Reassessment initiated beyond four years requires a reasoned belief that income escaped assessment because the taxpayer failed to make a full and true disclosure of material facts. Third-party search information adopted without independent enquiry or a direct nexus to the taxpayer's records does not meet that jurisdictional threshold; the reassessment was therefore quashed. Section 69C requires proof that unexplained expenditure was actually incurred. Where export receipts were supported by contemporaneous business, customs and banking records, uncorroborated third-party material without effective cross-examination could not establish cash payments or unexplained expenditure. The addition was deleted, avoiding double taxation of recorded export receipts.

Appellate review must decide on the merits a disallowance arising from an assessment order; the existence of a separate additional claim does not justify refusing to determine that challenge. The disallowance therefore requires fresh merits adjudication by the Tribunal. Conversely, a fresh bad-debt claim first raised before the first appellate authority cannot be entertained where it neither arises from the reassessment nor falls within the scope of the underlying revision proceedings. That additional claim is unavailable in those appellate proceedings.

Banking companies governed by the Banking Regulation Act, 1949 fall outside the minimum alternate tax regime under Section 115JB. Leave-encashment liability may accrue under the mercantile system, but Section 43B(f) defers its tax deduction until actual payment to the employee. UPS qualifies for depreciation at the computer-equipment rate where it forms an integral part of the computer system and lacks independent functional use. Accordingly, minimum alternate tax does not apply to the banking company, leave-salary provision is deductible only on payment, and UPS receives computer-equipment depreciation.

Final assessment is unsustainable where a timely uploaded adjournment request is not considered because of a system-related inwarding delay. Natural justice requires a meaningful opportunity for the assessee to respond before finalisation. Portal records showing that the request was filed within the compliance period, but was not placed before the Assessing Authority, negate the premise that no response was filed. Proceeding with assessment without considering that request or affording an effective hearing breaches procedural fairness.

Statutory appellate remedy does not necessarily preclude writ scrutiny where an asserted breach of natural justice affects the assessment process. Faceless assessment procedures must comply with audi alteram partem: the taxpayer must receive reasonable time to answer a proposed adverse addition, and timely submitted replies and supporting material must be considered. Providing less than three working days and proceeding on an assumption of non-compliance despite acknowledged email submissions vitiates the assessment. Reconsideration must follow a reasonable hearing and consideration of the materials already furnished.

Determinate trust taxation under section 164 concerns measures intended to close tax-avoidance loopholes involving private trusts. The central legal issue is the validity of CBDT Circular No. 13/2014, which addresses the tax treatment of determinate private-trust arrangements under section 164 and the use of such structures for tax avoidance.

Supreme Court declined to interfere with the High Court's impugned ruling after considering the petitioner's submissions and record. The special leave petition was dismissed, and pending applications were disposed of. No underlying income-tax issue, statutory provision, or substantive legal principle is identified; the disposition rests solely on the absence of grounds for intervention.

Electricity subsidy computed as a percentage of energy charges incurred after production begins is a revenue receipt where it directly reduces manufacturing power costs. The purpose test governs characterisation: the scheme's object and operative mechanism prevail over the timing, source or form of payment. Although intended to promote industrial growth, the subsidy was limited to the post-production period and was neither linked to capital investment nor earmarked for asset acquisition, construction, capital-borrowing repayment or business expansion. It therefore provides operational assistance in carrying on business and is chargeable to tax as revenue income.

Assignment for consideration of leasehold rights in land and buildings allotted by an industrial development corporation is treated as a transfer of benefits arising from immovable property. Such assignment falls outside taxable supply under the GST framework governing transactions in immovable property and therefore does not attract GST. The applicable jurisdictional precedent remains binding because it has neither been stayed nor recalled, supporting non-levy on transfer to a third-party assignee.

Under the Uttar Pradesh GST Act, the monetary-limit policy for departmental litigation binds the Department. For GSTAT appeals, the prescribed threshold applies unless a specified exception is established. Commissioner authorisation to file an application does not override that policy. Where the disputed amount falls below the threshold, a departmental appeal is not maintainable unless the Department specifically pleads and proves a recognised exception, including a recorded case-specific opinion under the residual exception.

Tax and penalty demands under Section 74 based on an allegation that a registered firm is bogus or non-existent require proof of tax evasion. A valid GSTIN, identifiable business premises, and filing of GSTR-1 and GSTR-3B for the relevant period supported the firm's registered taxable status. The absence of goods at the premises during verification, without evidence that the firm was non-existent or had evaded tax, did not substantiate the allegation. The tax and penalty demand was therefore unsustainable.

