Closure of criminal proceedings cannot rest on an assumption that prosecution's purpose is satisfied where assessment and appellate orders have been partly set aside and remitted, leaving tax liability unresolved. Liability determined and discharged only after the closure order does not establish that it had been fully satisfied when closure was ordered. The closure lacked a sustainable basis and requires reconsideration by the Trial Court after taking account of subsequent developments.

A reassessment notice under Section 148 must be validly issued as a jurisdictional precondition to reassessment under Section 147. Section 159 permits proceedings to continue against legal representatives only when proceedings were initiated during the deceased assessee's lifetime; it does not cure or validate proceedings initiated by a notice addressed to a person already deceased. Where the legal heir objects to jurisdiction without participating in the proceedings, a notice issued after the assessee's death cannot be treated as a notice to that heir. The notice and any direction treating it as issued to the legal heir are void from inception and without jurisdiction.

Unsigned appeal memoranda are a curable procedural defect and should not ordinarily prevent adjudication of underlying tax disputes on merits. The High Court found that, although the assessee had failed to rectify the notified defect and was expected to exercise greater diligence, refusing restoration would make the Tribunal's default dismissals final without merits review. The Tribunal appeals were therefore restored, subject to payment of costs and rectification of the defects within the stipulated period, and were directed to be decided on merits.

Documented long-term gains from listed-share sales through recognised stock exchanges, supported by securities transaction tax, demat records and banking channels, cannot be treated as unexplained cash credits merely because of unusual price movements or concerns about intermediaries. The human-probabilities test remains evidentiary and does not replace positive, corroborated proof linking the taxpayer to unaccounted cash, operators or price manipulation; the gains retain capital-gain exemption. Where the underlying additions fail for lack of such evidence, related concealment penalties lack a basis. Reopening or reassessment founded solely on assessment findings that do not survive also cannot stand.

Validity of reassessment reopening under sections 147 and 151 was raised where approval or sanction of the competent authority was alleged to be absent or granted by the wrong authority. The scope of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA) and the relevance of issuance of notice within four years were also in issue. The Supreme Court dismissed the special leave petition because the special leave petition against the relied-upon judgment had already been dismissed.

Section 197 applications seeking a nil-rate withholding certificate for domain name registration charges under the India-USA DTAA must be decided on their merits, with due regard to treaty obligations rather than revenue targets. The Supreme Court declined to interfere with the High Court's ruling and dismissed the Special Leave Petition, leaving that ruling in force.

Kar Vivad Samadhan Scheme settlement scope concerns the conclusiveness of settlement and the bar on reopening a settled income-tax demand. The Supreme Court dismissed the Special Leave Petition, finding no reason to interfere with the High Court's order. The available material does not specify the High Court's reasoning or the precise legal effect of the order beyond the dismissal of the challenge.

GST exemption for services relating to admission or conduct of examinations is construed strictly and does not extend to affiliation, affiliation-processing, annual registration, or late-registration functions that are antecedent or administrative. Such fees are treated as taxable supplies. Circular No. 234/28/2024-GST confines "as is where is" regularisation to affiliation services and does not cover registration-related charges. Where GST was not separately collected, gross receipts require cum-tax valuation under Rule 35. Extended limitation under Section 74 requires proof of fraud, wilful misstatement, or deliberate suppression intended to evade tax; non-payment and a bona fide view on taxability are insufficient. Interest and penalties apply only to surviving, recomputed tax liabilities, not to time-barred or regularised demands.

Traceable e-wallet credits of quantified GST rate-reduction benefits satisfy Section 171 where they are unconditional, unrestricted, non-expiring, carry monetary value, and are linked to identified recipients and invoices. Automated labelling as "Offers and cashback" does not displace the substance of transaction-specific evidence establishing that the benefit reached eligible customers. Valid credits and accepted credit notes discharge the anti-profiteering obligation to the extent substantiated. An unreconciled residual not linked to any customer or invoice remains unpaid and must be deposited in the Consumer Welfare Fund with applicable interest. No penalty applies for the period preceding the penal provision.

Under the anti-profiteering framework, additional input tax credit must ordinarily be passed on through commensurate price reductions. Verified escalation in major construction-input costs may be considered where it demonstrably offsets that tax benefit. Where accepted additional construction expenditure exceeds the saving from additional input tax credit, the net savings are negative; deducting the cost escalation from the input tax credit saving is therefore appropriate. No profiteering arises in those circumstances, and there is no contravention of the pass-through requirement.

