Regulatory assets in electricity tariff determination are exceptional deferrals of recoverable revenue, not a routine means of carrying revenue gaps. Cost-reflective tariffs must balance consumer interests with recovery of reasonably incurred distribution-licensee costs. Rule 23 limits a revenue gap by reference to 3% of approved Annual Revenue Requirement and requires a time-bound recovery plan with carrying costs. New regulatory assets require liquidation within three years; existing assets require liquidation within four years from 1 April 2024. Regulatory Commissions must determine tariffs timely, conduct regular truing-up and ensure cost recovery. Appellate supervision extends to monitoring the liquidation roadmap, audit requirements and performance of statutory duties.

Settlement of cheque-dishonour proceedings on agreed instalments resulted in closure of the petition and pending criminal complaints, eliminating any remaining controversy for adjudication. The earlier deposit requirement was dispensed with. The suo motu action concerning unauthorised money lending was also closed after a draft bill circulated among States and Union Territories contemplated legislative measures to curb the practice, with an expectation that fair and proper legislation would be enacted.

Existing State money-lending laws continue to bar unlicensed lending, including lending supported by promissory notes, cheques, title deeds, or other security. They restrict interest under the Dam Dupat rule, prevent enforcement of loans advanced by unlicensed lenders, and criminalise unlicensed money lending. Proceedings brought by a private lender should be stopped at the threshold unless the lender produces a money-lending licence or shows that no interest was charged. Anticipated future legislation does not suspend civil or criminal remedies, appellate relief, or investigations under State money-lending and applicable criminal laws.

Refund interest raises unresolved questions on whether refundable deposits attract 12% or the notified 6% rate, and whether interest runs from the deposit date or only after three months from receipt of the refund application. Divergent coordinate-bench views and the statutory refund-interest framework, including the notification prescribing 6%, require consideration by an appropriate Bench. The questions remain pending for appropriate orders, with no final adjudication on the applicable rate or commencement of interest.

Arm's length price adjustment for consultancy-expense reimbursement remained sustainable because the arrangement arose during the relevant financial year and could not be treated as a recurring issue governed by earlier years. Selection of the Comparable Uncontrolled Price Method was unsupported by material identifying comparable transactions or demonstrating the benchmarking of the payment. Records also failed to substantiate allocation of the overseas employee's higher salary and related costs to services rendered for the assessee.

Cash deposits during demonetisation were not unexplained money where their nature and source were supported by documented agricultural-land sale receipts, a sale deed, cash book, affidavit, and an earlier scrutiny assessment of the property transaction. Section 69A applies only where money is unrecorded and the assessee fails to provide a satisfactory explanation. Receipt of sale consideration in cash and maintenance of the cash book were undisputed. The perceived improbability of retaining cash for an extended period did not displace the evidenced source, particularly given the stated medical, tax, and intended property-purchase needs. The addition was deleted.

Revisionary jurisdiction under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Verification of fresh unsecured loans through confirmations, tax returns, computations, balance sheets, bank statements and supporting agricultural-land evidence constituted an inquiry. Comparing loan amounts only with lenders' taxable income, without considering exempt income, capital and other funds, did not establish absence of inquiry. A supervisory view that further verification was desirable cannot equate an allegedly inadequate inquiry with no inquiry. On these facts, the assessment order was not erroneous and prejudicial, rendering the section 263 revision invalid.

Prior approval of the competent authority is a jurisdictional requirement for reopening assessment under the Income-tax Act. A notice issued under section 148 before that approval is granted is invalid and cannot confer reassessment jurisdiction. Where approval follows issuance of the notice, the notice is non est and the consequential reassessment must be quashed.

Principles of natural justice required a further opportunity for the assessee to produce material supporting claims relating to share capital, unsecured loans, sundry creditors and expenditure. The Tribunal did not decide the merits of the additions, set aside the appellate order, and remanded the matter to the Commissioner (Appeals) for fresh adjudication, directing the assessee to substantiate its case.

Section 153A permits additions to completed or unabated assessments only on incriminating material found during the assessee's search; external enquiries, third-party statements, regular books and uncorroborated information do not suffice. Allegations of bogus purchases or suppressed production require reliable evidence, including an established purchase trail and proof of non-genuine transactions; unsupported yield estimates cannot justify rejection of books or profit estimation. Valuation estimates alone do not establish unexplained investment, particularly where differences reflect subjective variation. Third-party survey material and loose papers require a clear link, corroboration and fair opportunity to test adverse statements. Cash discrepancies may be explained through contemporaneous cash records and supporting evidence.

