Consideration for live telecast rights in a composite cricket media-rights agreement is not royalty because a live sporting event is not a pre-existing copyrighted work and no copyright is transferred. Consideration attributable to non-live or repeat telecast rights is royalty, as it relates to the use of copyright. Where tax was required but not deducted, only the royalty component is disallowable under the withholding-tax provisions. Applying the established live-to-non-live viewership ratio, 93% of the payment attributable to live broadcasts is not disallowable, while 7% attributable to non-live broadcasts is royalty and is disallowable.

Section 54F applies only where long-term capital gains arise from transfer of an asset other than a residential house; a transfer of a residential property is therefore governed by Section 54, not Section 54F. Section 54 requires the same assessee who transfers the original residential property to purchase or construct the replacement residential property within the prescribed period. A property bought solely in the spouse's name is treated as acquired by a distinct legal person and cannot be linked to the assessee's sale for the exemption. Consequently, capital gains remain taxable where neither provision's conditions are met.

Disallowance computed under Section 14A read with Rule 8D cannot, merely because it is disallowed for normal tax computation, be added to book profit under Section 115JB. The relevant Explanation permits adjustment only for expenditure relating to exempt income determined under the book-profit computation, and does not import the Section 14A/Rule 8D mechanism. Accordingly, book profit cannot be increased solely by the amount disallowed under Section 14A using Rule 8D.

Eligibility under the Direct Tax Vivad Se Vishwas Scheme, 2024 extends to a person whose writ petition challenging an interest determination and rejection of an interest-waiver application was pending on the specified date. Such a person falls within "appellant", while the challenged interest is treated as disputed interest and tax arrears. FAQ 15 applies only where the waiver application itself remained pending before the competent authority on that date; it does not exclude a pending High Court challenge to a decided waiver application. This interpretation permits settlement of a genuine pending interest dispute.

Section 179 liability imposed on a company director requires consideration of the director's reply and supporting documents submitted in response to the show-cause notice. Failure to consider those materials breaches principles of natural justice and renders the liability order unsustainable. The order was quashed, with the matter requiring fresh decision in accordance with law after proper consideration of the director's response and documents.

Approval for reassessment after expiry of the extended three-year period required sanction from the authority specified under Section 151(ii). The relaxation period under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 permitted approval under Section 151(i) only until 30 June 2021. Consequently, approval by the Principal Commissioner under Section 151(i) for an order under Section 148A(d) and notice under Section 148 issued on 29 July 2022 did not meet the statutory requirement. The reassessment revival was therefore without jurisdiction.

Validity of a penalty notice was examined in relation to a cyclostyled show-cause notice that retained irrelevant particulars, raising vagueness concerns and questioning whether such a notice could validly found a penalty. The Supreme Court declined to exercise its discretionary jurisdiction under Article 136 and dismissed the special leave petition, leaving the impugned order undisturbed.

Reassessment notices for pre-2021 assessment years are considered in relation to the six-year limitation prescribed under the erstwhile reassessment regime. For AY 2017-18, a notice issued after expiry of that period was challenged. The Special Leave Petition involved an inordinate delay that was not satisfactorily explained, and the High Court's orders were not disturbed.

GST exemption for uncoated paper and paperboard under tariff heading 4802 applies only where a recipient established as a manufacturer uses the paper exclusively to produce exercise books, graph books, laboratory notebooks or notebooks. Rate treatment turns on established actual end use at the manufacturing stage, not paper grade, specification, tariff heading alone, or intended use. Paper put to the specified uses is exempt; paper used for other purposes is taxable at 18%. The revised rate scheme takes effect from 22.09.2025, leaving no stated uncertainty over supplies from that date.

Ruled or lined uncoated paper, whether supplied in rolls or cut sheets, remains classifiable under Heading 4802 because ruling, lining and cutting do not create finished stationery articles under Heading 4820. The end-use exemption for qualifying paper applies only to a direct supply to a manufacturer that actually uses it to produce specified books; intended eventual use through an intermediate supply chain is insufficient. Each supply is independently assessed for exemption. Paper mills supplying reels to intermediate processors must charge tax where no separate exemption applies, as recipient-side reverse charge is inapplicable; input tax credit remains subject to statutory conditions.

