condition or permit review through a change of opinion. Writ jurisdiction remains available for a jurisdictional challenge to a reassessment notice despite an alternative appellate remedy or consequential assessment order. Excise-duty refunds received under an industrial incentive scheme for establishing an undertaking are capital receipts rather than taxable revenue income. Goodwill arising on amalgamation qualifies as a depreciable intangible asset, and an audit-based contrary view without new material cannot support reopening of an earlier allowance.

Section 311 of the Code of Criminal Procedure permits summoning, examining, recalling or re-examining witnesses at any stage and requires its use where evidence is essential to a just decision. Where additional documents are necessary to resolve facts in issue, their admission may require witness examination to prove them. The power serves truth and justice without favouring either side. When an application is allowed because the proposed evidence is necessary to decide those facts, costs should not be imposed merely for permitting the documents' production and proof.

Section 197 nil-withholding certificate proceedings concerned cost cross-charges claimed to be cost-to-cost reimbursements not chargeable to tax. The Assessing Officer treated the services supplied to the associated enterprise as technical services and the related payments as taxable fees for technical services. The Supreme Court dismissed the challenge to the High Court order while clarifying that the Revenue may examine the receipts' taxability in the regular assessment process.

Post-amalgamation loss set-off under the Kerala Agricultural Income Tax Act, 1991 concerns whether an amalgamated company may carry forward and set off the amalgamating company's losses against its own income. The relevant issues include succession to the business and the statutory eight-year limitation on carrying forward losses. The subject matter also includes review proceedings concerning the claimed entitlement to such loss set-off.

Request-specific road restoration performed by a public works department for a business pipeline network constitutes a taxable supply where charges reflect reciprocal restoration work, rather than compensation for breach or damage. Routine road maintenance as a public function does not extend non-supply or exemption treatment to customised services supplied to a business entity. Under reverse charge, the recipient bears GST liability for taxable government services; an unsubstantiated double-taxation plea or refund sanction granted to other State registrations does not establish refund entitlement. Electronically authenticated GST proceedings remain valid where the notice states the factual and legal basis, the recipient responds substantively, and no prejudice arises from absence of a physical DIN.

Request-driven road-restoration services supplied by a government authority to facilitate a business entity's commercial pipeline activity constitute consideration for a taxable supply. Charges linked to permission for road cutting and targeted physical restoration are distinguished from compensation, liquidated damages, and routine public-road maintenance. Governmental-function exclusions and exemptions do not extend to business-specific services, and the recipient business entity is liable for GST under reverse charge where no tax payment under forward charge is established. A notice that adequately discloses the factual and legal basis and is authenticated through the GST portal is not invalid merely because no physical Document Identification Number is present, absent prejudice.

Commercial, request-driven restoration of road damage caused by business pipeline cutting constitutes a taxable supply when a government authority performs it for calculated charges. It is distinguishable from routine public-road maintenance and does not qualify as a sovereign non-supply function or an exemption relating to local-government functions; GST paid under reverse charge is therefore not refundable. Refund orders issued in other jurisdictions neither bind an independent determination nor override statutory conditions. An unsubstantiated allegation of prior forward-charge payment does not displace reverse-charge liability. Refund proceedings remain valid where the notice adequately states the basis for denial and electronic portal authentication establishes the notice and order's identity and integrity despite no physical document identification number.

Road-restoration charges paid by a business entity to a public authority for work requested to facilitate a commercial pipeline project constitute consideration for a taxable supply. The reciprocal arrangement-permission to cut roads in exchange for specified restoration work-supports reverse-charge liability rather than treatment as compensation or damages. Targeted restoration for an identified business project is not a non-supply governmental function or an exempt public-road-maintenance service; exemption provisions require strict construction. Electronically authenticated GST portal proceedings remain valid where the notice discloses the basis of the claim and permits an effective response, despite the absence of a physical Document Identification Number. Consequently, reverse-charge tax on the service is payable and no refund basis arises.

