Offshore supply profits from equipment, integrated designs and spares manufactured, delivered FOB and paid for outside India were not taxable in India where title passed abroad, no fixed-place PE was established, and the supervisory PE had no connection with the supplies. The attribution of those profits was deleted. Supervisory services exceeding the treaty duration threshold created a supervisory PE; receipts directly connected with it were taxable as net business profits under Article 7, not gross-basis fees for technical services. Offshore designs and drawings supplied solely for internal plant use transferred no right to commercially exploit intellectual property and were business income, not royalty or fees for technical services. Advance-tax interest was not chargeable for the relevant period, while return-delay interest and tax-deduction credit required verification.

For arm's length pricing of preform silica imports, the Comparable Uncontrolled Price (CUP) method applies where reliable internal and external uncontrolled-price data exist for the same raw material. Customs data and internal uncontrolled purchases supported that the associated-enterprise purchase price did not exceed uncontrolled prices. In the absence of changes in the transactions, parties or asset base, a consistently accepted CUP method should not be replaced by the Transactional Net Margin Method (TNMM) without justification. Under TNMM, a diversified manufacturer and service provider without reliable segmental revenue or margin data is not functionally comparable to an entity manufacturing only optical fibre. The CUP-based pricing was accepted, and the TNMM-based transfer-pricing adjustment was deleted.

Specified amendments under rule 2 of the Gujarat Goods and Services Tax (Eighth Amendment) Rules, 2021 take effect from 1 January 2022. The operative provisions are sub-rules (2) and (3), clause (i) of sub-rule (6), and sub-rule (7) of rule 2.

Penalty proceedings for concealment require the Assessing Officer to reach satisfaction during assessment; a later notice cannot replace that jurisdictional requirement. Section 271(1) uses "may", preserving discretion and preventing automatic penalty merely because additional income is declared in returns filed under section 148. The deeming fiction in section 271(1B) applies strictly only where an addition or disallowance is made and the assessment order contains a clear direction to initiate penalty. A statement that proceedings "will be initiated separately" is only a future intention. Explanation 5A may deem concealment in specified circumstances but cannot cure invalid initiation or make penalty automatic. Penalties were deleted, while their merits remained open.

Renewal of charitable registration for an institution established without a written trust deed must be assessed by examining its charitable objects, genuineness of activities and legal compliance relevant to those objects. A written constitutive instrument cannot be imposed as an additional statutory condition where the rules also recognise applicants established otherwise than under an instrument. Registration records and certificates under public-trust law, together with an undisputed history of charitable educational activity, require objective consideration. Refusal solely for non-production of a trust deed was unsustainable, and renewal was directed. Donor-tax approval could not be refused solely because registration renewal had been rejected; absent any independent adverse finding, approval was directed subject to other statutory conditions.

Composite letting of commercial premises, amenities and permanently embedded fixtures is assessable as income from house property where the ancillary agreements are integral to and co-terminus with the principal leave-and-licence arrangement. The substance of the arrangement and the parties' dominant intention prevail over separate documentation or apportionment of consideration; amenities not independently exploitable remain part of the integrated commercial unit. Such assessment permits the standard deduction for house property income. Interest on a refinanced loan remains deductible where it replaces acquisition-related borrowing, the funds are traceable to property acquisition, and no diversion to a non-qualifying purpose is established, subject to arithmetical verification of utilisation.

Charitable exemption remains available to trusts pursuing education, medical relief or relief of the poor where rental income and licence fees arise from property held under trust. The restrictive proviso to the charitable-purpose definition applies only to advancement of general public utility, not to specified charitable objects merely because incidental income is generated. A valid charitable registration cannot be disregarded without cogent material that activities are non-genuine or outside the charitable objects. Rental and licence receipts do not constitute commercial activity absent an independent business venture, private diversion of funds or departure from charitable purposes; exemption was consequently restored.

Reassessment additions based solely on material gathered after reopening cannot survive where no addition or modification is made on the issue that formed the basis for reopening. Although the Explanation to section 147 permits assessment of subsequently noticed income after a valid reopening, the Tribunal applied the principle that this power depends on making an addition on the foundational reopening issue. The condition applies equally to reassessment following search where section 148A procedure is dispensed with. As the Revenue did not establish any addition based on material available at initiation, all additions arising from subsequent enquiries and verification were deleted. Both appeals were allowed, with remaining grounds left open.

Input tax credit for relevant invoices or debit notes may be availed only where supplier details are furnished in FORM GSTR-1 or through the invoice furnishing facility and communicated to the recipient in FORM GSTR-2B. A new recovery procedure permits sale or disposal of detained or seized goods or conveyance where penalty remains unpaid, subject to auction notice, payment safeguards, special treatment for perishable or hazardous goods, and stay on appeal in specified cases. The amendments also revise annual-compliance deadlines, refund documentation, disposal of sale proceeds, provisional attachment objections, and related GST forms.

COVID-19-related fixed overheads incurred during lockdown to retain employees and maintain business continuity were treated as extraordinary, non-operating costs and excluded from the tested party's operating cost for TNMM profitability analysis. Capacity underutilisation may warrant an adjustment; where comparable companies' data is not publicly available, transfer-pricing authorities should obtain it before determining the adjustment. Transfer-pricing adjustments under Chapter X are confined to international transactions with associated enterprises and cannot extend to unrelated-party transactions. Bad-debt double-addition claims require verification where the amount was allegedly already offered to tax. Working-capital adjustments requir.....

