Section 129(3) of the CGST/KGST Act imposes a mandatory seven-day period, measured from service of notice, for issuing a detention-penalty order concerning a transit-document discrepancy. The term "shall" requires strict compliance because the provision authorises coercive detention and seizure; the absence of an express consequence for delay does not make the limit directory. An order passed after the prescribed period is illegal and without jurisdiction, with consequential setting aside of the penalty and appellate orders and release of the bank guarantee.

Transfer-pricing comparability under the Transactional Net Margin Method may apply a turnover ceiling where it rests on a rational and logical basis, despite no prescribed turnover filter. Comparable entities must be closely aligned in functions, assets and risks because enterprise size and significant turnover differences can affect pricing. A software-product developer that owns intellectual property or develops and markets products is functionally distinct from a captive software-development service provider developing solely for its associated enterprise. Where the final comparable set has been determined, remand may be confined to reconsideration of identified exclusions rather than requiring a wholly fresh arm's-length-price exercise.

Internal comparables under the transactional net margin method should generally be preferred to external comparables where audited segmental accounts reliably distinguish associated-enterprise and non-associated-enterprise transactions. Segmental financials extracted from audited accounts may support arm's length price determination where a chartered accountant certifies both their mathematical accuracy and allocation on a generally accepted rational basis. A claim that segmental data were not maintained is unsustainable when the relevant segmental figures are demonstrably derived from audited accounts.

Section 152(3) preserves the pre-amendment reassessment regime for searches initiated from 1 April 2021 to 1 September 2024. Where information concerning an assessee arose from a third-party search within that transitional period, the former framework, including the relevant Explanation to section 148, remained applicable despite its omission. A direct reassessment notice under section 148 could therefore be issued without a prior notice under section 148A(b). The jurisdictional objection failed; the assessee could pursue the statutory appeal on the additions but could not reopen that jurisdictional issue.

Questions of law proposed in an appeal from a Tribunal's miscellaneous-application order must arise from that order, rather than from an unaltered finding in the original appellate order. Where the miscellaneous order only modified the terms of remand and left intact the finding that an accepted sale-and-purchase software transaction subject to arm's length price determination did not give rise to a dependent agent permanent establishment issue, challenges to that finding fell outside the appeal's scope. The Revenue's appeal was dismissed, while its right to challenge the original Tribunal order in accordance with law remained open.

Writ jurisdiction remained available despite a statutory appellate remedy because the disputed GST classification involved an apparent jurisdictional error of law without factual dispute; the non-functionality of the Tribunal when the petitions were filed also supported intervention. Licensing of copyright in cinematographic films by the original holder was classified as intellectual-property rights in goods other than information technology software: a passive audiovisual film lacks the computer-based manipulation or interactivity required for software, and its delivery method does not alter the supply's character. Pre-1 October 2021 GST regularisation at 12% on an "as is where is" basis extended to producer-to-distributor theatrical-rights licensing and could not be confined to downstream transactions, rendering the contrary classification and demands erroneous.

Selection of the most appropriate method for product replacement services supplied at nil sale price depends on the taxpayer's functional profile. Where the taxpayer acts only as a service provider and custodian of imported spares, without setting resale prices, selecting customers, or bearing attendant risks, TNMM applies rather than RPM for arm's-length price recomputation. Comparable selection for benchmarking those services is governed by settled transfer-pricing principles and does not raise a substantial question of law. The erstwhile five per cent tolerance range must be considered when recomputing the arm's-length price in accordance with applicable judicial principles.

Transfer-pricing studies for software development services cannot be rejected merely because comparability filters require modification when the taxpayer's functions, assets, risks, contractual terms, tested-party selection, databases and search keywords remain undisputed. Modified filters should instead be applied to the identified database, with the accept/reject matrix reviewed and functionally unsuitable comparables excluded before determining the arm's-length price. Interest on delayed associated-enterprise receivables is a separate international transaction where it is not aggregated with transactional net margin method margins after a working-capital adjustment; receivables and payables cannot be set off. The software-development arm's-length price and consequential delayed-receivables adjustment were restored for fresh consideration.

Transfer-pricing treatment of compulsorily convertible debentures turns on their legal status until actual conversion or redemption. Ind AS presentation of a component as equity within a compound financial instrument does not by itself change outstanding debentures from debt; interest remains allowable where reclassification is solely for financial-reporting purposes, subject to verification of conversion or redemption. Notional interest on delayed associated-enterprise receivables should not be imputed where comparable non-associated customers receive the same no-interest treatment and the taxpayer applies that practice consistently. The relevant principle is commercial uniformity across comparable transactions.

Cash deposits made during the demonetization period in bank accounts accepted as receiving business turnover cannot be selectively treated as unexplained money solely because of their timing. The deeming fiction applies only where the Revenue establishes its statutory conditions, including material linking deposits to an independent undisclosed source. Where deposits show no abnormality or disproportionality against admitted business, gross receipts cannot be assessed entirely as unexplained money; only the profit embedded in turnover is assessable. The separate addition for such deposits was deleted, while the determined business income remained undisturbed.

