Bona fide delay in claiming exemption for BSNL VRS-2019 compensation may be condoned where comparable employees have obtained similar relief and rejection on limitation would prevent consideration of an otherwise recognised claim. Government-approved and funded ex-gratia compensation under the BSNL Voluntary Retirement Scheme-2019 is treated as retrenchment compensation eligible for exemption under Section 10(10B). A prior offer of the amount to tax and processing of the return under Section 143(1) do not bar a fresh exemption claim. The Assessing Officer must verify eligibility, allow the exemption, determine consequential tax payable or refundable, and grant admissible interest under Section 244A.

Exemption under Section 11 is not denied solely because Form 10B was furnished after the prescribed time where the audit report accompanied the return and was available with the processing authority before return processing. Procedural delay in furnishing the audit report does not defeat a charitable institution's exemption claim if the report is available at the assessment or processing stage and remaining statutory conditions are fulfilled. Denial of exemption also does not justify treating the institution's entire receipts as income without computation on commercial principles.

Reassessment notices must conform to the faceless, algorithm-based assessment framework where prior rulings require that process. Where the final assessment order is already challenged before the Commissioner of Income Tax (Appeals), writ adjudication of the jurisdictional objection may render the statutory appeal redundant. The appellate authority must consider the objection to the Jurisdictional Assessing Officer's notice consistently with the applicable prior rulings, and the taxpayer must seek appropriate relief through that appeal within the stipulated period.

For search-based reassessment where the search falls within Section 152(3), the pre-Finance (No. 2) Act, 2024 regime applies. The first proviso to Section 149(1) adopts the limitation framework of Sections 153A and 153C for assessment years beginning on or before 1 April 2021. Under Explanation 1 to Section 153A, the ten-year period runs from the end of the assessment year relevant to the financial year of search. For a search in financial year 2024-25, the permissible ten-year block extends from AY 2016-17 to AY 2025-26; AY 2015-16 falls outside it. A reassessment notice for AY 2015-16 is therefore beyond limitation and without jurisdiction.

Final assessment orders issued while timely objections to a draft assessment order remain pending before the Dispute Resolution Panel cannot stand if they conflict with the Panel's binding directions. An eligible assessee invokes the statutory procedure under Section 144C by filing objections within time, requiring completion of the assessment in conformity with those directions. Failure to intimate the Assessing Officer of the objections was a bona fide lapse that conferred no advantage and did not displace the binding effect of the Panel's directions. Where the transfer-pricing order underlying the assessment was revised pursuant to those directions, the final assessment, consequential demand and penalty-initiation notices were invalid; a fresh assessment was required.

Interim restraint on processing income-tax returns filed by sitting judges was modified because the automated system could not independently identify those returns. Identification details were required to enable exclusion of the relevant returns from processing while allowing other returns to be processed without disruption. The modification application was disposed of, and the writ petition remains pending without final adjudication.

Reassessment initiated beyond three years cannot rest on erroneous bank information that fails to establish the statutory threshold for escaped income under the post-Finance Act 2021 regime. Where the sole basis for notice under Section 148A(b) incorrectly reported term deposits because of a bank technical or system error, and the actual alleged escaped income was below the prescribed threshold, the extended reopening period was unavailable. Materially false information could not support an effective show-cause notice or confer reassessment jurisdiction beyond the normal limitation period. The reassessment notice, consequential proceedings, assessment and penalty orders were invalid and set aside in favour of the assessee.

Revision jurisdiction cannot be used to introduce a tolerance-limit claim omitted from a self-assessment return once the statutory period for filing a revised return has expired. Where the return was processed and demand raised on the basis of the taxpayer's self-assessment, remand for fresh consideration of that omitted claim is impermissible. A revision application cannot operate as a substitute for a time-barred revised return.

Collection of tax at source under section 206C was considered in relation to compounding fees recovered from persons engaged in illegal mining, transportation or storage of minerals without a lease, licence, or contractual transfer of mining or quarry rights. The issue concerned the scope of the MMDR Act and Rule 71(5) of the Chhattisgarh Minor Mineral Rules, 2015. The Special Leave Petitions were dismissed because the Special Leave Petitions challenging the common judgment had already been disposed of.

Compostable bags and packing materials made from Poly Lactic Acid and Poly Butylene Adipate Terephthalate are classified as plastic articles under Chapter 39, heading 3923 2990, because the materials are polymeric plastics rather than paper. Entry 319 of Schedule I to Notification No. 9/2025-Central Tax (Rate) grants the concessional GST rate only to biodegradable bags. Compostable-plastic certification under IS/ISO 17088 does not establish compliance with the separate standard and CPCB certification required for biodegradable plastics under IS 17899 T:2022. Consequently, compostable bags do not qualify as biodegradable bags or for the concessional GST rate.

