Proposed amendments to Section 46 of the Customs Act, 1962 would mandate advance filing of Bills of Entry before the end of the day preceding arrival of imported goods for home consumption or warehousing. The requirement is intended to facilitate pre-arrival processing and assessment and reduce clearance time. The Board may prescribe different deadlines for specified cases, but not later than the end of the day of arrival. Possible relaxation for certain land, airport, neighbouring-country and short-haul imports remains subject to the amendment taking effect.

Registration compliance requires bank-account details within 30 days of registration or before filing FORM GSTR-1 or using the invoice furnishing facility, whichever occurs first. Non-compliance may result in suspension and restriction on FORM GSTR-1 filing until compliance. Where input tax credit availed in FORM GSTR-3B exceeds credit reflected in FORM GSTR-2B beyond prescribed thresholds, FORM GST DRC-01C requires payment with interest or an electronic explanation within seven days. Unpaid and unexplained differences may proceed to demand, and recovery of unpaid recoverable amounts may be initiated through FORM GST DRC-01D.

Provision for doubtful debts unsupported by evidence or write-off is not an ascertained liability for book-profit computation under section 115JB, and unsubstantiated expenditure and unidentified unclaimed liabilities remain disallowable or taxable. An ad hoc expense disallowance is impermissible where business expenditure is accepted and books are not rejected. Software licence and maintenance costs require item-wise assessment of purpose, duration, recurrence and enduring benefit. Foreign-exchange hedging and marked-to-market gains require a direct export nexus for deduction under section 10A. Excess dividend distribution tax requires verification for refund, while employee stock-option discount is allowable business expenditure.

Section 46 requires advance filing of Bills of Entry, generally by the end of the day preceding arrival, subject to mode- and consignment-based exceptions. Airport and Land Customs Station imports may be filed by the end of arrival day, while specified seaport consignments receive the same deadline. Late filing attracts late charges. Advance Bills of Entry may be filed with House Bill of Lading or House Airway Bill details where master transport documents are unavailable. The Master Bill of Lading or Master Airway Bill may later be updated through an automated, fee-free online amendment.

GST search powers require seized documents, books and things to remain with the proper or authorised officer only while necessary for examination, inquiry or proceedings; returning custody while retaining seizure is inconsistent with that scheme. Material still required may be taken into fresh custody through a fresh seizure order linked to the original seizure. A prohibition order may apply only to goods liable to confiscation where physical seizure is impracticable, not to office equipment, files, documents, books or things that are not confiscable goods; the prohibition order was quashed. Sealing premises is permissible only during an ongoing search when access is denied, not after search completion to store seized material; de-sealing and restoration of possession were directed.

GST registration cancelled for non-compliance may be considered for revocation where pending returns are filed, tax liabilities are paid and late fees are deposited. Filing returns shortly after cancellation supports fresh consideration because permanent cancellation can restrict the taxpayer's ability to conduct business. Revocation applications should be assessed by the competent authority after compliance with return-filing, tax-payment and late-fee requirements. The appellate and revocation-rejection orders were set aside, and the revocation application was remitted for fresh consideration within two months.

Non-consideration of an assessee's detailed reply to a GST show cause cum demand notice violates principles of natural justice. An ex parte adjudication order passed without addressing that reply is infirm and perverse. The High Court therefore quashed the order and remitted the matter for fresh, independent and reasoned adjudication after an effective opportunity of hearing. No merits of the underlying GST demand were decided.

Writ jurisdiction against CGST Orders-in-Original is unavailable where the statutory appeal provides an efficacious and comprehensive remedy for reviewing facts, law, evidence and adjudicatory correctness. Objections concerning hearing, notice service, technical difficulties, evidentiary authentication, corroboration, cross-examination and voluntary payment require record-based factual assessment by the appellate authority. Neither patent lack of jurisdiction nor a manifest, common breach of natural justice was established to justify bypassing that remedy. Petitioners who had already invoked the statutory appeal could not simultaneously pursue writ relief over the same order without exceptional circumstances. The writ petitions were dismissed, with merits left open for appellate consideration, including any request to exclude time spent in writ proceedings according to law.

Input tax credit under section 16(5) of the CGST Act is a retrospective statutory entitlement where relevant returns were filed within the prescribed cut-off. Failure to submit a rectification application within the period set by a departmental circular does not by itself defeat that entitlement. The denial of credit was quashed because the show-cause notice acknowledged timely filing under section 16(5), and the claim was remitted for reconsideration, subject to satisfaction of other eligibility conditions.

Amortised write-offs of the net realisable value of advances and goodwill arising under a High Court-approved amalgamation scheme were treated as allowable miscellaneous expenses. Identical claims for the immediately succeeding assessment year had been accepted by the Tribunal and affirmed by the jurisdictional High Court. The claims were disclosed in the accounts and represented a legally permissible treatment under the approved amalgamation scheme. The binding earlier determination governed the identical issue, supporting allowability in favour of the assessee.

