Genuine hardship in delayed revised-return claims requires prima facie verification without converting condonation into final tax adjudication.
Section 119(2)(b) may permit admission of a delayed revised-return claim where expiry of the Section 139(5) period causes genuine hardship. Condonation removes only the procedural bar and does not establish exemption, refund, or interest entitlement. Genuine hardship requires assessment of bona fides, the nature of the omission, promptness after discovery, legal plausibility, and the consequence of refusal. Circular No. 9/2015 permits prima facie verification and inquiry, but substantive taxability and refund entitlement remain for merits examination.

TDS credit after verified deduction protects taxpayers from demands and refund adjustments caused by deductor default.
TDS credit in domestic deductor-default cases depends on verified actual deduction from the taxpayer's income, not solely on deposit, TDS statements, Form 16 or Form 16A, or Form 26AS reflection. Section 205 bars direct or indirect recovery, including refund adjustment, to the extent tax was deducted. The taxpayer must provide reliable payment-specific evidence, and the Assessing Officer must verify the claim while the Department proceeds against the defaulting deductor.

Timely reserved judgments: a three-month framework, transparency, and staged remedies protect liberty and require reasoned decisions.
Reserved High Court judgments are subject to a three-month framework for a reasoned pronouncement, supported by monthly monitoring, status disclosures, date-recorded certified copies, and automated notice to advocates. Urgent matters may receive an operative-part pronouncement, but reasons must be uploaded within seven days or, where practical difficulties exist, within fifteen days. Parties may seek early pronouncement after the specified period and, after further delay, request withdrawal and assignment for a fresh hearing.

Settlement-price depression allegations require cogent proof of manipulation, not merely short exposure, closing sales, or position-limit non-disclosure.
Settlement-price depression under the PFUTP framework requires cogent proof of a manipulative act, device, scheme or artifice, not merely a substantial short derivative position, closing-window sales, or an incentive to benefit from a lower settlement price. Position concentration and position-limit non-disclosure are distinct from PFUTP fraud. Sales below the last traded price require market-wide causal analysis of other trading activity, execution mechanics, benchmark methodology, commercial rationale, and actual price impact. A genuine hedge and agency-attributed exposure do not, without further proof, establish manipulation.

Foreign LTC tax exemption requires domestic travel; employers must deduct tax on known non-exempt travel reimbursements.
Foreign LTC/LFC payments for itineraries containing an overseas leg are outside the Section 10(5) exemption, which is confined to actual eligible domestic travel subject to Rule 2B shortest-route and fare conditions. Under Section 192, employers must include known non-exempt payments in estimated salary and deduct tax; they cannot disregard available claim records showing foreign or circuitous travel. A recovery restraint does not automatically suspend the deduction obligation. Section 201 recipient-compliance conditions, interest, and penalty based on reasonable cause require separate analysis.

Inverted-duty GST refunds remain available where higher-taxed component inputs, rather than only principal inputs, cause accumulated eligible credit.
Refund of accumulated unutilised ITC under an inverted-duty structure depends on a causal link between higher-taxed input goods and lower-taxed output supplies. The test is not restricted to the principal raw material; higher-rated component inputs may support a claim despite parity between the principal input and output. Refund remains confined to credit on input goods, excluding input services and capital goods. Rule 89(5) separately determines the maximum refundable amount through its turnover-based formula, subject to statutory exclusions and prescribed filing and verification requirements.

Mandatory goods-detention timelines bar delayed GST penalty orders despite administrative complications, while independently lawful proceedings may remain available.
Section 129(3) imposes two mandatory sequential deadlines: a penalty notice must be issued within seven days of detention or seizure, and the penalty order must follow within seven days of service of that notice. The service date, rather than reply, valuation or intervening events, controls the latter period. Administrative difficulty cannot extend either deadline. The framework also requires a hearing, while inspection reporting timelines and administrative forms remain distinct and cannot dilute the statutory time limits.

Input tax credit requires actual supplier tax payment, while reversal must rest on transaction-specific evidence and procedures.
Input tax credit under Section 16(2)(c) of the CGST Act is conditional upon actual payment of the tax charged on the supply to the Government. The condition is cumulative and is not replaced by the recipient's invoice, payment to the supplier, receipt of supply, return filing, or bona fides. Self-assessed credit is reversible with applicable interest where the supplier has not paid tax, but may be re-availed after subsequent supplier compliance. A bona fide-purchaser exception cannot be read into the actual-payment requirement, although any reversal or demand must rest on specific statutory facts, supporting material, and reasoned adjudication.

Vested appellate rights prevent later penalty-only pre-deposit conditions from burdening appeals arising from earlier commenced adjudication.
Substituted CGST pre-deposit requirement for penalty-only orders does not govern an appeal arising from a formal show-cause notice issued before 1 October 2025, absent express retrospective language or necessary implication. The right of appeal and its applicable conditions vest when the lis commences; a filing-stage deposit that bars institution is substantive, not merely procedural. Admitted amounts remain payable, while a mandatory applicable deposit cannot ordinarily be waived or reduced by the Appellate Authority.

Extended GST limitation requires show cause notices to plead fraud, wilful misstatement, or suppression through specific factual allegations.
Section 74 requires the notice itself to state the material facts supporting the precise statutory limb invoked and the causal nexus between that conduct and the alleged tax consequence. The phrase "by reason of" requires a pleaded connection; a tax discrepancy coupled with a conclusory allegation of fraud or suppression is insufficient. The notice should identify the relevant act, omission, representation, non-disclosure or device, explain why it is deliberate or wilful, and enable an effective response.

