Section 153B(1) required search-related assessments to be completed within twelve months from the end of the financial year in which the final search authorisation was executed. Where the final authorisation was executed in financial year 2020-21, the statutory deadline was 31 March 2022. The COVID-19 limitation extension applied only to judicial and quasi-judicial matters, including appeals, suits and petitions, and did not extend deadlines for original assessment proceedings. Assessments completed on 11 April 2022 were consequently beyond limitation and invalid.

Completed, unabated assessments may be subjected to additions under Section 153A only where the search yields incriminating material relating to the assessee; absent such material, the additions are unsustainable. Reassessment requires recorded reasons founded on correct material facts and genuine application of mind; an erroneous factual premise prevents valid formation of the requisite belief and renders reopening void from inception. A concealment penalty cannot continue where its sole underlying quantum addition has been deleted, because no independent basis remains.

Transfer-pricing comparability requires alignment with Rule 10B, including consideration of turnover, brand value, economies of scale, bargaining power and ownership of intangibles where those factors materially affect profitability. An upper turnover filter may therefore support exclusion of high-turnover software-development comparables that are materially larger and functionally dissimilar. A question concerning comparables that was not raised before the Tribunal does not arise for consideration at the subsequent stage. The exclusion of identified high-turnover comparables remains sustainable on comparability grounds.

Interest under Section 244A(1)(b) applies to refunds arising after an order treating a deductor as an assessee in default is quashed, where the refund falls outside Section 244A(1)(a). Interest runs from the date of payment until the refund date. Section 244A(1B), inserted with effect from 1 April 2017, does not deny interest on a refund processed before its commencement. Retention of money without authority warrants compensatory interest for the period of its use and retention.

Recall application was allowed, restoring the writ petition. The petition was then closed with liberty to initiate fresh proceedings on the same cause of action, including a challenge to Section 147A. Existing protection was continued for 90 days, preserving interim safeguards while permitting a renewed statutory challenge on the same factual basis.

Section 270AA permits determination of an immunity application only after expiry of the statutory appeal period, as grant of immunity is conditional on that expiry and other prescribed requirements. Rejection remains impermissible without a meaningful opportunity of hearing under the proviso to Section 270AA(4). A one-day notice to appear, followed immediately by rejection, does not provide adequate time to produce records and substantiate the immunity claim and breaches principles of natural justice. Immunity applications must therefore be reconsidered after an effective hearing and consideration of submissions and supporting material.

Assessment proceedings under section 153A were challenged because the section 153D approval was allegedly vitiated by total non-application of mind. The Supreme Court declined to exercise its Article 136 jurisdiction to interfere with the High Court order, dismissing the special leave petition and disposing of related interlocutory applications, where applicable.

Composite works-contract services supplied to the Government or a local authority for specified water supply, water treatment, sewerage treatment or disposal infrastructure attracted GST at 12%, comprising 6% CGST and 6% SGST, on 1 June 2022. The concessional rate entry remained operative until its omission took effect on 18 July 2022. Contractual recovery or reimbursement of an increased tax burden from the other contracting party falls outside the matters eligible for an advance ruling under the CGST Act. Consequently, the advance-ruling mechanism cannot determine entitlement to recover additional tax arising from a later rate change.

State Government grants of mineral-extraction rights under Short-Term Permits constitute taxable licensing services for the right to use minerals, classified under SAC 997337. Royalty is contractual consideration for that grant rather than a tax; consequently, GST is payable by the business recipient under the reverse charge mechanism at the applicable rate. Short-Term Permits receive the same GST treatment as quarry and mining leases because the grantor, mineral right and royalty basis are identical. Differences in the permit's area or duration affect tenure only and do not alter the nature of the supply or reverse-charge liability.

The first proviso to Section 98(2) barred consideration of an advance-ruling application because the applicant's supply characterisation-providing transportation vehicles to goods transport agencies-was already pending in enforcement proceedings and had been decided in an earlier comparable-supply order. As the same question of exemption or taxability under the GST enactments underpinned proposed input-tax-credit reversal, classification, exemption and taxability could not be examined on the merits.

Ex-works transfer of title in aircraft supplied for consideration in the course of business constitutes a taxable supply of movable goods under GST. Aircraft manufactured and procured in Gujarat, then supplied ex-works to a government purchaser from Gujarat, remain taxable in India because no applicable exemption covers the supply. Registration is required in Gujarat where taxable outward supplies originate from that State and the supplier's aggregate turnover exceeds the prescribed threshold. The domestic procurement and onward supply therefore form a taxable supply chain with a registration nexus in Gujarat.

