Consistent treatment of depreciation is required when calculating operating profit to operating cost margins under the Transactional Net Margin Method. Including depreciation in the assessee's operating costs while excluding it from comparable companies' costs produces a non-comparable operating-margin analysis. On excluding depreciation consistently, the assessee's profit level indicator exceeded the arm's length margin and its operating revenue exceeded the computed arm's length price. The international transactions were therefore treated as being at arm's length, and the transfer-pricing adjustment was deleted.

Section 148A(b) requires that a person receive at least seven days to respond before reassessment proceedings are initiated. A notice allowing only five effective days, or six days including its issue date, fails to meet that mandatory minimum and invalidates the notice and reassessment founded on it. Where the reassessment addition is deleted because the proceedings are void from the outset, a penalty under Section 271AAC(1) that depends on that addition has no surviving basis and is unsustainable.

Section 69C additions for alleged bogus or unaccounted purchases require reliable evidence connecting the taxpayer to the expenditure. Uncorroborated parallel tally data recovered from a third party, without purchase invoices, delivery proof, payment evidence, transport records or independent verification, cannot by itself support such an addition where the taxpayer's contrary records remain unrebutted; the addition was therefore deleted. Reliance on third-party statements or seized material without allowing cross-examination or confrontation of underlying details also breaches principles of natural justice and independently undermines the addition. Unexplained-expenditure charges cannot rest solely on untested third-party search material.

Approval of a resolution plan under Section 31(1) binds all stakeholders, including governmental authorities, and extinguishes claims omitted from the approved plan. Where Revenue does not lodge its claim during the corporate insolvency resolution process, reassessment proceedings and consequential tax demands concerning the pre-resolution-plan period cannot be initiated or continued. Such unsubmitted tax claims do not survive resolution-plan approval, preventing further recovery action for the relevant period.

Reassessment may be initiated only on information suggesting that income chargeable to tax has escaped assessment. A GST adjudication order was not shown to constitute qualifying information under the applicable risk-management strategy. Proceedings under the Income-tax Act must therefore be undertaken independently and cannot rest solely on GST adjudication or the result of a related GST appeal. On the available preliminary record, the reassessment notice was not quashed; challenges to any resulting reassessment order remain available in accordance with law.

Reassessment following a completed scrutiny assessment is invalid where it revisits a share-sale transaction, valuation, purchaser credibility, genuineness and capital-gains exemption already examined and accepted after detailed inquiry. An assessment order need not record every query or reasons for accepting a claim; inquiry and acceptance establish formation of opinion. Reopening on the same material therefore constitutes a change of opinion. A new objection to an exemption claim that was not stated in the show-cause notice cannot support reopening, and recorded reasons cannot be supplemented through an affidavit or oral submissions. The reassessment notices and consequential proceedings were quashed.

E-invoicing for coaching supplies is mandatory where a notified supplier exceeding the applicable turnover threshold makes a genuine supply to a registered recipient. Recipient status depends on contractual liability to pay the consideration, assessed from enrolment and contractual terms; payment of fees or provision of a GSTIN alone does not establish that status. The supplier's e-invoicing obligation is independent of the recipient's intended business use or entitlement to input tax credit. Input tax credit remains governed separately, with the claimant bearing the burden of proving eligibility. Individual transaction genuineness, business-to-business classification, and credit entitlement remain open to examination.

Papad Khar, manufactured from sodium chloride, sodium carbonate and sodium bicarbonate, is classified by its composition, manufacturing process and functional character under tariff item 28362090, rather than as salt under Heading 2501 or yeast or prepared baking powder under Heading 2102. It is treated as an inorganic carbonate preparation taxable at 18% GST under the applicable Schedule II entry. Exemption available to finished papad does not automatically extend to Papad Khar as an input or processing ingredient. Inputs and finished goods require independent tariff classification and tax treatment, and Papad Khar does not fall within the claimed exemption entries.

Urgent GST appeal listing may be granted where sufficient cause justifies limited exemption from ordinary Registry scrutiny. Inherent procedural powers, urgent-matter procedures and early-hearing mechanisms support procedural relaxation to secure substantial justice, without dispensing with substantive statutory requirements. Continuing inability to conduct business following GST registration cancellation established the pleaded urgency. Urgent-hearing relief was granted and the main appeal was directed to be listed for admission.

