Principles of natural justice required a further opportunity for the assessee to produce material supporting claims relating to share capital, unsecured loans, sundry creditors and expenditure. The Tribunal did not decide the merits of the additions, set aside the appellate order, and remanded the matter to the Commissioner (Appeals) for fresh adjudication, directing the assessee to substantiate its case.

Section 153A permits additions to completed or unabated assessments only on incriminating material found during the assessee's search; external enquiries, third-party statements, regular books and uncorroborated information do not suffice. Allegations of bogus purchases or suppressed production require reliable evidence, including an established purchase trail and proof of non-genuine transactions; unsupported yield estimates cannot justify rejection of books or profit estimation. Valuation estimates alone do not establish unexplained investment, particularly where differences reflect subjective variation. Third-party survey material and loose papers require a clear link, corroboration and fair opportunity to test adverse statements. Cash discrepancies may be explained through contemporaneous cash records and supporting evidence.

Completed and unabated search assessments under section 153A require assessee-specific incriminating material found during the search. Documents seized from third-party premises cannot alone support additions in such assessments unless the statutory section 153C satisfaction requirement is met. Alleged on-money additions based on undated, unsigned, vague or incomplete loose sheets require independent corroboration establishing actual cash receipts. Where purchasers do not admit cash payments, bookings are cancelled, entries are notional, or figures correspond to cheque payments, loose sheets lack evidentiary value for determining undisclosed income.

Transactional Net Margin Method analysis may select a foreign associated enterprise as the tested party where it is the least complex, low-risk entity, particularly where materially unchanged facts support a consistent approach. Broad functional similarity can suffice for foreign comparables when identical comparables are unavailable. Any transfer-pricing adjustment should not exceed the margin retained by the associated enterprise in relevant customer transactions. Functionally dissimilar comparables must be excluded; employee-cost and persistent-loss filters may be inappropriate; and remaining margins require computation from annual reports. Working-capital differences in receivables and payables require corresponding adjustment for a reliable arm's-length determination.

Transfer-pricing benchmarking requires comparable companies to be functionally similar and reasonably comparable in scale. When implementing a DRP direction to recompute margins from annual reports, the TPO must remain within that direction and cannot exclude expenses as non-operating without a corresponding direction; margins require recomputation without those exclusions. High-turnover companies may be excluded where turnover disparity makes them unsuitable comparables for captive software-development services. Companies providing diversified, high-end technology, product-development, artificial intelligence, cloud, blockchain and specialised services are not functionally comparable with routine captive software-development and testing services. The arm's-length price requires redetermination after applying these comparability filters.

Unsecured-loan additions are unsustainable where loans are repaid with interest in the same assessment year and evidence establishes each creditor's identity and existence. PAN details and corporate registration supported the creditors' existence. The appellate factual findings did not raise a question of law warranting interference, resulting in deletion of the addition in favour of the assessee.

Special Additional Excise Duty (SAED) on exports of aviation turbine fuel (ATF) outside India is revised to Rs. 11 per litre. The revised rate replaces the entry in column (4) against serial number 1 of the table in Notification No. 08/2026-Central Excise, which was issued on 26 March 2026 and last amended on 30 September 2026. The revised rate takes effect on 31 October 2026, the date of publication in the Official Gazette.

Special Additional Excise Duty rates on exports of petrol and diesel outside India are revised through changes to the duty entries in column 4 of the table under Notification No. 06/2026-Central Excise. The entry against serial number 1 is replaced with nil, and the entry against serial number 2 with Rs. 11.5 per litre. The revised entries take effect on 31 October 2026, the date of publication in the Official Gazette.

Government Departments, establishments, agencies, local authorities and public sector undertakings registered solely as Tax Deductors at Source are registered persons for GST purposes. Supplies to them are B2B supplies, including B2G supplies reported as B2B, rather than B2C supplies. Registered suppliers meeting the prescribed aggregate-turnover condition must issue e-invoices for such supplies by reporting invoice particulars to an Invoice Registration Portal and obtaining an Invoice Reference Number. Where e-invoicing applies, an invoice, credit note or debit note without the required Invoice Reference Number is not legally valid.

Electronically filed GST registration-cancellation requests remain effective despite acknowledged portal technical issues where portal records establish timely submission. The cancellation process must be completed, with a hard copy and fresh electronic application furnished where necessary. Cancellation is to operate from 31 December 2019, and, upon acceptance, GST returns filed after that effective date are void and non est.

