Section 153D requires prior approval for each assessee and each assessment year after examination of the relevant draft assessment order and material. A single consolidated approval for multiple assessees and assessment years, without discernible separate consideration, does not satisfy that requirement and demonstrates lack of independent application of mind. Approval is not an administrative formality; a mechanically granted consolidated approval is invalid, vitiates the assumption of jurisdiction, and renders the resulting assessment orders liable to be quashed.

Transfer-pricing benchmarking under the transactional net margin method requires economically and functionally comparable entities. Material turnover differences can affect market position, bargaining power, economies of scale, brand advantage, capacity for complex contracts and profitability; high-turnover and functionally dissimilar entities should therefore be excluded when benchmarking captive software development services. Interest on overdue associated-enterprise receivables must reflect the actual credit risk. Where no basis supports a higher spread and the holding-company receivable presents limited credit risk, LIBOR plus 200 basis points is an appropriate benchmark. The arm's-length price requires recomputation on these bases.

CSR-related donations disallowed as business expenditure under Explanation 2 to section 37(1) may nevertheless qualify independently for deduction under section 80G, provided its conditions are met. Adding back the CSR outlay under section 37(1) prevents double deduction, while mandatory CSR spending does not prevent a payment from being treated as a donation where no quid pro quo exists. Revisionary jurisdiction under section 263 requires both demonstrable error and prejudice to the Revenue. It is not available merely because another view is possible where the assessment record shows enquiry into donation receipts, supporting evidence, payment mode and computation, and the deduction is legally sustainable.

For assessment years beginning before 1 April 2021, the first proviso to section 149(1)(b) permits a notice under the new reassessment regime only if reassessment remained within the erstwhile limitation period when the notice was issued. The extended limitation period under the new regime cannot revive a reassessment power already time-barred. For Assessment Year 2016-17, the former six-year period expired before the June 2024 notice, rendering it time-barred and legally invalid.

Proper officers should accept complete GST registration cancellation applications within 30 days, except where mandatory particulars are missing or a successor entity in a transfer, merger or amalgamation is unregistered. Cancellation takes effect from the date sought, but not before the application date. Applicants must receive written discrepancy details, seven working days to respond, and an opportunity of hearing before rejection. Cancellation does not discharge existing liabilities, and the final return remains mandatory. Closing-stock tax liability may be discharged with the final return, with any shortfall paid in cash.

Refund claim for Assessment Year 1999-2000 must be considered by the assessing authority after the petitioner furnishes the revised return and indemnity bond. The petitioner may submit those details, and the assessing authority must hear the petitioner before deciding the refund claim. The matter was listed for a further date.

Clause (i) of Explanation 1 to section 115JB requires a provision for diminution in the value of an asset to be added back to net profit for book-profit computation. The Schedule VI definition of "provision" covers amounts written off or retained for asset diminution; therefore, a provision for doubtful debts remains such a provision even when shown as a reduction from sundry debtors on the asset side of the balance sheet. Principles governing an actual write-off for ordinary deduction purposes do not apply to this distinct computation. Failure to examine the required add-back may render an assessment erroneous and prejudicial to Revenue, permitting revision under section 263.

Reassessment under sections 147 and 148 requires tangible material with a live link to income escaping assessment in the relevant year. Findings from subsequent assessment years cannot be mechanically applied where the relevant year lacked global-deal agreements, related revenue transfers, and the Hyderabad unit. Material discovered during an ongoing assessment for a later year was distinguishable. Recorded reasons founded on later-year facts amounted to a reason to suspect rather than a reason to believe; the reassessment and consequential assessment were invalidated.

Eligible active registered recipients meeting the applicable aggregate annual turnover threshold may report recipient-generated self-invoices for specified reverse-charge domestic supplies from unregistered persons and imports of services. RCMDOM and RCMIMP must be selected as the relevant e-invoice supply types when reporting through an authorised Invoice Registration Portal. Submission and validation of prescribed invoice particulars would generate an Invoice Reference Number, subject to applicable GST provisions, notifications and e-invoice specifications.

GST exemption applies to services supplied by entities registered under section 12AA of the Income-tax Act for advancement of religion, spirituality or yoga. Residential programme fees covering boarding and lodging are exempt where such advancement is the primary and predominant purpose. Accommodation or food and drinks supplied merely or primarily for consideration, including donations, are taxable, as are fitness camps and classes in aerobics, dance or music.

