Compensation received by BSNL employees under the 2019 Voluntary Retirement Scheme is exempt under Section 10(10B) of the Income-tax Act. Earlier coordinate-bench decisions accepting identical exemption claims support the same treatment where Revenue identifies no factual or legal distinction. Tax authorities should not deny an otherwise lawful tax relief merely because the taxpayer was unaware of the entitlement. Taxable income and any consequential refund require recomputation after giving effect to the exemption.

Penalty imposed under Section 270A of the Income-tax Act and the consequential demand notice under Section 156 were challenged through writ jurisdiction under Article 226. An equivalent penalty order and consequential demand notice had already been quashed in a coordinate-bench decision. As the applicability of that decision was undisputed, the penalty order and consequential demand notice for the relevant assessment year were quashed in favour of the assessee.

Section 31(1) of the Insolvency and Bankruptcy Code makes an approved resolution plan binding on the corporate debtor, creditors, government and statutory authorities. Statutory tax claims relating to periods before plan approval are extinguished if they are not incorporated in the plan, and cannot subsequently be enforced through reassessment proceedings, assessment orders or demand notices, even where underassessment is later discovered. Where material facts are undisputed and the dispute concerns the legal effect of an approved resolution plan, writ jurisdiction may be invoked despite an available statutory appellate remedy.

Reassessment under Sections 148A(d) and 148 requires fresh tangible material distinct from issues examined in the original scrutiny. Reopening an assessment for a mutual-fund short-term capital loss previously scrutinised and accepted, based on the same material and survey allegations already addressed in binding identical-fact decisions, constitutes an impermissible change of opinion and is invalid.

Erroneous tagging of a Central Tax writ petition with an unrelated Income-tax Act batch resulted in application of an inapplicable ruling and section 151A. The resulting order contained an apparent error because the petition did not concern the Income-tax Act. The order was set aside, and the writ petition was restored for listing before the appropriate roster Bench.

Payments for live-feed broadcast rights limited to telecasting specified matches do not constitute royalty for income-tax purposes where the licensee receives no enduring benefit. Royalty character may arise if the rights permit recording, preservation, re-telecast, or other commercial exploitation of the feed beyond the stipulated event or licensed period. In the absence of those exploitation rights, payments for live-feed telecast rights fall outside royalty taxation under the Income-tax Act.

Replacement dies and moulds forming components of manufacturing machinery qualify as repair expenditure rather than independent plant. Research-related deductions, including qualifying work-in-progress, remain allowable on materially identical facts. Captive-power profits may support the applicable deduction on a notional-profit basis. Foreign agency commissions remain allowable where the facts and legal position are unchanged, including their characterization for income-tax purposes. UPS and voltage stabilizers used with computers attract depreciation as integral computer equipment at 60%, while a temporary parking shed attracts depreciation only at 10%.

Section 102 of the CGST Act and KGST Act permits rectification of an error apparent on the face of the record. An inadvertent typographical discrepancy may be corrected without a personal hearing where the correction does not alter the advance ruling, increase tax liability, or reduce admissible input tax credit. The hearing proviso is inapplicable in those circumstances. Rectification remains confined to the identified typographical error, leaving all other findings, discussion, and the ruling unchanged.

Section 107 of the CGST Act sets a three-month appeal period and permits the First Appellate Authority to condone delay only for one additional month on sufficient cause. As a statutory authority, it has no inherent power to extend that outer limit; equitable considerations or High Court directions confined to particular writ proceedings do not enlarge its jurisdiction. Where the Department has implemented an order restoring GST registration, enabled business continuation and return filing, estoppel and orderly administration prevent a later challenge seeking to reverse that position. Registration restoration consequently remains effective despite invalid condonation beyond the statutory limit.

Confiscation under Section 130(1)(ii) requires facts establishing deliberate tax evasion through unaccounted goods, not a short bona fide delay in recording genuine stock transactions. A pre-survey invoice, subsequent verification in regular books and statutory returns, and an accountant's temporary absence support the conclusion that delayed posting differs from non-accountal intended for clandestine removal. Physical-stock allegations based on visual approximation rather than standard weighment are also unreliable. Where assessment proceedings substantially accept the stock explanation and identify only minor discrepancies, treating the same transactions as both reconcilable and confiscable is legally inconsistent.