Departmental GST appeals before GSTAT must comply with the binding monetary-limit policy issued under the Uttar Pradesh GST Act. Where the dispute concerns only penalty, the disputed penalty is the relevant amount for applying the prescribed threshold. The Revenue must specifically plead and establish a listed exception to maintain an appeal below that threshold. Statutory authorisation to institute an application does not itself displace the monetary-limit requirement or prove an exception. In the absence of evidence of a specified exception or a recorded Commissioner opinion under the residual exception, the appeal is not maintainable for merits adjudication.

Credit notes reduce taxable turnover under section 34 only when validly issued and declared within the statutory time limit. For inverted-duty-structure refund calculations under Rule 89(5), credit notes relating to supplies in the relevant refund period may reduce adjusted total turnover. Credit notes connected with earlier financial-year invoices but issued after the applicable declaration deadline cannot be excluded from adjusted total turnover. Refund eligibility must therefore be calculated without reducing turnover for those time-barred credit notes, and any resulting excess refund is recoverable.

Credit notes issued for returned, rejected, or reduced-value supplies reduce taxable turnover and may be deducted from adjusted total turnover under the accumulated input tax credit refund formula. Deduction is available where credit notes relate to invoices within the refund period. Credit notes issued during that period but relating to invoices from an earlier financial year cannot reduce adjusted total turnover if issued after the statutory deadline for declaring them. After excluding those belated notes, the recomputed maximum refund still exceeded the refund claimed, leaving the claim admissible.

Retrospective upward price revisions for pre-GST clearances determine the goods' true value at original clearance. The transitional reporting mechanism for post-GST debit notes enables declaration and payment of differential tax but neither creates a new taxable event nor shifts the original time of supply. Interest attaches to delayed payment of differential tax from the original clearance period. Where contractual price escalation creates a bona fide transitional interpretative dispute and tax is voluntarily paid without fraud, wilful misstatement, suppression, or deliberate non-compliance, penal consequences are unwarranted.

Assignment of leasehold rights in an industrial plot and building for consideration transfers the benefits of immovable property to the assignee, who replaces the original lessee. Under section 7(1)(a), Schedule II clause 5(b), and Schedule III clause 5 of the CGST Act, the assignment is not taxable as a supply of services. Its classification as other miscellaneous services under Serial No. 35 of Notification No. 11/2017-Central Tax (Rate) is inapplicable. The jurisdictional ruling excluding these transactions from GST remains binding unless stayed or recalled; consequently, GST is not leviable.

For 2017-18, supplier credit notes did not themselves require recipients to reverse input tax credit: the statutory framework then governed reduction of the supplier's output liability, the matching mechanism was not operational, and Rule 37 applied only to non-payment of suppliers within 180 days. Past-period GSTR-3B errors could be corrected on a net basis. Excess IGST should ordinarily be refunded or adjusted against future IGST liability; a refund paid through the electronic credit ledger would be recredited as IGST input tax credit, then cross-utilisable against CGST and SGST. Direct cross-head adjustment bypassed that route but was a bona fide, revenue-neutral procedural lapse that did not support tax, interest, or penalty recovery.

Where GST registration was cancelled before issuance of a show-cause notice, portal-only service may not provide effective notice because the noticee may be unable or not required to access the Common Portal. Binding departmental instructions requiring physical service in those circumstances apply. Absence of physical service deprives the noticee of an effective opportunity to respond and renders an ex parte adjudication unsustainable. The matter requires fresh adjudication after permitting a reply, necessary requests for documents or cross-examination, and adequate prior notice of personal hearing.

Ex parte cancellation of GST registration without recorded reasons warranted writ intervention under Article 226. The cancellation order was quashed and set aside, with fifteen days granted for filing pending returns and depositing outstanding dues. Absence of reasons in the cancellation order was the central legal defect requiring corrective relief.

Article 226 writ jurisdiction remains available despite an alternative statutory remedy where adjudication breaches procedural fairness and audi alteram partem. Section 74(9) requires consideration of the taxpayer's representation before liability is determined. Rule 142(4) requires a reply in Form GST DRC-06 but does not make electronic filing the exclusive mode: an acknowledged manually filed reply cannot be disregarded solely because it was not uploaded on the portal. Failure to consider that reply, objections, and documents permitted for submission before the allowed time expires violates natural justice, vitiates the adjudication, and requires reconsideration after an effective hearing.