GST taxpayer administration in Rajasthan is allocated between Central Tax and State Tax authorities to maintain a single interface for registered persons. Six previously unallocated taxpayers are assigned to either the Centre or the State according to the specified turnover categories. Taxpayers may verify their assigned authority through designated websites and report discrepancies or missing details to either authority for rectification by the State Level Committee.

GST registration cancellation appeals dismissed solely as time-barred may be restored where a genuine explanation establishes that non-compliance and delay arose from lack of awareness of online requirements and reliance on advisers who failed to act. Cancellation that brings business operations to a standstill supports consideration of the appellate remedy on merits. The appellate authority must entertain and decide the appeal in accordance with law, subject to payment of applicable late fee, penalty and other statutory deposits.

Fresh GST proceedings under Section 74 may be initiated within two years from communication of an earlier writ order that quashed a prior notice while expressly permitting fresh action, provided fraud, wilful misstatement or suppression of facts to evade tax exists. Section 75(3), read with that binding direction, preserves the period for consequential adjudication; an earlier dropped Section 73 notice does not bar the fresh proceedings. However, a show cause notice containing unnecessary accusations that the taxpayer misled the Court demonstrates prejudgment and breaches the requirement of neutral adjudication. Such a notice must be set aside, with any fresh action undertaken by a different officer.

Jurisdiction over a GST waiver application arising from a combined demand order was not defeated merely because part of the operations concerned another State. Sections 79 and 128A refer to the relevant proper officer, but neither the recovery provision nor the GST Rules prescribe a basis for identifying that officer in this situation. Rule 164 contemplates a single waiver application in Form GST SPL-01 or GST SPL-02 rather than multiple applications. Where one officer issued a combined demand order covering Chennai and Maharashtra operations, no statutory basis existed to refuse jurisdiction over the Maharashtra waiver claim. The rejection of that limited claim was set aside and remanded for fresh consideration after reasonable opportunity.

Duplicate assessment orders arising from the same GSTR-3B and GSTR-1 return mismatch cannot coexist where both concern the same assessment period and identical tax liability. The later order was quashed because it duplicated the earlier assessment, notwithstanding the absence of an SGST-CGST bifurcation. The earlier assessment order was set aside and remanded for fresh consideration to provide a reasonable opportunity to contest the tax proposal on merits. That remand was conditional on payment of the entire tax demand within the stipulated period.

Section 128A permits waiver of interest and penalty where proceedings under Section 73 determine unpaid or short-paid self-assessed tax; direct recovery under Section 79 without Section 73 proceedings does not support a waiver application. Circular No. 238 cannot narrow that statutory scope. Rule 164 limits voidness of an approved waiver in Form GST SPL-05 or GST SPL-06 to specified failures to make additional payment; authorities lack power to issue void orders outside those circumstances. Rule 164 creates mandatory filing and disposal timelines. Failure to decide within the prescribed period may result in deemed approval, subject to fulfilment of Section 128A, whereas late applications or late payment cannot be cured through substantial compliance.

GST recovery for a deceased proprietor's dues cannot be pursued against a private limited company that is legally distinct from the proprietary concern; Form GST DRC-13 notices attaching the company's bank account were therefore quashed. Adjudication against the deceased proprietor's family members required examination of the statutory conditions governing liability on a taxable person's death under Section 93(1)(a) and 93(1)(b) of the CGST/KGST Act. Because those material circumstances were not considered, the adjudication orders were quashed and remitted for fresh consideration after the family members may respond to the show-cause notices on all available grounds.

Discrepancies between export turnover reported in Forms GSTR-3B and GSTR-1 require a registered taxable person to receive an opportunity to produce documents establishing the nature of the transactions and substantiating export turnover. Where non-participation in GST adjudication is explained and applicable Board Circulars contemplate such documentary verification, an ex parte determination may require fresh consideration. The appellate rejection based on inability to condone delay beyond 120 days and the adjudication order were quashed, with the proceedings restored for reconsideration after production of supporting documents and issuance of a reasoned order.

For limitation purposes, a dealer's declared date of communication of an adjudication order must be treated as the actual communication date unless the Revenue rebuts it with cogent material. Treating the order date itself as the communication date, despite an unrebutted assertion of later receipt, cannot justify dismissal of the statutory appeal as time-barred. The appellate order was quashed, and the appeal was remitted to the appellate authority for fresh consideration after hearing the parties.

The eighteen-month period for an Interim Board to dispose of a pending settlement application runs from its first allotment to, and action by, an Interim Board. An administrative transfer to another Interim Board does not restart or extend that limitation, because repeated transfers would undermine the statutory time-bound settlement framework. Exercise of the power to call for a report indicates that the application had already been allotted to and was within the first Interim Board's jurisdiction. The limitation period is mandatory; settlement and consequential rectification orders made after its expiry are time-barred and void. Questions concerning abatement and its consequences remain open.