GST demands alleging wrongful input tax credit recredit must disclose the factual and legal basis of the charge in the show-cause notice, and adjudication must address the taxpayer's explanation through reasoned findings. Tax paid under the wrong IGST or intra-State tax head must follow the prescribed refund mechanism; unilateral recredit through GSTR-3B does not automatically create valid input tax credit. Payments actually made under the correct Central and State tax heads require recognition and reconciliation with the original payment and any recredit, preventing both double taxation and duplicate credit or refund. Interest requires findings of wrongful availment and utilisation, while penalty cannot stand independently where the underlying wrongful-credit charge fails.

GST exemption for municipal functions under Article 243W applies to services rendered by local authorities, not to an auction lessee commercially collecting weekly-market fees under tender conditions. Such collection arises from a contractual commercial right, and the contractor remains liable for applicable Central and State taxes. COVID-related lease waiver or refund of lease amounts and security deposit is not unconditional where GST and income-tax liabilities remain unpaid. Tender terms may permit adjustment of losses or expenditure against amounts payable to the licensee, requiring statutory dues to be cleared before lease-related relief or refunds are claimed.

Ex parte GST demand and rectification orders concerning alleged non-payment of compensation cess on outward cigarette supplies were set aside to permit a response to the show-cause notice. Compensation cess liability required determination after the taxpayer was afforded an opportunity to reply. Submission of the reply was conditional on payment of 25% of the balance tax amount, enabling the compensation cess issue to be considered after the taxpayer's response.

Ex parte confirmation of a GST demand without a reply from the taxable person is to be reconsidered through fresh adjudication on merits. A further opportunity to submit a reply and supporting documents is conditional on deposit of 25% of the disputed tax for each liability through the Electronic Cash Ledger. Amounts already paid or recovered beyond that deposit must be adjusted against the liability determined afresh. On compliance, notice must be issued and a fresh order passed expeditiously. Bank attachment must be vacated, subject to the stipulated deposit and absence of other tax arrears; non-compliance permits recovery in accordance with law.

Interest on wrongly availed IGST input tax credit must be determined by considering the aggregate electronic credit ledger balance available under the IGST, CGST and SGST heads. Under the combined-balance test, interest does not arise if the aggregate balance remains at or above the wrongly availed IGST credit from availment until reversal. If that aggregate balance falls below the wrongly availed credit, interest applies only to the extent of the shortfall. The interest liability requires fresh determination using this test after affording the assessee a personal hearing.

GST seizure and detention proceedings under Section 129 require consideration of a post-facto GST registration amendment and whether the e-way bill and tax invoice establish tax compliance rather than an attempt to evade tax. Reconsideration on merits is required in light of prior rulings addressing similar circumstances, with the affected taxpayer to receive an opportunity of hearing before a fresh determination. The central legal point is the evidentiary relevance of registration status and accompanying transport and invoice documents in detention proceedings.

Effective service of GST notices requires more than portal upload where a cancelled registration and repeated non-responses indicate that notice may not reach the registered person. Although portal upload is a valid service method, the proper officer should use other service modes available under section 169(1) to ensure an actual opportunity to respond. Section 75(4) requires an effective personal hearing. An ex parte assessment made without reasonable steps for effective notice and without such hearing breaches principles of natural justice and is unsustainable.

Delay of 89 days in filing a statutory appeal may be condoned where serious illness of the taxpayer's accountant genuinely prevented portal access and communication of the assessment order. Restoration of the appellate remedy is conditional on paying the balance needed to reach 25% of disputed tax, after crediting recovered amounts. On compliance, the appeal must be taken on record, heard personally, and decided on merits.

Section 16(5), retrospectively effective from 1 July 2017, allows registered persons to claim input tax credit for financial years 2017-18 through 2020-21 in returns filed up to 30 November 2021, despite the limitation in Section 16(4). Input tax credit falling within that extended statutory period cannot be reversed solely on limitation grounds. Recovery measures based on such reversals must be released, with amounts already recovered adjusted or refunded as applicable.

Input tax credit disallowed as time-barred under Section 16(4) is unsustainable where the limitation issue is covered by an earlier common order quashing a departmental order on the same point. For remaining GST assessment issues, portal upload is a valid mode of service, but repeated non-response requires use of other prescribed service methods, preferably registered post, to ensure effective notice. An ex parte assessment without that effort or a personal hearing breaches principles of natural justice. The limitation demand cannot stand, while the remaining issues require fresh determination after effective notice, reply and personal hearing.