Reopening of a completed scrutiny assessment after four years requires the assessee's failure to make a full and true disclosure of material facts necessary for assessment. Where unabsorbed depreciation was disclosed, no depreciation was claimed for the relevant year, and delayed TDS deposit had been examined and dropped in the original proceedings, reassessment cannot be used to review or revisit those matters. The notice under Section 148 and the consequential reassessment order were invalid and quashed.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer examines written explanations on CENVAT credit valuation, excise-duty refund and additional depreciation, and adopts a legally permissible view, revision cannot rest merely on the Commissioner's preference for another view. Lack of detailed reasoning in the assessment order alone does not establish error or prejudice. On these principles, revision was invalid because the relevant matters had been considered and no addition was warranted on their merits.

Internal TNMM acceptance in determining arm's length pricing is governed by the transfer-pricing framework in sections 92 to 92C and Rule 10B. Where binding precedent has already resolved an identical challenge arising from the same impugned order, the issue is fully covered and does not raise a substantial question of law. The transfer-pricing adjustment deletion therefore remains unaffected.

Denial of an assessee's requested and acknowledged video-conference personal hearing breaches the mandatory personal-hearing requirement under the faceless assessment procedure. Where the assessment is completed without granting that hearing, despite a request made in response to the show-cause notice, the assessment order and consequential tax demand cannot be sustained. The requirement protects the assessee's opportunity to be heard before finalisation of the assessment.

Duly accounted sales receipts recorded in audited books, supported by sales and quantitative details, and accepted as income cannot also be treated as unexplained cash credits. Where the corresponding sales are undisputed and the profit element has already been offered to tax, a further addition for the same receipt would tax the amount twice. Section 68 therefore does not apply to an accepted sales receipt merely because it is reflected as a credit entry.

Section 145(3) permits income estimation after rejection of books of account, but the estimate must have material support and relevant internal or external comparables. A fixed net-profit estimate for steel trading cannot rest on assumptions where sectoral margins are materially lower and no comparable data supports the rate. Consistency with comparable prior-year determinations, absent distinguishing facts, supports sustaining the appellate estimate as a factual finding. Fact-supported estimation does not give rise to a substantial question of law under Section 260A.

Section 250(6A) contemplates, where possible, hearing and deciding income-tax appeals within one year from the end of the relevant financial year. The qualification "where it is possible" does not permit indefinite postponement. Prolonged pendency, including a first appeal pending for over six years, constitutes genuine hardship warranting priority disposal. Such an appeal should be decided within three months of receipt of the order.

Section 151 reassessment approval must be granted by the authority competent under the limitation framework applicable on the relevant date. Once the three-year period has expired, approval by a lower specified authority is jurisdictionally defective, and additional time to respond to a notice cannot cure that defect. The Finance Act 2023 proviso changing the computation for identifying the approving authority operates prospectively and does not retrospectively validate an invalid sanction. Third-party survey material can support reopening only where it establishes a direct, live nexus with the assessee; loose papers and statements lacking identifying details or transactional connection are insufficient.

Provisional reversal of input tax credit reported in Table 4(B)(2) of GSTR-3B does not, without a quantified statutory demand or unequivocal admission, establish self-assessed GST liability. A pending investigation into an alleged stock shortage is not a determination of tax payable and cannot alone justify retaining the reversed amount as tax. A later demand order under separate challenge cannot retrospectively validate the original grounds for rejecting refund or characterise the earlier reversal as payment towards that demand. Refund remains subject to satisfaction of the applicable statutory requirements.

GST on hotel accommodation hired by the Department of Home requires the accommodation proprietor to obtain GST registration and remit the tax to the GST authorities. The hiring Department must bear the prescribed GST separately, in addition to the rent payable for the accommodation. The arrangement therefore treats GST as an additional charge over the stipulated rental amount while placing registration and remittance obligations on the service provider.

GST recovery from a deceased registrant's inherited estate requires proceedings to be initiated against the legal representative in an individual capacity, with effective notice and hearing. Recovery provisions permit liability to be recovered from the estate where the business has discontinued, but do not validate notices or orders issued solely in the deceased person's name. A legal representative's appearance or objection cannot cure that defect. The foundational breach of natural justice can justify writ intervention despite an available statutory appeal. Fresh proceedings may be taken lawfully against the rightful heir in respect of the inherited estate.

