Reassessment notices issued after expiry of the extended three-year period required approval from the higher specified authority under Section 151(ii). The relaxation provision permitted approval under Section 151(i) only until 30 June 2021. Consequently, a notice issued on 29 July 2022 with sanction from the Principal Commissioner, rather than the authority prescribed by Section 151(ii), lacked a jurisdictional precondition. The reassessment notice and consequential proceedings were invalid for defective statutory approval.

Additional evidence relating to unsecured loans, share valuation and futures-and-options losses may be admitted under Rule 29 where it is material to disputed additions, was not withheld deliberately, and is necessary for a just decision. Where factual verification is required, the affected issues may be remanded for fresh consideration after allowing the other side an opportunity to respond. Bad debts arising from loans advanced in the ordinary course of a money-lending business may be deductible when written off in the accounts and the related interest has been offered to tax. Under the post-amendment position, proof of actual irrecoverability is not required if the statutory conditions are met.

Long-term capital-gain addition based on stamp-duty valuation of one co-owner's share was deleted because the same property sale had been accepted as genuine for the other co-owners holding equivalent shares. Verification of the sale agreement and registered sale deed in those assessments supported consistent treatment of materially identical interests in the same transaction. Applying a different standard to one co-owner would create unequal tax treatment; accordingly, no addition was sustained for that co-owner's share.

Reassessment based on investigation information identifying a supplier as an accommodation-entry provider may be supported by fresh tangible material indicating that income escaped assessment. Where purchases are treated as non-genuine, the addition may be confined to the profit element rather than the full purchase value. Consistency is central when the same supplier, factual matrix and circumstances remain unchanged across assessment years: an earlier profit-rate approach should ordinarily continue absent a material change in facts or law. A 12.5% estimate is presented as representing the benefit derived from grey-market purchases.

A penalty notice under section 271(1)(c) must clearly specify whether the charge is concealment of income or furnishing inaccurate particulars of income, as the two limbs have distinct meanings. A notice or penalty order that leaves the charge unspecified is vague, demonstrates non-application of mind, and cannot be cured by assessment proceedings or other material. Where neither document identifies the applicable limb, initiation of penalty proceedings is invalid and the penalty is unsustainable; the penalty merits need not be examined.

Reassessment initiated beyond three years from the end of the relevant assessment year requires approval under Section 151 from the Principal Chief Commissioner or Principal Director General, or, where absent, the Chief Commissioner or Director General. Approval by a Principal Commissioner does not meet this statutory requirement, invalidating the reassessment proceedings. Limitation must also be calculated by applying the rules for deemed notices and excluding the period allowed for response under Section 148A(b). Where the surviving period expires before issuance of the Section 148 notice, the notice is time-barred and consequential reassessment cannot stand.

Effective opportunity of hearing is required under the principles of natural justice and audi alteram partem before an assessment and consequential penalty action can be sustained. The text states that allowing only two days to respond, not considering an adjournment request, and the assessee's inability to upload its response denied an adequate opportunity to address the proposed assessment. It identifies the resulting assessment order, demand and penalty proceedings as untenable for breach of natural justice.

A faceless-assessment show-cause notice must allow at least seven days for a response under the applicable SOP. Allowing only six days deprives the assessee of the prescribed opportunity to respond and breaches principles of natural justice. Earlier lack of diligence by the assessee does not cure this procedural defect in the notice under challenge. The assessment and consequential orders were set aside, with the matter restored to provide a fresh opportunity to respond to the show-cause notice.

An Indian advertising company providing a comprehensive advertising service to a foreign client on its own account is not an intermediary merely because it procures media space from media owners. The foreign client is the recipient where it contracts for, is invoiced for, and pays the service; neither its Indian representative nor the target audience is the recipient. Such services are not performance-based, and the recipient-location rule applies where no specific rule governs. Where the foreign client is outside India, the service may qualify as export subject to applicable conditions. Mere facilitation of a direct foreign-client-media-owner arrangement is intermediary service.