Valuation-based additions for unexplained construction investment require rejection of the books before a Departmental Valuation Officer's report can support an addition. Additional evidence may be admitted where delayed production is reasonably explained and the material is examined in remand without authenticity concerns. Capital and cash-credit additions fail where banking records, PAN details, returns and confirmations establish identity, creditworthiness and genuineness without rebuttal. Adequate interest-free funds support the presumption that interest-free advances came from those funds. Depreciation on vehicles within a block of assets remains allowable despite personal-use disallowance of vehicle expenses. Books cannot be rejected solely for absence of a stock register, and uncorroborated, unconfronted third-party material cannot sustain unexplained-investment additions.

Refund allowed in an assessee's appeal may be released despite a pending departmental appeal before the Tribunal where no hearing has been fixed. Withholding was considered unwarranted given the petitioner's status as a manufacturing company and its undertaking to deposit any liability ultimately arising if the departmental appeal succeeds. Release was made conditional on furnishing that undertaking and a certified copy of the order, with the Revenue directed to issue the refund within six weeks. The departmental appeal remained subject to adjudication by the Tribunal.

Electronic service of GST show-cause notices and adjudication orders requires more than uploading them to the 'View Additional Notices and Orders' tab of the GST Common Portal. Portal-only uploading does not constitute proper service under the CGST Act unless the recipient acknowledges receipt or responds. A retrospective amendment permitting functions under the GST Rules to be performed through the portal does not expand the portal's specified functions or replace formal statutory service. The writ petition was disposed of consistently with the established position on deficient portal-only service.

Section 171(1) requires suppliers to pass any additional input tax credit arising from GST implementation to recipients through a commensurate price reduction. Project-specific CA-certified data was accepted because statutory records consolidated figures across projects and could not provide a project-wise split. The post-GST ratio of credit availed to purchase value had declined, showing that no additional input tax credit accrued. Transitional VAT credit passed to eligible purchasers did not concern the applicant, whose agreement was executed after GST implementation and for whom no corresponding VAT credit arose. The DGAP report was accepted and profiteering was not established.

Appeals under the advance ruling mechanism lie before the Appellate Authority only against an advance ruling pronounced under section 98(4) of the CGST Act. An order rejecting an advance ruling application under the first proviso to section 98(2) does not constitute such a ruling. Consequently, an appeal against rejection of the application is not maintainable under section 100(1), and was held inadmissible.

Entry No. 128 exempts uncoated paper and paperboard under Heading 4802 only when actually used to manufacture exercise books, graph books, laboratory notebooks or notebooks. Tariff classification alone does not establish eligibility: the use-based condition requires a factual end-use relationship, and purchaser declarations, purchase orders or contractual terms evidencing intended use are not conclusive. Exemption notifications require strict construction and cannot be expanded through unstated certification or verification requirements. As no statutory framework prescribes end-use certificates, bonds, monitoring, diversion consequences or records, the Advance Ruling Authority cannot recognise purchaser documents as a legally sufficient compliance mechanism. The manner of availing the exemption falls outside advance-ruling jurisdiction.

Compostable polymer bags and packing materials made from PLA and PBAT blends are classifiable as plastic articles for the conveyance or packing of goods under heading 3923 2990, rather than as paper products under Chapter 48. Eligibility for the concessional GST rate applicable to biodegradable bags depends on compliance with the separate standards for biodegradable plastics, including IS 17899 T:2022 and the required CPCB certification. Certification as compostable under IS/ISO 17088 does not establish that the goods are biodegradable, particularly because the biodegradable-plastics standard excludes compostable plastics within that regime. Such compostable bags are therefore outside the concessional entry for paper sacks, bags and biodegradable bags.

Erroneous bank information concerning a term deposit could not support reassessment for assessment year 2015-16 when it was the sole basis for the notice and the normal three-year period had expired. Extended-period reassessment required satisfaction of the statutory conditions, which technical or system-generated erroneous data could not meet. The notice seeking an explanation, together with the consequential reassessment, assessment and penalty orders, was set aside. The writ petition succeeded, and costs were directed against the Bank for providing the incorrect information.

Dispute Resolution Panel directions bind the Assessing Officer when an eligible assessee files timely objections to a draft assessment order. A bona fide failure to separately intimate the Assessing Officer of those objections, where it causes no advantage or prejudice, does not justify ignoring the Panel's directions. Where the transfer-pricing order forming the sole basis of the final assessment has been revised pursuant to those directions, an assessment based on the superseded order is unsustainable. The final assessment, consequential demand and penalty-initiation notices were set aside, and the assessment was restored for fresh completion in conformity with the Panel's directions and revised transfer-pricing order.

Reassessment notices must be initiated through the faceless assessment framework rather than by the Jurisdictional Assessing Officer where algorithm-based random allocation governs reassessment proceedings. A final assessment order issued under the faceless regime does not cure the initial jurisdictional defect. Where the final order is already challenged before the Commissioner of Income Tax (Appeals), the jurisdictional objection should be raised and considered in that statutory appeal, applying the relevant High Court precedents. The assessment order need not be independently quashed in writ proceedings when the pending appeal can address the objection.