Section 112(3) governs the time for filing an appeal before the Tribunal and does not impose a separate six-month limit on the Commissioner's review of a first appellate authority's order. The departmental appeal was filed within the applicable extended limitation period. The objection to its maintainability, based on alleged delay in the review order, was rejected, and the appeal was admitted for hearing on merits.

Section 16(5), retrospectively effective from 1 July 2017, overrides the Section 16(4) time limit for input tax credit on invoices or debit notes relating to financial years 2017-18 to 2020-21 where the Section 39 return was filed by 30 November 2021. Input tax credit claimed through a 2018-19 return filed on 30 October 2019 therefore falls within the extended period and cannot be denied solely as time-barred under Section 16(4). Credit eligibility remains conditional on compliance with all other statutory input tax credit requirements.

Breach of principles of natural justice formed the primary challenge to the tax-demand order, with the petitioner asserting that substantial recovery had already been made. Subject to verification and confirmation of the prior recovery, the impugned order was set aside and the matter remanded for reconsideration after providing a reasonable opportunity.

Retrospective extension of the time limit for claiming input tax credit permits eligible registered persons to claim credit where returns were filed within the period prescribed under Section 16(5). A limitation-based denial under Section 16(4) cannot be sustained in such circumstances. The extended period applies retrospectively, allowing the taxpayer to obtain input tax credit despite the earlier time-bar objection, provided the statutory conditions for eligibility and timely return filing under the extended provision are met.

Further adjudication on merits is conditioned on the petitioner depositing an additional portion of the disputed tax within the stipulated period and filing a reply with supporting documents to the show-cause notice. The issue arises from non-participation in consequential proceedings after the death of the person who conducted the business, despite an earlier deposit of part of the disputed tax and expiry of appellate limitation. Upon compliance, the adjudicating authority must issue due notice and determine the matter on merits.

Personal hearing under Section 75(4) requires effective advance intimation of hearing dates through the common portal. Where the last three hearing dates are not communicated and that omission is undisputed, the mandatory hearing requirement is not met. The resulting breach requires fresh adjudication after adequate advance notice, preserving the petitioner's opportunity to be heard.

GST appellate delay arising from defective portal-based communication may warrant condonation where a show-cause notice and adjudication order are uploaded under a non-designated portal tab, preventing effective knowledge and resulting in an ex parte demand. Although the statutory appellate authority is confined by the prescribed limitation for condoning delay, portal uploading without acknowledgement or response may not constitute sufficient service in such circumstances. Denial of adjudication on merits would cause grave prejudice; accordingly, the delayed appeal was directed to be entertained and decided on merits.

Effective service of GST notices and adjudication orders through the designated portal tab is material to an assessee's ability to pursue a statutory appeal. Although section 107 of the Rajasthan and Central GST laws restricts the Appellate Authority's power to condone delay, uploading communications under an incorrect portal tab, followed by delayed recovery action, may establish lack of effective knowledge of the proceedings. In such circumstances, refusing merits adjudication would cause serious prejudice. The delay was condoned, allowing the assessee's appeal to be entertained and decided on merits if filed within the stipulated period.

Delay in filing a statutory GST appeal may be condoned where an ex parte order uploaded only on the common portal did not come to the taxpayer's knowledge within the prescribed limitation period. Although section 107 of the Rajasthan and Central GST laws binds the Appellate Authority to statutory timelines, portal-only uploading and the resulting lack of knowledge may constitute circumstances beyond the taxpayer's control. Restoring the appellate remedy prevents prejudice from denial of adjudication on merits, enabling the appeal to be entertained and decided on merits.

Writ jurisdiction was declined where a GST demand could be challenged through an available statutory appeal that had not been invoked. The petition was filed more than a year after the demand order, and neither the merits of the demand nor the alleged breach of natural justice was adjudicated. The petitioner was required to pursue the statutory appellate remedy.

Restoration of an appeal dismissed for non-appearance was addressed where the petitioner's auditor or tax consultant could not attend notified hearings. The stated inability to attend was treated as sufficient grounds to reopen the appellate proceedings, while protecting procedural discipline through costs and a direction to appear before the appellate authority. The dismissal order was set aside, the appeal was restored for adjudication on merits subject to payment of costs, and the merits remained open.