Interest income earned by a co-operative society from investments with a co-operative bank qualifies for deduction available for income derived from investments with other co-operative societies. The exclusion applicable to a co-operative bank's own deduction claim does not prevent another co-operative society from claiming deduction on such interest. The tax-deduction-at-source provision concerning interest payments does not remove co-operative banks from the class of co-operative societies for this purpose. Consequently, interest from investments with co-operative banks remains eligible for the deduction.

Approval of a corporate insolvency resolution plan extinguishes past claims, including statutory dues, for periods before approval. Its binding effect prevents reassessment proceedings against the corporate debtor for a pre-plan assessment year, even where fresh information later emerges regarding alleged transactions before plan approval. Consequently, pre-resolution-plan tax liabilities cannot be pursued through a newly initiated reassessment.

Draft assessment orders under Section 144C(1) must be made and forwarded within the applicable limitation period under Section 153, including any extension arising from a transfer-pricing reference. Expiry of that period renders a subsequently issued draft order time-barred and without jurisdiction. Final assessment orders, demand notices and penalty show-cause notices founded on such an invalid draft order cannot survive. Availability of a statutory appellate remedy does not bar writ jurisdiction where the assessment proceedings suffer from a clear jurisdictional defect caused by limitation expiry.

Section 148A(1) requires a reassessment show-cause notice to provide the information suggesting income escapement, including the relevant transaction, valuation or computation basis, and statutory basis, so that the taxpayer has an effective opportunity to respond. Supplying that foundational information after expiry of the limitation period under Section 149(2)(b) cannot retrospectively cure an invalid notice, and a consequential Section 148 notice cannot validate the defective initiation. Section 56(2)(x) does not apply merely because proportionately allotted fresh rights shares are subscribed below computed market value where the shareholder's percentage holding remains unchanged; such allotment does not establish receipt of property from another person for inadequate consideration.

Assessment transfer and centralisation under Section 127 may be justified where a search yields material linking an assessee to the searched group and related entities. Centralisation facilitates coordinated investigation and assessment of matters arising from the same search. A transfer order does not finally determine tax liability, and the assessee may contest the assessment on merits after relevant material is supplied. On those grounds, transfer to a Central Circle is treated as valid and non-arbitrary.

Review petitions challenging a criminal-appeal judgment on wilful tax-evasion prosecution were dismissed because the filing delay lacked satisfactory explanation and no ground for review existed on merits. The proceedings concerned prosecution immunity available through Settlement Commission procedures, the binding effect of CBDT circulars and prosecution guidelines, and statutory sanction and sanctioning-authority competence for prosecution.

Special leave petition concerning unexplained gold found in an appellant's locker involved four 24-carat gold bars rather than gold jewellery. The Supreme Court found no ground to interfere with the impugned judgment under Article 136 of the Constitution and dismissed the petition. The legal point centres on the characterisation of the seized gold as bullion bars, not jewellery, and the Court's discretionary refusal to grant special leave.

Recovery of tax dues through application of seized assets raises the interaction between recovery powers under section 226(4) and the application of seized assets under section 132B. Where seized amounts are also under investigation and provisional attachment under PMLA, the central issue is whether PMLA's overriding provisions and the characterisation of assets as proceeds of crime take priority over tax recovery. Competing non-obstante clauses require determination of which special statutory regime governs the assets.

Validity of reassessment notices after statutory amendment and TOLA raises the requirements for sanction by the specified authority, pre-notice procedure under section 148A, and information suggesting that income has escaped assessment. The issues also include whether reopening based solely on a change of opinion is impermissible and whether the statutory information threshold for issuing a notice under section 148 is satisfied. These requirements govern the legal validity of reassessment proceedings.

Special leave petitions concerning penalties for contraventions involving loans or deposits under sections 271D and 271E were dismissed because the filing delays, reported as 427 and 433 days, lacked satisfactory explanation. No substantive determination was made on the requirement for the reassessment Assessing Officer to record satisfaction during reassessment proceedings.

Appellate review of an advance ruling under Sections 100(1) and 101(1) is confined to the ruling and the factual record on which it was issued. It does not permit a fresh classification determination based on a materially altered product, revised packaging, or evidence produced only after the original ruling. Where a later test report lacks batch, manufacturing, or other particulars connecting the tested sample to the original product, it cannot establish product identity or equivalence. Classification of the subsequently presented product therefore cannot be determined through that appeal.

