Section 17(4) permits qualifying banking companies, financial institutions and non-banking financial companies to avail fifty per cent of eligible input tax credit instead of proportionate credit. A registration not engaged in deposit-taking, loans or advances cannot use the mechanism, while an election by one qualifying distinct-person registration requires all qualifying registrations of the same entity to comply. Same-PAN supplies receive the second-proviso relaxation only when both supplier and recipient have opted. Eligible credit must be reported, reversed, reclaimed and disclosed in FORM GSTR-3B through the prescribed non-IMS or IMS process.

Unregistered recipients may claim refund of GST borne on cancelled construction-service agreements or prematurely terminated long-term insurance policies only where the period for the supplier to issue a credit note has expired. The claimant must obtain temporary registration, complete Aadhaar authentication, provide a PAN-linked bank account, and file FORM GST RFD-01 with statement 8, the supplier's certificate, and supporting evidence. Separate claims are required for different suppliers. Refund cannot exceed invoice tax and is proportionately restricted where the supplier has returned only part of the amount paid.

Each registrant that receives input-service invoices for distinct persons and must distribute the related credit requires ISD registration. The ISD must distribute credit only to the recipient to whom it is attributable and must ascertain its prima facie eligibility before distributing it in the relevant month through FORM GSTR-6. Recipients remain responsible for credit eligibility and applicable reversals. Credit transferred by a same-PAN, same-State registrant to an ISD is a credit-transfer mechanism, not an outward supply, and is excluded from turnover and Net ITC refund computation.

No Claim Bonus does not represent consideration for a supply by an insured to an insurer because the insured has no contractual obligation to refrain from lodging a claim. It is an admissible discount in valuing insurance services where disclosed in the policy terms and recorded in the invoice, and GST applies to the premium payable after that deduction. Mandatory e-invoicing exemptions for specified entities or sectors apply entity-wide, rather than only to specified categories of supplies.

Expenditure disallowance linked to exempt income is not permissible where no exempt income was earned or receivable during the relevant year; rule 8D cannot produce a disallowance in the absence of such income. Unsecured-loan additions require consideration of additional appellate evidence relevant to the identity, creditworthiness and genuineness of loan credits. Where the first appellate authority has not addressed that evidence or recorded its admission under rule 46A, the loan-credit issue requires fresh determination on merits after both sides receive an opportunity to be heard.

GST appellate pre-deposit requirements require full payment of the admitted amount-tax, interest, fine, fee and penalty that the taxpayer accepts and does not challenge-before an appeal is filed. The contested balance is tax in dispute, and the statutory pre-deposit is calculated as ten per cent of that disputed tax. For an appeal before the Appellate Tribunal after modification of liability at the first appellate stage, the further pre-deposit is calculated on the disputed tax liability confirmed at that stage.

Where fraud, wilful misstatement, or suppression to evade tax is not established, a notice issued under section 74(1) is to be treated as a notice under section 73(1). The consequential order redetermining tax, interest, and penalty must be issued within two years from communication of the relevant direction. However, redetermination is limited to demands for which the original notice was issued within two years and nine months from the applicable annual-return due date or the date of erroneous refund. For multi-year notices, only timely noticed financial years may be redetermined.

Show cause notices must identify each noticee, factual allegations, supporting evidence, legal provisions, charges, demand basis, financial-year-wise quantification where possible, and reply procedure without prejudging liability. Fraud, wilful misstatement, or suppression-based demands require material showing deliberate intent to evade tax; non-payment or a discrepancy alone is insufficient. Adjudication requires a speaking order that evaluates the noticee's submissions and evidence, remains within the notice's grounds and quantified demand, provides issue-wise findings and calculation, and is electronically summarised on the portal.

Section 40A(2)(b) requires related-party payments to be tested against payments made in comparable circumstances before treating expenditure as excessive or unreasonable. Borrowing rates charged by financial institutions, even with an added lending margin, are not necessarily valid comparables for unsecured private loans obtained through personal relationships, without institutional security, documentation, or repayment conditions. Interest paid at 15% on such unsecured related-party loans was therefore not treated as excessive or unreasonable, and the related disallowance was deleted.

Presumptions of consideration and legally enforceable liability arising from a cheque under the Negotiable Instruments Act are rebuttable. An accused may establish a probable defence on a preponderance-of-probabilities standard through direct evidence or surrounding circumstances, after which the complainant must prove the debt or liability by acceptable evidence. Pre-presentation misuse complaints, stop-payment instructions, disputed signature, consultancy relationship, lack of loan security or records, and failure to prove lending source and capacity may collectively rebut the presumptions. Without cogent proof of the alleged loan, a conviction for cheque dishonour cannot be sustained.

