Ghamella/Tasla is classified as a taxable article under the specific Chapter 73 tariff description rather than as an exempt agricultural hand tool. Its concave, load-bearing container design lacks the active working attributes of a hand tool, so the specific entry prevails over the general exemption entry. The later exclusion from the agricultural-tools exemption is clarificatory and does not create retrospective tax liability. Internal audit clearance or pre-notice administrative closure is not a quasi-judicial adjudication and does not bar a subsequent show cause notice on res judicata grounds. Describing the unchanged product as an exempt implement supports penalty for deliberate misstatement and suppression of taxable supplies.

Penalty under Section 129(3) for alleged diversion of goods requires reliable evidence that the actual movement or delivery contravened GST law, even where valid invoices and e-way bills accompany the consignment. Vehicle proximity to another factory, discrepancies in a transport bilty, and the driver's statement do not, without corroboration, establish delivery to an undeclared recipient where the goods' description and quantity match the accompanying documents. Failure to provide GPS-camera footage relied on adversely may deny a fair opportunity to contest the allegation. The penalty orders were set aside and the penalty quashed.

Refund of accumulated Compensation Cess ITC for domestic leather-product supplies under the inverted-duty structure requires more than lawful availment of credit. Section 54(3) limits refunds of unutilised ITC to statutory categories; credit usable only for Compensation Cess does not itself establish a cash-refund right. The claimant must meet the inverted-duty test and show that the exclusion for nil-rated or exempt outward supplies does not apply. A clarification on qualifying zero-rated supplies does not create an unconditional domestic-supply refund. As statutory entitlement was not established, the refund-granting order was set aside and rejection orders restored.

Customs and food-safety legislation operate concurrently: border control, tariff classification, valuation and anti-fraud enforcement remain within Customs powers, while food-safety compliance is regulated separately. A Customs Proper Officer may draw samples of imported food before Bill of Entry routing through FICS for Customs examination and investigation; routine FSSAI sampling does not create exclusive jurisdiction. Executive instructions cannot restrict statutory Customs powers. Challenges to sampling, testing methods, chain of custody and laboratory-report admissibility should be resolved in show-cause adjudication. Judicial review should not prematurely quash those processes or impose fresh-sampling, testing, cargo-release, or charge-waiver directions beyond the writ relief sought.

Delayed production of invoices and bilties did not establish that intercepted makeup accessories were documented, where the driver initially produced all documents available and the later material was uncorroborated. Unidentified buyers and sellers, unverified business credentials, unexplained discrepancies, and no reliable link between the documents and goods supported treating the consignment as undeclared. Transit-State action was not excluded by the asserted inter-State movement because the claimed out-of-State destination was not established. The documented-consignment precedent was distinguishable, and the penalty for transporting undeclared goods was sustained.

Refund of accumulated Compensation Cess input tax credit on coal used to manufacture leather products for domestic supply under an inverted tax structure depends independently on the conditions in Section 54(3); credit standing in the electronic credit ledger does not itself create a cash-refund right. Availability of credit, including the absence of a blocked-credit restriction, concerns credit availment rather than refund eligibility. Inability to use cess credit against other liabilities and the absence of cess on domestic output supplies do not establish inverted tax structure eligibility. Clarifications and export-related decisions concerning zero-rated supplies do not support the domestic refund claim. The refund-granting appellate order was set aside, restoring the original rejections.

Refund of accumulated Compensation Cess input tax credit on coal used to manufacture domestically supplied leather products is limited to the statutory categories for unutilised credit. A cess burden on inputs, where domestic outward supplies do not attract the cess, does not by itself meet the inverted tax structure requirement. Eligibility to avail credit, including the absence of a blocked-credit restriction, is distinct from entitlement to a cash refund. Restrictions on credit utilisation neither bar every refund nor create an independent refund right. Clarifications and authorities concerning zero-rated supplies or exports do not establish eligibility for domestic supplies.

Section 129(1)(a) of the GST Act treats transportation in contravention of the Act or Rules, including movement after expiry of an e-way bill, as attracting civil penalty without requiring proof of intent to evade tax. A claimed vehicle breakdown must be established by reliable material. GPS data concerning another vehicle, repair records lacking evidentiary value, and an explanation not contemporaneously disclosed do not substantiate the claim. Guidance that does not address movement with an expired e-way bill provides no justification; on these facts, the penalty was upheld.

