Condonation of delay in a statutory appeal was warranted where serious illness of the person responsible for business affairs constituted sufficient cause and was supported by medical material. Compliance with the mandatory pre-deposit requirement before filing reinforced the availability of the appellate remedy. Dismissing the appeal solely as time-barred despite sufficient cause and pre-deposit compliance would be unduly technical and render the statutory remedy illusory. The delay was condoned, the appellate dismissal was quashed, and the appeal was directed to be admitted and decided on merits.

Availability of a statutory appeal against rejection of a GST registration-cancellation application does not bar writ jurisdiction under Article 226, but strongly informs its discretionary exercise. Where the challenge requires resolution of disputed facts and appraisal of the record, the statutory Appellate Authority is the appropriate forum. The writ petition was therefore not entertained, with liberty to pursue the statutory appeal; the Appellate Authority must decide it independently of observations made in the writ proceedings.

Retrospective extension of the input tax credit limitation under section 16(5) protects eligible registered persons whose belated claims were barred under section 16(4) but fall within the extended period. Input tax credit cannot be denied solely on limitation in such circumstances. The assessment disallowance was quashed to that extent, consequential recovery was restrained, and amounts already recovered were to be refunded or adjusted against future tax liabilities.

Defective service of a GST show-cause notice and adjudication order through an incorrect common-portal tab justified condonation of delay in filing the GST appeal. Uploading a notice on the portal alone was treated as insufficient service where there was no acknowledgement or reply, and belated recovery action supported the taxpayer's claim that the order appeared under "Additional Notices and Orders" rather than the designated tab. Although the Appellate Authority was bound by the statutory limitation period, refusal to hear the appeal would cause grave prejudice where the delay arose from circumstances beyond the taxpayer's control. The appeal was directed to be entertained and decided on merits if filed within the stipulated period.

Sufficient cause supported condonation of delay in a GST appeal where the taxpayer lacked effective knowledge of the show-cause notice and adjudication order because they were uploaded under a non-designated portal tab. Although the Appellate Authority remained bound by the limitation prescribed under section 107 of the RGST/CGST Act, circumstances beyond the taxpayer's control and the risk of grave prejudice justified merits review. The delay was condoned, with a direction to entertain and decide the appeal on merits if filed within the stipulated period.

Fresh adjudication was permitted where the petitioner had not participated in the original proceedings and the statutory appellate limitation had expired. The impugned order was quashed, subject to an additional pre-deposit of 25% of the disputed tax and submission of a reply to the show-cause notice within the stipulated period. The earlier order was to operate as an addendum to the show-cause notice for the fresh proceedings. No further extension or concession was available; failure to comply allowed recovery proceedings to continue in accordance with law after due notice.

Retrospectively inserted section 16(5) extends the time for eligible registered persons to claim input tax credit for specified financial years where the section 39 return was filed by 30 November 2021. It overrides the limitation in section 16(4) for claims falling within that extended period, while preserving the requirement to satisfy all other statutory conditions. Input tax credit claimed through a March 2019 return filed within the extended deadline cannot be denied solely for delay. Limitation-based disallowance, consequential recovery, and related demands are to be removed, with recovered amounts refunded or adjusted against future tax.

Section 112(3) confines the prescribed limitation period to filing an appeal before the Tribunal and does not impose a separate six-month deadline on the Commissioner to review the first appellate order. A departmental appeal filed within the applicable extended filing period therefore remains maintainable even where the Commissioner's review occurred after six months. The maintainability objection was rejected, and the appeal was admitted for adjudication on merits.

Urgent listing of an appeal against GST registration cancellation may be granted without awaiting ordinary Registry scrutiny where sufficient cause and continuing prejudice are shown. Procedural rules permit exemption from procedural requirements and directions necessary for substantial justice, reflecting the principle that procedure should facilitate adjudication rather than defeat substantive rights through technicality. Cancellation preventing the appellant from conducting its sole business justified limited urgent listing, as delay could make appellate relief ineffective. The exemption applies only to listing and does not waive statutory requirements or determine maintainability or merits, which remain open.

Papad Khar, an alkaline manufactured mixture containing sodium chloride, sodium carbonate and sodium bicarbonate, is classified as an inorganic carbonate under tariff item 28362090. It is not covered by Heading 2501 because it is neither crude nor merely physically processed salt, and it does not possess the characteristics of yeast or prepared baking powder under Heading 2102. As a Chapter 28 inorganic chemical outside the relevant exclusions and alternative schedules, it attracts GST at 18%. Exemption for exempt papad does not extend automatically to Papad Khar used as an input; each input and finished product requires separate classification and rate determination.

