Condonation of delay in filing a GST appeal was granted in writ jurisdiction despite the Appellate Authority's statutory inability to extend the limitation under section 107 of the RGST/CGST Act. Delay attributable to circumstances beyond the petitioner's control, coupled with the grave prejudice arising from refusal of merits review, justified relief. The High Court directed the Appellate Authority to entertain and decide the appeal on merits, subject to filing within the stipulated period.

Excess input tax credit demand required reconsideration because the disputed credit had been reversed and surplus credit remained in the Electronic Credit Ledger. The High Court quashed the demand order, which had confirmed the show-cause notice without a reply, and remitted the matter for fresh adjudication on merits. The taxpayer must file a reply to the show-cause notice with supporting documents within the stipulated period; otherwise, recovery may proceed in accordance with law.

GST adjudication requires consideration of the taxpayer's reply to the show-cause notice and a further opportunity of personal hearing before an adverse order is made on that reply. Inconsistent dates in the adjudication order and its annexure supported the inference that the subsequently filed reply had not been considered. The High Court set aside the adjudication and appellate orders and remitted the matter for fresh adjudication after personal hearing, subject to the stipulated further deposit. The original adjudication order would revive if the taxpayer failed to cooperate.

Statutory limitation under Section 73(2) of the Telangana GST Act governed the validity of the show-cause notice and assessment orders for financial year 2020-21. Issuance of the notice after the prescribed deadline, followed by assessment orders beyond the applicable cut-off, constituted a jurisdictional error. The time-barred proceedings, including the consequential recovery notice, were therefore set aside.

GST appellate remedy requires the statutory pre-deposit even where tax dues were paid during adjudication proceedings. Payment of the disputed tax, or a challenge to the correctness of tax or penalty, does not dispense with this filing condition; those issues must be determined on the appeal's merits. The petitioner could pursue the statutory appeal only after making the prescribed deposit and filing a delay-condonation application. The appellate authority was directed to consider the delay application sympathetically and, if satisfied, decide the appeal on merits.

Voluntary reversal of excess input tax credit, with applicable interest, before issuance of a demand-cum-show-cause notice eliminates further interest liability under section 73 of the CGST Act where revenue records verify the claim. The taxpayer's reversal was accepted as genuine, resulting in the first appellate order being set aside and the appeal being allowed. Any necessary demand appropriation must be issued by the proper officer within one month of communication.

Political contribution deductions supported by banking payment and a receipt from a registered unrecognised political party cannot be disallowed merely on general search material suggesting that the recipient operated a cash-back arrangement. Such material may warrant inquiry, but cash repayment to a particular donor requires assessee-specific evidence establishing a transactional nexus. Search presumptions do not establish cash receipt by a person from whose possession or control the material was not found, particularly where third-party material is not supplied and cross-examination is unavailable. An unexplained-money addition also requires proof that the assessee owned unrecorded money; inferred cash receipt based on alleged commission, without foundational evidence, is conjectural.

Interest on borrowed capital extends to service fees and other charges connected with money borrowed, debt incurred or a credit facility. Protection insurance, processing fees and annual maintenance charges paid in connection with a bank loan used to acquire a let-out property fall within this broader meaning where their genuineness and nexus with the borrowing are undisputed. Such charges are deductible as interest on borrowed capital in computing income from house property, and the related disallowance is not sustainable.

Reassessment beyond three years requires escaped income to meet the statutory threshold; where unaccounted purchases had corresponding sales and the embedded profit was separately assessed, only that profit constituted escaped income. Reassessment notices for AY 2014-15 to AY 2018-19 were therefore quashed. Material seized during a third-party search required notice under section 148 before assessment, rendering the direct AY 2022-23 assessment void. No cross-examination breach arose without a specific request, and the pre-amendment reassessment regime permitted a 30-day return period. Where corresponding sales were accepted, tax applied only to embedded profit, not the full unaccounted purchase value.

Surrendered excess stock and cash identified during a survey were characterised as business income where the taxpayer consistently offered them as miscellaneous business income, dealt regularly in the excess stock, and had no independent undisclosed asset or non-business income source. Such income was therefore taxable at normal rates. The enhanced rate introduced under section 115BBE applied prospectively from Financial Year 2017-18, corresponding to AY 2018-19, and did not apply to AY 2017-18. Disallowance of investment-related expenditure under section 14A was sustained as statutorily computed, and ad hoc disallowances of specified business expenses were also sustained where ledger extracts and cash payments did not justify interference.

