Two-zero decoding of figures on pages 4 and 5 of Annexure B-3 was supported by the equipment costs, withdrawals, cash position and capital investment, while a one-zero decoding lacked an equivalent factual basis. The resulting undisclosed-profit addition was restored on that basis. Entries in Annexures B-1 and B-2, apart from those pages of Annexure B-3, had already been assessed in the firm's hands. As the individual assessee lacked the financial capacity to undertake transactions of the reflected scale, additions for unexplained investment and undisclosed profit in the individual assessment remained deleted.

Registrar of Companies fees paid for increasing share capital qualify for amortisation under section 35D(2)(c)(iv) of the Income-tax Act. Expenditure connected with the issue of shares and public subscription is not confined to the specifically listed underwriting commission, brokerage, or prospectus-related charges. The comma after "issue" supports a broader reading that includes fees incurred for issuing share capital. Issuance of shares to a holding company does not affect eligibility. The expenditure is therefore allowable for amortisation.

Section 260A confines appellate review of factual findings to instances of perversity, absence of supporting evidence, or legal error. Rejection of books of account under Section 145(3), when founded on seized material and affirmed after appraisal of records, remains a factual determination not subject to reassessment merely because a different view is sought. Consequential income estimation and acceptance or restriction of fee-refund credit similarly remain factual matters unless a substantial question of law arises. Fee-refund relief falls within the Tribunal's determination where the Revenue challenges related addition relief and the assessee contests the sustained addition through a cross-objection.

CBDT Circular No. 11 of 2020 concerning residential-status consequences for Indian seafarers unable to leave India during the COVID-19 pandemic was challenged, alongside a request for a compassionate tax policy granting exemption where their Indian stay exceeded 182 days in a financial year. The respondents were asked to consider the representations sympathetically, with reference to specified judicial decisions, and to take an appropriate decision within four weeks.

GST exemption for psyllium seeds as fresh or chilled goods depends on their condition at the time of supply. Raw psyllium seeds classified under Heading 1211, when stored in dry and ventilated godowns and supplied without evidence preserving their fresh condition, are treated as dried rather than fresh. Consequently, they cannot claim the fresh-seeds exemption or the exemption for goods of seed quality. Dried psyllium seeds under Heading 1211 fall under the applicable rate entry and attract GST at 5%. The decisive principle is that a conditional fresh-goods exemption is tested at supply, not by the goods' condition when procured from farmers.

Section 112(2) of the CGST/UPGST Act, 2017 is invoked in a departmental GST appeal concerning a low disputed tax-and-penalty amount. The appeal challenged the first appellate authority's decision, but the grounds were considered insufficient to warrant admission for merits review. The provision is treated as supporting summary disposal where the disputed amount is low and no substantial challenge to the impugned order is identified. The matter therefore concerns the admission-stage treatment of departmental GST appeals involving limited tax and penalty disputes.

Detention and penalty for alleged reuse of e-way bills require an established contravention supported by cogent evidence. Where goods match the accompanying invoices, e-invoices and e-way bills in description, quantity, value and ownership, a vehicle's second verification on the same day does not by itself prove that the goods were previously delivered or re-transported. An undisproved repair bill and driver's explanation cannot be displaced by suspicion alone. In the absence of independent evidence of e-way bill reuse or intent to evade tax, detention and penalty proceedings are unsustainable, and the deposited amount is refundable in accordance with law.

Detention and penalty for alleged e-way bill reuse require cogent evidence of a completed earlier transport, delivery of the same goods, and intention to evade tax. Where goods are accompanied by a valid invoice, e-invoice and e-way bill, and no discrepancy exists in their description, quantity, value or ownership, an inference drawn merely from prior e-way bill verification and a later vehicle location is insufficient. Suspicion and presumptions cannot establish reuse of an e-way bill, GST contravention or tax-evasion intent; detention and penalty proceedings are therefore unsustainable.

A petition concerning a show-cause notice was disposed of with liberty to submit a reply and supporting documents. The competent authority must thereafter proceed in accordance with law after affording a reasonable opportunity to the petitioner.

Regular bail was granted in allegations of fraudulent availment and passing of input tax credit. Although further investigation into the alleged larger conspiracy remained pending, the complaint had already been filed. Continued custody, parity with a co-accused who had obtained bail, and the likelihood of a lengthy trial supported release. Bail was made subject to furnishing a personal bond and surety.

Principles of natural justice require an effective opportunity to respond to a show-cause notice before adjudication. Uploading the notice solely under the portal's "Additional Notice and Orders" tab, without separate intimation, prevented a response and hearing and breached that requirement. The limitation-based appellate rejection, underlying adjudication order, and consequential bank attachment were quashed. Fresh adjudication on the appeal grounds was directed after affording a hearing.

