Ekal Anubandh introduces an optional Single All-India Multipurpose Electronic Bond (SEB) for importers and exporters, replacing transaction-specific bonds across ports for selected customs obligations. The SEB may cover provisional assessment, export-promotion schemes, concessional-duty imports or exports, conditional import or export, warehousing, and manufacture or other operations in private or special warehouses; the National Bond under the IGCR procedure remains separate. Users may select obligations, add obligations or bond value later, pay stamp duty and execute the bond electronically through NeSL, without notarisation. Electronic bank guarantees can be linked and validated through ICEGATE, while paper guarantees remain subject to prescribed verification. Phased implementation will follow ICEGATE advisories.

Rejection of Service Exports from India Scheme benefits was inconsistent with an applicable Division Bench ruling on a similar claim. That ruling had invalidated cancellation of the relevant scrips, directed removal from the Denied Entry List, and set aside the penalty. The rejection order therefore could not be sustained and was set aside, restoring the claimant's position under the Scheme in line with the earlier ruling.

AD Code registration for exports follows a one-time registration model: an AD Code and associated bank account registered against an IEC at one Customs port may be used at all Customs locations for filing shipping bills. New registrations and updates must be requested online through ICEGATE and approved at the selected port of registration. Multiple AD Codes and bank accounts may remain linked to one IEC. Amendments to a particular AD Code account can be made only at its registered port, while existing AD Codes are mapped to the port where the last related shipping bill was filed.

Rule 22(4) permits the proper officer to drop GST registration cancellation proceedings where a registered person, instead of replying to a notice for non-furnishing of returns, furnishes all pending returns and pays outstanding tax, interest and late fee. Given the serious civil consequences of cancellation, restoration may be considered when these compliance requirements are met. A registered person may seek restoration within the stipulated period, and the concerned authority must consider and dispose of the application expeditiously in accordance with law upon compliance. The writ petition was disposed of with liberty to pursue restoration.

The SOP for movement and cross-stuffing of International Transshipment-FCL containers between Port Terminals and designated CFSs now requires the Port Terminal Operator to verify container numbers and seal integrity before permitting terminal exit or entry; exit verification must be undertaken against the EIR copy. Physical verification by the Preventive Officer at terminal gates is dispensed with to reduce congestion, while Customs control continues through the Custodian-cum-Carrier Bond under HCCAR, 2009. Any container-number or seal discrepancy found during transit or upon arrival must be immediately reported to the jurisdictional AC/DC, and further processing requires the proper officer's permission. All other Customs checks and statutory requirements continue unchanged, with immediate effect.

Maintainability of PILs alleging tax evasion depends on a genuine public injury and cannot be used to advance private commercial disputes or seek judicial supervision of statutory tax investigations. Assessment of alleged GST and income-tax evasion, the quantum involved and resulting liability requires examination of commercial and tax records through prescribed statutory procedures. Where tax authorities have initiated enquiries and no mala fides or dereliction of statutory duty is shown, non-disclosure of enquiry progress does not justify mandamus or court monitoring. Recasting substantially similar relief previously rejected for lack of locus as a PIL does not cure that defect. The High Court dismissed the PIL at the threshold and forfeited the security deposit for abuse of PIL jurisdiction.

Section 16(5) of the GST Act allows registered persons to avail input tax credit for specified financial years through a return under Section 39 filed on or before 30 November 2021. Input tax credit claimed on 20 December 2019 for Financial Year 2018-19 therefore fell within the extended statutory period. The assessment requiring payment or reversal of that credit was set aside, and the writ petition succeeded.

GST adjudication orders should ordinarily be challenged through the statutory appellate remedy where the taxpayer participated in proceedings and filed a detailed reply. Allegations concerning inadequate reasoning, service defects without demonstrated prejudice, electronic evidence, cross-examination, and overlap with an earlier statutory audit involve disputed facts and evidentiary assessment suitable for appellate examination. Writ jurisdiction is not ordinarily exercised unless a recognised exceptional ground, including a genuine breach of natural justice, is established. The writ petition was dismissed while preserving factual and legal contentions for appeal, and the writ-pendency period was excluded from limitation if an appeal is filed.

Electronic uploading of a show-cause notice and order-in-original in the Common Portal's 'View Additional Notices and Orders' tab does not, by itself, constitute valid service under the CGST Act where the assessee neither acknowledged receipt nor responded. The retrospective amendment permitting specified CGST Rules functions through the Common Portal does not expand those functions to replace formal service of notices or orders. Where portal upload may result in civil consequences and the assessee lacked knowledge of the uploaded materials, service remains ineffective. The writ petition was disposed of consistently with this principle.

Section 75(4) requires a personal hearing where an adverse decision is contemplated, and a show-cause notice for short-paid GST indicates such contemplation without requiring a separate written request. An assessment order issued without considering the taxpayer's reply, despite the reply and hearing request being on record, reflects non-application of mind. The assessment order was set aside, with fresh proceedings permitted from consideration of the reply after granting a personal hearing in accordance with law. Exemplary costs were directed against the respondent authority for treating the matter as though no reply had been filed.

