Section 54F can treat two separately registered flats as one residential house where their substance and functional character establish a single family residence. The provision does not require residential accommodation to be one physical unit, located on one floor, or acquired through one registered instrument. Simultaneous purchase from the same developer in the same building and wing, coupled with intended combined residential use, supports treatment as one residential house. Deduction under section 54F is consequently available for investment in both flats.

Reassessment proceedings require recorded reasons for reopening to be furnished when requested after the assessee files a return in response to the reopening notice. The assessee must then have an opportunity to raise objections, which must be disposed of through a speaking order. Failure to formally communicate the recorded reasons is a mandatory jurisdictional defect; presumed awareness from earlier proceedings or assessment questionnaires cannot cure that non-compliance. Reassessment undertaken without these safeguards is invalid and liable to be quashed.

Under section 153A, the six assessment years are those immediately preceding the assessment year relevant to the previous year of search, excluding the search assessment year. In contrast, Explanation 1 to section 153A, applied pari materia to section 153C and the limitation framework under section 149, calculates the ten-year period from the end of the assessment year relevant to the search year. The search assessment year therefore forms the first year of that ten-year block. For a search during FY 2024-25, AY 2015-16 falls outside the prescribed period, making a section 148 notice time-barred.

GST adjudication requires verified findings based on statutory returns, reconciliations, books of account and other relevant records. Excess input tax credit claims require scrutiny of GSTR-9, GSTR-9C and statutory disclosures. Manufacturers making taxable and exempt supplies must apportion input tax credit, while traders need not proportionate credit where exempt goods are purchased and supplied without input tax credit. Orders must address taxpayer replies with reasons, contain accurate notice particulars, follow independent verification before issuing notices, provide hearing where required, and avoid recovery while rectification applications remain pending.

Jurisdictional objections to an arbitral tribunal deciding an excepted matter must be raised at the prescribed stages of arbitration. Sections 16(2) and 16(3) require timely objections to jurisdiction or excess of authority, subject only to the tribunal accepting a justified delay. Participation with knowledge of a contractual limitation and without specific objection constitutes deemed waiver under Section 4. Section 34 cannot be used independently to bypass those time limits and waiver consequences, consistently with the policy of minimal judicial intervention under Section 5. The award therefore remained immune from challenge on the excepted-matter objection.

ITC claimed in FORM GSTR-3B but absent from FORM GSTR-2A for FY 2017-18 and 2018-19 must be verified against statutory conditions, including possession of prescribed documents, receipt of supplies, payment to the supplier, supplier tax payment, required reversals, and the time limit for availment. Verification of supplier tax payment depends on a professional certificate for higher per-supplier mismatches and a supplier certificate for lower mismatches. The process is confined to bona fide reporting errors in ongoing or pending proceedings and excludes completed proceedings.

Proper officers must communicate show-cause notices and adjudication orders through physical mode in unregistered assessment proceedings under Section 63 of the OGST Act, 2017. Effective service must be verified to enable the noticee to participate, file objections or explanations, and produce relevant material before adjudication. Physical service is required to avoid ex parte assessment without a meaningful opportunity of hearing and disputes concerning non-service.

Transportation services for goods sent outside India have the foreign destination as their place of supply where both supplier and recipient are located in India. The supply is treated as an inter-State supply and is chargeable to IGST. The Indian recipient may claim input tax credit of the IGST charged, subject to applicable eligibility conditions, apportionment provisions and blocked-credit restrictions. The supplier must report the place of supply in FORM GSTR-1 using State code "96-Foreign Country".

Pre-CIRP GST dues of a corporate debtor are operational debt and cannot be pursued through coercive recovery; the proper officer may file the claim in insolvency proceedings. Where finalised insolvency proceedings reduce confirmed statutory dues, those proceedings are treated as other proceedings for recovery purposes. The jurisdictional Commissioner must issue FORM GST DRC-25 to communicate the reduced demand where FORM GST DRC-07 or DRC-07A was issued. Recovery may continue only for the reduced dues.

Capital-gains tax treatment is queried where land bequeathed to son X was sold after alleged manipulation of title documents. Although title was confirmed in X's favour, the earlier sale to buyer 1 was not declared null and void. Buyer 1 proposes a resale to buyer 2, with X joining as a consenting party and receiving part of the consideration. The issues concern long-term capital gains, partial consideration, application of section 78, and recording payment to X in the sale deed.

GST registration applications must be filed online using the form applicable to the applicant category, with complete and legible identity, business constitution, signatory, premises and other required particulars. Principal and additional business premises require accurate addresses and prescribed ownership, lease, consent, co-working or Special Economic Zone evidence. Aadhaar-authenticated applications generally follow the shorter processing timeline, while non-authenticated or risk-selected cases can require biometric checks or physical verification. Deficiencies must be addressed through the prescribed notice-and-reply process; unnecessary documents and subjective objections are excluded. Simplified registration provides automated processing for eligible small taxpayers subject to input tax credit restrictions.

