Rule 96(10) of the Central Goods and Services Tax Rules, 2017 was omitted on 8 October 2024 without a saving clause. Section 6 of the General Clauses Act, 1897 does not apply to the omission of a rule; proceedings under an omitted rule can continue only if preserved by an express provision or other legal device. Show cause notices issued after the omission without such preservation lack statutory backing and are legally ineffective.

Writ jurisdiction may be exercised in appropriate circumstances to reopen a statutory GST appeal dismissed as time-barred, notwithstanding the statutory limit on the appellate authority's power to condone delay. Reopening restores the opportunity for a hearing and decision on the merits where the tax computation was not adjudicated because the appeal was dismissed on limitation.

Objections to GST prosecution based on prior sanction and a monetary threshold may be pursued before the writ court or at an appropriate subsequent stage. The FIR also alleged offences under the Bharatiya Nyaya Sanhita, 2023, and interim protection against it was not warranted. The merits of the GST-related contentions remain open.

The assessment years specified in the English version of the notification for the Andhra Pradesh Electricity Regulatory Commission under section 10(46) of the Income-tax Act, 1961 are corrected from the period 2019-20 through 2023-24 to the period 2020-21 through 2024-25. This removes assessment year 2019-20 and adds assessment year 2024-25. The Hindi version remains unchanged.

Where a Bill of Export is filed under a claim of drawback or a similar scheme under the Customs and Central Excise Duties Drawback Rules, 2017, the SEZ unit, developer or Domestic Tariff Area supplier must claim the benefit from the Specified Officer. If the unit or developer does not intend to claim the benefit, it must give the supplier a disclaimer so that the supplier may claim it. The substituted rule takes effect from its publication in the Official Gazette on 30 October 2026.

Resident individual status and transaction value determine deemed export declaration and service import reporting requirements. A resident individual, defined as a natural person resident in India, is deemed to submit an Export Declaration Form for services upon providing the authorised dealer with the required payment receipt information for crediting the exporter's account. Other service exporters receive the same treatment where the inward remittance does not exceed Rs. 10 lakh or its foreign currency equivalent. For service imports by persons other than resident individuals, authorised dealers must enter details in IDPMS within five working days of receiving them if the invoice or contract value exceeds Rs. 10 lakh or its equivalent. The amendments take effect from 1 October 2026.

Indian Missions abroad must take up quality complaints and trade disputes with the relevant authorities for appropriate redress, whether the complaints are filed by applicants or referred by the concerned Foreign Trade divisions. The Missions and the divisions must periodically update the action taken and status of each complaint on the DGFT portal until resolution or final disposal. Complainants must be able to access all updates through the portal, with timely updates continuing until the matter is resolved, closed or otherwise disposed of under the prescribed procedure.

Individual persons resident outside India may complete digital KYC from Financial Action Task Force (FATF)-compliant countries, with the revised framework effective from 3 December 2026. Intermediaries must verify identity, collect an overseas address and undertake in-person verification or, where physical verification is not feasible, video verification with an authorised official present and concurrent audit. KYC Registration Agencies must tag attributes verified against official or source databases as validated, but all KYC records remain portable regardless of validation status. Intermediaries may rely on eligible third-party KYC records but remain ultimately responsible for KYC and risk-based enhanced due diligence. Existing KYC requir.....

Interim resolution professionals or resolution professionals must ensure compliance with real estate regulation during the corporate insolvency resolution process (CIRP) of debtors with real estate projects. They must obtain available project information from the relevant regulator's portal and may use it to prepare the information memorandum, verify claims and assess project status. Reliance on portal records where debtor records are incomplete, unavailable or inconsistent is subject to verification and reconciliation. The resolution professional may invite the regulator's written views on resolution plans and must share any views received with the committee of creditors and prospective resolution applicants. Within seven days of appointme.....

