Service of a show-cause notice under section 37C(1)(a) requires evidence of actual delivery, not merely proof that it was dispatched by speed post. Where receipt is disputed, a dispatch register without an acknowledgment, delivery record, or comparable tangible proof does not establish effective service. Absence of proven service prevents valid continuation of proceedings, breaches principles of natural justice, and renders a service-tax demand time-barred and unsustainable.

Petitioner challenged provisional attachment orders affecting several bank accounts under the Customs Act, alleging unreasonableness, excessiveness, arbitrariness, and infringement of equality and trade-freedom guarantees. The relief sought included disclosure of attachment details, quashing of related show-cause notices, release of frozen accounts, and restraint on further coercive recovery action. The dispute concerned the scope and effect of customs-related provisional attachments and associated enforcement measures.

Weighted deduction for research and development expenditure in a recognised, certified facility is available where the expenditure is approved and genuine. Before 1 July 2016, the absence of a prescribed format to quantify the eligible deduction meant that Form 3CL could not govern quantification; digital expenditure-wise ledgers could suffice, and objections over separate books, staff use, or technicalities did not warrant denial. Disallowance of expenditure relating to exempt income may be computed under section 14A and Rule 8D where the Assessing Officer records satisfaction, investments generate exempt income, and administrative or managerial investment activity establishes indirect expenditure, particularly where the taxpayer has made no compliant computation.

Gains from shares and debt-oriented mutual funds held in an investment portfolio retain their character as capital gains notwithstanding separate trading in similar instruments. Long-term capital gains from such investments qualify for exemption under Section 10(38), while long-term and short-term gains cannot be recharacterised as business income solely because the taxpayer also carries on trading activities. Consistent treatment of the investment portfolio, supported by prior comparable determinations, sustains the distinction between investment holdings and trading stock.

Employees' ESIC and EPF contributions deposited after due dates prescribed by applicable welfare statutes are not allowable deductions in processing under section 143(1). Applying the binding requirement of timely deposit under the respective statutes, late payments are disallowed against the assessee. The disallowance applies where amounts were admittedly paid after the relevant statutory due dates.

Arm's length price of intra-group technical and stewardship service payments was sustained at nil because the taxpayer did not establish actual receipt or commercial benefit from the services. A broadly worded service agreement, without defined deliverables, cost-allocation methodology, performance benchmarks or validation mechanisms, did not substantiate the charges. General or post-period emails, brief managerial visits, and unsupported presentations or meeting notes were insufficient. Contemporaneous, verifiable evidence such as meeting records, training material, project documentation and identifiable service deliverables was required to demonstrate rendition and benefit of the intra-group services.

Cash-payment disallowance under section 40A(3) requires evidence that an impugned cash payment was claimed as expenditure in the profit and loss account. Where audited books and the tax-audit report remain unrejected, incomplete rough cash records alone do not establish such a claim, particularly without verification from alleged recipients. Cash deposits during demonetisation are not unexplained income when unrejected books record sufficient cash balances and bank evidence identifies the specified bank notes deposited. Additions based only on doubts, surmises, or conjecture cannot displace a recorded and credible source of deposits.

Interest or dividend income earned by a co-operative society from investments with another co-operative society is deductible under section 80P(2)(d). A co-operative bank falls within the definition of a co-operative society, while section 80P(4) only prevents the co-operative bank itself from claiming section 80P deduction; it does not bar another co-operative society from deducting interest received from deposits with that bank. Where competing interpretations exist, the interpretation favourable to the assessee applies. Accordingly, fixed-deposit interest earned by a co-operative housing society from a co-operative bank qualifies for deduction, subject to verification.

Section 271D penalties for contravening cash-loan restrictions are subject to the limitation period under Section 275(1)(c), consistent with CBDT Circular No. 10/2016. Where no assessment proceedings were initiated or completed for the relevant assessment years, the limitation limb linked to completion of proceedings does not apply. The Assessing Officer's reference to the Addl./Joint Commissioner initiates penalty proceedings; a subsequent Faceless Penalty Unit notice does not alter that date. Penalty orders passed after the resulting six-month deadline were barred by limitation and invalid.

Unappealed reassessment orders place the limitation for penalties under section 271(1)(c) within section 275(1)(c). The ordinary deadline expired on 30 June 2020, while pandemic-related relief under TOLA and applicable circulars extended it only until 30 September 2021. General limitation extensions granted during the pandemic could not enlarge this special statutory limitation regime. Once the prescribed period expired, the tax authority lacked jurisdiction to impose the penalty. Consequently, a penalty order issued on 23 November 2021 was time-barred and liable to be quashed.

