Under the Income-tax Act, 2025, the Central Government, the Board, or an income-tax authority empowered to grant an assessee's approval may withdraw it at any time, even without an express withdrawal power in the underlying provision. Withdrawal requires recorded reasons and a reasonable opportunity of being heard. The corresponding 1961 provision has broadly the same effect, although its requirements for reasons and an opportunity to show cause are placed in a proviso.

Family-business governance should separate ownership from management, ownership returns from employment remuneration, family money from business money, and family discussions from business decisions. Working family members should receive market-based, role-linked salaries, while ownership returns should be paid through dividends. Family-related payments, loans and asset use require documentation, arm's-length terms and clear accounting. Succession planning should use objective candidate assessment, staged delegation and a formal handover, supported by aligned wills, company articles and shareholder agreements.

Omission of Rule 96(10) without a saving clause prevents its export-refund restrictions from governing proceedings pending on 8 October 2024. The prior applicability of the rule during the export period does not preserve pending enforcement. Departmental authorities must process affected IGST refund claims without invoking the omitted restriction, while verifying payment records, prior re-credits, refund applications, and other statutory requirements. Claims for interest and penalty require separate examination of their legal basis and admissibility.

Section 17(5)(d) blocks input tax credit on construction of resort or hotel buildings used as the taxpayer's own business setting, even where taxable accommodation, restaurant or event services are supplied. The retrospective substitution of plant and machinery for plant or machinery, together with the definition excluding buildings and civil structures, prevents treating the resort building as plant. Credit remains item-specific: construction inputs are blocked, whereas movable assets may qualify if invoice-wise evidence establishes that they were not used for construction.

Funding-round term sheets should be assessed as allocations of exit proceeds, governance rights and risk, not only valuation. The Waterfall Test should model shareholder payouts at sale values below, equal to and above post-money valuation. Liquidation preferences, including participating or multiple preferences, can materially reduce founder returns, while anti-dilution protections, especially full-ratchet provisions, can reallocate ownership after a down round. Cap tables should model future financing, option-pool top-ups and convertible instruments, and protective provisions should be examined for investor veto rights.

Entry 52B applies the higher Compensation Cess rate only when engine capacity, length, ground clearance and popular SUV identity are cumulatively met. Although the later amendment expressly specifies unladen ground clearance, the Tribunal treated that standard as consistent with the earlier entry because no laden measurement could be implied. Manufacturer promotional material may establish SUV identity, but technical certificates remain evidentiary and must be assessed against the taxing entry.

Written partnership, LLP and founder agreements should convert foreseeable disputes over ownership, decision-making, contributions, intellectual property, exits, contingencies and cash use into agreed procedures. The SPLIT-UP framework addresses shares and vesting, management authority and reserved matters, capital and work commitments, assignment of business intellectual property, exit and valuation arrangements, unexpected events, and policies for working-capital retention and distributions. Deadlock provisions may use mediation, a casting vote or buy-sell mechanisms, while exit terms may provide rights of first refusal and lawful restrictive covenants.

Rectification of the register of members under Section 59 is a summary remedy available only to a person who already holds a validly issued share certificate. It cannot establish an initial share entitlement, validate a defective certificate, or compel issuance of a certificate. Where no valid certificate, allotment material, board resolution, register entry, or established privity of contract exists, a disputed claim to shares requires adjudication through an appropriate civil or arbitral forum. Procedural rules cannot enlarge the statutory jurisdiction under Section 59.

Review petitions concerning State legislative competence to regulate betting on games of skill, the distinction between skill and chance, and the meaning of betting and gambling were dismissed for want of merit. Part II of Tamil Nadu's amendment and related Schedule, together with challenged Karnataka amendment provisions, remained intra vires. The measures were neither manifestly arbitrary nor disproportionate notwithstanding arguments on res extra commercium, public order, and nomen juris.

Enhanced additional court fee applies prospectively where the taxing lis commenced on or after 1 April 2016, because a higher court-fee condition imposed after commencement cannot burden the vested right of appeal without express or necessarily implied retrospective operation. The taxing lis commences when the assessing authority, dissatisfied with the return, seeks material or evidence, including through a pre-assessment notice; the assessment year, assessment order date, and appeal filing date do not determine commencement. Appeals and revisions arising from earlier proceedings remain subject to the prior rate, and the appellate or revisional authority must determine an unestablished commencement date.