Uncoated paper under tariff item 48025590 qualifies for exemption under Entry 128 only when actually used to manufacture exercise books, graph books, laboratory notebooks or notebooks. Tariff classification alone does not secure the use-based exemption, which must be applied strictly according to its terms. Purchaser declarations, purchase orders and contractual stipulations may evidence intended use but do not conclusively prove actual end-use. As the notification provides no deeming, certification, verification or diversion-recovery mechanism, advance-ruling jurisdiction does not extend to validating those documents as sufficient proof or creating a procedure for claiming the exemption.

Appeals against rejection of an advance-ruling application under the first proviso to Section 98(2) are not maintainable before the Appellate Authority. Section 100(1) limits appellate jurisdiction to an advance ruling pronounced under Section 98(4). A rejection at the application stage under Section 98(2) does not constitute a ruling under Section 98(4) and therefore falls outside the statutory category of appealable orders.

Section 171 requires suppliers to pass on benefits from tax-rate reductions or additional input tax credit through commensurate price reductions. Project-specific data certified by a chartered accountant was accepted where consolidated GST returns and financial records covering multiple projects could not be further bifurcated. The input-tax-credit-to-purchase-value ratio decreased from the pre-GST to post-GST period, indicating that no additional input tax credit accrued. Transitional VAT credit passed to eligible purchasers did not concern a purchaser whose agreement was executed after GST implementation and whose pre-GST advance VAT had been deposited with the VAT department. No anti-profiteering liability arose for the relevant transaction.

Service of a show-cause notice or order-in-original under the CGST Act requires more than uploading it in the Common Portal's 'View Additional Notices and Orders' tab. Sections 169 and 146, read with the CGST Rules, do not treat portal-only upload as formal service. The retrospective Finance Act amendment enabling functions under the Rules through the Common Portal does not expand the portal's specified functions to replace prescribed service requirements. Rule 142 permits electronic communication but does not validate an uncommunicated notice or order. Without acknowledgement or a reply establishing knowledge, portal upload is ineffective, and consequential relief under the applicable precedent remains available.

Refunds already allowed cannot be withheld merely because Revenue later files an unlisted Tribunal appeal. Where the taxpayer is an established manufacturer with no indicated risk of avoiding a future liability, an undertaking to deposit any amount ultimately determined in the pending appeal sufficiently protects Revenue's interests. The refund must therefore be released upon furnishing that undertaking, subject to repayment of any liability determined in accordance with law.

Section 16(5) grants retrospective entitlement to input tax credit where returns for the relevant tax periods were filed before its prescribed cut-off. Failure to apply for rectification within a time limit set by an administrative circular does not defeat that statutory entitlement. Input tax credit must therefore be considered for an assessee meeting the filing cut-off under Section 16(5), notwithstanding delayed return filing or non-compliance with the circular's rectification timeline.

Writ jurisdiction should not ordinarily be invoked against appealable adjudication orders where an efficacious statutory appeal can examine factual and legal challenges. The appellate mechanism may consider adequacy of reasons, replies, service and hearing opportunities, procedural prejudice, electronic-record authentication, corroboration, relied-upon documents, cross-examination, and DRC-03 payments. Alleged procedural and evidentiary defects requiring individual scrutiny do not, without a patent jurisdictional defect or manifest common denial of natural justice, justify bypassing that remedy. A party that has already filed a statutory appeal cannot simultaneously seek writ relief against the same order absent exceptional circumstances. Challenges must therefore proceed before the appellate authority.

Composite assessment orders under Section 74 cannot validly cover more than one tax period or assessment year. Each relevant period requires separate assessment proceedings and a separate order, ensuring the registered person has an effective opportunity to respond and exercise statutory remedies for that period. Combining the tax periods 2019-20 and 2020-21 in one assessment order is impermissible. Separate orders may be issued after affording due opportunity to the assessee.

Non-consideration of a taxpayer's written reply to a GST show cause cum demand notice breaches principles of natural justice, even where opportunities for personal hearing were provided. An ex parte adjudication issued without addressing the detailed reply is legally infirm. The adjudicating authority must consider the reply, provide an effective hearing, and issue a fresh reasoned decision.

Uploading a show-cause notice or order-in-original only under the GST portal's 'View Additional Notices and Orders' tab does not constitute valid service under the CGST Act where the assessee neither acknowledges receipt nor responds. Although the common portal may perform functions under the retrospective amendment, the CGST Rules do not prescribe portal uploading as a formal mode for serving such notices or orders. Communication capable of producing serious civil consequences cannot replace statutory service solely through a portal entry. Defective portal-only service therefore attracts the applicable relief framework.