Reassessment under the amended scheme may be initiated where portal information links transactions to an assessee's PAN, provided the material is relevant and the assessing authority applies its mind to objections. Detailed reasons to believe are not required at the initiation stage. A GST communication does not bar an independent income-tax enquiry where identity theft has not been conclusively established. Reassessment may therefore continue, while the identity-theft defence remains open for examination. Although the assessee must substantiate that plea with evidence, the Revenue must first establish through positive primary evidence that the disputed transactions were undertaken by the assessee rather than another person.

Discounted Cash Flow valuation of shares issued by a newly incorporated company was recognised as a valid method for section 56(2)(viib) purposes, even before its later notification under Rule 11UA. Recognition by valuation professionals was distinguished from legislative notification, and the Net Asset Value method was considered unsuitable for a newly incorporated company. Although the valuation rule used mandatory language, the Assessing Officer was required to identify defects in the valuation report or methodology and could not replace projected returns with an independent estimate. Procedural valuation rules could not defeat substantive rights without a substantial legal breach. The share-premium addition was deleted and that deletion was affirmed.

Internal CUP was treated as the most appropriate method for determining the arm's length price of project-office transactions under a turnkey power-project contract. Where the Indian project office bore the contract's risks and rewards, all revenue was attributed to India, and the unrelated customer regarded the head office and project office as one entity, the contract with that customer satisfied the comparability requirements for an internal CUP. CUP was preferred over TNMM as a more direct and suitable method, while the proposed TNMM comparables were rejected. The transfer-pricing adjustment was consequently not sustained, and the appeals were dismissed for lack of a substantial question of law.

Section 264 provides beneficial and remedial revisional relief against over-assessment, including errors in a taxpayer's return. Relief is not dependent on filing a revised return within the prescribed time or on whether the error arose from the taxpayer's voluntary action or a departmental order. Taxing the same income in two assessment years can create an over-assessment where the combined effect of the relevant orders results in double taxation. A revisional authority must examine the claim and reconciliations on their merits rather than reject relief solely because an intimation accepted the returned income in isolation.

Charitable registration under section 12AB depends on the predominant purpose, the manner of carrying on activities and application of income; incidental fees for public facilities, medical relief, poverty relief, education or skill development do not by themselves establish a commercial purpose. Rent paid to a trustee's related person for premises with mixed residential use does not alone make activities non-genuine without material showing fictitious or excessive rent or return of funds. Expenditure reasonableness and compliance with sections 11 to 13 ordinarily remain assessment issues. CBDT's extended Form 10AB deadline allowed section 80G approval applications filed within the relaxation period.

MAT book-profit computation under section 115JB does not permit adding back expenditure disallowed under section 14A merely because it relates to exempt income. The Special Bench ruling in Vireet Investment establishes that section 14A disallowance is not an adjustment to book profit. Explanation 1 to section 115JB(2) exhaustively specifies permissible additions and does not include demerger expenditure disallowed under section 35DD in the regular tax computation. Consequently, neither the section 14A disallowance nor the section 35DD disallowance is added back while computing MAT book profit.

Eligible CSR donations qualify for deduction where they are made to institutions covered by section 80G and are not contributions to Swachh Bharat Kosh or Clean Ganga Fund. Explanation 2 to section 37(1) prevents CSR expenditure from being claimed as business expenditure, but does not bar relief under other provisions. A statutory CSR obligation does not remove a payment's character as a donation when an eligible mode is voluntarily selected; the deduction was therefore granted. Dividend distribution tax on dividends paid to a UK holding company is limited to the beneficial rate under Article 11 of the India-UK tax treaty. Tax retained above that rate was required to be refunded.

Tax deduction at source on foreign-travel leave fare concession was not required where judicial interim directions prevented the employer-bank from making the deduction. The bank had sufficient and reasonable cause because it could not lawfully act contrary to those directions. Consequently, the conditions for treating it as an assessee in default and imposing consequential interest for non-deduction were not met. The demand raised for default and interest was cancelled, and the bank was not liable for the impugned non-deduction during the subsistence of the interim directions.

Reassessment based on search-related information may be initiated under reassessment provisions where the Assessing Officer also relies on independent enquiries into transactions with an alleged entry provider, rather than on search material alone. Approval for the reassessment notice was treated as procedurally valid and non-mechanical, and the challenge to reassessment failed. Where sales are accepted but purchases from an alleged accommodation-entry provider remain unverifiable, the entire purchase amount need not be disallowed, particularly where the relied-on statement was retracted. The addition was confined to the profit element reflected in the taxpayer's gross-profit position, fixed at 6% of the disputed purchases. The appeal was partly allowed on the quantum of addition.

Reasonable cause was established for cash receipts from farmers and subsequent cash repayments connected with a proposed agricultural-land purchase that could not be completed after the purchaser's father died. Bank records, the death certificate, affidavits and farmers' land records supported the explanation that the amounts were returned after six months. Penalties for contraventions of the statutory restrictions on accepting and repaying loans or deposits in cash were deleted, and the penalty orders were set aside.