For reassessment notices served before 1 April 2019, the applicable nine-month limitation period excludes only the period during which a judicial stay actually remained in force. Limitation resumes when the stay is vacated, not when the vacation order is communicated. Where more than sixty days remain after vacation, the statutory minimum sixty-day extension does not apply. On this calculation, the limitation expired before the reassessment order was made; administrative notifications did not extend the deadline, and the order was time-barred and quashed.

For unabated assessments under sections 153A and 153C, additions for unsecured loans, share capital and share premium require corroborated incriminating material found during search. Entries already recorded in regular books and routed through banking channels, uncorroborated retracted statements, general investigation information and post-search enquiries do not establish unexplained credits. Where confirmations, bank records and financial records supporting identity, creditworthiness and genuineness remain undisproved, suspicion cannot sustain the additions. The section 68 additions were deleted, and the related interest disallowances also failed because they rested solely on the allegation that the loans were non-genuine.

Alleged bogus purchases supported by purchase bills, delivery challans, supplier confirmations, stock records, banking payments and corresponding sales cannot be treated as wholly non-genuine merely on general sales-tax information absent transaction-specific defects. Independently confirmed purchases attract no addition; remaining disputed purchases warrant only a 5% addition for embedded profit, supported by gross-profit trends. Commission expenditure is deductible as wholly and exclusively incurred for business where confirmations, payment workings, recipients' tax records, TDS details and a nexus with sales substantiate the payments, with no cogent rebuttal. Taxable income is recomputed accordingly.

The first proviso to Section 149(1) retains the pre-amendment reassessment limitation for assessment years beginning on or before 1 April 2021. The amended regime's extended ten-year period operates prospectively and cannot revive reassessment notices already barred under the former six-year period. For assessment year 2015-16, notices issued after 1 April 2021 fall outside the applicable limitation framework. Consequently, the notice issued on 4 April 2022 was time-barred, and the related reassessment proceedings could not be sustained.

Late-filing fee under section 234F was considered unjustified where a return filed in response to a section 148 reassessment notice disclosed interest income and corresponding tax deducted at source. Absence of a return under section 139(1), by itself, did not support a routine fee when no outstanding tax liability or prejudice to the Revenue was established. The fee was accordingly set aside.

Interest paid or credited by a co-operative bank to a non-member co-operative society falls within the co-operative society exemption from tax deduction at source; the recipient's income-tax deduction eligibility does not determine the payer's obligation. Interest on specified NRE fixed deposits exempt from income tax is not chargeable in India and therefore does not attract withholding on non-resident payments. The exclusion of co-operative banks from the member-interest exemption applies prospectively, so interest on a member's deposit closed before 1 June 2015 remains outside withholding. Relief from default where a resident payee has paid tax requires verification of an accountant's Form 26A certificate.

Section 48(i) permits deduction of expenditure only where credible evidence establishes that it was incurred wholly and exclusively in connection with the property transfer. A cancellation payment made after completion of the sale was not deductible where the underlying memorandum imposed no contractual obligation to pay it on rescission and no direct transfer nexus was proved. A claimed sale commission was likewise not deductible because no concrete evidence showed that services were rendered to facilitate the transfer. Unsupported or afterthought claims cannot reduce taxable capital gains.

GSTR-3B due dates for February, March and April 2020 remain unchanged, but interest and late-fee relief applies where returns and tax are furnished within prescribed timelines. Reduced or nil interest depends on the taxpayer's preceding-year aggregate turnover and timely filing; non-compliance attracts regular interest, late fee and potential penalty from the original due date. Late-fee waivers also apply to specified GSTR-1 filings. Input tax credit restriction under rule 36(4) is deferred for February through August 2020 and must be applied cumulatively in the September 2020 return. Specified returns, statements, e-way bills and statutory compliance periods receive separate extensions.

Electronic Certificates of Origin issued by New Zealand issuing bodies are valid for preferential tariff treatment when issued in the prescribed format, authenticated by the issuing body's seal and authorized signature, and uploaded on e-Sanchit. Importers or Customs Brokers must accurately declare certification particulars in the bill of entry. A proof of origin may support only one importation, and system controls will prevent reuse of the same certification number. Post-importation preferential tariff claims are available for qualifying originating goods in transit or under customs control on 20 October 2026.