Completed and unabated search assessments under section 153A require assessee-specific incriminating material found during the search. Documents seized from third-party premises cannot alone support additions in such assessments unless the statutory section 153C satisfaction requirement is met. Alleged on-money additions based on undated, unsigned, vague or incomplete loose sheets require independent corroboration establishing actual cash receipts. Where purchasers do not admit cash payments, bookings are cancelled, entries are notional, or figures correspond to cheque payments, loose sheets lack evidentiary value for determining undisclosed income.

Transactional Net Margin Method analysis may select a foreign associated enterprise as the tested party where it is the least complex, low-risk entity, particularly where materially unchanged facts support a consistent approach. Broad functional similarity can suffice for foreign comparables when identical comparables are unavailable. Any transfer-pricing adjustment should not exceed the margin retained by the associated enterprise in relevant customer transactions. Functionally dissimilar comparables must be excluded; employee-cost and persistent-loss filters may be inappropriate; and remaining margins require computation from annual reports. Working-capital differences in receivables and payables require corresponding adjustment for a reliable arm's-length determination.

Transfer-pricing benchmarking requires comparable companies to be functionally similar and reasonably comparable in scale. When implementing a DRP direction to recompute margins from annual reports, the TPO must remain within that direction and cannot exclude expenses as non-operating without a corresponding direction; margins require recomputation without those exclusions. High-turnover companies may be excluded where turnover disparity makes them unsuitable comparables for captive software-development services. Companies providing diversified, high-end technology, product-development, artificial intelligence, cloud, blockchain and specialised services are not functionally comparable with routine captive software-development and testing services. The arm's-length price requires redetermination after applying these comparability filters.

Unsecured-loan additions are unsustainable where loans are repaid with interest in the same assessment year and evidence establishes each creditor's identity and existence. PAN details and corporate registration supported the creditors' existence. The appellate factual findings did not raise a question of law warranting interference, resulting in deletion of the addition in favour of the assessee.

Central excise exemption treatment is amended by substituting, against serial number 1 in column (4), the entry "Rs. 11 per litre". Exercising the exemption-making power under section 5A of the Central Excise Act, 1944, read with section 147 of the Finance Act, 2002, the substituted entry applies from publication in the Official Gazette.

Central excise exemption rates in Notification No. 06/2026-Central Excise are amended by substituting the column (4) rate for serial number 1 with Nil and for serial number 2 with Rs. 11.5 per litre. The substitutions take effect upon publication in the Official Gazette and are confined to the stated table entries.

Government Departments, establishments, agencies, local authorities and public sector undertakings registered solely as Tax Deductors at Source are registered persons for GST purposes. Supplies to them are B2B supplies, including B2G supplies reported as B2B, rather than B2C supplies. Registered suppliers meeting the prescribed aggregate-turnover condition must issue e-invoices for such supplies by reporting invoice particulars to an Invoice Registration Portal and obtaining an Invoice Reference Number. Where e-invoicing applies, an invoice, credit note or debit note without the required Invoice Reference Number is not legally valid.

Electronically filed GST registration-cancellation requests remain effective despite acknowledged portal technical issues where portal records establish timely submission. The cancellation process must be completed, with a hard copy and fresh electronic application furnished where necessary. Cancellation is to operate from 31 December 2019, and, upon acceptance, GST returns filed after that effective date are void and non est.

Under the Odisha Goods and Services Tax Act, 2017, three central GST clarifications apply mutatis mutandis for uniform administration. They address export-of-services requirements, determination of place of supply, and GST taxability of personal and corporate guarantees. The clarifications apply across designated tax formations and first appellate authorities as clarificatory guidance, with implementation difficulties capable of being referred to the Commissioner of State Tax.

Customs Broker licensing requires applicants to submit a single complete online application through the CBLMS portal, select the Policy Section having jurisdiction over their intended place of business, and pay the prescribed fee. The Regulation 6 written examination is a computer-based bilingual multiple-choice examination and a prerequisite for grant of a Customs Broker licence. Applicants meeting the written-examination qualifying standard must appear for an oral examination. Candidates with benchmark disabilities may request appropriate arrangements with supporting evidence. False or forged application materials may cause rejection, licence cancellation, and action under applicable law.