Deliberate customs undervaluation may result in confiscation, redemption fine and personal penalty despite post-detection payment of differential duty and interest. Such payment may mitigate quantum but does not cure a false import declaration. Provisional assessment, final assessment and prior release of goods address duty determination and clearance, not the consequences of intentional misdeclaration. Undervaluation should be established through reliable corroborated material, including commercial documents, electronic records and inquiry statements. Personal penalty depends on evidence of an individual's active role in conduct rendering goods liable to confiscation, rather than position in an importing firm alone.

Assignment of an existing leasehold interest in MIDC land is distinguished from the original grant of a lease. Although Schedule II treats a lessor's grant of rights to occupy land as a supply of services, the article characterises a lessee's assignment as transfer of existing rights and benefits arising from immovable property. It explains that the statutory treatment of a lease grant does not expressly extend to every subsequent assignment, making the legal character of the transaction central to GST classification.

The State Government appoints 18 May 2020 as the date on which section 172 of the Arunachal Pradesh Goods and Services Tax Act comes into force.

Custodianship of the Container Freight Station operated by Hind Terminals Private Limited for import and export cargo has been renewed under Regulations 10 and 13 of the Handling of Cargo in Customs Areas Regulations, 2009. The renewal is coextensive with the validity of the operator's AEO certificate and remains subject to compliance with those Regulations. An AEO-LO Customs Cargo Service Provider's custodianship approval continues only while its AEO authorisation remains valid and is not suspended or revoked.

The Arunachal Pradesh Government rescinds a prior State Tax notification under its statutory powers and the prescribed return-filing rule, in public interest and on the Council's recommendations. Actions taken and omissions occurring before the rescission remain unaffected.

FORM GSTR-1 filing deadlines for details of outward supplies are extended under the Arunachal Pradesh GST framework. Registered persons must furnish the form by the eleventh day of the succeeding month, while persons required to furnish quarterly returns must file by the thirteenth day of the succeeding month. The revised deadlines take effect from 1 January 2021 and supersede earlier specified notifications, without affecting prior actions or omissions.

For a concluded assessment year under Section 153C, additions require incriminating material relating to that year; additions based on already disclosed share transactions without such material are unsustainable. A documented loss on sale of shares is allowable where evidence establishes allotment, holding, transfer and consideration, and no contrary evidence shows that the transaction is sham; share price movement alone is insufficient. Further disallowance of expenditure relating to exempt income is unwarranted where the assessee has already disallowed an amount exceeding the exempt dividend income. The additions, share-loss disallowance and further exempt-income expenditure disallowance did not survive.

Importers, exporters and trade stakeholders are cautioned against making illegal payments to customs brokers, intermediaries or others who cite purported demands by customs officers or customs handling charges. Illegal gratification by officers is prohibited, while making such payments may expose payers to penal consequences. The department collects only lawfully applicable statutory duties, cess, fines, penalties and interest through online payment modes on the ICEGATE portal. Demands, harassment or undue delay may be reported with supporting evidence through the designated complaint mechanism, with confidentiality assured.

Rule 14A creates an electronic GST registration option for applicants whose monthly output tax liability on supplies to registered persons remains within the prescribed limit. Eligibility requires Aadhaar authentication and restricts multiple registrations under the same Permanent Account Number in the same State or Union Territory. Withdrawal requires FORM GST REG-32, completion of required return filing, and absence of cancellation proceedings. The proper officer verifies the application under rule 9 and issues an order allowing withdrawal in FORM GST REG-33 or rejecting it in FORM GST REG-05.

Customs anti-corruption compliance requires stakeholders not to make payments beyond legitimate service charges to secure clearance or satisfy alleged demands of Customs Officers. Customs collections are limited to statutory duties, cess, fines, penalties and interest payable under law, through ICEGATE or the TR-6 challan mechanism at designated banks. Demands for illegal gratification, harassment or undue delay may be reported with supporting evidence through the notified complaint channels, with confidential handling and examination or referral for appropriate action.

Digital accessibility compliance timelines for regulated entities are extended for conducting accessibility audits of digital platforms and remediating audit findings. The extended deadline is October 31, 2026. All other obligations under the earlier circulars concerning compliance with the Rights of Persons with Disabilities Act, 2016 and its rules remain unchanged and continue to apply.