Reassessment initiated beyond four years requires established failure by the assessee to make a full and true disclosure regarding the income alleged to have escaped assessment on the recorded reasons. Where no addition survives on either recorded ground-recomputation of Section 14A disallowance or alleged NSEL income-an addition on a separate issue lacks jurisdictional support. Explanation 3 to Section 147 permits assessment of another escaped-income issue discovered during valid reassessment proceedings, but does not cure an invalid reopening or enlarge the substantive jurisdiction under Section 147. The reassessment and the unrelated addition could not survive.

Contribution towards augmentation of an electricity transmission line owned and maintained by the electricity board was treated as revenue expenditure where it secured adequate power supply for an existing business without conferring ownership, possession, or an enduring capital advantage. The board retained ownership, maintenance responsibility, and the ability to supply other consumers. The expenditure was incurred wholly and exclusively to improve business efficiency and profitability. Revision was not sustainable because the Assessing Officer had made enquiries and correctly allowed the deduction; the assessment was therefore neither erroneous nor prejudicial to Revenue interests.

Business expenditure incurred wholly and exclusively for road and bridge projects in the ordinary course is deductible under section 37(1), even where no corresponding income is booked for a particular project. Absence of project-specific income does not itself invalidate the expenditure; the relevant enquiry is whether taxable receipts or income escaped recognition. Income from one project had been recorded, and identical findings for the preceding assessment year had attained finality. The disallowance was therefore deleted, sustaining deduction of the infrastructure-project expenditure.

Losses of an undertaking eligible for deduction under Section 10B remain available for set-off against taxable profits of other undertakings and for carry-forward under the general loss provisions. Section 10B requires separate computation of export profits solely to quantify the deduction for each eligible undertaking; it does not alter the treatment of that undertaking's profit or loss in computing combined income. Rules governing aggregation, inter-source and inter-head set-off, and carry-forward therefore continue to apply.

TDS on payments to non-residents was considered where the ITAT found that payments to three non-resident companies were not royalty under the applicable DTAA. The High Court dismissed the Revenue's appeal but allowed the Revenue to seek review or restoration if its review petition concerning Engineering Analysis Centre of Excellence succeeds before the Supreme Court. The Supreme Court disposed of the petition and related pending applications.

PTFE braided gland packing with a cross-sectional dimension exceeding 1 mm is excluded from Section XI by Note 1(g), despite its braided form and industrial sealing use. As it does not qualify as textile material, it cannot be classified as a textile article for technical use under heading 5911. The residual PTFE classification under HSN 39209949 applies to PTFE products other than rigid or flexible plain sheets. Clear tariff headings, Section and Chapter Notes, and HSN Explanatory Notes prevail over industry practice or trade parlance. The packing falls under Schedule II and attracts GST at 18%.

GST-rate reductions must be passed to recipients through commensurate price reductions under the anti-profiteering framework. Retaining the same tax-inclusive cinema ticket price by increasing the base price after a GST reduction allows the supplier to retain the tax benefit and breaches that obligation. Regulatory directions or permissions concerning permissible cinema fares do not create an exception to the separate duty to pass on the tax benefit. Profiteering is quantified by retaining the pre-reduction base price, applying the reduced GST rate, comparing that commensurate price with actual prices, and calculating the excess collected on relevant sales. Where recipients are unidentifiable, the amount with applicable interest is credited equally to the Central and State Consumer Welfare Funds; no penalty applies for the investigation period.

GST rate reduction on cinema admission tickets had to be passed to recipients through a commensurate price reduction under the anti-profiteering provisions. Maintaining the existing cum-tax ticket price by increasing the base price defeated the tax benefit and breached that obligation. Regulatory fare limits, High Court permission to collect proposed fares, and representations to licensing authorities did not override the independent duty to reduce prices. Profiteering was computed by retaining the pre-reduction base price, applying the reduced GST rate, and measuring excess collections on actual ticket sales. The quantified benefit, with applicable interest, was directed to designated consumer welfare funds because recipients were unidentifiable; no penalty applied for the investigation period.

Section 129(3) requires a penalty order in detention proceedings to be issued within seven days of service of the detention notice. The mandatory term "shall", the coercive nature of detention and penalty proceedings, and strict construction of fiscal law support treating this period as binding. Where the relevant dates are undisputed and on record, the limitation objection may be raised before the Tribunal. E-invoices, reported supplies and tax payment may also negate an inference of intent to evade tax merely from the absence of an e-way bill. A penalty order issued after the prescribed period is time-barred, illegal and without jurisdiction, invalidating the consequential appellate order.

Stock transfers between premises bearing the same GSTIN, undertaken under a delivery challan without consideration or a distinct counterparty, do not constitute supplies and do not attract GST. Consequently, the tax-linked penalty mechanism under Section 129 cannot apply where no tax is payable. Although an e-way bill may be required for movement of goods for reasons other than supply, its absence in such circumstances is a document-related contravention subject to the specific applicable penalty provision, rather than Section 129. This treatment applies where there is no material indicating fraud, suppression, or non-genuine movement.

