For Section 54F deduction, adjoining flats acquired under separate sale deeds may constitute one residential house where they function as a single composite dwelling. Separate flat numbers, sale deeds, tax-deduction entries, and database records do not conclusively establish independent residential houses. Where adjoining newly acquired units are used as one residence, they satisfy the requirement of investment in one residential house. Similarly, existing adjoining flats used as a single dwelling do not amount to ownership of more than one residential house under the proviso. On unrebutted evidence of composite residential use, the Section 54F deduction is allowable.

Section 54F can treat two separately registered flats as one residential house where their substance and functional character establish a single family residence. The provision does not require residential accommodation to be one physical unit, located on one floor, or acquired through one registered instrument. Simultaneous purchase from the same developer in the same building and wing, coupled with intended combined residential use, supports treatment as one residential house. Deduction under section 54F is consequently available for investment in both flats.

Reassessment proceedings require recorded reasons for reopening to be furnished when requested after the assessee files a return in response to the reopening notice. The assessee must then have an opportunity to raise objections, which must be disposed of through a speaking order. Failure to formally communicate the recorded reasons is a mandatory jurisdictional defect; presumed awareness from earlier proceedings or assessment questionnaires cannot cure that non-compliance. Reassessment undertaken without these safeguards is invalid and liable to be quashed.

Under section 153A, the six assessment years are those immediately preceding the assessment year relevant to the previous year of search, excluding the search assessment year. In contrast, Explanation 1 to section 153A, applied pari materia to section 153C and the limitation framework under section 149, calculates the ten-year period from the end of the assessment year relevant to the search year. The search assessment year therefore forms the first year of that ten-year block. For a search during FY 2024-25, AY 2015-16 falls outside the prescribed period, making a section 148 notice time-barred.

GST adjudication requires verified findings based on statutory returns, reconciliations, books of account and other relevant records. Excess input tax credit claims require scrutiny of GSTR-9, GSTR-9C and statutory disclosures. Manufacturers making taxable and exempt supplies must apportion input tax credit, while traders need not proportionate credit where exempt goods are purchased and supplied without input tax credit. Orders must address taxpayer replies with reasons, contain accurate notice particulars, follow independent verification before issuing notices, provide hearing where required, and avoid recovery while rectification applications remain pending.

Jurisdictional objections that claims concern contractual excepted matters must be raised before the arbitral tribunal at the prescribed stage. Sections 16(2) and 16(3) require timely pleas on jurisdiction or excess of authority, subject to justified delay under Section 16(4); Sections 16(5) and 16(6) provide subsequent recourse after a timely plea is decided. Knowing participation without objection constitutes waiver under Section 4. Section 34(2)(a)(iv) does not revive objections barred by waiver or delay, consistent with minimal judicial intervention.

ITC claimed in FORM GSTR-3B but absent from FORM GSTR-2A for FY 2017-18 and 2018-19 must be verified against statutory conditions, including possession of prescribed documents, receipt of supplies, payment to the supplier, supplier tax payment, required reversals, and the time limit for availment. Verification of supplier tax payment depends on a professional certificate for higher per-supplier mismatches and a supplier certificate for lower mismatches. The process is confined to bona fide reporting errors in ongoing or pending proceedings and excludes completed proceedings.

Proper officers must communicate show-cause notices and adjudication orders through physical mode in unregistered assessment proceedings under Section 63 of the OGST Act, 2017. Effective service must be verified to enable the noticee to participate, file objections or explanations, and produce relevant material before adjudication. Physical service is required to avoid ex parte assessment without a meaningful opportunity of hearing and disputes concerning non-service.

Transportation services for goods sent outside India have the foreign destination as their place of supply where both supplier and recipient are located in India. The supply is treated as an inter-State supply and is chargeable to IGST. The Indian recipient may claim input tax credit of the IGST charged, subject to applicable eligibility conditions, apportionment provisions and blocked-credit restrictions. The supplier must report the place of supply in FORM GSTR-1 using State code "96-Foreign Country".

Pre-CIRP GST dues of a corporate debtor are operational debt and cannot be pursued through coercive recovery; the proper officer may file the claim in insolvency proceedings. Where finalised insolvency proceedings reduce confirmed statutory dues, those proceedings are treated as other proceedings for recovery purposes. The jurisdictional Commissioner must issue FORM GST DRC-25 to communicate the reduced demand where FORM GST DRC-07 or DRC-07A was issued. Recovery may continue only for the reduced dues.