Section 80C deduction omitted from an original return cannot be introduced through rectification of an intimation under section 143(1), because no such claim was made during return processing. Where evidence of an eligible fixed-deposit investment is available, the taxpayer may instead seek condonation to file a revised return and make the deduction claim in that return in accordance with law. The rectification claim remains unavailable, while the revised-return route is preserved subject to condonation.

For AY 2025-26, the section 87A rebate applied to income-tax computed on total income within the prescribed threshold, without excluding tax on short-term capital gains taxable under section 111A. Section 111A prescribed the applicable tax rate but did not bar the rebate. A subsequent restriction limiting rebate to tax computed under the concessional tax regime applied only from AY 2026-27 and could not operate retrospectively. Administrative circulars and procedural utilities cannot impose a substantive statutory restriction. Excluding tax attributable to eligible short-term capital gains from the rebate was therefore unsustainable, requiring recomputation and full rebate subject to verification of remaining eligibility conditions.

Appellate authorities must decide an income-tax appeal on its merits where it has not been withdrawn, notwithstanding the assessee's non-prosecution or failure to make further compliance. Dismissal without examining grounds challenging reassessment and additions for unexplained bank credits fails to discharge the appellate duty to adjudicate the issues raised. Challenges concerning audited books, business history and bank withdrawals require consideration after providing an opportunity to substantiate the contentions and produce supporting material. The appeal was restored for fresh appellate adjudication in accordance with law.

Unverified sundry creditors may be examined as unexplained credits; their classification alone does not preclude an addition. Business-expenditure disallowances cannot be substantially reduced without evidence substantiating the expenditure. Appellate relief deleting the creditor addition and reducing the expenditure disallowance was set aside because the assessee sought to produce evidence for the accounting entries and its tax-exemption claim. The additions and exemption claim were remitted to the Assessing Officer for fresh factual consideration on the evidence, without a decision on merits.

Belated furnishing of a charitable trust's prescribed audit report in Form 10BB, after uploading Form 10B, does not by itself justify denial of exemption. Applying the jurisdictional High Court ruling, ITAT required verification of the belated Form 10BB before granting the claim. The lower authorities' orders were set aside, and the exemption was directed to be allowed upon proper verification; the appeal succeeded for statistical purposes.

Section 271AAD authorises only the Assessing Officer, Joint Commissioner (Appeals) and Commissioner (Appeals) to initiate or impose penalty for false entries in books of account; it does not confer that power on the Principal Commissioner or Commissioner. Penalty is not automatic and requires a final determination that a false entry exists. Revisionary jurisdiction cannot be used to direct the Assessing Officer to commence section 271AAD penalty proceedings while the underlying disallowance of contract expenditure remains under appellate consideration. The revisionary direction was therefore legally unsustainable and was quashed.

Section 110A permits provisional release of seized goods pending adjudication subject to the bond, security and conditions required by the adjudicating authority. Dry dates were seized on allegations that their Pakistani origin had been misdeclared as United Arab Emirates origin, making their import prohibited on national-security and public-policy grounds. As a show-cause notice had been issued and adjudication was underway, the strategic nature of the import prohibition supported refusal of provisional release. The refusal was sustained, and the appeal for release of the goods was dismissed.

Extended limitation could not support recovery of Special Additional Duty on goods transferred from an FTWZ to a domestic tariff area unit because the exemption practice followed directions and decisions of SEZ and FTWZ authorities, including a chartered accountant's certificate. The Tribunal found no mala fides or suppression of facts intended to evade duty. As the entire demand lay outside the normal limitation period, the extended period was unavailable and the exemption's merits required no examination. The duty demand, confiscation and penalties were set aside, and Revenue's penalty-enhancement appeal was dismissed.

Voluntary statements made before Customs officers may serve as substantive evidence because Customs officers are not police officers for the statutory rule excluding police confessions. An unretracted statement, where no coercion is established and independent material corroborates its contents, may be relied upon to determine a Customs Broker's role in improper imports. Knowing advice to classify areca nuts under an incorrect tariff heading, claim an inapplicable exemption, and facilitate clearance of prohibited goods can establish abetment and justify penalties against both the Customs Broker and its director. The penalties were upheld because knowledge and intention were established through voluntary, corroborated evidence.

Absolute confiscation of imported computer hard discs was set aside because the goods had already been redeemed on payment of fine and were unavailable for further redemption; the confiscation merits had attained finality. Reliance on Supreme Court precedent supporting redemption meant that a subsequent absolute-confiscation direction was non-est in law. Enhanced penalties on the importer and its business head were also set aside because the original penalties were proportionate to the offence and market value had not been determined to establish the profit margin. The adjudication order allowing redemption and imposing the original penalties was sustained.