Intervener standing in writ proceedings does not extend to appellate standing where the intervener was not a party to the writ petition. Participation before the Single Judge solely as an intervener confers no appellate right superior to that of parties to the writ action. The intervener may nevertheless make submissions before the appropriate court on the underlying issue.

State and Union tax authorities cannot simultaneously initiate action against the same assessee for identical tax periods. Parallel proceedings by both authorities for the relevant periods are impermissible, and only one authority may exercise jurisdiction for those periods. This prevents overlapping enforcement action concerning the same taxable person and period.

GST classification of bus body building as a composite supply depends on the principal supply identified from the facts. Tyre retreading is ordinarily a service because retreading imparts the essential character and rubber is ancillary; value is only a guiding factor. Retreaded tyres supplied where the old tyres belong to the supplier are goods. Priority Sector Lending Certificates and Renewable Energy Certificates are goods classifiable under heading 4907, while duty credit scrips receive nil GST. Electricity transmission or distribution by a utility is exempt, but specified ancillary consumer charges and government loan guarantees for consideration are taxable.

Concessional GST conditions distinguish a prohibition on taking input tax credit from a restriction on its utilisation. Credit that is not taken cannot enter the electronic credit ledger. Credit that is not utilised may be availed and retained but cannot be set off against tax on the specified service, while remaining available for other eligible taxable supplies. For specified rail services, credit on goods used in supplying the service may be used for taxable outward supplies of goods but not for tax on that service.

Rule 8 governing Punjab GST registration is amended, generally with effect from 11 September 2024, to replace the Aadhaar-authentication process for applicants other than persons notified under section 25(6D). Where common-portal data analysis and risk parameters identify an Aadhaar-authenticating applicant, completion additionally requires biometric-based Aadhaar authentication, a photograph, and verification of original uploaded documents at a facilitation centre notified for this purpose.

Input tax credit on GST charged for foreign-exchange conversion, card fees, current-account charges, and operational bank charges is treated as available where the services are legitimate business overheads. Bank-issued tax documentation, including a consolidated GST tax invoice, is suggested for reconciling GST reflected in GSTR-2B. The adequacy of transaction advice displaying GST deducted, and the implications of claiming unmatched credit where no consolidated invoice is issued, remain unresolved.

Transfer-pricing comparability under the transactional net margin method requires a separate functions, assets and risks analysis for every proposed comparable. Retaining Infosys BPO Ltd., where its suitability was not challenged, does not establish the functional comparability of other high-end ITES entities. Low-end ITES/BPO providers should not be benchmarked against Eclerx Services Ltd., whose analytics and knowledge-process outsourcing functions materially differ. ICRA Techno Analytics Ltd.'s segment, involving business analytics, operational solutions and internally developed customised software, is likewise functionally dissimilar. The appropriate comparable set therefore excludes dissimilar KPO and business-analytics entities when determining the arm's-length price.

Appeals against orders imposing penalty without a tax demand require payment of ten per cent of the penalty at the first appellate stage and a further prescribed payment for appeal to the Appellate Tribunal. A track-and-trace mechanism may be prescribed for notified goods and persons dealing in them. Covered persons may be required to affix unique identification markings, furnish information and machinery details, maintain records, and pay prescribed system-related amounts. Contravention attracts an additional penalty equal to the higher of the specified fixed amount or ten per cent of the tax payable on the goods.

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to the Revenue; Explanation 2 does not displace these twin conditions. Where scrutiny examined JDA receipts, capital-gains treatment, records and explanations, revision cannot substitute another plausible view or commence a fishing inquiry. A landowner's revenue share under a Joint Development Agreement is long-term capital gain where the land remains a capital asset and the developer alone bears construction, approvals, marketing, funding and project risks. Deferred receipt of agreed consideration does not, by itself, create an adventure in the nature of trade or business income.

Provisional attachment of a bank account under Section 83(2) ceases to operate once the statutory one-year period from the attachment order expires. Expiry of that period causes the attachment to lapse, requiring the bank account to be de-frozen. The respondents accepted that the attachment had expired under the statutory time limit and no continued restraint could be maintained.