E-invoicing applies to coaching-service supplies genuinely made to registered recipients where the supplier falls within the notified class and no exclusion applies. Recipient status depends on an enforceable contractual liability to pay consideration; the student may be the beneficiary, while a parent, guardian or sponsoring enterprise may be the recipient only if contractual terms establish that liability. Mere fee payment or provision of a GSTIN is insufficient. Proposed-supply questions may be raised, but recipient identity and place of supply cannot be determined through advance ruling where they require transaction-specific assessment. Supplier e-invoicing obligations operate independently of the recipient's input tax credit eligibility or business purpose.

Reassessment cannot revisit capital-gains and share-sale exemption issues already examined and accepted in a scrutiny assessment on the same facts, as doing so amounts to a change of opinion. Detailed inquiries into share valuation, purchaser identity and creditworthiness, transaction genuineness, and the consequential exemption claim establish formation of an opinion even where the assessment order does not address every query. The change-of-opinion principle applies under the revised reassessment procedure, in which a show-cause notice under section 148A(b) performs the function of recorded reopening reasons. The reassessment notices and related proceedings were quashed; the limitation challenge remained open.

Reassessment based on information linked to GST adjudication requires independent application of the Income-tax Act. Information suggesting escaped income may include material obtained through a CBDT risk-management strategy, but the record must establish that the relevant strategy covers the GST adjudication order. Income-tax authorities cannot rely solely on the GST proceeding or its appellate outcome when issuing or pursuing reassessment. The reassessment notice remained undisturbed, while any reassessment was required to proceed independently under the Income-tax Act and remain open to subsequent challenge.

Consistent treatment of depreciation in calculating the profit level indicator under the Transactional Net Margin Method is necessary for a valid arm's-length comparison. Including depreciation in an assessee's operating cost while excluding it from comparable companies' operating costs produces an anomalous comparison and can distort the assessed margin. Recomputing the assessee's margin without depreciation, consistently with the comparables, placed the international transactions with associated enterprises at arm's length. The resulting arm's-length price adjustment and related addition were deleted.

Section 87A rebate is available against tax on total income, including short-term capital gains taxable at special rates under section 111A, for an individual governed by section 115BAC(1A) whose total income does not exceed the prescribed threshold. The rebate applies to the tax liability computed on total income without distinguishing between income taxed at normal rates and income subject to the special rate for short-term capital gains. The stated position sustains entitlement to rebate on tax attributable to such gains.

Reassessment initiated on departmental information flagged through the Insight Portal remains valid where the Assessing Officer independently confronts the taxpayer with the information, considers the response, passes an order under section 148A(d), and then issues notice under section 148. Such information may provide a starting point for enquiry without constituting borrowed satisfaction. However, sale proceeds from shares cannot be treated as unexplained accommodation entries merely on investigation allegations or suspicion where broker transactions, demat records, contract notes and banking channels remain undisputed, and no independent corroboration, cash trail, or link to an entry provider is established. The reassessment survived, but the share-sale addition was deleted.

Uncorroborated electronic records cannot alone support additions for unexplained investments, expenditure, interest, sales or debtor balances unless independent evidence establishes their nexus with the assessee and the recorded transactions. Excel worksheets, payment sheets and electronic debtor data containing inconsistencies, without supplier or debtor verification, books, invoices, banking records or other supporting material, failed this standard; the related additions were deleted. WeChat diary figures were accepted only to the extent actually recorded, with gross profit estimated thereon, because no evidence justified applying a multiplier. Cash-rent expenditure was disallowed for want of receipts, ledger entries, landlord confirmation or payment proof, and unexplained stock investment was sustained because the stock difference remained unreconciled.

Cash deposits fully disclosed through a revised computation during assessment, with tax paid and the computation accepted, may constitute under-reporting rather than misreporting where the assessment does not identify any statutory ingredient of misreporting. Assessment of the deposits as income from other sources does not itself establish misreporting. On that classification, immunity from penalty for under-reporting is available, and penalty imposed for misreporting is unjustified. The appeal was allowed.

Section 54F eligibility depends on residential houses owned by the assessee personally. A residential property owned by a company remains the company's asset and is not treated as owned by its director. Where the assessee also jointly owns a property with a spouse, counting that property still leaves only one residential house other than the property in which the qualifying investment is made. The disqualifying condition for ownership of more than one such house therefore does not apply, and the section 54F deduction remains available.

Revaluation surplus credited to a retiring partner following revaluation of partnership land does not constitute the partner's share in the firm's total income and is not exempt under section 10(2A). For the relevant assessment year, distribution of the enhanced value of partnership assets attracted section 45(4), under which the resulting capital gains were taxable in the firm's hands rather than in the retiring partner's hands. The post-1 April 2021 substituted provisions did not apply. Accordingly, the addition of the revaluation surplus in the retiring partner's assessment was deleted, although the exemption claim was rejected.