Omission of Rule 96(10) without a saving or sunset clause prevented its continued application to pending export refund proceedings. Proceedings initiated under an omitted rule can continue only where an express saving provision or statutory legal fiction preserves them. Applying this principle, the High Court treated the Supreme Court precedent as applicable and quashed the adjudication notices and orders founded on Rule 96(10), allowing the writ petitions.

Intermediary-service classification turns on whether a supplier arranges or facilitates an identifiable main supply between other parties; a subcontractor supplying contracted services on its own account is excluded. Marketing, promotion, business-support and IT-enabled services provided independently on a principal-to-principal basis, without authority to bind the foreign principal or participate in third-party arrangements, qualify as export of services rather than intermediary services, supporting refund of unutilised input tax credit. Section 107(11) bars the first appellate authority from effectively remanding a refund matter after annulling the original order, while preserving the Tribunal's separate remand power.

Departmental appeals disputing only a penalty are governed by the disputed penalty for monetary-limit purposes. Where the amount is below the prescribed limit, the Revenue must specifically identify and establish a recognised exception. Reliance on a residual exception requires material that the Commissioner considered the particular matter and recorded the requisite opinion; bare approval or authorisation to appeal is insufficient. Maintainability must be determined before merits, resulting in threshold dismissal where policy compliance is not shown.

Departmental GST appeals involving disputed tax below the prescribed monetary limit require the Revenue to specifically plead and establish a recognised exception to the litigation-control policy. The threshold is calculated on aggregate disputed tax, excluding interest and penalty. Mere Commissioner authorisation does not establish the residual exception; the record must show a case-specific exercise of that power and its supporting basis. Where no applicable exception is proved, the appeal is not maintainable, may be dismissed at the threshold, and the underlying tax merits remain unexamined.

Road restoration charges paid by a business entity for PWD-authorised road cutting and request-driven restoration constitute consideration for a taxable service because payment is directly linked to identified work and bilateral reciprocity. Such work is not a non-supply or exempt public-function service merely because routine road maintenance is governmental; it is performed for the entity's commercial activity. Government services supplied to registered business entities attract reverse charge where forward-charge payment is unproven, so refund of GST paid under reverse charge is unavailable. Electronic GST proceedings authenticated through the portal remain valid without a physical DIN where notice particulars enable a meaningful response and no prejudice arises.

Road restoration charges paid for request-driven repair after excavation for commercial pipeline laying constitute consideration for a taxable service rather than compensatory damages. Routine public-road maintenance differs from targeted restoration supplied to a business entity; consequently, non-supply treatment and the governmental-services exemption do not apply, and tax under reverse charge remains payable. Prior refund sanctions in other jurisdictions and unsubstantiated double-taxation claims do not displace that mechanism. Electronic GST proceedings remain valid where portal records authenticate the application, notice, replies and orders, and the notice gave adequate factual and legal particulars without prejudice despite no physical DIN. The refund rejection and reverse-charge payment were sustained.

Road restoration charges paid for restoring public roads excavated for a commercial gas pipeline constitute consideration for a taxable service because the payment directly corresponds to requested restoration work. Targeted, fee-based restoration for a business entity differs from routine public road maintenance and does not qualify as non-supply or for public-function exemption treatment. GST is payable by the recipient under reverse charge, resulting in rejection of the refund claim. Electronically issued GST notices and orders authenticated through the official portal remain valid without a physical DIN where they clearly state the factual and legal basis and cause no prejudice.

Road restoration charges paid to the PWD for restoring public roads cut for a business pipeline project constitute consideration for a taxable service, rather than compensatory payment or liquidated damages, because they arise from a requested and reciprocal restoration arrangement. Targeted restoration for a business entity is not treated as a general governmental or public-utility function eligible for non-supply treatment or exemption; the recipient remains liable under the reverse-charge mechanism and cannot obtain a related refund. Electronic GST proceedings remain valid without a physical Document Identification Number where portal authentication establishes the notice's source and integrity and the recipient suffers no prejudice. The refund claim was rejected.

Section 260A(7) imports CPC appellate procedure into High Court income-tax appeals to the extent compatible with Section 260A. Because such appeals resemble second appeals and Order XLII applies Order XLI to them, Order XLI Rule 22 can permit cross-objections despite no express provision in Section 260A. A cross-objection remains limited to the adverse part of the Tribunal's order and must raise a substantial question of law. It cannot expand jurisdiction to factual issues or matters outside that order. Maintainability therefore depends on satisfying the statutory substantial-question-of-law requirement.

Section 132B provides statutory simple interest on cash requisitioned under section 132A from the day after expiry of 120 days following requisition until completion of assessment. Where no tax liability is determined, the requisitioned cash must be released, with interest at one-half per cent for every month or part thereof during that pre-assessment period. Following assessment and discharge of any liability, seized cash must be released forthwith. Continued retention contrary to that requirement warrants restitutionary compensation for loss of use of money, irrespective of whether the tax department earned interest on the retained cash. Interest at six per cent per annum applies until actual release.