Punjab GST revises FORM GST RFD-01 refund statements for inverted-duty input tax credit, exports, SEZ supplies, deemed exports and place-of-supply tax adjustments. FORM GSTR-9 introduces reporting guidance and optional simplified disclosures for specified earlier financial years, including consolidated reporting of supplies, input tax credit and reversals. It also permits signed PDF uploads for specified input tax credit reconciliation details in FORM GSTR-9C without chartered accountant certification. FORM GSTR-9C provides optional non-filing of designated reconciliation tables and revised alternative auditor-certification formats.

GST practitioner enrolment applications in FORM GST PCT-1 may be approved or rejected for State enrolment by the Assistant Commissioner or Deputy Commissioner having jurisdiction over the applicant's declared address. Applicants may select either the Centre or the State as the enrolling authority and must record that choice in Item 1 of Part B of the form.

Provision for bad and doubtful debts, when simultaneously reduced from the corresponding debtors or advances under a regular accounting policy, constitutes a write-off rather than a mere provision for an unascertained liability. Where the accounts and resultant book profits have been finalised and adopted, such a write-off is allowable in computing book profits and need not be added back. A concern regarding possible double deduction does not justify an adjustment where that issue did not arise from the underlying proceedings.

Revisionary jurisdiction under section 263 requires an assessment order to be both erroneous and prejudicial to the interests of Revenue. Limited-scrutiny reasons stated specifically in a revision notice do not exceed the scrutiny scope where they are substantively consistent with the generally expressed reasons in the scrutiny notice. Where the Assessing Officer has sought and received documentary information on the limited-scrutiny issues, the matter concerns, at most, alleged inadequacy rather than lack of enquiry. Revision is unavailable when the Assessing Officer adopts a legally sustainable pass-through treatment and no finding establishes that the governing judicial principle is inapplicable.

Implementation of the Government of India's Reservation Policy across public sector banks, public sector insurance companies, sectoral regulators and public financial institutions was addressed through capacity building to support uniform and effective application. Deliberations considered practical implementation issues, operational challenges and actionable measures for consistent policy application, alongside related welfare measures and interactive discussion of implementation questions.

Marketing-agency payments for market-development and sales services require verification of the provider's business profile, actual services, personnel deployed, payments received and outputs generated before they can be characterised as capital or revenue expenditure. The taxpayer retains the primary burden of substantiating the claim, but a disallowance must rest on proper inquiry and substantive evidence rather than website extracts alone. An adjustment reducing intangible assets cannot be disallowed as current-year expenditure where no corresponding amount was debited to the profit and loss account, subject to verification of the accounting treatment and whether an earlier capitalisation was reversed.

New tax-determination provisions confine the earlier determination routes to tax periods through Financial Year 2023-24 and establish a unified route for later periods. The route sets notice and order deadlines, distinguishes fraud-based and other penalties, and permits payment-based closure at prescribed stages. Interest and penalty may be waived for specified earlier-period demands when the full tax is paid by the notified deadline, subject to exclusions for erroneous refunds, pending litigation not withdrawn, and non-refund of amounts already paid.

GST exemption applies to patient transportation in ambulances supplied by Government or private providers. Private providers supplying such services to a State Government under National Health Mission arrangements may qualify under the government-service exemption where the supply relates to public health or health and sanitation functions. Pure services qualify without goods; composite supplies qualify only if goods do not exceed 25 per cent of total value and the activity relates to the relevant local-government function.

Section 263 revisional jurisdiction requires the revisional authority to examine the record and independently form its opinion. Reliance solely on the Assessing Officer's proposal constitutes borrowed satisfaction and lacks independent application of mind, rendering revision invalid. Where loan transactions have been examined through summons and lender responses, an alleged deficiency is inadequate enquiry rather than lack of enquiry; it does not justify revision on that basis. Explanation 2 cannot support a revision order unless its proposed application was put to the assessee in the show-cause notice. The revision order was therefore quashed.

Reverse charge applies to passenger motor vehicle rentals with fuel included in the consideration when a non-corporate supplier does not issue an invoice charging GST at 12% and supplies the service to a body corporate. Where GST at 12% is charged, the body corporate recipient is not liable under reverse charge. The supplier must not collect tax from the recipient for a reverse-charge supply. The clarification also applies from 1 October 2019 to 31 December 2019.