Free home delivery of ready-to-eat food, involving preparation at the supplier's premises and delivery at a customer-specified time and place, was treated as a taxable service with a significant service element. From July 2012, supplying food for human consumption in this manner fell within declared services and also within the earlier concept of outdoor catering. Service tax was consequently sustainable for the normal limitation period. The extended limitation period and related penalty were not sustainable because the supplier was registered, filed ST-3 returns, paid service tax, and the allegations arose from its own records, with no evidence of suppression intended to evade tax.

Appealability of Tribunal directions under Rule 41 is limited: a procedural or implementation direction intended to give effect to a final order is not an order passed in appeal and falls outside Section 35G appellate jurisdiction. Rule 41 permits consequential directions, including compensatory interest, where necessary to implement a final refund order. Service tax paid for laying potable-water pipelines for a State agency's public-welfare project was treated as paid under a mistake of law rather than as duty, displacing duty-refund limitation requirements. Interest runs from three months after the original refund application, not later supporting documents; statutory delayed-duty refund rate limits do not govern compensatory interest.

Rechargeable lanterns, emergency lamps and study lamps with built-in rechargeable batteries fall under CETH 8513 1090 as portable electric lamps with a self-contained electricity source. Connection to AC mains solely to recharge the batteries does not convert them into lamps operating from an external fixed power source under CETH 9405 2010. Where the revised classification was disclosed to the Department through intimation and monthly ER-1 returns, and the dispute arose from tariff interpretation following audit, suppression is not established. The extended limitation period and penalties therefore do not apply; differential duty and interest remain sustainable only for the non-time-barred period, subject to the portion already set aside.

Separate arraignment of a sole proprietary concern is unnecessary for a cheque-dishonour complaint against its proprietor. Statutory vicarious criminal liability applies where the drawer is a juristic entity distinct from the individuals sought to be held responsible for its affairs. A sole proprietorship has no legal existence separate from its proprietor; use of a trade name or maintenance of a bank account in that name does not create a separate legal person. Accordingly, proceedings may continue against the proprietor in that capacity without impleading the proprietary concern separately, while questions concerning the underlying liability and defences remain for trial.

United States trade measures prohibit Canadian dairy products, most alcoholic beverages and motorcycles, and exclude Canadian products from large, long-term government contracts until full and fair reciprocity is available for American products. Canada has imposed retaliatory tariffs on hundreds of American goods, maintaining that countermeasures are necessary where Canadian businesses face United States tariffs. The dispute has prompted Canada to pursue domestic investment, infrastructure development and trade diversification, including exploration of closer European Union cooperation.

Government procurement reciprocity has been invoked to make Canadian products ineligible for large, long-term United States government contracts until "full and fair reciprocity" is afforded to American products. Canada has imposed retaliatory tariffs on hundreds of American products to prevent tariff-free entry of those goods while Canadian businesses remain subject to United States tariffs. Canada also identifies trade diversification, domestic investment, infrastructure development and deeper European Union cooperation as measures to reduce economic dependence and preserve policy autonomy.

GST charged on eligible job-work services such as punching, printing, and laminating is not subject to a blanket bar on input tax credit merely because of the service nature. Where lower-rated taxable outward supplies are manufactured using higher-rated inputs and services, accumulated credit may be considered for an inverted duty structure refund. Refund entitlement remains separate from credit eligibility and is subject to statutory exclusions, input tax credit conditions, and the prescribed refund formula.

Angel Funds registered on or before September 10, 2025 must implement the Accredited Investor mandate by March 31, 2027, extending the previous compliance deadline. Until that date, they may offer investment opportunities to no more than 200 non-accredited investors. From March 31, 2027, these Angel Funds must not accept non-accredited investor contributions for investments in investee companies. Existing investors may continue to hold investments already made, subject to the fund's PPM and fund documents. All other provisions governing Angel Funds under Chapter 8 of the AIF Master Circular remain unchanged, and the revised timeline applies immediately.

Open API integration on the Trade Connect e-Platform enables eligible exporters to connect ERP, accounting and other systems with the Certificate of Origin process for electronic application submission, certificate issuance and verification. DGFT prescribes onboarding credentials, public-IP whitelisting, PBKDF2 password protection, token-based authentication and digital signing of requests and responses using SHA-256 RSA signatures and 2048-bit X.509 certificates. Access tokens may be reused during their 60-minute validity. Exporters must submit prescribed applicant, certificate, invoice, product, shipment, supporting-document and declaration data through the CoO File API, with agreement-specific validation of origin criteria and shipment r.....

