Consequential assessments made solely under revisional directions cannot survive once the underlying revisional order is quashed, because they have no independent jurisdictional basis. Interest on fixed deposits and loans is assessable as business income where the funds arise from real-estate development operations and are temporarily deployed pending project use. On that basis, brought-forward business losses may be set off against such interest income. The appellate relief treating the interest receipts as business income and invalidating the consequential assessment was sustained.

Notional usage charges for premises occupied by a sister concern are not taxable as income from other sources without evidence of actual receipt or enforceable accrual. Where an arrangement is implemented through reimbursement of common costs rather than stipulated usage charges, related expense treatment must reflect the actual income position. Expenditure wholly and exclusively incurred to earn income from other sources is deductible, while building-related expenses may be restricted to the area producing actual rental income assessable under house property. Trade incentives and brand-promotion costs incurred in the ordinary course of business remain revenue expenditure despite incidental brand benefit. Depreciation on moulds and dies is available where their use in manufacturing packaging containers establishes that the assets were put to use.

Section 56(2)(x) addition based on the difference between recorded purchase consideration and stamp-duty valuation cannot be sustained where the purchaser specifically disputes the stamp-duty value and seeks referral to the Departmental Valuation Officer. Distinct valuation characteristics of a basement and ground floor required consideration. Mechanical adoption of the stamp-duty value, without a reasoned determination of the objections or a valuation reference, rendered the addition unsustainable; it was deleted in favour of the assessee.

Failure to obtain a tax audit does not attract penalty where reasonable cause is established under the Income-tax Act. Bank deposits representing milk-pouch sale proceeds did not constitute the taxpayer's income where only commission or trade discount was returned as income. Acceptance of the returned commission income in reassessment, coupled with the explanation and supporting material for non-audit, supported deletion of the penalty for failure to obtain tax audit.

Credit for tax deducted at source reflected under an assessee's PAN may extend to the full deduction where jointly earned rental income is divided among co-owners, the other co-owners have offered their shares to tax without claiming credit, and they support the claim. Although Rule 37BA(2)(i) prescribes declaration and reporting conditions for allocating credit to a person other than the deductee, denying the unclaimed balance would leave tax retained without any claimant. Procedural requirements should advance substantive justice; accordingly, full TDS credit is available to the PAN holder.

Substantial delay in filing an appeal may be condoned where cumulative circumstances establish sufficient cause; delay duration alone is not determinative. Personal difficulties, COVID-19 disruption, portal glitches, the complexity of a foreign tax credit claim, availability of Form No. 67, and efforts to resolve the tax demand supported condonation and revival of the appellate remedy. Foreign tax credit for German taxes on stock-option income requires substantiation and examination under applicable law and the India-Germany double taxation arrangement. Credit is allowable only proportionately to Indian tax attributable to that income, subject to fresh verification and grant of admissible credit.

Stay conditions requiring payment of part of a disputed tax demand must be supported by reasons under the applicable guidelines. Where an office memorandum requires evaluation of specified parameters before fixing stay terms, authorities must explain why a deposit condition is retained even when most of the demand is stayed. An order staying most of the demand while requiring payment of the balance without disclosed reasons warrants reconsideration. The stay application should be restored for an expeditious, reasoned decision after giving the assessee an opportunity of hearing.

Withdrawal of the show cause notice rendered the dispute over withdrawal of the advance ruling application, abeyance of departmental proceedings, CBDT Circular compliance, Assessing Officer jurisdiction and Article 226 writ relief academic. The special leave petitions were dismissed because no issue remained for consideration after the notice was withdrawn.

Semi-detergent oil-base and detergent soap bars/cakes used to remove stains and deodorise clothing are classified as laundry soaps under HSN 34011942. Classification depends on the products' composition, form and stated use, including their substantial filler content and absence of features associated with soaps designed for washing the body, hands or face. A definition of "toilet preparation" in legislation enacted for another purpose does not control GST tariff classification. Applying common-parlance meaning and heading 3401, the products attract GST at 18% under Entry 66 of Schedule II to Notification No. 09/2025-Central Tax (Rate).

Offset-printing job work on Kraft Paper and Duplex Paper, including cutting, sorting, plate preparation, drying, finishing, quality checks and packing, constitutes a naturally bundled composite supply. Printing is the principal supply, so the entire service is taxed according to that principal supply. The concessional job-work rate for printing goods under Chapters 48 or 49 applies only where the goods processed attract central tax at 2.5% or nil. As Kraft Paper and Duplex Paper attract 9% CGST, the concession does not apply. The residual job-work entry therefore applies, resulting in GST at 18%.