Section 275(1)(a) requires penalty proceedings to remain in abeyance while an appeal against the relevant assessment order is pending before the Appellate Tribunal. A penalty order for under-reporting of income passed during that pendency is contrary to the statutory bar, regardless of whether the Assessing Officer had been informed of the appeal. The penalty order was quashed, with liberty to recommence penalty proceedings if the assessment appeal is decided against the assessee and the law permits.

Incomplete inventory and stock records, coupled with absent individual ledgers and trial balance, justify rejection of accounts where they cannot disclose true profits. Following valid rejection, net-profit estimation must rest on relevant material rather than ad hoc rates; net-profit rates declared or earned in the five immediately preceding years and special-audit results guide recomputation, with interest excluded from turnover or gross receipts and no further expense deduction. Interest on bank or financial-institution deposits and delayed customer instalments is taxable as Income from Other Sources where the taxpayer does not conduct money-lending, financing, banking, or similar activities, irrespective of the funds' source.

Vehicle expenses and depreciation for cars registered in a director's name were restricted by 25% because no logbook or equivalent evidence excluded personal use and the company funded loan margin money; prior-year non-disallowance did not create res judicata in income-tax proceedings. Interest disallowance on borrowings was deleted because the interest-free advance's source and the loans' use, repayment and purpose had been explained, while the assessment lacked reasoned consideration. Rent paid for the director's residence remained deductible, with the accommodation taxable as a perquisite in the director's assessment. Penal interest for delayed loan instalments remained deductible as compensatory contractual expenditure, not an offence-related or legally prohibited payment.

TDS credit on compulsory-acquisition compensation is tied to the assessment year in which the deduction is reflected in Form 26AS. Tax deducted during FY 2022-23 and reflected for AY 2023-24 cannot be claimed for AY 2024-25. The procedure under section 155(20), Rule 134 and Form 71 does not alter that factual alignment; any entitlement for AY 2023-24 remains subject to independent adjudication.

Section 151 sanction for reassessment requires meaningful, independent application of mind; a bare endorsement that notice is fit to issue on the Assessing Officer's recorded reasons is mechanical and invalid. This statutory safeguard applies even if sanction is administrative, because reasons must demonstrate the approving authority's consideration. Conflicting non-jurisdictional High Court views remain independently persuasive where related special leave petitions were summarily dismissed, since neither merger nor binding law under Article 141 follows. The assessee-favourable construction was applied, invalidating the sanction and quashing the reassessment while other grounds remained open.

Functional comparability for captive cost-plus ITeS providers requires alignment of scale, brand, intangibles, technology and service profile; materially dissimilar outsourcing, accounting or publishing businesses are excluded, while functionally similar ITeS providers may remain comparable. Companies outside the TPO search matrix cannot be rejected solely on that basis if they satisfy applicable filters, subject to functional, asset and risk analysis and annual-report verification. Delayed associated-enterprise receivables are international transactions requiring separate benchmarking after the comparable credit period, using LIBOR plus an appropriate spread. Foreign-exchange gains on reinstated trade payables and receivables lack the direct and proximate export nexus required for a section 10AA deduction.

Capital-gains holding period for a residential flat acquired under a builder's allotment letter runs from allotment rather than later registration, because the statutory test is whether the asset was held. A flat held beyond the applicable long-term period consequently qualifies for long-term capital-gains treatment, with indexation and section 54 relief available in accordance with law. For section 56(2)(vii)(b), an allotment letter containing the essential acquisition terms may constitute the relevant agreement. Where part consideration was paid through banking channels before allotment, stamp-duty value must be determined as on the agreement date, requiring valuation and recomputation on that basis.

Profit on payments for subcontracted civil work cannot be separately estimated where the underlying contract receipts and profit have already been recorded, as this would duplicate disclosed profit; the related addition was deleted. A donation deduction remains disallowable where banking entries are unsupported by receipts. For delayed provident fund remittances, compensatory interest is deductible, whereas statutory damages for breach of payment obligations are penal and disallowable. The payment requires bifurcation between interest and damages, with the allowable interest component to be verified and permitted.

Extended reassessment beyond six years from a search requires material showing that escaped income is represented in the form of an asset. Additions for unexplained money and unexplained expenditure cannot support the extended period where they are not founded on an asset discovered during the search; a statement recorded during search does not, by itself, satisfy that statutory condition. On that basis, the reopening was invalid, the additions remained deleted, and the Revenue's appeal was dismissed. The assessee's cross-objection was infructuous.

Enhanced 10% tolerance band under section 43CA is treated as a curative measure against hardship from deemed sale consideration and applies retrospectively; additions for two flat transfers whose valuation differences fell within that band were deleted. Where stamp-duty valuation is disputed for a transfer under section 43CA, the agreement-date value may apply if the earlier-agreement and banking-channel receipt conditions are met, and the section 50C valuation procedure must be considered. The remaining flat's proposed addition requires verification of the allotment material and statutory conditions, with a Valuation Officer reference where warranted, before redetermination.