Timely credit of tax to the Electronic Cash Ledger may satisfy the payment condition for Section 128A amnesty where the amount is subsequently appropriated to the Electronic Liability Register through FORM GST DRC-03A. Rule 164(2) requires credit against the debit entry created by the relevant order, while timely ledger credit demonstrates that tax was received within the prescribed period. Although the proviso to Rule 88B(1) does not directly govern amnesty payments, it supports the legal significance of timely Electronic Cash Ledger credit. Delayed filing of the appropriation form should not alone defeat amnesty where substantive payment was timely made and later procedurally completed.

GST registration cancellation was set aside to allow a further revocation opportunity, considering the taxpayer's stated reasons for not pursuing available remedies and technical difficulties. Revocation required furnishing proposed returns, paying due taxes, and substantiating the intended place of business. Registration was to be restored if the revocation application was accepted.

Pre-trial bail in alleged fraudulent input tax credit matters engages Article 21, the presumption of innocence and the right to speedy trial. Detention before conviction is not punitive; bail remains the norm unless the prosecution establishes concrete risks of absconding, witness intimidation or evidence tampering, or other exceptional circumstances. Completion of investigation, filing of the complaint, absence of criminal antecedents, delayed charge-framing and a Magistrate-triable offence favour release where trial is unlikely to conclude within a reasonable time. Continued custody is unwarranted in those circumstances.

Criminal acquittal on benefit of doubt does not bar a departmental inquiry or require the disciplinary authority to reach the same result. Departmental proceedings apply the preponderance-of-probabilities standard and are not controlled by criminal evidentiary rules. Non-examination of a complainant does not invalidate disciplinary findings where other witnesses and relevant material corroborate the charge. When accepting inquiry findings, the disciplinary authority need not separately address every representation point. In intra-court writ review, concurrent factual findings may be disturbed only for perversity or an apparent legal error; reappreciation of supported evidence is impermissible. These principles support the continued operation of disciplinary dismissal.

Bagasse is non-excisable, so the Cenvat Credit Rules, 2004 do not require reversal of Cenvat credit on its clearance. Treating bagasse as an exempted item for this purpose is unsustainable, and the contrary circular was rescinded following the governing Supreme Court position. Consequently, no 6% Cenvat credit reversal is payable on clearance of bagasse.

Retrospective reclassification of excisable goods through a show cause notice requires a statutory enabling provision. Section 11A of the Central Excise Act, 1944 permits classification-related notices where duty has been short-paid or not paid, but does not independently authorise a notice proposing only a retrospective change in classification. A notice that neither alleges short payment or non-payment of duty nor identifies another statutory basis for retrospective reclassification lacks legal sustainability.

Retrospective service-tax exemption applied to services supplied by a sub-broker to a member of a recognised or registered association in relation to forward contracts during 10 September 2004 to 30 June 2012. Because the disputed services fell within that exempt period, the service-tax demand for 1 April 2008 to 31 March 2009 was unsustainable and was set aside.

Residential complex service covered buildings comprising more than twelve residential units under the Finance Act, 1994. Independent villas and apartments built under separate plot-sale and construction arrangements, with individual construction permissions, did not satisfy that statutory description. Board circulars clarified that developers and builders bore no service-tax liability before 1 July 2010. Consequently, construction of such independent residential units during January 2009 to June 2010 fell outside taxable residential complex service, rendering the service-tax demand unsustainable.

Service-tax exemption for services relating to electricity transmission or distribution covers maintenance and repair work directly integral to operating high-tension and low-tension lines and associated equipment, including re-stringing, strengthening, laying, sagging, binding and jumpering. Such work has a sufficient nexus with transmission or distribution, rendering the tax demand unsustainable. Extended limitation cannot apply merely because services were supplied to government bodies where the provider was registered and filed ST-3 returns; absent suppression, wilful misstatement, fraud, collusion or intent to evade, related penalties must be set aside.