Section 148A(1) requires disclosure of information suggesting escaped income, but not the source from which that information was obtained; a notice and annexure sufficiently identifying the proposed reassessment basis enable an effective response. A determination under Section 148A(3) must nevertheless examine an assessee's material claim that the income proposed for reassessment was already included and taxed in an earlier assessment year. Addressing only the abstract taxability of the amount, without verifying prior inclusion from available returns and supporting material, is insufficient and vitiates the reassessment decision-making process.

TDS credit must be granted, with consequential relief, where deduction from the assessee's income is verified even if the deductor failed to remit the tax to the Central Government. Section 205 protects the assessee from recovery of tax already deducted, and an insolvency claim against the deductor for unpaid receivables does not bar the credit claim. An intimation determining tax payable is enforceable as a demand only upon mandatory service on the assessee. Where service cannot be proved, the demand cannot support recovery proceedings or adjustment of refunds under Section 245.

Refunds crystallised after TDS assessment or appellate relief constitute vested rights payable with applicable interest. Sections 200A and 201 operate separately: processing and adjustments of TDS statements under section 200A may involve Rule 31A and Form 26B, but those requirements do not govern refunds determined under section 201 or appellate orders. Form 26B cannot therefore be made a compulsory condition for such refunds. Outstanding demands against the assessee or related TANs cannot justify withholding or adjusting the refund unless a valid adjustment order is passed under section 245.

Revisional jurisdiction does not arise where an assessment allowing deduction for interest on advances to members contains no error prejudicial to revenue interests. The deduction was restricted to the assessee's gross total income, while the record did not establish that interest from fixed deposits with a non-cooperative bank had been claimed as deductible. Nor did it support allocating expenditure to further restrict the deduction. The revisional order therefore lacked jurisdiction, and the assessment order remained valid.

Pending statutory appeals against reassessment proceedings must be decided within 12 weeks where they raise objections to the validity of sanction and the absence of a mandatory Document Identification Number in approval. The appellate authority must consider these grounds, including additional grounds, in the statutory appellate process. No merits determination was made on whether the sanction had been granted by the correct authority or whether the approval was defective for want of a Document Identification Number.

Penalty for concealment or furnishing inaccurate particulars cannot survive where the sole underlying bad-debt disallowance has been deleted and that deletion stands confirmed. With no surviving tax addition, there is no basis to sustain penalty in respect of alleged concealment or inaccurate particulars linked to that addition. Penalty under Section 271(1)(c) was therefore deleted in favour of the assessee.

Statutory housing boards performing housing-development functions can pursue objects of general public utility and remain eligible for tax exemptions under Sections 11 and 12. Recovery of charges for public statutory functions does not by itself make the activity commercial; its character depends on the statutory objects, functions, regulatory controls, nature of receipts, and whether charges substantially exceed costs with only a nominal mark-up. Section 2(15), read with Section 13(8), therefore does not deny charitable-exemption benefits where housing activities continue to serve public functions.

Section 90(2) gives priority to a Double Taxation Avoidance Agreement where its provisions are more beneficial to the assessee. Section 206AA operates as a procedural tax-withholding requirement and does not displace a beneficial treaty rate for payments to non-residents. Tax need not be deducted at the higher rate solely because the non-resident deductee has not furnished a permanent account number when the applicable treaty prescribes a lower rate. The treaty rate consequently governs tax deduction at source in such circumstances.

Article 226 writ jurisdiction is discretionary and ordinarily should not be used to challenge reassessment proceedings where the reassessment order itself is not impugned and the taxpayer has already pursued a pending statutory appeal against that order. Invoking an effective statutory remedy for the same cause precludes parallel proceedings seeking substantially the same relief through writ jurisdiction. The reassessment challenge is therefore not maintainable, and no writ interference is warranted while the statutory appeal remains pending.

Fresh Isabgol seed exemption depends on the condition of psyllium seeds when supplied. Psyllium seeds classified under tariff item 1211 90 13 qualify for the heading 1211 exemption only if fresh or chilled; intentionally dried goods attract 5% GST. Procurement through APMC auctions and storage in dry, ventilated godowns were treated as drying, while no evidence established that the seeds remained fresh between harvest and onward supply. Consequently, the supplies do not qualify for the exemption for fresh Isabgol seeds and are taxable at 5%.

