Aluminium shelving classed by import condition: use allowed only if statutorily permitted; supports aren't parts at import.
Classification requires sequentially applying GRI 1 with relevant Section and Chapter Notes; aligned HSN Explanatory Notes guide interpretation. Use is relevant only where permitted and must reflect intended use objectively evident at importation per the as imported principle. A "part" must have an essential functional nexus to machine operation; mere supporting platforms or shelves that do not contribute mechanically to operation are not parts and may instead fall under material-based structure headings.

Composite GST show cause notices spanning multiple financial years misalign tax-period limitation and may be quashed.
Issuance of a single consolidated show cause notice covering distinct financial years was held impermissible because GST liability is tethered to tax-period returns and limitation timelines; consolidation misaligns period-specific adjudication clocks, constitutes a jurisdictional defect, and warrants quashing with liberty to re-issue notices in strict conformity with the period-wise statutory scheme.

Composite GST show cause notices aggregating multiple financial years lack scope; demands must be period-specific and limitation-linked.
The GST demand-and-recovery framework is period-based: tax liability and limitation are tied to returns for each tax period or financial year, and limitation is computed from the annual return due date or an erroneous return for that year. Consolidating multiple financial years into one consolidated show cause notice is outside the statutory design and constitutes a jurisdictional defect; administrative advisories cannot override the period-specific statutory scheme. Authorities may, if no other impediment exists, initiate proceedings framed strictly period-wise under the applicable demand provisions.

Gold/jewellery cases require mandatory section 138B admissibility for investigation statements before proving ownership or smuggling links.
Section 138B creates a mandatory admissibility regime for section 108 investigation statements: unless clause (a) applies, the maker must be examined before the adjudicating authority and an admissibility opinion recorded before using those statements to prove truth. Ownership cannot be fixed on an appellant where such statements are excluded, and confiscation/penalty theories for jewellery must follow the correct statutory route-section 111 for imported goods and section 120 when alleging goods are made from smuggled inputs. Documentary explanations require verification before rejection.

Unsecured loans through banking channels cannot be treated as unexplained credits absent transaction specific incriminating material.
Unsecured bank routed loans cannot be treated as unexplained credits where the assessee produced confirmations, lender bank statements, audited accounts and tax filings, and the Assessing Officer relied chiefly on uncorroborated third party search statements or administrative press releases without transaction specific incriminating material. For years prior to the Finance Act, 2022 amendment, a generalized source of source obligation for loan credits is not mandated; repayments in the lender's account are distinct from fresh upstream borrowings. Appellate authorities may independently verify facts under their powers if the AO is given opportunity to respond.

Reassessment jurisdiction: both JAO and FAO held to have concurrent authority, pending apex resolution of the faceless regime.
The Delhi High Court holds that both JAO and FAO possess concurrent jurisdiction to initiate reassessment under Section 148, construing Section 151A as administrative/enabling rather than jurisdiction-extinguishing. It reasons that routine SLP dismissals do not automatically create binding Article 141 precedent to overturn a coordinate-bench High Court view, and declines to treat the Delhi precedent as per incuriam absent a contrary Supreme Court ratio; interim apex stays are case-specific and do not displace the Delhi position.

Cheque dishonour cases: statutory presumptions preserved; tax breaches don't negate enforceability; procedural reforms directed.
Once a cheque's execution is admitted, statutory presumptions of consideration and of a legally enforceable debt arise and, though rebuttable, the initial burden lies on the accused; unsupported claims of payer incapacity or a 'blank cheque' are insufficient without positive evidence. Breach of tax-related cash-transaction rules attracts fiscal penalties but does not render the underlying loan unenforceable for cheque-dishonour purposes. Revisional courts may not overturn concurrent factual findings absent perversity or jurisdictional error. Procedural reforms and calibrated compounding measures are directed to expedite and streamline Section 138 proceedings.

Electronic service of GST show cause notices must be in the prescribed portal location to ensure a real opportunity to be heard.
Uploading an SCN only under a secondary portal compartment, rather than the primary prescribed location, does not constitute due communication; where an adverse decision is contemplated the Proper Officer must afford an opportunity of hearing, and defective electronic service that prevents participation vitiates the ensuing adjudication, permitting writ intervention to set aside and remit for proper notice and hearing.

Electronic Credit Ledger blocking permitted only up to ITC actually available; negative balances and extra statutory recovery are impermissible.
Rule 86A may be invoked only where input tax credit is actually available in the Electronic Credit Ledger at the time of the blocking order; the power permits disallowing debit equivalent to such available credit as a temporary preventive measure and does not authorize creation of negative ledger balances or serve as a recovery provision. Excess blocking beyond the ECL balance is ultra vires and recovery must proceed under the Act's substantive provisions.

Search assessments under section 153A permit full reassessment for abated years but limit reopened completed years to incriminating search material.
Section 153A's assessment power is search-linked: for abated years the AO may reassess total income afresh, but for completed/unabated years additions under section 153A are permissible only where specific incriminating material relating to that year is found during the search; absent such material, disturbance of a completed assessment must proceed, if at all, under sections 147-148 subject to their conditions.

