Bogus donation receipts, return of purported donations to contributors, and facilitation of improper deductions supported an addition representing income from the receipt-facilitation arrangement rather than the full donation amounts. Concurrent factual findings on these matters were not open to interference in an appeal confined to questions of law. The political party's accounts did not show a true and correct position, and mandatory Election Commission reports were improperly filed or not filed; it was therefore disentitled to exemption under Section 13A. The additions and denial of the political-party exemption were sustained.

Section 14A read with Rule 8D does not permit expenditure disallowance where no exempt income is earned or claimed during the relevant assessment year. Consequently, no related adjustment to book profit arises under the MAT provisions where the underlying disallowance does not survive, particularly where book profit is negative. Mark-to-market loss on foreign-currency swap contracts used to convert rupee borrowings and reduce interest costs is deductible when consistently recognised under Accounting Standard-11 and matched by taxation of corresponding gains. Such exchange-fluctuation loss represents an accrued, subsisting liability rather than a contingent or hypothetical loss.

Belated filing of Form No. 10 for accumulation of charitable income for Assessment Year 2016-17 may be condoned under Section 119(2)(b) where reasonable cause is established and the accumulated amount is invested in prescribed modes. Circular No. 7/2018 permits Commissioners to consider such delayed forms for the first year of mandatory electronic filing. Investment of surplus in eligible term deposits supports the exemption claim. Condonation should advance substantial justice where refusal would cause genuine hardship, particularly if the delay was neither deliberate nor unexplained, enabling exemption for accumulated income under Section 11.

A reassessment notice based solely on a broker's seized inquiry-register entry alleging on-money payment for land purchase was unsustainable where the entry pre-dated the registered transaction, recorded asking rates rather than concluded sales, and did not identify or link the assessee or co-purchasers. Matching survey numbers alone did not establish a live and direct nexus between the seized material and the assessee's transaction. The statutory presumption for seized material could not transform a disconnected and unreliable entry into evidence of undisclosed payment. The notice under Section 148 was quashed.

Penalty for misreporting of income requires the notice to disclose the statutory and factual basis for alleging misrepresentation or other bad faith under Section 270A(9), and the penalty order must provide supporting reasons. A bare assertion of misreporting or a general reference to Section 270A is insufficient, particularly because misreporting attracts a higher penalty and excludes immunity under Section 270AA. Tax sought to be evaded must also be computed on the relevant assessed difference rather than the entire assessed normal income where the figures differ only to a stated extent. Invalid proceedings may be restarted in accordance with law, subject to the assessee's available contentions.

Recording a satisfaction note is mandatory before issuing a notice under section 153C. The High Court quashed notices for the relevant assessment year because the requisite satisfaction was recorded after a 22-month delay rather than within the immediate period required under the Calcutta Knitwears principle and Circular No. 24/2015. The Supreme Court found no ground to interfere with that determination and dismissed the special leave petition, leaving the quashing of the section 153C notices in force.

Bogus share trading loss was disallowed because the taxpayer neither substantiated the claimed loss with documents nor appeared before the Assessing Officer. The High Court treated the Tribunal's deletion of the disallowance as perverse, finding that its reliance on retraction of an oath statement and its conclusion on cross-examination ignored material factual deficiencies and reflected non-application of mind. The Supreme Court condoned delay and dismissed the Special Leave Petition, finding no ground to interfere with the High Court's order.

Passing on input tax credit benefits to eligible pre-GST homebuyers satisfies the anti-profiteering requirement where the supplier reduces prices commensurately with the determined benefit. The revised computation, including the pre-GST goods component, determined an additional input tax credit benefit of 4.23% for 31 eligible homebuyers. Documentary credit notes showed that the supplier passed on an amount exceeding the calculated entitlement. Accordingly, no contravention of the anti-profiteering requirement under Section 171 of the Central Goods and Services Tax Act, 2017 was established.

Condonation of delay was warranted where a statutory appeal against an adjudication order had been dismissed solely for filing beyond the condonable period. Applying binding and coordinate decisions in materially similar circumstances, the delay was condoned and the appeal restored so that the statutory appellate remedy could be determined on merits.