Detention of goods for alleged reuse of an e-way bill requires cogent evidence that the same goods had completed an earlier journey and that the e-way bill was reused. Where goods are accompanied by an invoice, e-invoice and e-way bill, with no discrepancy in description, quantity, value or ownership, an earlier vehicle verification or location alone cannot establish re-transportation. Contravention of GST law and intention to evade tax cannot be presumed from suspicion; the department must prove both by independent evidence. On these facts, the detention and penalty proceedings were set aside, and refund of the deposited amount was directed in accordance with law.

Alleged reuse of an e-way bill cannot justify detention and penalty where the goods are supported by an invoice, e-invoice and e-way bill without discrepancies in description, quantity, value or ownership. Re-transportation must be established by independent, cogent evidence that an earlier journey was completed or the goods were delivered; an inference from prior e-way bill verification alone is insufficient. Intention to evade tax cannot be presumed from suspicion, and the alleged falsity of a vehicle-repair bill must also be proved. The detention and penalty orders were set aside, and refund of the deposited amount was directed in accordance with law.

Psyllium seeds fall under tariff sub-heading 1211 90 13 within Heading 1211. GST exemption for fresh or chilled seeds depends on the goods' condition when supplied, not on processes before procurement from farmers. Storage in dry ventilated godowns constitutes drying, and absent evidence that the seeds remained fresh from harvest through onward supply, they cannot be treated as fresh or chilled. The supplies therefore fall under the rate entry for dried goods and are taxable at 5%. Exemption claimed for goods of seed quality is also unavailable on that classification.

Tax-residency relief for Indian seafarers unable to remain outside India during the COVID-19 pandemic was sought through quashing CBDT Circular No. 11 of 2020 and adoption of a compassionate tax policy. The proposed policy would grant at least sixty days' exemption to seafarers who spent more than 182 days in India during a financial year. Representations were directed to receive sympathetic consideration, with an appropriate decision requested within four weeks, without examination of merits.

Section 260A confines High Court interference with Tribunal findings on rejection of books, income estimation and fee refunds to cases of perversity, lack of evidentiary support or legal error. Where seized material, account books and submissions require factual examination, alternative computations do not themselves create a substantial question of law. Once books are rejected, income and allowable fee refunds may be determined by estimation. The Tribunal may examine the basis and extent of fee-refund relief when the Revenue challenges that relief and the assessee files a cross-objection concerning the sustained addition; this remains within its appellate jurisdiction.

Fees paid to the Registrar of Companies for increasing share capital through shares issued to a holding company qualify for amortisation as preliminary expenditure. The provision covers expenditure incurred in connection with the issue of shares; it is not confined to expenses relating to a public subscription. The enumerated expenses are descriptive, and the comma after "issue" prevents a restrictive reading that would exclude Registrar fees. Accordingly, disallowance of the claimed amortisation was unsustainable, and amortisation of the share-capital issue fees was allowed.

Numerical entries in seized records may be read by appending zeros only where the interpretation is supported by the nature of the entries and surrounding material. The High Court restored the addition based on the Commissioner (Appeals)' reasoned interpretation of pages 4 and 5 of Annexure B-3, holding that the Tribunal could not append a single zero after rejecting larger multipliers without reasons. Additions for unexplained investment and undisclosed profit from other rough-diamond entries were deleted because those transactions had already been considered for taxation in another entity's assessment and the assessee lacked financial capacity to conduct the business independently. Revenue appeals were partly allowed.

Revisionary jurisdiction requires both an erroneous assessment order and prejudice to Revenue. It cannot be exercised merely because the revisionary authority considers that the Assessing Officer should have made further or different inquiries. Where the assessee disclosed material supporting indexed cost of acquisition and cost of improvement, and the Assessing Officer considered the explanation before accepting the claim, the assessment reflects a conscious view. Revision cannot therefore substitute the revisionary authority's opinion for the Assessing Officer's considered decision on the disclosed material.

Revision of an assessment for lack of inquiry requires an erroneous and prejudicial order, not merely a different view of matters examined during scrutiny. Where the Assessing Officer made inquiries into depreciation on fixed assets, commission paid to a non-resident, and deductions for employing new workmen, and applied mind to the responses, revision was not sustainable. The Principal Commissioner had identified neither a flaw in the assessee's replies nor a specific defect in the prescribed audit report. The revision order was quashed, and the tax appeal was dismissed because the Tribunal's findings disclosed no legal infirmity.