Deemed assessments arising from filed VAT returns, prescribed documents and proof of tax payment may be reopened for escaped turnover or wrongly availed input tax credit only within the applicable six-year statutory limitation. A dealer's later request for copies of assessment records does not extend, enlarge or revive that period. Reopening proceedings commenced after six years, and consequential assessment orders, are therefore barred by limitation and beyond statutory jurisdiction.

Rule 26 of the Central Excise Rules, 2002 permits penalties where a person deals with excisable goods known or believed to be liable to confiscation, or issues documents enabling another person to obtain an ineligible benefit. Penalty could not be sustained because the seized goods were not held liable to confiscation and no material showed that the appellant issued invoices or other documents enabling an ineligible benefit. The statutory requirements for imposing the penalty were therefore not met, and the penalty was set aside.

Extended-period limitation cannot support a duty demand where the taxpayer repeatedly disclosed its clearances and duty-payment structure, and Revenue acknowledged the position through correspondence and periodic audits. Revenue knowledge of the material facts prevents reliance on the extended period when the show-cause notice is beyond the normal limitation period. The demand is time-barred, and no penalty is imposable.

Composite construction contracts requiring procurement and supply of materials on which VAT or sales tax is paid, together with execution of construction work, fall exclusively within Works Contract Service. Following its introduction into the service-tax levy from 1 June 2007, such arrangements cannot be classified as Construction Service merely because the underlying activities resemble construction. The service-tax demand classified under Construction Service for the disputed composite contracts was therefore unsustainable.

Service tax under the reverse charge mechanism was not payable on mining royalty where the relevant mining lease deeds were executed before 1 April 2016 during the negative-list regime. The subsequent accrual or payment of royalty did not independently create liability for a later period. Applying the established treatment of mining royalty, the service-tax demand and consequential penalty relating to those pre-existing leases were unsustainable.

Receipts attributable to newspaper sales constitute sale transactions rather than taxable service receipts and must be excluded when determining service-tax liability. Once those amounts are excluded, the remaining receipts for each relevant period fall below the applicable threshold exemption of Rs. 10 lakhs. Consequently, no service tax is payable on the remaining receipts, and no penalty arises.

The extended limitation period for denying CENVAT credit under the proviso to Section 73(1) requires evidence of suppression, wilful misstatement, fraud, or comparable deliberate conduct intended to evade tax. Regular self-assessment, ST-3 filings disclosing credit, and audit detection of irregular credit do not by themselves establish that intent. Where a registered assessee supplies records during audit and no mala fide intent is proved, including where it is a State instrumentality, the extended period is unavailable and the resulting demand is unsustainable.

Affiliation and recognition fees collected by a statutory nursing council for granting or renewing permission, recognition and affiliation to nursing colleges and institutions are not chargeable to service tax. The applicable principle treats comparable fees received by universities and statutory educational authorities as outside service-tax liability. Consequently, service-tax demands, related interest and penalties founded on those fees cannot be sustained.

Extended limitation for a service-tax demand was unavailable where tax had been self-assessed, declared and paid, though belatedly, and an application under the Sabka Vishwas Scheme concerning interest and penalty had been accepted. These circumstances placed the material particulars within the Department's knowledge and negated reliance on the extended period. As the show-cause notice was issued outside the normal limitation period, the demand was time-barred and consequential penalties were not imposable.

Extended limitation cannot rest solely on audited accounts and records available to the department: accounting treatment or non-declaration, without wilful suppression or intent to evade, is insufficient. Labour charges paid to local workers for renovation, where the recipient procures materials and no contractor supplies goods and services, do not establish a taxable works contract under reverse charge. Shared advertising-cost recovery between associates is reimbursement, not consideration for Business Promotion Service, absent a provider-recipient relationship. Employee secondment for the recipient's work constitutes manpower supply, but a demand dependent on an invalid extended period is time-barred.