GST on processing brass statues and qualifying wooden handicrafts is 5% where goods belong to a registered recipient and the finished goods are predominantly handmade by craftsmen; processing goods of an unregistered person falls under the residual service entry at 18%. Commercially cast or moulded resin statues and ornamental vases are plastics articles, classified under tariff items 3926 40 29 and 3926 40 99 respectively, rather than as original sculptures under heading 9703. Marble and wooden idols of a god or goddess are GST-exempt from 22.09.2025; the exemption excludes decorative non-deity figures and does not depend on a particular eight-digit tariff classification.

Mandatory pre-movement E-Way Bill generation under Rule 138(1) applies to taxable goods exceeding the prescribed consignment value. Absence of the E-Way Bill at interception is treated as substantive non-compliance because online generation is a statutory mechanism for monitoring goods movement; later production does not cure the lapse. A short inter-State route, the nature of the goods, post-interception generation, and repetition of the lapse may collectively indicate an intention to evade tax rather than a technical or procedural error. On those facts, detention, tax and penalty provisions may be invoked.

E-way bill compliance applies to movement of goods, including movement otherwise than by way of supply, unless a specified exemption is satisfactorily established. Transporting an owned excavator back to registered premises under a delivery challan does not, by itself, remove that requirement. A claimed short-distance exemption must be supported by evidence of its applicability. Absence of evidence on consideration received for use of the excavator and corresponding GST treatment, combined with transport without an e-way bill, supports an inference of intent to evade tax rather than a merely procedural lapse. Penalty for the movement was therefore justified.

Assessment procedure requires separate notices and separate adjudication for each distinct tax period; a single composite assessment covering multiple financial years is unsustainable. Assessment and accompanying summary orders must be signed to have legal efficacy, and unsigned orders are ineffective. Fresh determination must therefore proceed tax period by tax period, with an opportunity of hearing for each period. The stated framework makes fresh adjudication conditional on deposit of 20% of the disputed tax within the stipulated period.

Ex parte GST adjudication may be set aside where the assessee was unable to answer a show-cause notice because of health grounds and the accountant's hospitalisation. Dismissal of the statutory appeal solely as time-barred, without examination on merits, does not displace the need for a fair opportunity where sufficient circumstances explain non-participation. Natural justice required restoration to the adjudicating stage, allowing the assessee to file a reply, produce supporting material and receive a hearing before fresh consideration.

Bail in an alleged fraudulent input tax credit prosecution was justified where the maximum punishment was five years, custody had continued for about four months, and the accused had no criminal antecedents. Predominantly documentary evidence and the absence of material suggesting witness influence, evidence tampering, absconding, or non-participation in trial weighed against continued pre-trial detention. The principles that bail is the rule, innocence is presumed, and Article 21 protects the right to a speedy trial supported release where early completion of trial was unlikely.

Presumptive taxation of an ordinary business and separate reporting of a futures and options trading loss are considered for ITR-3 filing. The issue is whether business turnover may be offered under the presumptive taxation scheme while futures and options activity is treated as a separate normal business and its loss is disclosed independently, without a tax audit. The query also concerns the relevance of digital futures and options transactions to tax-audit applicability.

Regular bail assessment focused on completion of investigation, filing of the charge sheet, custody duration, and parity with a co-accused who had obtained bail. Relevant considerations included the strength of the prima facie case, the applicant's availability for trial, the risk of absconding, and the possibility of witness tampering. Release was considered appropriate where these factors supported bail, subject to conditions ensuring attendance at trial and preventing interference with the proceedings.

Restoration of an appeal dismissed for failure to comply with mandatory pre-deposit requirements and repeated non-appearance requires a credible, substantiated sufficient cause. Receipt of Registry communications requiring proof of pre-deposit, failure to cure the defect, and absence on listed dates weighed against restoration. Technical payment difficulties, the COVID-19 period, management changes, and alleged late knowledge of dismissal did not adequately explain the prolonged delay, particularly where professional representation had filed the appeal and Tribunal orders were publicly accessible. Restoration was denied.

Limitation for filing appeals against Orders-in-Original depends on the actual date of communication, not merely the date on which the order was issued. Where delivery before the assessee's asserted receipt date is disputed, the Department must establish service rather than presume communication from issuance. Verification by field formations, after giving the assessee an opportunity to present its position, is required to determine whether the appeals were time-barred. The limitation question was remitted for fresh determination based on the verified communication date.