Omission of export-refund restriction requires pending integrated-tax refund claims to be assessed under surviving statutory and procedural conditions.
Omission of Rule 96(10), effective from 08 October 2024 without a saving clause, applies to integrated-tax export-refund proceedings pending on that date. Such claims are assessed without the former restriction concerning specified notification benefits because Section 6 of the General Clauses Act does not preserve an omitted subordinate rule. The omission does not remove independent requirements for zero-rated supplies, refund eligibility, export documentation, returns, limitation, verification, or the applicable Rule 96 and Rule 89 procedures.

Interim arrest protection cannot survive dismissal of anticipatory bail; GST arrest requires communicated authorisation, not merely a summons.
Interim protection from arrest is ancillary to a live anticipatory-bail proceeding and cannot subsist as a freestanding direction after an application is dismissed as not maintainable. Under the GST arrest framework, a summons does not by itself make the summoned person an accused or create a legally sustainable apprehension of arrest. Arrest depends upon the Commissioner's reasons to believe and an order authorising arrest. The Section 69 authorisation order must be communicated before arrest, enabling the affected person to pursue available remedies before personal liberty is curtailed.

Section 87A rebate may apply after special-rate computation of qualifying short-term capital gains, absent an express statutory exclusion.
Section 111A requires qualifying short-term capital gains to be taxed at the prescribed special rate, while section 87A operates as a rebate from income-tax computed on total income for an eligible resident individual under the applicable section 115BAC(1A) regime. Special-rate taxation governs computation and does not itself imply exclusion from the rebate. Unlike section 112A(6), section 111A contains no express provision reducing the rebate base by tax on qualifying gains. Eligibility depends on the statutory terms applicable for the relevant assessment year.

Extended GST limitation requires pleaded foundational facts linking alleged fraud, wilful misstatement, or suppression to tax evasion.
Section 74 permits extended GST limitation only where tax short payment, erroneous refund, or wrongful input tax credit arose by reason of fraud, wilful misstatement, or suppression of facts to evade tax. A mismatch or discrepancy alone is insufficient. The show cause notice must disclose foundational facts identifying the transaction, withheld or misstated material, deliberate conduct alleged, and its factual link to tax evasion. Audit objections or approaching limitation cannot replace the proper officer's independent satisfaction. Liability cannot be confirmed on grounds beyond those specified in the notice.

Transfer-pricing comparability requires turnover and related-party transaction filters to reflect functional, economic, and data-based reliability rather than fixed thresholds.
Transfer-pricing comparability under the transactional net margin method requires economically reliable uncontrolled comparables selected through functional, asset, risk, contractual and market analysis. Turnover is not a universal statutory threshold, but material scale differences may justify exclusion where they affect margins through brand value, intangibles, bargaining power or economies of scale. Related-party transaction tolerance should ordinarily be the lowest practicable level; a higher threshold requires a recorded finding that sufficient lower-related-party comparables are unavailable. Any re-determination and comparable selection must comply with statutory conditions, reliable data requirements and Rule 10B.

Make-available requirement limits treaty characterization of management and support payments as fees unless recipients gain independent technical capability.
Fees for technical services under Article 12(4) of the India-Singapore DTAA require more than managerial, technical or consultancy characterisation. The services must satisfy an additional treaty gateway, including making available technical knowledge, experience, skill, know-how or processes that enable the recipient to apply the technology independently. Advice, operational assistance, recurring support, training or business benefits do not alone establish transfer of technical capability. Where the DTAA is more beneficial than the broader domestic definition, the treaty limitation governs, subject to treaty-residence and documentation requirements.

Income-tax rebate may extend to short-term capital gains tax when total-income conditions under the new regime are met.
Under the pre-restriction statutory formulation, a resident individual taxable under section 115BAC(1A) and within the prescribed total-income ceiling is analysed as eligible for section 87A rebate against income-tax on total income, including tax on qualifying short-term capital gains under section 111A. Section 111A fixes the special-rate computation but contains no express rebate exclusion. The explicit exclusion for specified long-term gains in section 112A(6) supports this distinction. Later limiting language in section 87A must be applied according to the statutory period concerned.

Extended reassessment limitation permits reopening on qualifying book entries, independently of disputes over whether seized cash entries are assets.
Extended limitation under section 149(1)(b) may operate where books, documents or evidence reveal escaped income meeting the prescribed monetary threshold and represented as an asset, qualifying expenditure, or entries in books of account. These categories operate disjunctively; qualifying book entries may therefore provide an independent jurisdictional basis without resolving whether cash entries are assets. Handwritten and digital records may be treated as books where possession, control, corroboration, and attribution establish their nexus with the taxpayer.

Reassessment limitation requires exclusion of allowed reply time, followed by a finite statutory period for consequential notice issuance.
Under the former reassessment framework, the time or extended time allowed for responding to a Section 148A(b) show-cause notice is excluded when computing limitation for the consequential notice. If the period remaining immediately after that exclusion does not exceed seven days, the sixth proviso supplies a seven-day residual period. The Section 148A(d) order and reassessment notice form a linked statutory sequence and must be completed within the resulting limitation period.

Pre-cognizance hearing protects proposed accused in money-laundering complaints by making prior hearing essential before valid cognizance.
Section 44 of the PMLA removes committal to the Special Court but does not exclude the criminal complaint procedure incorporated through Sections 46 and 65. Section 71 gives priority to the PMLA only where an actual inconsistency exists. Where the BNSS governs cognizance, the first proviso to Section 223(1) requires a meaningful hearing for the proposed accused before cognizance. The safeguard is distinct from exemptions from complainant examination, is mandatory and substantive, and permits submissions on legal sufficiency and prima facie material without converting the stage into a merits trial.