Commercial suits require disclosure of documents under Order XI Rule 1 of the Code of Civil Procedure; reliance on undisclosed documents requires leave and reasonable cause for non-disclosure. Where an error in the original board resolution was known at institution, a replacement created during final arguments after an objection did not justify leave. A foundational absence of authority to institute a suit differs from a curable procedural defect: a later resolution replacing the original basis of authority cannot ratify that absence or establish the signatory's authority to represent the company.

Cost-to-cost reimbursement of interest expenditure among group entities does not attract tax deduction at source under section 194A when it contains no income element. Where entities share collectively borrowed funds, allocate third-party interest according to their use, and reimburse the expenditure without markup, the payments represent recovery of expenditure rather than income. Tax is deducted on interest paid to third-party lenders; no default or consequential interest liability arises from the reimbursements.

Charitable exemption for advancing general public utility remains available for non-commercial, government-funded railway infrastructure activities, despite recovery of administrative costs and interest earned on temporarily deposited project funds. The distinction is between commercial activity and activities conducted at cost or with a nominal mark-up. Relevant features include transfer of the resulting assets to the railways and no dealings with the public. Under Rule 27, a respondent who obtained complete relief at the first appellate stage may raise an alternative jurisdictional ground where the relevant facts are on record. Admission of that ground does not determine its constitutional merits.

Commission income from accommodation entries was calculated on reduced turnover rather than total debit and credit entries after payment details identified debit entries as loan repayments. The assessment had applied a commission rate to total transactions, but no material contradicted the distinction supported by the payment details. The commission addition was consequently restricted, with the same approach applied to the connected matter.

Section 69A of the Income-tax Act, 1961 governs additions for unexplained money. Demonetisation-period cash deposits were disputed where the assessee's historical cash sales accounted for most total sales, and November cash deposits were lower than in the corresponding month of the preceding year. The addition of the deposits was deleted in favour of the assessee.

Assessment founded on the incorrect premise that no return was filed is void from the outset where the return was on record, had been processed and had resulted in a refund. Objections to reopening must be disposed of before reassessment is completed. Failure to do so invalidates both the reopening and the resulting assessment, leaving them without legal effect.

Belated furnishing of Form 10B before an appellate authority can satisfy the audit-report requirement for a charitable trust's exemption claim through substantial compliance. Where the statutory audit was completed earlier but the report was not verified during processing and no regular assessment was made, the report remains subject to verification, and the exemption claim must be determined in accordance with law.

Section 68 of the Income-tax Act, 1961 governs additions for unexplained cash credits, including deposits attributed to recorded cash sales during demonetization. An estimated abnormal increase in cash sales, assessed through a human probability test, does not by itself sustain an addition where evidence of sales, purchases, stock and cash availability remains uncontroverted. Relevant evidence includes audited books recording the deposits, a maintained stock register and sales accepted in the VAT assessment. The purchases were not alleged to be bogus, and the revenue did not rebut the evidence of cash availability or disprove the recorded transactions.

Cash deposits in a commission-based discounting business cannot be treated entirely as unexplained income under section 69A without considering corresponding debit transactions. Where customer receipts and payments are not fully recorded, the assessing officer must verify possible income suppression, including whether declared commission relates only to recorded receipts. If it does, income on unrecorded deposits should be estimated using the disclosed profit ratio. An assertion that the omissions did not suppress income requires verification where it lacks an independent auditor's report.

Section 69A applies to unexplained money attributable to the assessee, and an addition cannot be sustained where cash deposits are established to belong to another person. This distinction is relevant where deposits are held in an account belonging to a partnership firm, while the assessee's separate account was closed before the relevant year.

Section 68 treatment of an unexplained loan turned on bank records showing that the funds were received and transferred out on the same day. No evidence supported the allegation that the funds belonged to the assessee or represented an accommodation entry, and the loan addition was deleted. Additions had also been made in the lender's assessment, while the related assessment and appellate orders were revenue records that did not require inquiry as fresh evidence.