Exemption for storage and warehousing of agricultural produce applies only to the outward warehousing service, not to the distinct inward supply of renting non-residential godowns. Godown rent therefore remains taxable as a real estate service even where the premises are used exclusively for exempt agricultural-produce warehousing. Rent charged by registered suppliers is subject to forward charge. From 10 October 2024, renting of non-residential property supplied by an unregistered person is subject to reverse charge for a registered recipient. The applicable rate for such renting is 18%, comprising CGST and SGST in equal shares.

Rule 24(4) of the GSTAT (Procedure) Rules, 2025 permits discretionary rejection of an appeal where notified procedural defects remain uncured despite sufficient opportunity. Six hearing opportunities, including before the bench and Registrar, were provided to rectify the defects. The appellant neither appeared nor sought adjournment and uploaded no additional documents to address the defect notice. Continued non-compliance after repeated opportunities may establish lack of diligence in pursuing the appeal and support exercise of the discretionary power.

Section 112 of the Central Goods and Services Tax Act, 2017 permits a person aggrieved by an order under section 107 to appeal to the Appellate Tribunal. Section 112(2) separately authorises the Tribunal to decline admission where the tax, input tax credit, fine, fee or penalty determined by the impugned order does not exceed fifty thousand rupees. Applying that discretion, the appeal concerning a penalty at the threshold was refused admission.

Net ITC for refunds of unutilised input tax credit on zero-rated supplies is confined to credit availed during the relevant refund period. A reversal of compensation-cess credit attributable to earlier tax periods, including residual credit remaining after an earlier refund, does not form part of relevant-period Net ITC and should not reduce it. Administrative guidance on reporting reversals cannot require deduction of every reversal recorded during the refund period irrespective of the period to which the underlying credit relates, as it cannot expand or override the statutory refund formula. The accumulated compensation-cess credit refund is consequently computed without deducting such earlier-period reversals.

Net ITC under Rule 89(4) comprises input tax credit actually availed and attributable to the relevant refund period. A reversal recorded during that period, where it relates to credit availed in an earlier period and is absent from relevant-period availment, does not reduce Net ITC in the formula for refund of unutilised cess credit attributable to zero-rated supplies. Paragraph 43(c) must be read consistently with Rule 89(4) and cannot extend the statutory formula to deduct every reversal recorded during the refund period. Administrative circulars bind departmental authorities but cannot override statutory provisions or restrict statutory refund entitlement; the accumulated cess credit refund remains admissible.

Net ITC for refunds of unutilized input tax credit on zero-rated supplies comprises credit availed during the relevant refund period under the statutory refund formula. A reversal of residual Compensation Cess credit relating to earlier tax periods, made after a prior refund was sanctioned, does not reduce Net ITC where it has no nexus with credit availed in the relevant period. Returns and the electronic credit ledger determine the credit actually availed during that period. Circular guidance cannot require deduction of all reversals reflected in a refund period if that approach enlarges or overrides the statutory formula.

Section 111 requires the appellate forum to regulate procedure consistently with natural justice. Its powers to dismiss a representation for default or decide it ex parte extend to appeals, and are matched by authority to set aside a default dismissal or ex parte order. Where a first appeal was validly instituted through the prescribed pre-deposit, disputed effective service of hearing notices and the absence of any apparent abandonment supported restoration. The statutory default-dismissal power therefore does not prevent a fresh first-appellate determination on merits after due hearing.

GST registration cancellation for non-filing of returns requires an adequate opportunity to respond to a show-cause notice and be heard. Where illness prevented the registered person from responding or attending the scheduled hearing, and no further date was fixed, cancellation after a single notice was set aside. Fresh proceedings must allow a response and hearing before a new order is passed, and must verify any return claimed to have been filed after cancellation.

GST appeals arising from show-cause notices issued before 1 October 2025 remain subject to the pre-substitution pre-deposit regime under Section 107(6), even where the appellate requirement was later replaced. The substituted pre-deposit requirement for disputed penalty does not govern proceedings initiated earlier. Challenges alleging inadequate consideration of contentions in an adjudication order require examination of facts and merits and should be pursued through the statutory appellate remedy rather than writ jurisdiction.