Cash payments towards credit-card dues used for trading purchases were treated as connected to business transactions, not wholly unexplained money. As the cards were not shown to have funded capital acquisitions or personal expenditure, taxing the full payments would tax gross receipts rather than real income. Under the presumptive-taxation scheme, the disclosed profit rate was accepted as fairly representing business profitability in the absence of contrary Revenue material. Accordingly, only the profit element in the cash payments could be added, while the balance was to be deleted.

Reasonable cause under the Income-tax Act protected an educational trust from penalty for non-compliance with notices issued during the COVID-19 pandemic. The disruption, the trust's bona fide belief regarding exemption, subsequent participation in assessment proceedings, and remand of the quantum proceedings supported its explanation. In the absence of independent material showing deliberate or wilful disregard, the default was treated as technical or venial. Although penalty proceedings are independent of assessment proceedings, reasonable cause rendered the penalty unsustainable and required its deletion.

Unexplained investment under Section 69 was deleted where confirmations, tax returns, financial statements, ledger accounts, bank records and fund-flow evidence established the source and movement of funds, including direct banking-channel payments to the property seller. Once this initial burden was discharged, contrary material was required to treat the investment as unexplained. Cash deposits under Section 69A were treated as explained to the extent supported by disclosed professional, interest and rental income, since disclosed cash cannot ordinarily be taxed again merely on bank deposit. However, insufficient records supported the opening cash balance, so only 50% of that balance remained taxable as unexplained money.

Share-sale proceeds and long-term capital gains cannot be treated as unexplained cash credits merely on general penny-stock investigation material where the taxpayer substantiates the transactions through share application records, broker notes, banking channels, demat statements, stock-exchange sale records and securities transaction tax payment. Cogent evidence must connect the taxpayer to price manipulation, sham transactions or accommodation entries; absent such evidence, the addition is deleted. Estimated commission expenditure for an alleged accommodation entry also cannot be added as unexplained expenditure when it is only consequential to the rejected cash-credit allegation and lacks independent evidence of expenditure.

A notice under Section 143(2) in reassessment proceedings following Section 148 is required only where the Assessing Officer considers verification of income, loss or tax liability necessary or expedient. A return filed in response to reopening is treated as a Section 139 return, and participation in reassessment may invoke the deemed-service rule under Section 292BB. A business-loss disallowance may be examined where it directly relates to the income forming the recorded basis for reopening; the factual validity of the write-off remains examinable through the statutory appellate process.

Following a search initiated after 1 April 2021, a timely pending original assessment may be completed under Section 143(3); reassessment under Section 148 is not mandatory. The post-2021 framework does not expressly bar scrutiny assessment after a Section 132 search, and Section 132(8) recognises Section 143(3) assessment concerning seized material. Explanation 2 to Section 148 applies where a completed assessment or intimation is followed by search, or the period for regular processing or scrutiny has expired; it does not replace an original assessment that remains pending within limitation. Timely issuance of notice under Section 143(2) and completion of assessment support validity.

Compounding fee must be recomputed under the CBDT Guidelines dated 16.05.2008 because their applicability had already been conclusively determined between the parties and affirmed in appeal. A direction to calculate and communicate the fee concerned quantification only and could not reopen the settled governing framework. The power to issue compounding instructions cannot displace a final inter partes judicial determination. The revised 2024 Guidelines were also inapplicable because the compounding application had not been rejected for a curable defect contemplated by those Guidelines. The recomputation must credit the amount already paid by the assessee.

Section 194A(3)(v) exempts a co-operative bank, as a co-operative society, from deducting tax at source on interest paid to non-member co-operative societies. The provision's exemption for payments by one co-operative society to another does not exclude co-operative banks, and the CBDT clarification confirms its application to interest on time deposits. Recipient societies' deductions under Section 80P(2)(d) concern their assessments and do not alter the payer's independent TDS obligation. As no TDS obligation arises on such payments, the bank cannot be treated as an assessee in default or charged consequential interest.

Retrospective expansion of taxability for offshore technical-service payments under Section 9(1)(vii) cannot displace relief available under the law in force when the payments were made. The Finance Act, 2010 Explanation removed the requirement that services be rendered in India and substantively widened the charging provision; it therefore operates prospectively where retrospective application would create a fresh tax liability or remove vested benefits. A later legislative amendment does not justify review of a concluded decision. Treaty protection under Article 12(4) of the India-USA DTAA remains available where more beneficial under Section 90(2), and withdrawal of beneficial Board circulars operates prospectively.