DGFT advises heightened vigilance and comprehensive due diligence in commercial dealings with M/s Julfikar Fashions Limited, Bangladesh, following a Quality Control and Trade Dispute complaint. Trade stakeholders are advised to assess transaction risks before processing applications, providing financial or credit support, trade facilitation, certifications or recommendations. Adverse experiences, payment-related issues, contractual disputes and other relevant information should be promptly reported for examination and action. The precautionary measure seeks to alert trade participants to potential risks and safeguard Indian exporters.

Imported metallic waste and scrap generally requires a Pre-Shipment Inspection Certificate from the country of origin. Shredded and unshredded scrap from designated safe countries or regions may be exempt where it is accompanied by a non-radioactive and non-explosive materials certificate, enters through specified sea ports, and undergoes mandatory radiation and explosive screening. Trans-shipments do not qualify. Exempt consignments may be cleared for home consumption at an eligible port or an Inland Container Depot upon proof that entry-port conditions were met.

For income-tax purposes, Director-General of Shipping means the official appointed by the Central Government under section 7(1) of the Merchant Shipping Act, 1958. Section 235 of the Income-Tax Act, 2025 and section 115V of the Income-Tax Act, 1961 use substantively corresponding definitions, with their application respectively limited to the relevant Part and Chapter.

GST on superior kerosene oil supplied to Linear Alkyl Benzene manufacturers is payable only on the net quantity retained for extracting normal paraffin used in manufacture. Where the remaining kerosene is returned to the refinery and consideration is paid only for the retained quantity, the returned quantity is excluded from the taxable supply. GST applies if the refinery subsequently supplies the returned kerosene to another person.

Section 52(4) requires operators collecting the specified amount to electronically furnish monthly statements of outward supplies and amounts collected. Technical portal issues prevented certain operators from obtaining registration and filing statements for October, November and December 2018. An Explanation declares 31 January 2019 as the due date for filing those statements, with effect deemed from 31 December 2018.

Recipients of deemed export supplies may avail input tax credit and claim refund, subject to debiting an equivalent amount from the electronic credit ledger and furnishing required declarations; a supplier claim requires the recipient's non-claim and non-availment undertaking. Registered persons who reported eligible zero-rated supplies in Table 3.1(a) rather than 3.1(b) may file refund applications for tax periods from 1 July 2017 to 31 March 2021, within the aggregate tax or cess reported in Tables 3.1(a), 3.1(b), and 3.1(c). For unutilised ITC refunds, adjusted total turnover uses the capped zero-rated goods value.

Unutilised tariff-rate quota (TRQ) allocations for raw sugar imports may be surrendered by holders until 15 November 2026. Surrender requires payment equal to 0.5% of the CIF value of the quantity returned under existing modalities. All other terms and conditions governing the raw-sugar TRQ remain unchanged, and the alteration is confined to the surrender timeline.

Article 227 supervisory jurisdiction is exceptional, confined to keeping subordinate courts within jurisdictional limits, and cannot ordinarily bypass the CPC's specific mechanism for rejection of a plaint. Where title, fraud, or document genuineness is disputed, those matters require determination through ordinary civil procedure, including a properly made plaint-rejection application. Order VI Rule 16 permits only the striking out or amendment of objectionable pleading matter, such as scandalous, frivolous, vexatious, prejudicial, or abusive material. It does not permit removal of an entire plaint, for which the CPC provides a separate rejection procedure.

Raw sugar imports classified under Exim Code 170114 remain free within the applicable Tariff Rate Quota of 10 lakh MT for duty-free import, subject to prescribed conditions. The deadline for duty-free import under the quota is extended from 31 October 2026 to 31 December 2026, while all other applicable import conditions remain unchanged.

Annual-return compliance under the Jharkhand GST regime is extended for registered persons covered by the annual-return requirement. For the period from 1 July 2017 to 31 March 2018, the time limit in the Explanation to section 44 is changed from 31 March 2019 to 30 June 2019, addressing delayed operationalisation of the electronic filing system. The extension is deemed effective from 31 December 2018.

GST dues for the pre-CIRP period are operational debt, recoverable through claims before the National Company Law Tribunal rather than coercive action against the corporate debtor. Existing registration is not to be cancelled solely due to CIRP, while the IRP/RP need not file pre-CIRP returns. During CIRP, new registration, post-commencement returns, tax payment, and other GST compliance are required. Transitional input tax credit is available for specified invoices bearing the erstwhile GSTIN, and eligible cash-ledger deposits may be refunded despite non-filing of corresponding returns.