Duplicate disallowance under section 143(1) may arise where expenditure for non-deduction of tax at source has already been voluntarily disallowed under section 40(a)(ia). Deduction under section 10AA is based on eligible SEZ-unit profits for tax purposes. Notional Ind-AS finance expenses recorded in the accounts but added back while computing taxable income do not reduce the deduction where eligible business profits are undisputed. These principles support computation without double disallowance and with deduction on full eligible SEZ profits.

Revision under section 263 cannot rest on an alleged failure to examine section 14A where the assessment record shows detailed enquiries into investments, interest expenditure, exempt income and Rule 8D. An assessment order need not expressly discuss every examined issue. For periods before 1 April 2022, section 14A read with Rule 8D did not support a disallowance where no exempt income arose, and a departmental circular could not override the statute. On those facts, the assessment was neither erroneous nor prejudicial to Revenue interests.

Stamp duty and registration charges paid for a property purchase cannot be treated as unexplained investment where documentary evidence establishes their source. Treasury receipts showed that the purchaser's spouse paid the charges and had arranged the purchase consideration. Because the source of the expenditure was substantiated during assessment, adding one-half of those charges to the purchaser's income as unexplained investment was unsustainable and was deleted.

Assessment proceedings against a company struck off from the register after it has ceased to exist lack jurisdictional validity. Where revenue authorities were aware of the strike-off but completed a best-judgment assessment without pursuing revival, the assessment is void. CBDT instructions contemplate seeking revival before completing assessment in such circumstances. The resulting appellate order and consequential additions were also treated as void and deleted.

Penalty notices under Section 271(1)(c) are invalid where they retain both concealment of income and furnishing inaccurate particulars limbs without identifying the applicable charge. The resulting vagueness denies the taxpayer a clear opportunity to respond, demonstrates non-application of mind, and requires deletion of consequential penalties under the applicable jurisdictional precedent. Dismissal of a special leave petition in a factually distinguishable matter neither results in merger nor constitutes a declaration of law under Article 141, particularly where both penalty limbs applied and the objection was not raised earlier.

Penalty notices initiating proceedings for concealment of income or furnishing inaccurate particulars must clearly identify the specific statutory charge. Retaining both limbs without striking out the inapplicable charge leaves the taxpayer without precise notice of the allegation, demonstrates non-application of mind, and vitiates the resulting penalty proceedings. Dismissal of a special leave petition does not cause merger with the Supreme Court order or create a binding declaration of law. It therefore does not displace an applicable jurisdictional rule on defective penalty notices, particularly where the relied-on decision is factually distinguishable.

For searches initiated between 1 April 2021 and 1 September 2024, Explanation 2 to section 148 deems search material to be information suggesting income escaping assessment, placing search-related assessments under sections 147 and 148. The inapplicability of section 148A in an assessee's own search case does not remove the mandatory section 148 notice. Regular scrutiny under section 143(2) cannot replace that reassessment procedure for additions arising from search material; an assessment made solely under section 143(3) is invalid.

Deletion of a disallowance for failure to withhold tax on payment was sustained because prior determinations on the same issue in the taxpayer's earlier assessment years remained unchallenged and undisturbed. Separate re-examination of the payment's nature and its taxability in India was therefore not required. The issue was resolved in favour of the taxpayer.

Non-submission of a self-certified copy of the impugned order constitutes a curable procedural defect in an appeal. The appellate process must afford the appellant an opportunity to rectify the deficiency before the appeal is rejected without consideration on merits. Dismissal solely for failure to file the self-certified copy, without allowing cure, is impermissible. Where the required copy is filed within the stipulated period, the appeal must be restored and determined on merits.

Bail pending trial for alleged fraudulent input tax credit offences may be warranted where Magistrate-triable charges carry a maximum five-year sentence, custody is prolonged, and proceedings show little progress. Article 21 protects personal liberty against extended incarceration without an expeditious trial, while requiring a balance with societal interests. Continuing investigation, delayed witness examination, and the non-arrest or non-examination of principal-firm proprietors are material considerations. Bail was granted without addressing the prosecution allegations on their merits.