Foreign Portfolio Investors (FPIs) investing only in Government Securities are no longer required to furnish investor group details. The exemption, previously limited to investments exclusively in Government Securities under the Fully Accessible Route, now applies to all FPIs investing only in Government Securities, including through the General Route. The change follows withdrawal of the concentration-limit requirement for Government Securities investments through the General Route, making investor-group identification unnecessary. Depositories, custodians and designated depository participants must update their systems accordingly. The revised compliance requirement takes effect immediately.

CSR funds received by a Section 8 charitable institution are generally permissible where the recipient is an eligible implementing agency and directly applies them to an approved project within permissible CSR activities and its charitable objects. Proper approvals, project arrangements, expenditure records, beneficiary details and utilisation evidence are required. Onward transfer to another institution requires a documented implementation arrangement, recipient eligibility, authority for transfer, monitoring and proof of actual utilisation; charitable status alone is insufficient. An assessment information notice verifies the payment and utilisation trail and does not itself establish a violation.

Section 115BAB was harmoniously construed to avoid requiring an impossible act: a qualifying company must exercise its option through Form 10-ID with its first return, yet manufacturing or production may commence by 31 March 2024. A company whose manufacturing had not begun in assessment year 2023-24 was ineligible for the concessional regime for that year. However, where manufacturing commences on or before the statutory cut-off, entitlement for subsequent assessment years must be considered and cannot be denied solely because the original Form 10-ID was filed before commencement.

A notice under Section 143(2) issued under the compulsory manual-scrutiny criterion for survey cases requires an underlying survey under Section 133A. Where no material establishes that a survey was conducted, selection under paragraph 1(ii) of CBDT Instruction No. 5/2017 exceeds the Assessing Officer's authority. The notice is invalid, and the consequential assessment under Section 143(3) is unsustainable and liable to be quashed.

Fair market value of land for long-term capital-gains computation need not be determined solely from Sub-Registrar guideline values, which are not conclusive evidence of market value. A substantiated valuation report using the reverse indexation method may support adoption of the property's value as on 1 April 1981 where sale instances and guideline data do not displace it. Investment-based capital-gains deduction for specified bonds, however, requires deposit within the prescribed six-month period. Where the Assessing Officer has no power to condone delay, a late investment does not qualify for deduction.

Compliance with the prescribed requirement to obtain and produce vehicle-owner declarations is distinct from compliance with the separate reporting requirement. Where the declarations were obtained and made available to the Assessing Officer, a reporting default alone does not justify disallowance of transport payments. The transport-payment disallowance was therefore unsustainable, as no failure to obtain the required declarations or factual error in the supporting findings was established.

Exemption for accumulation of income under Section 11(2) cannot be denied solely because the return and Form 9A were filed after the Section 139(1) due date. Timely filing of the prescribed form is treated as directory where Form 9A and Form 10 were available in the assessment record during the original and consequential assessments. Procedural delay in filing a return under Section 139(4) and Form 9A does not override a substantive claim to exemption for accumulated income. The assessee was therefore entitled to Section 11(2) exemption for all relevant assessment years.

Section 148A requires the Assessing Officer to consider the assessee's response and all available material before issuing a reassessment notice under Section 148. Reassessment for alleged bogus purchases was impermissible where purchase details had been examined during original scrutiny and were resubmitted in response to the Section 148A(b) notice, but were not evaluated in the Section 148A(d) order. Reliance on an undisclosed third-party statement, without an opportunity for rebuttal, did not independently establish income escaping assessment. Reopening on the same previously examined material constituted a change of opinion. Consequently, the Section 148A(d) order, Section 148 notice and reassessment were quashed.

Section 271B penalty proceedings operate independently of assessment proceedings and require initiation within a reasonable four-year period from the relevant assessment year; initiation after about ten years rendered the earlier-year penalties time-barred. Delay in completion of the State Co-operative Department audit may constitute reasonable cause for delayed submission of the Section 44AB report, although it does not excuse non-submission after the audit is complete. For later years, a Section 142(2A) special audit fulfilled the essential purpose of the Section 44AB audit, and the audit-related delay and absence of prejudice negated penal action.

Donation of current income by one charitable institution to another institution with similar charitable objects constitutes application of income for charitable purposes. The restriction effective from 1 April 2003 applies only to donations made from income accumulated for subsequent application under Section 11(2), not to donations from current income. Consequently, such current-income donations qualify as charitable application, and the related addition is to be deleted.

Deduction for a service co-operative bank is unavailable where the return claiming it was not filed within the due date prescribed for filing returns. Eligibility for the statutory deduction depends on timely compliance with the mandatory return-filing requirement. Applicable jurisdictional precedent requires a co-operative society to claim the deduction through a return filed by the prescribed due date, and a previously contrary precedent was distinguished. Consequently, the deduction remained unavailable for all relevant assessment years despite condonation of the delay in filing appeals.