Electronic GST refund processing requires applicants to submit FORM GST RFD-01, prescribed statements, undertakings and supporting invoices on the common portal, without physical submission. ARN generation marks filing, electronically transfers the claim, and starts the 15-day period for acknowledgement or deficiency memo. A deficient claim is not processed; ledger debits are automatically re-credited and a corrected claim must be filed afresh, subject to the statutory limitation. Claims require all due returns, subject to specified alternative returns for composition taxpayers, non-resident taxable persons and input service distributors.

GST recovery through WAMIS permits deduction of outstanding CGST, OGST and IGST liabilities from payments due to works contractors after a demand has crystallised, been served, become payable, and is not stayed. Circle Nodal Officers upload valid attachment orders and component-wise recovery details; active orders require departments to deduct available bill amounts after current statutory dues, using FIFO priority for multiple orders and prescribed tax-to-other-dues sequencing. Recovered sums are recorded in the recovery ledger, held under designated deduction heads, deposited through WAMIS and IFMS, and set off against the relevant demand. WAMIS supports partial recovery, monitoring, reconciliation, and audit trails.

Management fees supported by documented business purpose and commercial expediency are allowable business expenditure, and transfer-pricing observations do not determine allowability. Sales commission for marketing and support services paid to a United States entity is not Fees for Included Services under Article 12(4)(b) of the India-US tax treaty where it is not chargeable to tax in India; no withholding obligation or corresponding disallowance follows. Deduction for SEZ-unit profits requires verification of the accountant's Form 56F report and detailed workings, with expenses apportioned between STPI and SEZ units on an actual-expenditure basis.

Rule 96(10) restricted IGST refunds on exports where exporters had availed specified concessional or exemption benefits on procurement, to prevent double benefit. Its omission is applied retrospectively from 23 October 2017 because no saving or sunset clause preserved pending proceedings. The General Clauses Act does not preserve proceedings following omission of a rule without an express continuation mechanism. Pending matters involving rule 96(10) are to be handled on that basis, with the same approach applying mutatis mutandis to omitted rules 89(4A) and 89(4B).

GST export-of-services payment conditions are treated as fulfilled where consideration is received in convertible foreign exchange or through repatriable INR accounts, including SNRR, INR Nostro and NRE accounts, subject to applicable foreign-exchange requirements, foreign trade policy restrictions, RBI directions and other required permissions. Export receivables set off against import payables may satisfy the condition when undertaken in accordance with RBI directions. Net retention of an Indian reinsurance broker's commission may also satisfy the condition where foreign-exchange law extinguishes the obligation to realise and repatriate the relevant proceeds.

Section 149's first proviso preserves the former reassessment limitation for assessment years beginning on or before 1 April 2021. Where the erstwhile six-year period had expired for Assessment Year 2014-15 on 31 March 2021, a notice issued later under the former Section 148, even if deemed a Section 148A notice under the substituted regime, could not revive reassessment jurisdiction. The reassessment notice and consequential reassessment were therefore time-barred and without jurisdiction.

Input tax credit on demo vehicles used for customer test drives is not blocked for authorised dealers under the dealer-agency model, although manufacturers directly supply new vehicles to customers. Demo vehicles in both dealer-agency and traditional dealership models are purchased under tax invoices and serve the equivalent purpose of promoting vehicle sales through test drives. The expression "such motor vehicles" covers vehicles used to further the supply of similar motor vehicles, rather than only the identical vehicle sold. The previous restriction denying credit to dealer-agents is withdrawn.

Interest on wrongly availed and reversed IGST credit is determined by the aggregate balance of IGST, CGST and SGST input tax credit in the electronic credit ledger. No interest arises if that combined balance never falls below the wrongly availed credit between availment and reversal, notwithstanding a lower IGST balance alone. If the aggregate balance falls below the wrongly availed amount, utilization and interest arise only to the extent of the shortfall. Compensation cess credit is excluded because it cannot be used for IGST, CGST or SGST liabilities or reversals.

Section 17(4) permits qualifying banking companies, financial institutions and non-banking financial companies to avail fifty per cent of eligible input tax credit instead of proportionate credit. A registration not engaged in deposit-taking, loans or advances cannot use the mechanism, while an election by one qualifying distinct-person registration requires all qualifying registrations of the same entity to comply. Same-PAN supplies receive the second-proviso relaxation only when both supplier and recipient have opted. Eligible credit must be reported, reversed, reclaimed and disclosed in FORM GSTR-3B through the prescribed non-IMS or IMS process.