Non-furnishing of a self-certified copy of the challenged order constitutes a rectifiable procedural defect rather than an independent basis to terminate appellate proceedings. Dismissal solely for that omission, without an opportunity to cure it, is unsustainable. Where the required copy is filed within the stipulated period, the appeal should be restored and considered on merits.

Section 151A confines the statutory jurisdiction for issuing the relevant notice. Issuance of a show-cause notice by the jurisdictional assessing officer fell outside that framework and was invalid. The notice and all consequential proceedings were therefore quashed, applying reasoning already adopted on identical grounds in connected matters.

Anti-dumping duty applies to Titanium Dioxide imported into India when originating in or exported from China PR, with producer-specific rates and an all-other-producers rate. The duty covers goods under specified tariff items, although product description governs classification, and excludes defined food, pharmaceutical, skin-care, textile and fibre applications, and nano or ultrafine material below the prescribed particle size. Individual producer rates require a valid commercial invoice containing the prescribed manufacturer certification; otherwise, the all-other-producers rate applies. The duty remains in force for five years unless earlier revoked, superseded or amended. Landed value follows customs assessable-value rules, and exchange rates are determined by the bill-of-entry date.

Notification rescinds the anti-dumping duty notification that imposed duty on imports of titanium dioxide originating in or exported from China PR. Actions already taken, or omissions occurring, before the rescission remain unaffected, preserving the legal effect of the rescinded notification for prior periods. The rescission operates under the Customs Tariff Act framework for anti-dumping duties.

Support for Alternative Trade Instruments under EPM now identifies exporters by Importer Exporter Code (IEC), abolishing declarations of intent and Unique Identification Numbers; existing UINs cease to operate. Support covers advance, revolving, and bullet-interest export factoring, with factors required to upload transaction data under modality-specific triggers. Factors must upload data within one month, while exporters must confirm eligible records and file monthly consolidated claims within two months of upload. Export eligibility depends on the Export General Manifest filing date. Eligible MSME exporters may access both factoring support and interest subvention, but cannot claim the same invoice or interest cost under both interventions; duplicate or excess claims attract recovery with interest and penalties.

The India-EFTA Trade and Economic Partnership Agreement operates as an enhanced framework for deeper engagement between India and EFTA countries, supporting expanded bilateral trade, investment and business linkages. Business expansion and investment opportunities were examined in technology, innovation, financial services and manufacturing, together with partnerships involving Indian businesses. The framework includes investment commitments and direct job creation over a 15-year period.

FORM GSTR-9 is substituted as the annual return for reporting taxable and non-taxable supplies, advances, exports, Special Economic Zone and deemed-export supplies, reverse-charge supplies, credit and debit notes, amendments, input tax credit, reversals, taxes paid, demands, refunds and HSN summaries. Filing requires prior filing of FORM GSTR-1 and FORM GSTR-3B. Additional liability not previously declared may be reported, but input tax credit unclaimed in the relevant financial year cannot be claimed through the annual return; additional liability declared in the form is paid through FORM DRC-03 only by the electronic cash ledger.

Net-profit estimation for gross contract receipts was reduced from 8% to 6% in an income-tax appeal. Concurrent appellate findings relied on departmental circulars and consistent Tribunal decisions supporting the 6% rate. As no error justifying appellate interference with that estimation was established, the reduction was treated as justified and the Revenue's challenge failed.

GST classification determines the treatment of food-related supplies and alcoholic-liquor job work. Cooking and supplying food through cloud kitchens or central kitchens, including takeaway or delivery, constitutes restaurant service and attracts GST at 5% without ITC. Ice-cream parlors selling pre-manufactured ice cream without cooking or preparation make a supply of goods taxable at 18%, despite incidental service elements. Contract manufacturing or job work relating to alcoholic liquor for human consumption is excluded from job work in relation to food and food products and attracts GST at 18%.

Availability of the benefit under section 128A of the CGST Act, 2017 is to be addressed in Odisha by applying, mutatis mutandis, CBIC clarification within the framework of the OGST Act, 2017. The clarification is intended to secure uniform implementation of issues concerning the section 128A benefit by tax administration and first appellate authorities.