Retrospective operation of Section 16(5) of the CGST Act preserves input tax credit for eligible taxpayers who furnished returns by the stipulated cut-off date, notwithstanding the limitation in Section 16(4). Its non obstante clause gives the statutory entitlement priority over a notification-based rectification deadline. Where an assessment-order appeal had already been filed and decided before the amendment, the prescribed rectification mechanism does not apply. Input tax credit remains subject to satisfaction of other eligibility conditions.

Article 226 may be invoked exceptionally to prevent grave prejudice where the statutory GST appellate limitation cannot ordinarily be bypassed. Explained medical circumstances beyond the appellant's control justified setting aside dismissal of a time-barred appeal and restoring it for decision on merits. Restoration remained subject to payment of admissible late fees, penalty and statutory deposits. The limitation framework under the Rajasthan and Central GST laws continues to bind the Appellate Authority, while writ jurisdiction remains available only in exceptional circumstances.

Rule 86A(3) of the Tamil Nadu GST Rules provides that a restriction on use of input tax credit imposed under Rule 86A(1) automatically ceases after one year. Continued blocking of the electronic credit ledger beyond that period cannot be sustained, particularly where the Rule 86A prerequisites are not independently satisfied. Internal departmental communication cannot justify an extended restriction. Where recovery is warranted following assessment, it must proceed through the regular statutory recovery mechanism. The credit ledger must be unblocked after the one-year restriction expires.

Breach of natural justice permits writ relief against a tax-determination order despite an available and already-filed statutory appeal. A determination order that merely records the assessee's reply, position and documents without considering the contentions, and is passed without an opportunity of hearing, is vitiated. The appellate remedy does not require the assessee to be relegated to appeal where the challenged order suffers from these procedural defects; writ jurisdiction remains available.

Input tax credit under Section 17(5)(d) is blocked only where immovable property is constructed on the taxable person's own account, subject to stated exceptions. Construction intended for sale, lease or licence is distinguished from personal use or premises from which the taxable person conducts business; ownership and capitalisation alone do not determine the restriction. Recovery through electronic cash or credit ledger debits requires prior electronic intimation in Form GST DRC-01D under Rule 142B and expiry of the prescribed seven-day period. Debits made without that procedure require restoration to the corresponding electronic ledger.

Omission of Rule 96(10) of the Central Goods and Services Tax Rules, 2017, effective from 8 October 2024, applies for the benefit of assessees in all proceedings pending on that date. The removal of the restrictive provision must be given effect when processing challenges to show-cause notices, orders-in-original and consequential refund claims. Pending matters are therefore to be dealt with without applying the omitted restriction.

Reasonable cause under section 80 of the Finance Act, 1994 may protect an assessee from penalty where a bona fide and reasonable belief supports non-payment of service tax. Contemporaneous departmental communications supporting the view that the services were non-taxable can establish that reasonable cause. A finding that there was no wilful suppression of facts or intent to evade tax, particularly where the extended limitation period is unavailable, materially reinforces the absence of culpable conduct. On these grounds, penalty under section 78 was unwarranted and set aside.

Uploading a show cause notice solely under the portal's 'Additional Notice and Orders' tab, without separately informing the taxpayer, denied a meaningful opportunity to respond before adjudication. This breached principles of natural justice because the taxpayer remained unaware of the notice and could not present a defence. The show cause notice and resulting adjudication order were quashed. Fresh adjudication may be initiated only after issuing a fresh notice and affording an opportunity of personal hearing.

GST adjudication based on a show-cause notice uploaded only in the portal's "Additional Notice and Orders" tab, without separate intimation, denied the assessee an effective opportunity to reply. Such portal-only service, where it leaves the assessee unaware of the proceedings, violates principles of natural justice. The show-cause notice, adjudication order and consequential notices were quashed, with fresh adjudication permitted after issuance of a fresh notice and an opportunity of hearing.

Bail conditions requiring a security bond equal to alleged tax and penalty dues are addressed as potentially onerous and incapable of enforcement where an accused stands on the same footing as co-accused subject to an identical condition. Declared family assets may provide adequate security for the alleged dues. The prescribed approach is that the bond equivalent to the full alleged tax and penalty amount need not be insisted upon when assets disclosed by the appellant's mother are accepted as security.