Road-restoration charges paid for planned restoration following road cutting for a business pipeline constitute consideration for a taxable service where the work is specifically requested and involves bilateral reciprocity, rather than compensatory damages. Targeted restoration undertaken for a commercial entity does not qualify as a general governmental public-function service or non-supply, and recipient-side reverse-charge liability applies where forward-charge payment is unproven. Refund sanctions for parallel registrations in other jurisdictions neither bind an independent appellate authority nor override statutory conditions. Electronic GST proceedings remain valid without a physical Document Identification Number where authenticated portal records establish source and integrity, the notice identifies the factual and legal basis, and no prejudice is shown.

Refund adjustment against a disputed penalty demand pending first appeal is ordinarily limited to 20% under CBDT stay guidelines. The guidelines do not distinguish assessment demands from penalty demands, so full adjustment before pending stay applications are decided conflicts with those instructions. Recovery should therefore be confined to 20% of the disputed penalty demand, with excess adjustment reversed and refunded with applicable interest and the balance demand stayed pending disposal of the first appeal.

Revisional limitation for a Debenture Redemption Reserve adjustment to book profit runs from the original assessment where reassessment was initiated on unrelated financial transactions. The High Court held that the original assessment continues to govern matters not forming part of reassessment, while the reassessment order supersedes it only for reassessed items. Although Explanation 3 permits assessment of another escaped-income issue noticed during reassessment, the DRR issue was not shown to have arisen then. The revisional order was therefore time-barred and set aside; the merits of the DRR adjustment remained open.

Functional comparability under TNMM requires selection or exclusion of comparables to conform to Rule 10B through a factual, data-driven analysis. A standard departmental comparable set cannot replace appropriately matched companies. Software product, product-development, licence and subscription businesses with significant intangibles may be functionally dissimilar to a software development service provider and therefore unsuitable as comparables.

CBDT stay instructions limit recovery of a tax demand disputed before the First Appellate Authority to 20% as a pre-condition for stay. Refunds for later assessment years may not be adjusted against the disputed demand where prior payments and such adjustments have already recovered more than that threshold. Adjustment beyond 20% is impermissible, and the excess recovery must be refunded within four weeks while the first appeal remains pending.

Information indicating income escaping assessment must relate to the same assessment year proposed for reopening. Reassessment for AY 2020-21 could not rest on agricultural-land sale information from FY 2020-21, which related to AY 2021-22 rather than FY 2019-20. Because the transaction had no bearing on income for AY 2020-21, it could not establish escapement for that year. The reassessment notices, initiating order and consequential proceedings were quashed.

Final-instalment payment under the Income Declaration Scheme depends on verifying that the cheque was tendered by the due date and that the amount was subsequently credited to the Income Tax Department's account. Applicability of the relevant circular was not determined on the available facts. The payment and credit were to be re-examined; where verified facts brought the declarant within the circular, Scheme benefits were to be granted.

Condonation of inordinate delay requires a pleaded and substantiated sufficient cause; filing before a court without territorial jurisdiction and subsequent administrative movement of papers, without a pleaded pandemic-related impediment, do not establish it. Gross negligence, deliberate inaction and unexplained delay undermine finality and certainty under limitation law, while delay may prejudice the opposing side. On these principles, the revenue's condonation request was rejected and its appeal was treated as barred by limitation.

Angadia cash-transit entries representing clients' funds do not constitute the operator's unexplained money where the operator acts only as a facilitator and no evidence establishes ownership or accrual of the principal. Only the embedded profit or commission is taxable, not gross cash-transit receipts. Commission embedded in unaccounted turnover was estimated at 0.30 per cent after credit for commission already assessed, reflecting the low-margin nature of the business, operating margins, scale of operations and comparable Angadia decisions. Such commission is taxable at normal rates rather than under section 115BBE, and additions for gross principal cash transactions were deleted.

Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.

Section 56(2)(x) was treated as inapplicable where land was acquired solely through purchase of leasehold rights rather than ownership rights in land. The interpretation followed co-ordinate Tribunal decisions that compared the provision with Section 50C and adopted the view favourable to the assessee amid conflicting High Court views. Characterising the transaction as a sale of land did not change its legal character as a transfer of leasehold rights. The related addition was deleted.

Revision under section 263 cannot rest solely on an Assessing Officer's failure to record satisfaction or initiate penalty for alleged cash-transaction violations of section 269SS. It requires both an erroneous assessment order and prejudice to Revenue. Penalty under section 271D is independent of assessment proceedings and, under the applicable statutory scheme, falls within the Joint Commissioner's competence. The limitation governing that penalty cannot be bypassed by setting aside a completed assessment to create a fresh penalty foundation, particularly where the underlying transactions admit two plausible views.