Common show-cause notices under Section 74 covering multiple financial years are treated as permissible, following a coordinate-bench view that restored notices and original orders previously quashed solely for combining years. Challenges to both original tax orders and appellate orders must be pursued through the statutory appeal before the Goods and Services Tax Appellate Tribunal. Quashing tax proceedings merely because a notice covers multiple financial years is therefore unsustainable, while substantive objections remain available through the appellate mechanism.

Article 226 writ jurisdiction may be exercised to condone delay in filing a statutory appeal against GST registration cancellation where strict application of the appellate limitation would deny an effective remedy. Although section 107 restricts the Appellate Authority's power to extend time beyond the prescribed limit, writ relief may be appropriate where cancellation affects business continuity and the taxpayer seeks to regularise statutory compliance. On the stated facts, the delay was condoned and the appeal was directed to be entertained and adjudicated on merits.

Statutory appellate remedy should ordinarily be pursued where penalty proceedings are challenged on the Deputy Commissioner's jurisdiction. Applicable State circulars authorised the Deputy Commissioner to issue penalty notices and exercise jurisdiction above the prescribed turnover threshold. The taxpayer participated on merits without raising the jurisdictional objection during the proceedings. Although lack of jurisdiction may be raised before a constitutional court at any stage, writ jurisdiction remains discretionary. The writ petition was disposed of with liberty to file a statutory appeal, and the pendency period may be claimed for exclusion under the Limitation Act, subject to satisfying its requirements.

Input tax credit cannot be denied merely because a supplier's GST registration was later cancelled or the supplier was unavailable during investigation; collusion between supplier and purchaser must be established. No prima facie material indicated fraudulent invoicing capable of attracting Section 132(1)(c). The purchasers had appeared before authorities, agreed to provide documents and cooperate, and had no criminal antecedents. As custodial interrogation was unnecessary, anticipatory bail was available subject to conditions requiring cooperation with the investigation.

Recovery of the balance tax demand was restrained pending disposal of the statutory appeal because amounts exceeding the required pre-deposit had already been recovered or deposited. The bank-account attachment was lifted, subject to monitoring of an adequate balance. The merits of the demand, including alleged non-availment of input tax credit, remain for determination by the Appellate Authority, which must decide the appeal expeditiously.

Writ jurisdiction against an ex parte GST assessment is generally unavailable where an effective statutory appeal exists and the taxpayer offers no cogent explanation for delayed challenge after communication of the assessment order. The writ petition was dismissed for availability of the appellate remedy and laches, while preserving liberty to file an appeal with an application for condonation of delay.

Pre-deposit for service-tax appeals under the legacy regime must satisfy section 35F of the Central Excise Act, as applied through the Finance Act. Although section 35F does not prescribe a payment mode, the CBIC instruction of 28 October 2022 requires payment through the dedicated CBIC-GST Integrated portal and treats Form GST DRC-03 payments as invalid. That instruction operates prospectively, allowing DRC-03 deposits made before its issue to be accepted. Reversal of input tax credit through Form GSTR-3B by debiting the electronic credit ledger after that date does not constitute a valid pre-deposit; payment must be made through the prescribed portal.

Withdrawal from bank accounts frozen under the Prevention of Money Laundering Act cannot be separately permitted by the High Court after directing the affected party to pursue the statutory remedy before the Adjudicating Authority. Questions concerning the freezing order, including any request to access frozen funds for employees' salaries, fall for determination by the Adjudicating Authority. The High Court's discretionary permission to withdraw funds for salary payments was set aside, and the Adjudicating Authority must determine the proceedings independently and in accordance with law.

Special Additional Duty refund rights linked to subsequent sale of imported goods and payment of sales tax or VAT cannot be restricted by a one-year limitation introduced only through an exemption notification. Although the Customs Act provides a refund mechanism, the notification-based limitation was treated as an impermissible restriction on a substantive refund right without statutory amendment. Consequently, a refund claim could not be rejected as time-barred solely because it was filed beyond one year from payment of Special Additional Duty, and no substantial question of law arose against the refund grant.

Documented share purchase and sale transactions supported by banking records, demat holdings, contract notes, recognised stock exchange sales, securities transaction tax and bank receipt of consideration support the genuineness of long-term capital gains. Sale proceeds should not be treated as unexplained cash credit merely on investigation material or an inference that price movements were inconsistent with company financials, where no independent enquiry disproves the evidence. Reliance on third-party material without examining relevant persons or allowing cross-examination is insufficient, particularly where the investor is not implicated in alleged price manipulation. Long-term capital gains exemption may consequently remain available.