Specified transactions under Odisha's GST framework are expanded to include supplies of goods or services, or both, received from an unregistered person where tax is payable by the recipient on a reverse charge basis, and imports of services. Supplies of goods or services, or both, to a registered person and supplies for export continue to be included.

Taxable income of an unregistered charitable institution is computed after accounting for relevant expenditure claimed under section 57 of the Income-tax Act, 1961, and permissible inter-head adjustments. Activity-wise surpluses and deficits are to be adjusted in the computation, rather than treating gross receipts as taxable income. These adjustments affect the institution's taxable income.

Registered concessionaires supplying operation and maintenance services to a concessioning authority during the concession period must pay Odisha State tax on the amount charged or debited from the escrow account towards operation and maintenance expenses they incur. The tax is payable in the tax period in which those expenses are charged or debited, and the escrow account must be maintained in accordance with the concession agreement.

Charitable exemption under section 11 of the Income-tax Act, 1961 does not require a registered charitable institution to be constituted as a trust or incorporated as a non-profit company. Under the proviso to section 2(15), the commercial character of an activity advancing general public utility depends on its predominant purpose and activities, rather than receipts in isolation. Government-funded railway projects undertaken for public benefit do not become trade, commerce or business merely because administrative charges cover overheads and deposit interest or surpluses are applied to project objectives.

Each courier must provide prescribed information for all bills of entry and shipping bills filed at the Sahar Courier Terminus to the custodian in physical form and Microsoft Excel format on the day of clearance, but no later than the next working day. The custodian must verify and compile the data before submission to the Deputy Commissioner, Courier Cell. Import information includes IGST and compensation cess paid; export information includes the payment or bond status, invoice details and export general manifest particulars.

Delivery services are specified under Odisha's GST framework for electronic commerce operators, other than postal and courier services. The specified category excludes services supplied through an electronic commerce operator where the supplier is liable for registration under section 22(1) of the Odisha Goods and Services Tax Act, 2017. The replacement takes effect on 1 November 2026.

Joinder in marital status suits may extend to persons without a present or direct interest where their participation assists complete adjudication; property litigation ordinarily requires a direct interest. Declaratory relief under section 42 of the Specific Relief Act is discretionary, and courts may require proof of admitted facts rather than grant a declaration automatically. Under section 43, a declaration of status binds the parties and persons claiming through them, including privies in blood. Its binding effect is distinct from res judicata, and it is not a judgment in rem.

Taxable services supplied to a Special Economic Zone developer or unit for authorised operations are exempt from service tax under Section 26 of the Special Economic Zones Act, irrespective of where the services are rendered. Section 51 gives the Act overriding effect over inconsistent laws, and no separate notification under the Finance Act is required for the exemption. Car hire services supplied to a Special Economic Zone unit for authorised operations qualify for the exemption.

Review and delay-condonation applications were allowed on the same reasoning as an earlier detailed order concerning other review applications. That order had addressed an issue arising from a Supreme Court order and was considered to cover a subsequent Supreme Court order. The appeal was restored to its original number for further proceedings.

For a charitable trust's exemption claim, furnishing the Form 10B audit report with the return is a procedural and directory requirement, and substantial compliance suffices. The report may be furnished later to the assessing or appellate authority on showing sufficient cause. Where the report was unavailable for verification when the return was processed, the Assessing Officer must consider and verify it and determine the exemption claim in accordance with law.

Cost-to-cost reimbursement of interest among group entities does not require tax deduction at source under section 194A when the reimbursement contains no income element. Where group entities obtain loans against project collateral, the principal borrowers deduct tax on interest paid to financial institutions, and the interest is allocated to the entities using the funds and reimbursed without markup. Interest for failure to deduct tax does not arise on such pure reimbursements.

Section 68 governs additions for unexplained cash credits. An addition cannot rest solely on an uncorroborated third-party statement recorded during a search where the alleged credit is not established in the assessee's books. Share application money was received and shares were allotted, while the audited financial statements did not record the alleged unsecured loan. The assessing officer conducted no further enquiries and did not provide an opportunity for cross-examination.

Protective additions for alleged commission or brokerage on job-work receipts cannot be sustained when the substantive addition is deleted because the underlying transaction is genuine. Documentary evidence and payments through banking channels established the genuineness of the transactions. The same reasoning applied to the relevant assessment years on identical facts, and the protective additions were deleted.

Section 263 permits revision only when an assessment order is both erroneous and prejudicial to the interests of revenue. A legally sustainable assessment made after inquiry cannot be revised merely because a different view is preferred. Reasonably ascertainable insurance claim liabilities, including claims incurred but not reported and claims incurred but not sufficiently reported, may be deductible when supported by actuarial estimates. Inquiry into the deduction and consideration of actuarial and other supporting material are relevant to whether the assessment rests on a permissible view.

The taxpayer bears the burden of proving the source of cash deposits. Even where that burden is not fully discharged, declared speculative income, socioeconomic status and family savings may warrant some credit on the particular facts, rather than treating all deposits as unexplained. The determination is fact-specific and is not to be treated as a precedent.

Under-reporting penalties are not justified for an excess weighted deduction for research and development expenditure where the original claim relies on a statutory auditor's certificate, the eligible deduction is voluntarily revised to reflect a subsequent report from the Department of Scientific and Industrial Research, and no inaccurate particulars of income are furnished. In these circumstances, the penalty is to be deleted.

Cash payments and incomplete identification of casual labourers do not by themselves justify an ad hoc disallowance of land levelling and road development expenses where supporting records are produced and no specific defects or evidence of non-genuine expenditure or expenditure unrelated to business are identified. Relevant records include ledgers, bills, vouchers and labour registers. Commercial expediency is assessed from the businessperson's perspective, taking account of the practical circumstances of hiring casual construction labour. An addition cannot rest on surmises or conjectures.

Reopening a completed scrutiny assessment after four years under section 147 requires a failure to disclose fully and truly the material facts necessary for assessment; a bare assertion of non-disclosure in the recorded reasons is insufficient. The reasons relied on investigation information without identifying undisclosed material facts, although bank details had already been furnished, making the reassessment invalid. The eventual disallowance also differed in nature from the alleged bogus purchases cited for reopening. Purchase disallowance for missing invoices was not justified where purchases from the same supplier were partly accepted, the books were not rejected, turnover was not found deficient, payments passed through banking channels and both parties confirmed the transactions.

Concealment penalties under section 271(1)(c) cannot survive deletion of the underlying disallowance under section 40(a)(ia) for non-deduction of tax at source, because deletion removes the penalty's foundation. A concealment penalty is also unsustainable where an expenditure disallowance is retained solely on estimation: the inherent subjectivity of an estimate makes it insufficient as the basis for the penalty. Neither the deleted disallowance nor the estimated expenditure disallowance provides a sustainable basis for the associated penalty.

Section 263 permits revision of an assessment that is erroneous and prejudicial to revenue, including where an issue requiring verification was assessed without inquiry or application of mind. A non-speaking assessment and the absence of a specific inquiry into expenditure attributable to exempt income can warrant fresh examination under section 14A. Satisfaction about the correctness of the expenditure claim requires examination of the accounts before Rule 8D is applied. A proposed rectification that does not proceed after objections does not, by itself, establish that the revisional authority acted on borrowed satisfaction. Re-examination may be directed without finally determining a disallowance.