Papad Khar is classified by its composition and functional character, not by its use in manufacturing papad. As a mixture containing sodium carbonate and sodium bicarbonate, it is neither salt under heading 2501 nor yeast or prepared baking powder under heading 2102; it falls under sub-heading 28362090 as an inorganic carbonate/bicarbonate preparation and attracts GST at 18%. Exemption available to papad does not automatically extend to its ingredients. Inputs and finished goods require independent tariff classification and must separately satisfy the relevant exemption entry. Papad Khar therefore does not qualify for the claimed GST exemption.

GST registration cancelled after three consecutive years of nil returns during non-business activity may be restored where financial and health difficulties genuinely explain the inactivity. Restoration is conditional on filing all outstanding returns and paying applicable tax, interest and late fees. Unutilised input tax credit cannot be applied towards these payments; it may be used only against future liability after departmental scrutiny and approval. The cancellation was revoked subject to compliance with these conditions.

Assignment by a lessee of its entire long-term GIDC leasehold interest in land and building to a third-party assignee constitutes a transfer of immovable property, not a supply of services. Where the assignor is fully divested of the rights and benefits attached to the leasehold property, the transaction differs from GIDC's original grant of lease, which is treated as a service. The assignment falls outside the scope of supply under Section 7(1)(a), read with Clause 5(b) of Schedule II and Clause 5 of Schedule III, and is not chargeable to GST under Section 9.

Effective service of GST show-cause notices requires more than portal upload where a taxpayer has not responded to repeated portal communications. In such circumstances, the proper officer should use other prescribed service modes under Section 169(1), preferably registered post, to ensure the taxpayer receives a meaningful opportunity to object. An ex parte assessment passed solely on portal service without a personal hearing provides inadequate opportunity and undermines fair adjudication. The assessment was set aside and remitted for fresh adjudication after receipt of objections and issuance of a clear personal-hearing notice.

GST appellate rejection for delayed filing and non-compliance with the mandatory pre-deposit requirement was set aside because alleged prior recoveries from electronic ledgers required verification. Fresh consideration on merits was directed, conditional on depositing 50% of the disputed tax in cash after adjustment of amounts verified as already recovered or paid. The taxpayer must also submit a reply supported by relevant documents. The remand therefore preserves appellate consideration only upon compliance with the stipulated deposit and documentary requirements.

Section 75(4) requires a personal hearing where the taxpayer requests one in writing or where an adverse decision is contemplated; a show-cause notice indicates such contemplated adverse action. The DRC-01 procedure envisages a distinct hearing, and failure to fix a hearing after the reply deadline cannot be justified where the reply and hearing request were available before assessment. Treating the reply as absent despite its filing demonstrates non-application of mind. An assessment issued without considering the taxpayer's reply and without granting the requested personal hearing is invalid.

Service of GST show-cause notices and orders-in-original requires compliance with the statutory modes under the CGST Act and Rules; mere upload in the portal's 'View Additional Notices and Orders' tab is insufficient. The retrospective amendment enabling functions under the Rules to be performed on the common portal does not expressly make portal upload a substitute for formal service. Upload may be effective where the taxpayer acknowledges receipt or participates by replying and contesting the proceedings. Without such acknowledgement or participation, ex parte adjudication based solely on portal upload cannot be sustained, and upload of a contested order alone does not commence the appellate limitation period.

GST adjudication challenges requiring factual and evidentiary appraisal, including objections to electronic evidence, forensic authentication, cross-examination and an earlier audit, must be pursued through the statutory appellate remedy. The appellate mechanism under the CGST Act permits reconsideration of both facts and law. Participation in adjudication through an authorised representative, attendance at the hearing and submission of a detailed reply undermine allegations of defective service, inadequate consideration or denial of effective hearing unless a patent natural-justice breach and resulting prejudice are demonstrated. Writ jurisdiction is ordinarily unavailable where an efficacious appeal exists, absent a jurisdictional error or another recognised exceptional circumstance.

Penalties under the Uttar Pradesh Goods and Services Tax Act, 2017 cannot exceed the statutory maximum where returns have been filed and applicable late fees paid. The aggregate penalty imposed beyond that limit was invalid. The penalty order and show-cause notice were quashed, resolving the issue in favour of the assessee.

Section 16(5) permits input tax credit for specified financial years where the Section 39 return was filed on or before 30 November 2021, notwithstanding the earlier statutory deadline. Input tax credit relating to financial year 2018-19, availed on 20 December 2019 after the then-applicable deadline, falls within this extended period and is admissible. The constitutional challenge to the input tax credit time-limit provisions was not pursued.