Fresh Isabgol seed exemption depends on the condition of psyllium seeds when supplied. Psyllium seeds classified under tariff item 1211 90 13 qualify for the heading 1211 exemption only if fresh or chilled; intentionally dried goods attract 5% GST. Procurement through APMC auctions and storage in dry, ventilated godowns were treated as drying, while no evidence established that the seeds remained fresh between harvest and onward supply. Consequently, the supplies do not qualify for the exemption for fresh Isabgol seeds and are taxable at 5%.

GST on processing brass statues and qualifying wooden handicrafts is 5% where goods belong to a registered recipient and the finished goods are predominantly handmade by craftsmen; processing goods of an unregistered person falls under the residual service entry at 18%. Commercially cast or moulded resin statues and ornamental vases are plastics articles, classified under tariff items 3926 40 29 and 3926 40 99 respectively, rather than as original sculptures under heading 9703. Marble and wooden idols of a god or goddess are GST-exempt from 22.09.2025; the exemption excludes decorative non-deity figures and does not depend on a particular eight-digit tariff classification.

Mandatory pre-movement E-Way Bill generation under Rule 138(1) applies to taxable goods exceeding the prescribed consignment value. Absence of the E-Way Bill at interception is treated as substantive non-compliance because online generation is a statutory mechanism for monitoring goods movement; later production does not cure the lapse. A short inter-State route, the nature of the goods, post-interception generation, and repetition of the lapse may collectively indicate an intention to evade tax rather than a technical or procedural error. On those facts, detention, tax and penalty provisions may be invoked.

E-way bill compliance applies to movement of goods, including movement otherwise than by way of supply, unless a specified exemption is satisfactorily established. Transporting an owned excavator back to registered premises under a delivery challan does not, by itself, remove that requirement. A claimed short-distance exemption must be supported by evidence of its applicability. Absence of evidence on consideration received for use of the excavator and corresponding GST treatment, combined with transport without an e-way bill, supports an inference of intent to evade tax rather than a merely procedural lapse. Penalty for the movement was therefore justified.

Assessment procedure requires separate notices and separate adjudication for each distinct tax period; a single composite assessment covering multiple financial years is unsustainable. Assessment and accompanying summary orders must be signed to have legal efficacy, and unsigned orders are ineffective. Fresh determination must therefore proceed tax period by tax period, with an opportunity of hearing for each period. The stated framework makes fresh adjudication conditional on deposit of 20% of the disputed tax within the stipulated period.

Ex parte GST adjudication may be set aside where the assessee was unable to answer a show-cause notice because of health grounds and the accountant's hospitalisation. Dismissal of the statutory appeal solely as time-barred, without examination on merits, does not displace the need for a fair opportunity where sufficient circumstances explain non-participation. Natural justice required restoration to the adjudicating stage, allowing the assessee to file a reply, produce supporting material and receive a hearing before fresh consideration.

Bail in an alleged fraudulent input tax credit prosecution was justified where the maximum punishment was five years, custody had continued for about four months, and the accused had no criminal antecedents. Predominantly documentary evidence and the absence of material suggesting witness influence, evidence tampering, absconding, or non-participation in trial weighed against continued pre-trial detention. The principles that bail is the rule, innocence is presumed, and Article 21 protects the right to a speedy trial supported release where early completion of trial was unlikely.

Presumptive taxation of an ordinary business and separate reporting of a futures and options trading loss are considered for ITR-3 filing. The issue is whether business turnover may be offered under the presumptive taxation scheme while futures and options activity is treated as a separate normal business and its loss is disclosed independently, without a tax audit. The query also concerns the relevance of digital futures and options transactions to tax-audit applicability.

Regular bail assessment focused on completion of investigation, filing of the charge sheet, custody duration, and parity with a co-accused who had obtained bail. Relevant considerations included the strength of the prima facie case, the applicant's availability for trial, the risk of absconding, and the possibility of witness tampering. Release was considered appropriate where these factors supported bail, subject to conditions ensuring attendance at trial and preventing interference with the proceedings.

Restoration of an appeal dismissed for failure to comply with mandatory pre-deposit requirements and repeated non-appearance requires a credible, substantiated sufficient cause. Receipt of Registry communications requiring proof of pre-deposit, failure to cure the defect, and absence on listed dates weighed against restoration. Technical payment difficulties, the COVID-19 period, management changes, and alleged late knowledge of dismissal did not adequately explain the prolonged delay, particularly where professional representation had filed the appeal and Tribunal orders were publicly accessible. Restoration was denied.