GST registration cancelled for non-filing of returns and non-payment of tax may be restored through revocation, subject to filing pending returns and paying tax due. The petitioner was permitted to apply for revocation of registration, and the registering authority was directed to consider the application with consequential action after compliance with these conditions.

Input tax credit claims may be examined under the specified GST circulars where recipients establish that suppliers paid the tax to the Government, addressing bona fide claims from the period when GSTR-2A was unavailable. The extended deadline for furnishing the September return is treated retrospectively as 30 November for the relevant period; eligible claims cannot be rejected solely because the return was filed after 20 October but by 30 November. However, the statutory conditions requiring tax payment and imposing a time limit for input tax credit are constitutionally valid. Claims within the circular-based or extended-deadline relief require individual consideration on merits.

Statutory appellate remedy under the Central Goods and Services Tax Act must ordinarily be exhausted before invoking writ jurisdiction against a GST demand order. An appeal lies to the Appellate Authority against the adjudication order, and the writ petition was not entertained because that remedy had not been pursued. If an appeal is filed within 30 days, the time spent prosecuting the writ petition must be excluded for limitation purposes. The disposal does not determine the merits of the underlying GST demand.

Separate show cause notices are required for distinct financial years; a composite notice covering multiple years is inconsistent with the governing procedural principles. The consolidated notice for financial years 2018-19 to 2021-22 and consequential orders were quashed. Fresh separate proceedings may be initiated for the relevant financial years, with exclusion of the specified period when computing limitation.

Consolidated or common show cause notices covering multiple GST tax periods are permissible under the GST enactments. Where proceedings remain at the response stage, objections to such notice require consideration by the Adjudicating Authority, followed by adjudication in accordance with law. The validity of a consolidated notice for the relevant tax periods is affirmed, with the issue resolved against the assessee.

Consideration of a temporary GST ID was required to facilitate access to the statutory appellate remedy. As the status of the application could not be confirmed, the respondents stated that the competent authority would decide it in accordance with law, which the petitioner accepted. The competent authority was expected to pass appropriate orders on the temporary-ID application within 30 days.

Delay in filing a statutory GST appeal may be condoned where circumstances beyond the taxpayer's control prevented timely filing and refusal to permit merits adjudication would cause grave prejudice. Although the appellate limitation framework under Section 107 binds the Appellate Authority, delayed appeals may be entertained on merits in such circumstances. The appeal was directed to be entertained and adjudicated on merits if filed within the stipulated period.

GST registration cancellation without a proper opportunity may be addressed through revocation where the registered person discontinued business, failed to file monthly returns, and seeks to resume operations. Revocation may be sought subject to payment of outstanding tax and filing of pending or proposed returns. The registering authority must consider the revocation application within the stipulated period after receiving the tax payment and required returns.

Section 75(4) of the Goods and Services Tax Act, 2017 requires an opportunity for personal hearing where an adverse decision is contemplated. Failure to afford the assessee a personal hearing before making an adverse GST adjudication order breaches this statutory requirement and the principles of natural justice. An order made without such hearing cannot be sustained and requires fresh adjudication after an effective personal hearing and supply of the documents relied upon.

GST adjudication under Section 73 requires effective communication of notices and a meaningful opportunity of personal hearing where an adverse determination of tax, interest or penalty is contemplated. Uploading notices and orders only in the Additional Notices and Orders tab was treated as insufficient communication. As the show-cause notice and reminder omitted the date, time and venue of the hearing, the ex-parte adjudication breached Section 75(4) and principles of natural justice. The order was set aside for fresh adjudication after allowing a reply and personal hearing.

Electricity charges recovered by a lessor may be treated as part of a composite supply of renting where electricity is incidental to use of leased premises, particularly where no separate electricity agreement exists or a markup is charged. Separate contracting, billing and dedicated metering may support an independent exempt supply of electrical energy, though this remains disputed where the lessor procures electricity onward. Recovery at actual cost does not automatically qualify for pure-agent treatment, which requires satisfaction of prescribed conditions and may be difficult where the lessor is the contractual recipient.