Binding interim High Court directions treating Leave Travel Concession reimbursements as non-income for TDS purposes prevented bank branches from being treated as assessees in default for non-deduction on reimbursements involving foreign travel. Section 201 liability arises only where tax was not deducted despite a subsisting legal obligation. Compliance with operative interim directions eclipsed that obligation for the relevant period, even though employees remained liable if the writ petition failed. A subsequent merits decision on the exemption issue could not retrospectively impose default liability. Consequently, demands for default and related interest were set aside.

Interest on non-performing assets of a co-operative bank is not taxable on notional accrual where recovery is uncertain and RBI prudential norms govern recognition, notwithstanding mercantile accounting. Reversal of a provision for bad and doubtful debts on an asset becoming performing is not deemed business income where it is neither recovery of an allowed bad debt nor remission of a loss, expenditure or trading liability. Provisions for standard assets may qualify for deduction as bad-debt provisions, subject to the statutory ceiling; rural advances must be computed using month-end outstanding balances, and fresh provisions cannot be netted against write-backs. Quantification requires fresh verification. Penalty does not arise merely because a disclosed deduction claim fails for lack of a book provision, absent concealment or inaccurate particulars.

Limitation for customs appeals against Bill of Entry assessments may exclude time spent bona fide pursuing a refund remedy and seeking amendment where that remedy was available under the then-binding jurisdictional law. Time before filing the refund application is not automatically excluded merely because it preceded an original proceeding, but subsequent time spent pursuing that remedy may be excluded under principles underlying Section 14 of the Limitation Act. Statutory relaxation of the appeal period then applies to appeals filed within the extended period. An appeal filed within the prescribed period cannot be rejected as time-barred. Restored appeals proceed on merits, with classification remaining open.

Availability of an appellate remedy under the Customs Act requires parties challenging orders-in-original to pursue the statutory appeal rather than seek writ relief on the merits. Attached bank accounts may be released pending that appeal where Revenue is secured through appropriation of the statutory pre-deposit from the attached funds and an unconditional bank guarantee for the remaining demand. On fulfilment of both conditions, the accounts may be operated to enable business continuity; failure to file the appeal or provide the required security permits appropriation of the entire amount due.

Warehousing permission confines imported goods to the bonded warehouse specified by the proper officer; diversion of manganese ore to an unauthorised private yard breaches that permission and renders the goods liable to confiscation. Warehousing remains subject to customs control, and storage at another premises managed by the same operator does not amount to compliance. The importer remains responsible for acts of its authorised warehouse operator unless statutory attribution is rebutted; duty evasion, clandestine clearance and mens rea are not necessary for confiscation. Search-related objections and electronic communications do not affect proceedings independently supported by statutory statements and transport, gate and warehouse record.....

Bulk drugs and active pharmaceutical ingredients imported under Chapters 28 or 29 qualify as drugs because they are substances used as components of pharmaceutical products. The specific description-based IGST entry for drugs and medicines under Sl. No. 226 of Schedule I to Notification No. 9/2025-Integrated Tax (Rate) applies to goods falling under Chapter 30 or any other chapter. This specific entry prevails over the general chapter-based entries for inorganic and organic chemicals. Imports for testing or research do not alter an API's character as a drug. IGST is chargeable at 5%, unless the goods fall within the nil-rated entry for drugs or medicines listed in Annexure I.

Termination of a share purchase agreement required prominent disclosure under the LODR Regulations where the listed entity had conspicuously announced approval of the acquisition. Mentioning the termination only in small print within a note to unaudited financial results, rather than in the principal board-meeting communication, was treated as no disclosure because investors rely on information about financial position, proposed ventures and collaborations. The complaint-dismissal communication was set aside, and SEBI and the stock exchange were directed to re-examine the mandatory-disclosure issue and issue appropriate orders within four weeks.

Jurisdictional officer designations under the Gujarat Goods and Services Tax Act, 2017 are restructured through amendment of the existing officer-jurisdiction table. New posts are inserted for the Economic Intelligence Unit, research functions, Economic Offence Wing, mobile squads, and enforcement divisions, including enforcement arrangements for Vapi and Division 12, Gandhidham. Earlier enforcement-research, mobile-squad and specified enforcement posts are deleted, while entries relating to enforcement-research State Tax Officers and Enforcement Division 11, Junagadh, are modified.

IDFC FIRST Bank's inaugural international investment-grade issuer credit ratings, with a stable outlook, are expected to improve access to international funding markets and global financial counterparties. The rating is intended to support standby letter of credit lines, foreign-currency funding through its GIFT City International Banking Unit, mobilisation of FCNR(B) deposits, correspondent banking relationships and cross-border trade finance. Strong capitalisation, improving profitability, stable asset quality and a granular retail funding profile underpin the outlook.

GST liability for insolvency and receivership services depends on the nature and specific classification of the service, not on whether the Insolvency Professional is enrolled as an Advocate. Insolvency Professionals constitute a distinct statutory class under the Insolvency and Bankruptcy Code and IBBI Regulations, and their services are separately classified from legal services. Applying the principle that a specific service description prevails over a general one, services rendered by an Advocate as an Interim Resolution Professional fall outside the reverse-charge category for legal services. Forward charge therefore applies, requiring GST registration, compliant invoicing and related compliance; reverse charge remains limited to legal services rendered in the Advocate's professional capacity.