Limitation for filing appeals against Orders-in-Original depends on the actual date of communication, not merely the date on which the order was issued. Where delivery before the assessee's asserted receipt date is disputed, the Department must establish service rather than presume communication from issuance. Verification by field formations, after giving the assessee an opportunity to present its position, is required to determine whether the appeals were time-barred. The limitation question was remitted for fresh determination based on the verified communication date.

Revenue appeals before CESTAT are subject to the National Litigation Policy's prescribed monetary threshold. Where the revenue involved is below that threshold, the appeal is not maintainable for litigation purposes and is dismissed without examination of the underlying merits. The stated appeal involved revenue below the applicable threshold and was consequently dismissed.

TDS credit may be allowed where a cash-basis taxpayer reconciles brought-forward and carried-forward credits with Form 26AS entries for the relevant assessment years. Where professional income has been offered to tax and the payer has deducted tax from payments but failed to deposit it with the Government, Section 205 of the Income-tax Act precludes a direct tax demand against the recipient to the extent of tax deducted. Denial of credit in those circumstances would impose tax on income from which tax has already been withheld.

Section 153C assessment of a person other than the searched person requires the six-year assessment block to be reckoned from the date satisfaction is recorded. Assessment years outside that block are invalid unless the relevant amendment is shown to apply. A satisfaction note must also establish that seized documents pertain or relate to the third person; describing documents as "belonging to" that person does not satisfy section 153C(1)(b), as that expression concerns specified assets. Failure on either jurisdictional requirement renders the assessment unsustainable.

Sale-of-goods arm's length price adjustment requires fresh determination where filed transfer-pricing documentation was not considered, because it is material to benchmarking and the taxpayer's functional profile; the adjustment was set aside for reconsideration. Notional interest on associated-enterprise trade receivables cannot be computed in isolation where interest-free trade payables coexist. Computation must account for both receivables and payables and their respective outstanding periods; the interest adjustment was set aside for recomputation. Both transfer-pricing matters require determination on a complete factual record.

Registration under the Rajasthan Public Trust Act, 1959 remained pending when the application for registration under section 12AB was considered. Evidence concerning the genuineness of the assessee's activities also required submission and evaluation. The application was restored for a fresh decision in accordance with law after obtaining the relevant trust registration and producing supporting material. No view was taken on substantive eligibility for section 12AB registration. The section 80G appeal was treated as consequential to the fresh determination.

Approved insolvency resolution plans that expressly extinguish tax payables and receivables for periods before their effective date preclude subsequent survival of those claims. A tax adjustment or disallowance relating to the pre-effective-date period cannot be sustained where it falls within liabilities extinguished by the plan. Tax dues and receivables incorporated into the approved plan likewise cease to survive for that period. The operative effect is to bar pre-effective-date tax claims, including disallowances connected with extinguished liabilities.

Limitation for a final assessment order following Dispute Resolution Panel directions runs under Section 144C(13) from the end of the month in which those directions are received. Upload of the directions to the departmental portal gave the Assessing Officer immediate access and triggered the limitation period; internal processing or delayed viewing could not postpone it. Directions uploaded on 30 September 2024 therefore required completion by 31 October 2024. The final assessment order dated 7 November 2024 was consequently time-barred and struck down in favour of the assessee.

Section 271AAB treats income admitted during a search as undisclosed income where the taxpayer specifies the manner in which it was derived, declares it in the return, and pays the related tax. A substantially higher net-profit rate than in preceding years may support the conclusion that the income would not have been voluntarily disclosed without the search. Where these statutory conditions are met, penalty at the prescribed 10 per cent rate is sustainable.

Tax deducted at source reflected in Form 26AS should not be denied merely because it was omitted from the return of income, where the tax was deducted and deposited on the assessee's behalf and the corresponding income was offered to tax. Rule 37BA should not be applied rigidly to defeat a genuine credit claim; procedural requirements yield to substantive justice. Retaining deducted tax beyond the lawful liability may constitute unjust enrichment and conflict with Article 265. Credit must be granted after verifying entitlement and corresponding income, with refund interest under Section 244A where applicable.