An assessee's appeal under Section 260A requires a substantial question of law. Challenges to refusal of delay condonation based on medical evidence and to stamp-duty-based property valuation were characterised as factual matters requiring reappreciation of evidence, not issues of statutory interpretation, conflicting legal views, or perversity. The tax-effect restrictions applicable to Revenue litigation do not remove an assessee's obligation to establish the statutory jurisdictional threshold. Accordingly, factual disputes over delay and valuation alone do not make a Section 260A appeal maintainable.

A statutory appeal or remand cannot be made contingent on payment of costs where automatic default consequences would revive an ex parte appellate order passed without adequate hearing. Although procedural costs may be imposed under appellate powers, they cannot defeat the substantive right to merits adjudication or validate an order affected by breach of natural justice. A reasoned first-appellate order must identify the points for determination, decisions and reasons. For cash-credit additions, the assessee must establish the lender's identity, creditworthiness and transaction genuineness; banking and corporate evidence requires independent factual evaluation rather than reliance on generalized third-party information. Fresh de novo adjudication is required where that evidence has not been effectively considered.

Paper bags and sacks classifiable under Tariff Item 48194000 of Heading 4819 fall within Entry 319 of Schedule I to Notification No. 09/2025-Central Tax (Rate). The entry expressly covers paper sacks and bags under Chapters 39 and 48, and the reference to biodegradable bags does not limit coverage to paper bags that are independently biodegradable. Accordingly, such paper bags attract GST at 5% rather than the higher Schedule II rate.

Ophthalmic binocular surgical microscopes specially designed for eye examination and delicate eye surgery are classified under tariff heading 9018 as medical or surgical instruments, rather than heading 9011 for general optical microscopes or heading 9012 for non-optical microscopes. The HSN notes expressly distinguish ophthalmic binocular-type microscopes mounted on adjustable supports for medical use. As goods of heading 9018, these microscopes fall within Entry 483 of Schedule I to Notification No. 09/2025-Central Tax (Rate) and attract the concessional 5% rate.

Condonation of a 418-day delay in filing a writ appeal requires credible and supported sufficient cause. Bereavement and hospitalisation assertions without particulars or records do not establish such cause. A belief that relief could be pursued before the GST Appellate Tribunal is untenable where the petitioner had approached the High Court because that Tribunal had not been constituted. An extension for filing appeals before the Tribunal does not cure delay in filing a writ appeal. Registration and return-filing deficiencies also did not justify appellate intervention; condonation was therefore refused.

Physical application for revocation of cancelled GST registration was permitted despite expiry of the ordinary statutory period. In the stated circumstances, the petitioner could approach the competent authority with a physical application within two weeks. The authority was required to entertain the application and decide it in accordance with law within three weeks of its submission.

Retrospective application of amended Rule 42(3) of the Central Goods and Services Tax Rules, 2017 was challenged in relation to reversal of input tax credit, interest and penalty for credit availed before the amendment took effect on 1 April 2019. The petition was withdrawn after the availability of an appellate remedy before the GSTAT was noted. The petitioner was permitted to file an appeal with the statutory pre-deposit and raise all available questions of law and fact.

A provisional attachment under Section 83 remains effective for one year from its date. Where that statutory period expires before disposal of a writ petition, the attachment ceases to operate by efflux of time, leaving no subsisting order for adjudication. A challenge directed solely against the expired provisional attachment therefore does not survive.

Statutory appeal limitation under GST permits restoration where the appeal is filed within the legally condonable period but lacks a delay-condonation application. The FORM GST DRC-07 summary was uploaded on the portal within the relevant period, and the appeal was filed within the further condonable period. The time-bar dismissal was set aside, requiring the appellate authority to consider delay condonation under law and, if satisfied, decide the appeal on merits.

Release of detained perishable goods under the owner-specific limb of section 129(1) depends on the claimant establishing ownership. Where the adjudicating authority found that the claimant was not the owner and the owner could not be traced, release could not be claimed under section 129(1)(a), although the claimant could seek release as a non-owner under section 129(1)(b). The direction to auction the goods while permitting the claimant to participate was set aside because non-ownership did not justify that direction. Release of the vehicle to its registered owner remained sustained, and the detention authority's jurisdiction remained open for adjudication in writ proceedings.

Section 73 demand proceedings based on alleged undervaluation of guarantees require prior scrutiny, audit, inspection or investigation to establish tax leakage and suppressed taxable value. Where authorities issue and confirm a demand without determining whether the guarantees are corporate guarantees or verifying the alleged suppression, the demand lacks the necessary factual foundation. The demand-confirming order was quashed, and the matter was remitted for inspection or investigation and fresh determination if warranted.