TNMM segmental comparability requires a reliable allocation of common operating expenses when OP/OC is used as the profit-level indicator. Information obtained from a proposed comparable does not itself establish the reliability of its segmental data. Because material entity-level expenses were not allocated to Datamatics Financial Services Ltd.'s BPO segment and no verifiable allocation basis was shown, its margin overstated profitability and the segment was excluded as an uncontrolled benchmark. Conversely, separately reported medical transcription, billing, coding and related IT-enabled service segments of Accentia Technologies Ltd. remained comparable: its distinct software development activity was identified and excluded, and no functional dissimilarity in the retained segments was established. Revenue's appeal and the assessee's cross-objections were dismissed.

Section 69 applies only to investments not recorded in the assessee's books of account. Immovable properties recorded in the firm's regular books, together with corresponding identifiable partners' capital contributions, cannot be treated as unexplained investments where the books have not been found defective or rejected. Concerns about an individual partner's financial capacity must be examined in that partner's assessment and do not, by themselves, make the firm's recorded investment unexplained. Principles applicable to unexplained cash credits do not govern recorded investments under section 69. The addition for unexplained investment was therefore deleted, while the reassessment challenge was left academic.

Belated electronic filing of Form No. 9A for deemed application of charitable income may be condoned where substantial compliance and sufficient cause are established. The administrative condonation remedy under section 119(2)(b) is additional and does not bar appellate consideration of an exemption claim after administrative condonation is refused. Filing during assessment proceedings in the first year of mandatory electronic filing, without evidence of deliberate or mala fide delay, supported condonation of the short delay. The delayed Form No. 9A was treated as valid, and the deemed-application claim was directed to be considered after verification of the remaining statutory conditions and a hearing.

Undisclosed-income additions for penny-stock transactions cannot rest solely on Investigation Wing information where recorded share purchases and sales show a loss and no substantive or corroborative evidence establishes unaccounted income. The ITAT therefore deleted that addition. It also deleted an estimated-profit addition for alleged share dealings: the taxpayer denied the transactions, and estimating profit from alleged turnover without substantive supporting material amounted to assumption, presumption and speculation. Both additions failed for lack of substantive and corroborative evidence.

Section 153C treats the recording of satisfaction, or receipt of seized records by the Assessing Officer of a non-searched person, as that person's deemed search date. Where that event occurs after 1 April 2021, proceedings under section 153C(3) are unavailable and reassessment under section 147 is the applicable route. A consolidated satisfaction note must also identify assessee-specific adverse material and explain its nexus to income alleged to have escaped assessment; generic references to digital devices or electronic evidence do not satisfy this requirement.

Admitted misdeclaration of imported used printers and accessories justified re-determination of customs value, which was sustained. Conditional redemption upon re-export is not permitted under the statutory scheme: where prohibited misdeclared goods cannot be cleared for home consumption and may only be re-exported, redemption fine is unjustified and was deleted. Misdeclaration of prohibited imported goods continues to attract penalty under Section 112(a)(i), although the penalty was reduced because redemption was unavailable. Section 114AA applies to business transactions involving false or incorrect information, rather than only fraudulent exports, and that penalty was sustained.

Interim status quo orders are discretionary protective measures intended to preserve the subject matter pending adjudication. Parties ordinarily should seek vacation or modification before the forum that granted such an order before pursuing appellate interference. In winding-up proceedings, disputed share transfers and the absence of prima facie evidence of active business operations supported preservation of the company's affairs. The status quo direction and arrangements safeguarding company funds continued pending expedited determination of the company petition, and appellate relief was refused.

Section 96(4) of the Insolvency and Bankruptcy Code, effective 26 May 2026, applies retroactively to pending applications under Sections 94 and 95, ending the interim moratorium for personal guarantors from that date. The pre-admission process is procedural, so no vested right arises in interim protection; retroactive operation addresses misuse of that protection. Interim orders in securitisation proceedings require contemporaneous written reasons addressing prima facie case, balance of convenience and irreparable loss. Oral directions cannot support restoration of secured-asset possession. Restraints on auction completion or sale certificates without hearing auction purchasers breach natural justice; the restoration and auction restraints were set aside.

Writ jurisdiction remains available despite an alternate statutory remedy where the challenge concerns seizure power, jurisdictional facts or deficient administrative decision-making, although factual merits remain for the statutory authority. Foreign-exchange seizure powers cannot retrospectively reach completed pre-commencement transactions, but may extend to actual payments made after commencement under a continuing arrangement. Connected financial transactions may be examined as a whole to establish a preliminary reason to believe, and recorded reasons cannot later be replaced by new grounds. Regulatory and tax proceedings do not preclude an independent foreign-exchange inquiry. Refusal of an overseas-investment no-objection certificate requires disclosed, rational reasons linked to the investigation; the unreasoned refusal required fresh consideration.

Indivisible composite construction contracts involving transfer of property in goods and VAT payment under the works-contract composition regime could not be subjected to service tax as erection, commissioning and installation service during October 2005 to March 2007. The applicable Finance Act framework covered service-only contracts and lacked charging and valuation machinery to separate and tax the service element of an indivisible works contract. Constitutional allocation of taxing powers also required exclusion of the goods component. A distinct taxable category for works-contract service was introduced only after that period.