Under the Odisha Goods and Services Tax Act, 2017, three central GST clarifications apply mutatis mutandis for uniform administration. They address export-of-services requirements, determination of place of supply, and GST taxability of personal and corporate guarantees. The clarifications apply across designated tax formations and first appellate authorities as clarificatory guidance, with implementation difficulties capable of being referred to the Commissioner of State Tax.

Customs Broker licensing requires applicants to submit a single complete online application through the CBLMS portal, select the Policy Section having jurisdiction over their intended place of business, and pay the prescribed fee. The Regulation 6 written examination is a computer-based bilingual multiple-choice examination and a prerequisite for grant of a Customs Broker licence. Applicants meeting the written-examination qualifying standard must appear for an oral examination. Candidates with benchmark disabilities may request appropriate arrangements with supporting evidence. False or forged application materials may cause rejection, licence cancellation, and action under applicable law.

GST on renting passenger motor vehicles with an operator depends on whether fuel cost is included in the consideration. Fuel-inclusive rental service is taxable at 5% subject to restricted input tax credit, or at 12% with input tax credit subject to statutory conditions. Where fuel cost is excluded from the consideration and paid separately based on actual consumption, the service is taxable at 18%.

Natural justice in GST scrutiny and adjudication requires an opportunity of personal hearing where a written request is made by the person chargeable with tax or penalty, or an adverse decision is contemplated. This applies to proceedings under sections 61, 73 and 74 of the OGST Act. Proper officers must provide a meaningful hearing before an adverse assessment and must activate the personal-hearing fields in the back-office portal to record the date, time and venue of hearing.

Schedule I treats supplies of goods between a principal and an agent as deemed supplies without consideration only where the agent acts representatively by supplying or receiving goods on the principal's behalf. The decisive indicator is whether the agent issues the relevant invoice in its own name and has authority to transfer or receive title to the goods. Pure procurement or auctioneering services, where invoicing remains in the principal's name, do not fall within this treatment. Representative agents may require compulsory registration, subject to exemptions for qualifying agricultural-produce commission-agent services.

Unpaid GST not debited to the profit and loss account and not claimed as a deduction cannot be disallowed under Section 43B. Section 43B requires actual payment as a condition for allowing a claimed deduction for tax, duty, cess or fee; it does not create an addition where no deduction has been claimed. Precedents supporting an adjustment were distinguishable on their facts. Accordingly, unpaid GST outside the profit and loss account does not attract a Section 43B disallowance.

Regulation 4G requires the resolution professional, with prior committee approval, to appoint independent qualified professionals for project-wise technical and cost-to-complete assessments of real estate projects. The assessment covers construction status, approvals, inventory, completion costs, funding needs, delivery timelines, and material risks. It must be completed before inviting expressions of interest, included in the information memorandum for prospective resolution applicants, and treated as an insolvency resolution process cost.

Only input tax credit accumulated on inputs because of an inverted duty structure is liable to lapse for supplies received up to 31 July 2018, limited to the unutilised balance after payment of GST through July 2018. Input services and capital goods are excluded. The lapsed amount is calculated under the prescribed inverted-duty refund formula, subject to the available balance. Credit relating to closing stock may be excluded, while credit attributable to zero-rated supplies, including exports, does not lapse. The self-assessed reversal must be reported in the August 2018 GSTR-3B return.

Where a corporate debtor has multiple real estate projects, the resolution professional must place project-wise RERA registration, completion, possession, occupancy, and completed and incomplete unit details before the committee of creditors at its first meeting. The committee may, by at least sixty-six per cent voting share and with recorded reasons, recommend excluding a project from the corporate insolvency resolution process. The resolution professional must then apply to the Adjudicating Authority with those reasons.

Uniform implementation of the Odisha GST Act extends CBIC clarifications to State GST administration on a mutatis mutandis basis. The clarifications address special procedures, place of supply, related-party service valuation, reverse-charge input tax credit, discount-compliance evidence, employee share reimbursements, insurance-related taxability and credit reversal, optical-fibre network credit eligibility, custodial services, and time of supply for annuity payments and spectrum allotment. They are clarificatory in nature, and implementation difficulties may be brought to the Commissioner of State Tax.