Section 98(2) of the Central Goods and Services Tax Act, 2017 bars admission of an advance-ruling application where the questions raised are already pending or decided in proceedings concerning the applicant. Classification and tax-rate questions previously determined in enforcement proceedings, following adequate hearing opportunities, cannot be reopened through the advance-ruling mechanism. The application is therefore inadmissible because the same questions had already been decided under the Act.

Actual electricity charges recovered from unit holders at the distribution company rate, without markup, for metered HVAC, non-HVAC and apportioned common-area consumption are deemed to be recovered as a pure agent under Circular No. 206/18/2023-GST. Although electricity supplied with maintenance services ordinarily forms part of a composite supply, the circular's deeming treatment applies where recovered charges equal those charged by the electricity board or distribution company and are separately identified from common-area maintenance charges. Such recovery is excluded from the value of supply under Rule 33 of the CGST Rules, and GST is not leviable on those electricity charges.

Refund under the inverted duty structure may cover accumulated input tax credit on higher-taxed packaging materials used for packaged tea. Packaging materials used in the course or furtherance of business qualify as inputs, and the refund calculation cannot be confined to bulk tea by disregarding ancillary eligible inputs. Circular No. 135/5/2020-GST is confined to credit accumulation caused by a GST rate reduction on the same goods at different points in time. Where bulk tea and packaged tea attract the same rate and no such reduction occurred, the circular does not bar the claim. An administrative circular cannot curtail a statutory refund entitlement.

Statutory appellate remedy before the GSTAT was treated as efficacious for challenging the impugned GST order. The petitioner was directed to file the appeal within the stipulated period, with exclusion of the writ-pendency period when calculating limitation. Pending disposal of the statutory appeal, coercive recovery was restrained. No final determination was made on the validity of the impugned order.

Section 75(7) of the Uttar Pradesh Goods and Services Tax Act, 2017 prohibits confirmation of a GST demand exceeding the amount proposed in the show cause notice. Where confirmed demands on two discrepancy counts substantially exceeded the amounts proposed in a single notice, the excess confirmation constituted a fundamental and incurable defect. The adjudication order was therefore unsustainable to the extent it confirmed demand beyond the show cause notice.

Pending representations seeking GST payment for taxable services require examination of the applicable GST rate, tender conditions, bills, invoices and payment records, including whether GST was already included in final bills. The competent authorities must assess the supporting material and communicate independent, reasoned and speaking decisions on each representation. No determination of the contractor's substantive entitlement to the claimed GST amounts was made. The representations were directed to be decided within six weeks.

Electronic-only service of a show-cause notice through the Common Portal after cancellation of GST registration does not provide an effective opportunity to participate in Section 74 adjudication. Where proceedings are initiated after deregistration, physical service is required under the applicable departmental circular because the deregistered person may not access, or be required to access, the portal. An ex parte adjudication based solely on portal upload in those circumstances cannot be sustained. Fresh adjudication requires effective notice, an opportunity to reply, seek relevant documents or cross-examination where necessary, and be heard.

Reasoned adjudication requires consideration of a detailed reply and a specific SEZ exemption claim. A conclusory statement that contentions are unacceptable, without addressing material submissions or giving reasons for rejection, is cryptic and non-speaking. The adjudication order was therefore invalid, requiring fresh determination after a hearing, with all contentions remaining open.

Pre-deposit requirements for statutory tax appeals are governed by the regime in force when adjudicatory proceedings commence, namely the date of the show-cause notice; a later substituted requirement does not apply to earlier notices. Challenges to an officer's authority require assessment under function-specific proper-officer provisions, delegated powers and rank-based notifications. Where those instruments do not reveal a patent jurisdictional defect, and challenges involve disputed evidence, natural justice, party roles, quantification or penalties, the statutory appellate remedy remains the appropriate forum.

GST proceedings commenced against an amalgamating company after its merger are void from inception because the entity no longer exists. Section 87 of the CGST Act does not authorise proceedings against a non-existent entity or cure the resulting jurisdictional defect. The GST order was set aside on that basis, and the Supreme Court declined to interfere by dismissing the special leave petition.