Equitable balancing to preserve a running concern supports a conclusive full and final settlement of an assignee's debt claims while challenges to NPA classification, debt assignment, and compensation valuation remain unresolved. Payment of a specified additional sum within 12 weeks, beyond amounts already paid, requires release of securities, guarantees, and title deeds and disposes of pending insolvency and debt-recovery proceedings. Default permits revival of those proceedings and withdrawal of the settlement benefits.

For textile cess under Section 5A of the Textiles Committee Act, bleaching, dyeing and other job-work processing of fabrics supplied by handloom or powerloom manufacturers do not constitute manufacture when the processed fabrics are returned to those manufacturers. As the Act does not define manufacture, a specialised definition in another enactment cannot be imported without legislative reference, incorporation, or statutes being in pari materia. In common parlance and within the statutory context, such processing refines existing fabric rather than producing a new textile; the job-worker is therefore not liable to textile cess.

Threshold exemption for diesel generator-set rental services applies where diesel and related input expenditure, shown separately in financial statements, is excluded from gross receipts because it does not constitute taxable-service value. On that basis, the service value falls below the prescribed exemption threshold, making the service-tax demand unsustainable. The appellate order should address the specifically raised claim under the applicable threshold-exemption notification.

Section 142(5) of the CGST Act governs post-GST refunds of tax paid under existing law where a service was not provided, including service tax paid on a cancelled flat booking. The claim must be disposed of under the existing law, with any amount found due payable in cash, subject to the unjust-enrichment bar. Limitation based on the relevant-date provisions of Section 11B of the Central Excise Act does not apply to this transitional refund mechanism. Refund cannot therefore be denied solely by reference to the date of service-tax payment or booking cancellation.

Food supplied under an institutional arrangement from premises provided by a hospital falls within taxable outdoor catering service under the expanded Finance Act, 1994 definition effective from 16 June 2005. VAT payment covers only the goods component and does not remove service-tax liability for the catering service, particularly where statutory abatements already exclude permissible goods value. The medical-establishment exemption for outdoor caterers ceased from 1 March 2006. Extended limitation requires deliberate suppression intended to evade tax; mere non-disclosure is insufficient. Reasonable cause under Section 80 precludes penalties, leaving service tax and interest limited to the normal limitation period.

Electronic records recovered from an accounts manager, together with signed printouts and statements confirmed by the manager and director, can constitute corroborative evidence of unaccounted cash receipts from flat purchasers. Facts concerning records maintained exclusively by those persons place the evidentiary burden on them under the rule governing facts within exclusive knowledge. Voluntary statements recorded during investigation remain usable evidence where a retraction is delayed and raised only in response to a show-cause notice. The absence of bank entries or purchaser statements does not by itself negate the evidentiary value of such electronic records and confirmations for service-tax liability.

Money-laundering bail was denied where material, including an independent audit, indicated alleged diversion of funds collected from allottees. The applicant's conduct was also considered to have delayed trial progress. These circumstances supported refusal of bail in the money-laundering proceedings, with the evidentiary material and trial delay forming the key considerations.

ECIR proceedings under the Prevention of Money Laundering Act require proceeds of crime derived from criminal activity linked to a subsisting scheduled offence. Quashing the sole predicate FIR removes the scheduled-offence foundation and leaves no basis to continue money-laundering action against persons or property connected with that FIR. The ECIR was consequently quashed for the petitioners and their associated directors, partners, employees and shareholders.

Conditional property-transfer arrangements used to secure or facilitate payment do not novate or discharge an operational debt unless they completely substitute, rescind, or extinguish the original obligation under contract law. Where the original liability is expressly preserved, payment and transfer have not occurred, and cheques for admitted dues are dishonoured, the operational debt remains enforceable through Section 9 insolvency proceedings. A pre-existing dispute must genuinely and substantively concern the operational claim; a collateral controversy over property transfer or specific performance, without contemporaneous evidence disputing supplied goods, amount, or liability, does not bar insolvency admission.

IBC moratorium under Section 14(1)(a) does not bar arbitral proceedings initiated by a corporate debtor through a counterclaim, because an unsuccessful counterclaim creates no pecuniary liability and a successful one may augment the estate. A pre-CIRP termination of a development agreement for non-performance does not make the terminated agreement estate property protected by the moratorium. Interim arrangements may therefore be reconsidered in aid of the surviving counterclaim. Section 60(5)(c) grants only limited residuary insolvency jurisdiction; where contractual termination predates and is unrelated to CIRP, the required nexus is absent, Section 63 creates no jurisdictional bar, and arbitral jurisdiction continues. An inaccurate description of a Section 29A extension does not alter that result if the application concerns the counterclaim.