Statutory GST pre-deposit and limitation requirements governed the remand of a time-barred appeal rejected for insufficient deposit. The amount previously recovered or paid from the electronic ledger was to be adjusted, subject to verification, towards 50% of the disputed tax required for the appeal. The appellate rejection was quashed on conditions requiring the assessee to deposit the balance as applicable and file a supported reply to the show cause notice, with the impugned order treated as an addendum. Fresh adjudication on merits was directed upon compliance, and bank-account attachment was to be vacated subject to the prescribed conditions.

Effective service of GST notices requires more than portal upload where repeated communications receive no taxpayer response. Although portal uploading constitutes valid service, the assessing officer should consider other statutory modes under Section 169(1), preferably registered post with acknowledgement due, to ensure that notice reaches the taxpayer. An ex parte assessment without an effective opportunity to respond and a personal hearing risks avoidable litigation. The assessment was set aside and remanded for fresh consideration after objections are filed, with a clear 14-day notice for personal hearing and a merits-based decision.

Assignment of a lessee's entire long-term leasehold rights in a GIDC plot, including rights in land and building, constitutes a transfer of benefits arising from immovable property rather than a supply of services under GST law. Unlike GIDC's original grant of a long-term lease, assignment to a third-party assignee transfers the lessee's complete right and interest. Applying the Supreme Court order in Gujarat Chamber of Commerce, Industries & Ors., the High Court treated the assignment as outside GST and quashed the show cause notice that had proposed to tax it as a service.

Papad Khar, an alkaline mixture of sodium chloride, sodium carbonate and sodium bicarbonate used in papad and snack preparation, is classified as other disodium carbonate under sub-heading 28362090. Its manufacture by mixing and processing prevents classification as common or rock salt under heading 2501, while its composition and culinary function distinguish it from yeast or prepared baking powder under heading 2102. Sodium chloride serves principally as a diluent or carrier, whereas the carbonates and bicarbonates provide the functional properties. As an inorganic chemical, Papad Khar attracts GST at 18%. The GST exemption for papad does not extend to Papad Khar merely because it is used as an input in manufacturing exempt papad.

Composite job-work involving cutting, sorting, plate preparation, offset printing, drying, finishing, quality checks, bundling and return of kraft or duplex paper is treated as a composite supply, with offset printing as the principal supply and ancillary activities following its tax treatment. The concessional printing job-work entry for goods under Chapters 48 and 49 applies only where the printed goods attract central tax at 2.5% or nil. As kraft paper and duplex paper attract 18% GST, the concessional entry does not apply; the residuary job-work entry applies, resulting in GST at 18%.

Common-parlance classification governs the distinction between toilet soap and laundry soap under GST where "toilet soap" is undefined. Definitions under statutes serving different objects and schemes, including the Medicinal and Toilet Preparations (Excise Duties) Act, cannot be imported for GST classification. Toilet soap ordinarily serves washing of the body, hands or face, whereas detergent and semi-detergent bars intended to remove stains and deodorise apparel are laundry soaps. Their stated use, composition, substantial fillers and absence of constituents characteristic of toilet soaps support classification under sub-heading 34011942. Products covered by Entry 66 of Schedule II to Notification No. 09/2025-Central Tax (Rate) attract GST at 18%.

Sections 144C and 153 require harmonious construction when determining limitation for a final assessment made pursuant to DRP directions. The non-obstante clause in section 144C(13) does not displace the outer time limit under section 153; the final assessment must therefore be completed within that prescribed limitation period. Applying the binding High Court precedent, the ITAT treated the final assessment for Assessment Year 2018-19 as time-barred and quashed it. Merits grounds remained open, with liberty to seek revival if a Supreme Court decision requires modification.

TDS credit on rental income from jointly owned property is ordinarily governed by section 199 and rule 37BA, which provide credit to the deductee and require prescribed declarations and reporting for transfer to another person assessable on the income. Where the entire TDS was deducted and reported against one co-owner's PAN, no transfer declaration was furnished, and the other co-owners neither claimed credit nor objected to that co-owner's claim, the entire credit should be allowed to that co-owner. Procedural requirements cannot permit the Revenue to retain TDS where no other person seeks the unclaimed credit.

Penalty for failure to obtain a tax audit was deleted because the assessee established reasonable cause under section 273B. Materials explained that milk-pouch sales were conducted on a commission or trade-discount basis and identified the related commission income. The lower authorities had not considered this statutory protection, despite reassessment accepting the returned income without any addition. The appeal was allowed and the penalty under section 271B was deleted.

Where an assessee disputes stamp-duty valuation under section 56(2)(x), distinguishes the valuation of different portions of the property, and requests a reference to the Departmental Valuation Officer, the Assessing Officer must make that reference before adopting the stamp-duty value. The basement and ground floor could not be valued on the same basis without addressing the assessee's objections through a reasoned finding. Adoption of the stamp-duty valuation without a valuation reference was therefore unjustified, and the addition for the difference between declared purchase consideration and stamp-duty value was deleted to the assessee's share.