Refund of accumulated Compensation Cess input tax credit on coal used for domestic outward supplies requires independent satisfaction of the inverted tax structure conditions under Section 54(3) of the CGST Act. Availability of Compensation Cess credit and absence of blocked-credit restrictions do not themselves create a cash-refund entitlement. Compensation Cess credit remains restricted to payment of Compensation Cess, but non-utilisability against other liabilities is not an independent refund ground. Rule 89(5) applies only after substantive refund eligibility is established. Circulars concerning zero-rated supplies do not support refund claims for domestic supplies merely because the output is not subject to Compensation Cess; the claims were therefore not admissible.

Section 129(4) requires an effective hearing and a reasoned penalty determination addressing the taxpayer's explanation and supporting material. For specified beverages moving between districts in Chhattisgarh, Rule 138(14)(d), read with the relevant notification, retains e-way bill requirements above the prescribed threshold. Payment through DRC-03 to secure release does not waive a statutory challenge or cure defective adjudication. Section 113(1) permits fresh adjudication by the original authority, confined to the existing notice and requiring factual consideration of the explanation for non-generation of the e-way bill.

Penalty under Section 129(1)(a) arises from transportation of goods in contravention of GST requirements and does not require proof of tax-evasion intent, because it addresses breach of a civil obligation. E-way bills expired for several days, without a timely extension or cogent evidence substantiating vehicle breakdown, establish such contravention. Stock-transfer documentation, invoices and e-invoices do not replace the requirement for a valid e-way bill. The Circular exception applies only where goods are accompanied by a valid e-way bill. Expired e-way bills without substantiated justification therefore attract detention and penalty consequences.

Section 129(1) applies to goods transported or stored in contravention of GST requirements without requiring independent proof of intention to evade tax, although explanations for discrepancies remain relevant. An onward supply during transit is permissible under the IGST place-of-supply rule, but does not remove the obligation to maintain e-way bills and other movement records accurately reflecting the physical journey. A live e-way bill for the original destination does not cover a diverted route, while an expired e-way bill showing a dispatch point never reached is materially inaccurate. Combined origin, destination and validity defects constitute substantive contraventions. Payment through DRC-03 for release does not bar appeal, but may be appropriated against the applicable penalty.

Inter-State transit claims concerning undeclared goods require reliable contemporaneous proof that invoices and transport documents cover the consignment, identify genuine transacting parties, and establish the stated out-of-State destination. Invoices and bilties produced after physical verification, without corroboration and containing discrepancies, do not establish genuine transport. A transit-state precedent is inapplicable where its essential facts-documented transactions, identifiable registered parties, acknowledged dealings, and a proven external destination-are absent. Failure to substantiate those matters supports penalty action for undeclared goods.

Detention penalties require an established transport contravention and reasoned consideration of the taxpayer's explanation. Service of FORM GST MOV-07 may be sustained where contemporaneous records and the recipient's response show that the notice was acted upon; however, unresolved notice records, inadequate hearing, or unreasoned findings prevent affirmation of liability. A confined fresh adjudication by the original authority may be necessary where primary evidence concerning vehicle movement and e-way bill compliance remains unresolved. Independent intent to evade need not be proved, but penalty is not automatic. Payment for release does not waive the statutory challenge and must be adjusted or refunded following fresh determination.

Refund of accumulated Compensation Cess input tax credit under the inverted duty structure requires satisfaction of the substantive conditions in section 54(3) of the CGST Act: accumulation must result from a higher tax rate on inputs than on output supplies, subject to exclusions for nil-rated or fully exempt supplies. Compensation Cess paid on coal, coupled with no cess on domestic leather-product supplies, does not independently satisfy that test. Input tax credit availability, restricted utilisation under the Compensation Cess Act, and refund entitlement are distinct. Rule 89(5) applies only after statutory eligibility is established; circulars on zero-rated supplies do not support refunds for these domestic supplies.

Section 129(1) of the CGST Act imposes detention and penalty consequences for transporting goods in contravention of the Act or Rules; proof of intent to evade tax is not required because the provision creates a civil penalty based on contravention. E-way bill validity may be extended only within the prescribed eight-hour period after expiry. Transport under e-way bills that expired six days earlier, without a timely extension or credible evidence substantiating vehicle breakdown, constitutes non-compliance. Interstate stock transfers remain subject to e-way bill requirements, and procedural objections do not assist where no prejudice results and evidence can be presented before the final fact-finding authority.