Corporate veil-piercing in execution is an exceptional response where promoters allegedly use layered entities and securities transactions to deplete shareholding represented as security through judicial assurances. Separate personality remains the rule, and control or ownership alone does not suffice; there must be a nexus between control, misuse of the corporate form, and frustration of enforcement. A forensic audit reconstructs share movements, pledges, sales, financing, approvals, disclosures, and fund flows, distinguishing legitimate enforcement of pre-existing security from coordinated asset dissipation.

Consolidated show cause notices may combine financial years governed by Sections 73 and 74 where liabilities are segregated period-wise, each component independently meets limitation and notice requirements, the additional ingredients for fraud-based proceedings are satisfied, and no actual prejudice arises. School affiliation and affiliation-form processing charges are independent taxable supplies where they concern institutional eligibility and compliance, rather than directly and immediately relating to student admission or the conduct of examinations. A broad connection with education does not satisfy the educational-services exemption.

Input tax credit from allegedly non-existent suppliers depends on proof of genuine supply and actual receipt of goods or services, not merely invoices, accounting entries, or banking-channel payments. Section 155 places the burden of establishing ITC eligibility on the claimant. Section 74 requires more than ineligible credit: the wrongful availment must be linked to fraud, wilful misstatement, or suppression to evade tax. Retrospective supplier-registration cancellation is relevant evidence but is not conclusive. A fraud-based notice must disclose facts showing fictitious suppliers, absence of supply, and a basis for inferring the recipient's knowledge or participation.

Section 45 of the Prevention of Money-Laundering Act remains the stringent ordinary bail threshold, requiring prosecutorial opportunity and, on opposition, reasonable grounds to believe that the accused is not guilty and unlikely to offend while on bail. Article 21 nevertheless requires a separate, fact-sensitive inquiry where prolonged pre-trial detention and an unrealistic trial timetable make custody disproportionate. Relevant factors include custody length, trial progress, remaining witnesses, secured documentary evidence, source of delay, predicate-case status, and risks of absconding or witness interference. Conditions such as passport surrender, attendance, non-contact directions, and residence disclosure may safeguard the trial.

Section 56(2)(viib) taxes only share consideration exceeding fair market value, while Rule 11UA allows an issuer of unquoted equity shares to elect a prescribed NAV or DCF method. The election does not make a DCF report conclusive: projections, discount rate, terminal value, data and calculations must be supportable on the valuation date. Assessment scrutiny may identify demonstrably wrong facts, material computational errors or objectively unsupported assumptions, and may require reconsideration or an independent valuation within the selected DCF method. It cannot rest solely on hindsight, unaudited management forecasts or a lower NAV result. The higher-value statutory limb may support asset-based valuation. The provision is stated not to apply on or after 1 April 2025.

Exported goods are zero-rated, but incorrect classification of IGST in the non-zero-rated field of FORM GSTR-3B can block the Rule 96 automated Customs refund. Where IGST is paid again in the correct zero-rated field and the automated refund relates only to that later payment, the original payment may be claimed as separately identifiable excess tax through FORM GST RFD-01 with a transaction-level reconciliation. The claim must establish double payment, the payment actually refunded, and absence of prior adjustment or duplicate benefit. Article 265 prohibits retention of tax not legally due, while Section 39(9) does not permit retrospective revision of the original return; the remedy is an excess-payment refund, not return amendment.

GST registration cancelled for continuous non-filing of returns may be revoked under Section 30 and Rule 23 only through a time-bound application and fulfilment of prescribed return-filing and payment conditions. For return-default cancellations, pending returns and all tax, interest, penalty and late fee must be discharged before applying; returns due between cancellation and revocation must generally be filed within 30 days after restoration. Cancellation proceedings require clear notice and an opportunity to respond, and must be dropped where pending returns and dues are regularised before cancellation. Portal refusal may obstruct filing but does not determine statutory eligibility or automatically restore registration; physical submission may be permitted where online filing is technically unavailable, leaving revocation to be decided according to law with procedural fairness.

Companies may file financial statements for financial year 2025-26 in specified AOC-4 forms until 31 December 2026, and annual returns in MGT-7 and MGT-7A until 31 January 2027, without payment of additional fees. The relaxation does not extend the statutory time for holding annual general meetings, and later filings attract all applicable fees, including additional fees, from the original due date.

Taxpayer's reply to a show-cause notice proposing cancellation of GST registration must be considered expeditiously by the Proper Officer. The Proper Officer must decide the reply and pass an order under the applicable statutory provisions. This requires a reasoned administrative determination on the proposed cancellation after consideration of the taxpayer's response, rather than leaving the response undecided.