Availability of a statutory appellate remedy despite delayed filing may be preserved where a substantial tax demand exists and the appellant asserts recent knowledge of the impugned order. An appeal filed within the permitted 30-day period must be entertained without rejection on limitation and decided on merits in accordance with law.

Objective and independent credit ratings measure CPSE financial strength, risk, credibility, and public-sector creditworthiness, supporting benchmarking and cost-effective access to global and domestic debt markets. Engagement between CPSE leadership and rating agencies focuses on rating methodologies, risk pricing, debt-market dynamics, transparent disclosures, and capital-structure optimisation. Such engagement is directed toward improving credit assessment, investor information, regulatory compliance, funding access at competitive rates, and market-facing disclosure practices.

Arunachal Pradesh substitutes the goods description at serial number 1, column (3), of the State Tax (Rate) Table. The entry now covers fly ash bricks, fly ash aggregates, and fly ash blocks. Made under statutory powers in the Arunachal Pradesh Goods and Services Tax Act, 2017, on the Council's recommendations, the substitution takes effect on 18 July 2022.

State Tax (Rate) commodity entries are revised under clause (ii) of the proviso to section 54(3). Serial number 1 becomes serial number 1AA, and serial numbers 1A to 1O are inserted. The added entries cover specified vegetable oils, vegetable fats and oils, edible mixtures or preparations, coal and manufactured solid coal fuels, lignite excluding jet, and peat including peat litter. The changes take effect on 18 July 2022.

State tax exemption under Notification No. 3/2017-State Tax (Rate) is amended by substituting the entry in column (4) against serial number 1 with "6%". The amendment, made under the Arunachal Pradesh Goods and Services Tax Act, 2017, takes effect from 18 July 2022.

Limitation for a suit seeking specific performance does not begin merely when a statutory restriction on alienation is repealed, because repeal is an uncertain contemplated event; it begins when performance is refused following notice. An agreement for sale that requires transfer of a prohibited fragment of agricultural holding is forbidden by law, except where the statutory contiguous-owner exception applies. Where the proposed sale violates that prohibition, the agreement is void ab initio and cannot be specifically enforced.

Insurance Web Aggregators in an International Financial Services Centre require registration, prescribed capital and net worth, professional indemnity insurance, fit-and-proper management, trained Authorized Verifiers, an India-hosted designated website, and dedicated operational infrastructure. IWAs must provide unbiased and current product comparisons, undertake needs-based solicitation, protect prospect data, use a secure Lead Management System, and share leads only in the permitted manner. Telemarketing and distance marketing require registered arrangements, explicit prospect consent, standardized disclosures, call-record retention and verification controls. IWAs must maintain records, address grievances, disclose material changes, comply with KYC and anti-money-laundering requirements, and may receive only permitted remuneration.

Arunachal Pradesh revises State Tax rate exemptions by applying the criterion "other than pre-packaged and labelled" to numerous listed food and agricultural commodities. Curd, lassi, buttermilk, jaggery, khandsari sugar and murki are expressly subject to this packaging-based limitation. Certain exemption entries are omitted, and "purified" is removed from a relevant description. "Pre-packaged and labelled" covers pre-packaged commodities whose package or securely affixed label must carry declarations under legal metrology law. The amendments take effect from 18 July 2022.

GST enforcement must adhere to statutory conditions, constitutional fairness and the rule of law rather than revenue targets. Input tax credit requires a reliable evidentiary trail establishing actual physical movement of goods, while bona fide purchasers and genuine recipients should not bear the consequences of a supplier's tax-payment default. Demand proceedings for fraud or wilful suppression require the essential statutory elements; absent those elements, such proceedings are unsustainable. Tax demands must also remain within the statutory scope of supply. A valid levy requires certainty regarding the taxable event, person liable, rate and measure of tax; ambiguity in any of these elements defeats the levy. Administrative authorities should address bona fide compliance errors proportionately and act as faithful trustees of statutory integrity.

Statutory restrictions on the sale of fragments apply to transactions that convey, lease, or transfer rights; an agreement to sell alone does not transfer title or ownership. An alleged statutory violation not pleaded or made an issue in the trial proceedings does not form the basis for challenging enforceability. Where the restriction has been repealed before institution of a suit for specific performance and execution of the sale deed would not contravene the repealed law, the agreement remains capable of specific performance.