Admission of an appeal concerning GST penalties is raised in relation to whether payment of a pre-deposit is required. Respondents have been directed to file counters within four weeks, and the matter will be listed thereafter. No determination on the pre-deposit requirement or the merits of the penalty appeal is recorded.

Unappealed GST advance rulings remain binding on the applicant and jurisdictional officer unless altered through statutory appeal, rectification, or voidness procedures. An administrative circular cannot retrospectively displace such a ruling or prescribe a GST rate contrary to the applicable rate notification; GST must be imposed through notification, not circular. Challenges absent from the show-cause notice and authorised appeal grounds cannot be introduced at the second-appellate stage. Refund objections based on supplier entitlement or unjust enrichment likewise cannot be raised outside the notice, particularly where the recipient bore the tax incidence, provided the prescribed certificate, reversed input tax credit, and met statutory refund-payment conditions.

Rules 10 and 24 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025 permit rejection of an appeal when notified defects remain unrectified after scrutiny. The Tribunal's inherent powers may also be used to secure the ends of justice and prevent abuse of process. Continued non-appearance, failure to cure defects despite repeated opportunities, and absence of explanation may establish abandonment of appellate proceedings. A defective appeal may therefore be rejected without any determination of its underlying merits.

Exclusive jurisdiction of the Principal Bench applies where multiple GST appeals raise an identical legal question. Appeals concerning GST on royalty payments under mining leases and consequential refund claims fall within that jurisdiction under the third proviso to Section 109(5) of the CGST Act, read with the notified framework. The transfer applications are therefore to be listed and heard by the appropriate Bench of the Principal Bench.

Supplier discounts or incentives disclosed in Column 5(O) of GSTR-9C do not, without more, establish an output-tax liability for the recipient. Section 15(3) governs exclusion of discounts from the supplier's taxable value and requires verification of pre-existing agreements, invoice linkage, credit notes, supplier reporting, return treatment, and any input-tax-credit reversal. Taxability must therefore depend on whether the recipient reduced outward turnover or tax liability. A discount cannot be recharacterised at the appellate stage as consideration for promotion or marketing services where that taxable-supply theory was absent from the show-cause notice and original adjudication.

GST demands founded solely on discrepancies between Form GSTR-3B, GSTR-2A, GSTR-9 and GSTR-9C require verification of underlying records. Excess input tax credit must be assessed on the net position after giving effect to disclosed reversals; gross-credit comparisons alone do not establish revenue loss. Output-tax differences require reconciliation with sales ledgers, invoices and financial books. Under Rules 42 and 43, proportional reversal applies only after specific and actual common credit is identified and segregated. Unreconciled portal data and treating all credit as common cannot determine tax, interest or penalty liability; de novo verification is required.

Entry 52B classifies qualifying vehicles for the higher Compensation Cess rate through cumulative engine-capacity, length, SUV identity and ground-clearance conditions. A prospective amendment defining ground clearance as unladen ground clearance does not introduce a laden-condition requirement into the earlier unamended entry. Fiscal classification cannot read an absent loading qualification into the entry; commercial identity and manufacturer specifications remain relevant evidence, while ARAI certification is technical but not conclusive. Vehicles meeting the specified unladen clearance therefore fall within Entry 52B. Where a lower cess rate is applied despite that classification and short-payment is detected through investigation, suppression of facts with intent to evade tax supports recovery of differential cess, interest and penalties under Section 74.

Rule 92(3) requires notice in FORM GST RFD-08 and a pre-decisional hearing before any part of a GST refund claim may be rejected. This requirement gives effect to audi alteram partem and principles of natural justice by requiring disclosure of precise grounds so the claimant can provide a meaningful response and supporting evidence. An appellate-stage hearing cannot cure the absence of the prescribed pre-decisional opportunity. Partial refund rejections made without this process, and appellate confirmations, are invalid and require fresh processing; the merits of the alleged input tax credit mismatch remain open.

Input tax credit denial requires specific disclosed grounds, a meaningful opportunity to respond, transaction-specific examination, and reasoned findings. A supplier's retrospective registration cancellation alone cannot support disallowance without independent verification and consideration of evidence concerning receipt of supplies and statutory conditions. The claimant's burden to establish credit eligibility must be assessed through a fair adjudicatory process. Statutory appellate review requires inquiry into the material and grounds on record, followed by a written merits-based decision with reasons; non-attendance does not justify dismissal for non-prosecution alone. Foundational defects in notices and original orders require fresh de novo adjudication, while substantive credit eligibility remains open.