Section 138 of the Negotiable Instruments Act applies where a cheque is issued, dishonoured because the account is closed, a demand notice is served, and payment is not made within the prescribed period. An undisputed drawer's signature triggers presumptions of consideration and legally enforceable liability under Sections 118(a) and 139. The drawer must rebut those presumptions on a preponderance of probabilities through a coherent, supported probable defence; inconsistent claims concerning the underlying loan, lost cheque book, or blank security cheques do not suffice. Revisional review is limited to fundamental legal error, perversity, or grave procedural irregularity, not fresh appraisal of evidence.

Successive applications under the Code of Criminal Procedure may proceed when changed circumstances or a fresh cause of action exists and relief has not been withheld through piecemeal litigation. Attachment of immovable industrial property under the Prevention of Money-Laundering Act preserves assets against transfer, conversion, disposition or movement pending confiscation; it does not ordinarily remove the interested person's right to enjoy the property. Pre-confiscation possession is exceptional. Attached plants may therefore remain operational, subject to continued attachment, non-alienation, required permissions and licences, and inspection safeguards, where operation preserves economic utility without frustrating potential confiscation.

Section 14A does not apply where no exempt income has been earned and no exemption has been claimed during the relevant year. Rule 8D, as a machinery provision, cannot independently support a disallowance when the substantive conditions for section 14A are absent. The Finance Act 2022 Explanation extending section 14A irrespective of exempt-income accrual applies prospectively from assessment year 2022-23. Accordingly, expenditure disallowance under section 14A read with Rule 8D is unsustainable for earlier years where no exempt income arose.

Interest earned by a co-operative credit society on term deposits and savings-bank deposits qualifies for deduction under section 80P(2)(a)(i) where the deposits represent the society's own funds generated through its credit-facility business. Such interest retains its business character as profits attributable to that qualifying activity. Interest on members' funds held as liabilities is distinguishable and does not share the same basis for deduction.

Bona fide errors in computing depreciation and reporting interest on an income-tax refund do not amount to concealment of income or furnishing inaccurate particulars where the depreciation error is corrected subsequently, the related disallowance is accepted, and relevant refund-interest particulars are already on record. On those facts, penalty for concealment is not leviable in relation to either the excess depreciation claim or omitted refund interest.

Section 68 additions for differences in sundry-creditor balances are unsustainable where the differences relate to opening balances rather than credits recorded in the relevant year. Remaining discrepancies may not warrant addition when entity-wise reconciliations are uncontroverted and the amounts have already been offered to tax in later years under Section 41(1). The same treatment applies where creditor differences for another assessment year are materially identical and similarly reconciled.

Unaccounted consideration for an office purchase requires cogent, credible and corroborative evidence that an amount beyond the recorded sale price passed between the parties. The initial evidentiary burden lies on the Revenue, and banking-channel payments and transaction records cannot be displaced by suspicion or general allegations alone. Where taxpayer material is self-serving and not fully reliable, a limited estimation may be warranted. The unexplained-investment addition was restricted to Rs. 69,955 and made taxable at normal rates rather than under section 115BBE.

GST on rental income from hotel accommodation hired by the Department of Home must be addressed by the accommodation providers. Recipients of the rental income must obtain GST registration and deposit GST on that income. The Department must pay the applicable GST in addition to the agreed daily room rent. The obligation to register and remit tax remains with the rental-income recipients, while the Department's payment obligation extends to the prescribed GST amount over and above rent.

Adjudication under Section 74 requires genuine consideration of the taxpayer's written response and evidence produced at the personal hearing. An order that substantially reproduces the show-cause notice and rejects the response without addressing the explanation or supporting material demonstrates non-application of mind. Such an adjudication order is invalid and must be set aside, while permitting fresh proceedings in accordance with law.

Reasoned adjudication under Section 73 of the Punjab Goods and Services Tax Act, 2017 requires a valid quasi-judicial determination of GST liability. Merely describing a taxpayer's written response to a show-cause notice as unsatisfactory, without considering the explanations raised or giving reasons for their rejection, does not meet that requirement. An order that fails to address the taxpayer's response is therefore unsustainable.

Specified Chapter 30 COVID-19 medicines receive a State GST exemption that limits tax to nil for Tocilizumab and Amphotericin B and to 2.5% for listed other medicines, including Remdesivir, Heparin, Itolizumab, Posaconazole, Infliximab, specified antibody combinations, 2-Deoxy-D-Glucose and Favipiravir. The measure applies from 1 October 2021 through 31 December 2021 inclusive and exempts tax only above those prescribed rates.