Customs appeals: High Court writs are generally restrained where a statutory High Court remedy exists and limitation lapsed.
Where a statute provides a remedy to the High Court itself, the High Court will ordinarily decline writ intervention under Article 226 to avoid bypassing the statutory machinery; a litigant who has by his own default allowed the statutory limitation for a reference or appeal to lapse cannot ordinarily rely on Article 226 to cure that lapse, and claims of tribunal non consideration demand clear, specific, verified pleadings.

Share buybacks and GST: expenses tied to buybacks are not eligible for ITC, and common ITC must be reversed.
The authority held that shares are "securities" excluded from "goods" and "services," but section 17(3) and the Chapter V rules treat "transactions in securities" as part of the "value of exempt supply" for ITC apportionment; therefore GST paid on expenses directly related to a share buyback is not eligible as ITC under section 16(1), and common ITC attributable to both taxable operations and the buyback must be reversed using the prescribed deeming values.

Mutual fund redemptions require proportionate ITC reversal under GST deeming provision; valuation set at 1% of sale value.
A statutory deeming provision includes transactions in securities within the value of exempt supply for ITC apportionment; the Explanation to the input tax credit rules fixes the value of a security at 1% of its sale value, and redemption of mutual fund units is treated as a sale for this limited valuation purpose, requiring proportionate ITC reversal where common inputs serve both taxable operations and such investment transactions.

GST extended-period proceedings require show cause notices to allege and disclose fraud or wilful misstatement.
Extended limitation under GST is available only where the tax shortfall is "by reason of" fraud, wilful misstatement or suppression to evade tax; these are jurisdictional facts. Show cause notices must allege such conduct and disclose the material basis for that inference, and must specify proposed amounts without language of final determination. Invocation of extended limitation without these ingredients vitiates proceedings and precludes remand; authorities may pursue recovery under the normal limitation where applicable.

Benami property orders grounded on a recalled precedent must be re-adjudicated without treating that precedent as binding.
The Tribunal held that where an adjudicatory order under the PBPTA is substantially founded on a Supreme Court judgment that has been recalled on review, that order cannot stand; the correct remedial course is to set aside and remit for de novo adjudication so the Adjudicating Authority may re-examine evidence and apply the law without treating the recalled Ganpati Dealcom decision as binding on the question of the amendments' temporal applicability.

Transition of cess credits: abolished cess balances are dead credits, not eligible for GST transition or cash refunds.
Unutilised Education Cess, Secondary & Higher Education Cess and Krishi Kalyan Cess balances whose utilisation was limited to the same cess and whose levies were abolished became dead CENVAT credits; they were not eligible for transition under the exhaustive list in Section 140 and its Explanations, and Section 142(3) only prescribes payment in cash where refund is otherwise due under existing law, not a new substantive right to refund or a means to evade pre GST limitation.

Bank account freezes: limited temporary freezes permitted on reasonable suspicion, with strict notice, review and three month cap.
A narrow implied power exists for banks to impose a temporary debit freeze without prior notice when there are reasonable grounds to suspect use of an account for money laundering or cyber fraud; this power must be exercised with same day communication to the accountholder, mandatory intimation to investigative authorities with proof, a one week window for accountholder explanation and bank decision, and a maximum three month continuation absent directions from competent authorities, after which the freeze must be lifted and access to the credit balance restored.

Section 143(2) notices not following CBDT formats invalidate ensuing scrutiny assessments; computer generation does not cure the defect.
A scrutiny notice that does not conform to CBDT-prescribed formats-specifically by failing to specify whether selection is for limited, complete, or compulsory manual scrutiny-is not a valid jurisdictional notice; non compliance with the binding CBDT Instruction vitiates the Assessing Officer's authority and renders any consequent scrutiny assessment void ab initio. Computer generation of the notice does not cure the defect. A pure legal challenge to such notice validity may be admitted at the appellate stage where no new facts are required.

Imported petroleum product: partial testing and non categorical reports cannot sustain classification as high speed diesel under tariff rules.
Classification requires evidence addressing all IS 1460:2005 parameters or, where full conformity is lacking, a Rule 4 "most akin" analysis showing closest resemblance among candidate headings based on reliable, reasoned laboratory results and expert opinion; partial testing or non categorical reports do not suffice to support penal or confiscatory measures.

Aircraft leases with no purchase option and retained lessor title remain operating leases, not interest-bearing financings.
Where aircraft lease documentation preserves legal title in the lessor, imposes a return obligation without any purchase option or residual-payment mechanism, and regulatory treatment aligns with operating-lease norms, the arrangement constitutes an operating lease; absent an enforceable transfer of ownership to the lessee at term end, lease rentals cannot be re-characterised as interest for treaty purposes merely because of lease tenure or finance-like pricing.