Capital-gains tax treatment is queried where land bequeathed to son X was sold after alleged manipulation of title documents. Although title was confirmed in X's favour, the earlier sale to buyer 1 was not declared null and void. Buyer 1 proposes a resale to buyer 2, with X joining as a consenting party and receiving part of the consideration. The issues concern long-term capital gains, partial consideration, application of section 78, and recording payment to X in the sale deed.

GST registration applications require complete electronic filing in the prescribed form, accurate applicant and business details, constitution-specific records, authorised-signatory proof, and verifiable Principal Place of Business documentation. Aadhaar authentication generally enables processing within seven working days, while cases requiring biometric checks or physical verification may follow a longer process. Clarifications may be sought only for specified deficiencies through FORM GST REG-03, with replies due in FORM GST REG-04. Officers must not demand extraneous documents or make subjective assessments of business premises. Inaction within the prescribed period results in deemed approval.

Electronic GST refund applications in FORM GST RFD-01 are filed, supported and processed through the common portal without physical submission. ARN generation marks the filing date, from which the proper officer must issue an electronic acknowledgement or deficiency memo within 15 days. Deficiency memos stop processing, automatically restore debited ledger amounts, and require a fresh application. Refund disbursement is made for all tax heads by the assigned officer after bank-account validation. Unutilized input tax credit claims are limited by statutory formulae, ledger balances and prescribed documentation, while rejected ineligible credit may entail recovery proceedings and conditional ledger re-credit.

GST recovery through WAMIS permits deduction of outstanding CGST, OGST and IGST liabilities from payments due to works contractors after a demand has crystallised, been served, become payable, and is not stayed. Circle Nodal Officers upload valid attachment orders and component-wise recovery details; active orders require departments to deduct available bill amounts after current statutory dues, using FIFO priority for multiple orders and prescribed tax-to-other-dues sequencing. Recovered sums are recorded in the recovery ledger, held under designated deduction heads, deposited through WAMIS and IFMS, and set off against the relevant demand. WAMIS supports partial recovery, monitoring, reconciliation, and audit trails.

Management fees supported by documented business purpose and commercial expediency are allowable business expenditure, and transfer-pricing observations do not determine allowability. Sales commission for marketing and support services paid to a United States entity is not Fees for Included Services under Article 12(4)(b) of the India-US tax treaty where it is not chargeable to tax in India; no withholding obligation or corresponding disallowance follows. Deduction for SEZ-unit profits requires verification of the accountant's Form 56F report and detailed workings, with expenses apportioned between STPI and SEZ units on an actual-expenditure basis.

Omission of rule 96(10) removes the restriction on IGST refunds for exporters who availed specified IGST exemption or concessional benefits on procurement. The omission operates retrospectively from the rule's original effective date for proceedings pending when it was omitted, because no express saving or sunset provision preserved those proceedings. The same treatment applies, mutatis mutandis, to the omission of rules 89(4A) and 89(4B).

Receipt of export-service consideration in convertible foreign exchange or repatriable INR accounts, including SNRR and INR Nostro accounts, satisfies the IGST export condition. Payments to stock brokers through SNRR or NRE accounts qualify, while NRO payments must be routed through repatriable INR accounts. RBI-compliant set-off of export receivables against import payables, and net retention of reinsurance-broker commission that extinguishes the exporter's realisation obligation under FEMA, also satisfy the condition.

Section 149's first proviso preserves the former reassessment limitation for assessment years beginning on or before 1 April 2021. Where the erstwhile six-year period had expired for Assessment Year 2014-15 on 31 March 2021, a notice issued later under the former Section 148, even if deemed a Section 148A notice under the substituted regime, could not revive reassessment jurisdiction. The reassessment notice and consequential reassessment were therefore time-barred and without jurisdiction.

Input tax credit on demo vehicles purchased by authorised agents under a dealer-agency model for customer demonstration and test drives is not blocked under section 17(5)(a) of the Central Goods and Services Tax Act, 2017. Although the manufacturer sells new vehicles directly to customers, demo vehicles facilitate the further supply of similar motor vehicles. The expression "such motor vehicles" permits credit for vehicles used to support the further supply of similar vehicles, placing dealer-agency and traditional dealership models on the same footing.

Interest on wrongly availed and reversed IGST credit is determined by the aggregate balance of IGST, CGST and SGST input tax credit in the electronic credit ledger. No interest arises if that combined balance never falls below the wrongly availed credit between availment and reversal, notwithstanding a lower IGST balance alone. If the aggregate balance falls below the wrongly availed amount, utilization and interest arise only to the extent of the shortfall. Compensation cess credit is excluded because it cannot be used for IGST, CGST or SGST liabilities or reversals.