A supplier's output tax liability cannot be reduced through a credit note where a registered recipient has not reversed attributable input tax credit, or where the tax incidence has been passed on to another person. Appeals against penalty-only orders require prescribed pre-deposits. Specified goods may be subject to a unique identification marking regime requiring affixation of markings, information reporting, record maintenance and machinery disclosures, with additional penalties for contravention.

Specified intra-State supplies of handicraft goods are exempt from tax under Punjab GST to the extent tax exceeds listed rates of 1.5%, 2.5% or 6%, subject to tariff classification and descriptions. Handicraft goods must be predominantly handmade, though tools or machinery may be used, and must have substantial ornamentation or other distinctive aesthetic, artistic, ethnic or cultural features distinguishing them from mechanically produced goods. Handmade or hand-embroidered shawls are subject to different rates based on sale value.

Registered persons must electronically furnish FORM GSTR-3B for January, February and March 2018 by the prescribed monthly due dates. Tax, interest, penalty, fees and other payable amounts must be discharged, subject to the statutory payment framework, no later than the applicable return-filing due date through debit to the electronic cash ledger or electronic credit ledger, as applicable.

Open justice and Article 19(1)(a) protect fair and accurate media reporting of proceedings conducted in open court, subject to permissible restrictions for privacy, fair-trial and other countervailing interests. Oral exchanges and tentative observations during hearings are not part of the formal judicial record or judicial determinations; blanket limits on reporting them would undermine transparency and accountability. Judicial restraint remains necessary in off-the-cuff language. Relief against coercive action arising from an FIR or complaint must be pursued through available criminal-procedure remedies, including inherent jurisdiction, rather than unrelated appellate proceedings.

Post-supply discounts may be excluded from the value of supply only where the supplier issues a credit note and the recipient reverses attributable input tax credit. Credit-note issuance extends to qualifying post-supply discounts. The refund framework includes refund of specified unutilised input tax credit, while the relevant refund-payment restriction excludes tax-refund claims for goods exported out of India with payment of tax.

Punjab SGST rate schedules are amended with deemed effect from 27 July 2018 through additions, omissions, substitutions and exclusions across the 2.5%, 6%, 9% and 14% schedules. Ethyl alcohol supplied for petrol blending is placed in the 2.5% schedule and excluded from the 9% entry. The changes revise classifications for fertilizer-grade phosphoric acid, apparel, coir products, bamboo flooring, fuel-cell vehicles, paints, domestic appliances, lithium-ion batteries, television sets and specified vehicles, while omitting several 14% entries and refining product-specific exclusions.

Customs designation is extended to Mandalgarh, Bhilwara, Rajasthan, as item (xiii) in the Rajasthan entry under serial number 10. The location may be used for unloading imported goods and loading export goods, including any class of such goods, under the statutory framework for appointing customs places within inland container depot arrangements.

Punjab GST refund provisions distinguish refunds of unutilised input tax credit on zero-rated supplies without payment of tax from refunds of integrated tax paid on exports. Input tax credit relating to specified concessional supplies and other inputs or input services used for exporting goods is covered. Refund of integrated tax paid on exports is ineligible where specified State, integrated-tax or customs benefits have been used, subject to stated EPCG capital-goods exceptions.

The India-Mauritius tax treaty Protocol replaces the treaty preamble to confirm that eliminating double taxation must not create opportunities for non-taxation or reduced taxation through tax evasion, avoidance, or treaty-shopping arrangements benefiting third-jurisdiction residents. It inserts an entitlement-to-benefits rule denying treaty relief where, considering all relevant facts and circumstances, obtaining the benefit was one of an arrangement's or transaction's principal purposes, unless granting relief accords with the relevant treaty provision's object and purpose. The Protocol entered into force on 10 August 2026 and applies from that date regardless of when tax is levied or the relevant taxable year.

Indian Computer Emergency Response Team (ICERT) will function as an Attached Office under the administrative control of MeitY with immediate effect. ICERT will also continue as the appointed agency for purposes of the Information Technology Act, 2000, as amended. The declaration formalises ICERT's administrative placement without displacing its continuing statutory agency role under that Act.