Under the CGST/WBGST appellate framework, the maximum of three adjournments is a ceiling, not an entitlement to obtain three postponements. Each adjournment requires sufficient cause and written reasons, consistent with the requirement for expeditious disposal of appeals. Physical incapacity may justify a final hearing opportunity where adequately demonstrated, but does not create a right to further adjournments. The appellate authority may reject subsequent requests and must determine the appeal independently on merits.

GSTR-2A is a facilitation tool rather than a statutory bar to input tax credit. Credit claimed within the extended period for FY 2017-18 requires invoice-wise reconciliation; non-reflection in GSTR-2A for FY 2018-19 alone cannot establish supplier default. Section 75(4) requires a personal hearing before an adverse GST decision, even without a specific request. Return scrutiny under Section 61 and demand proceedings under Section 73 are independent, so absence of FORM GST ASMT-10 does not itself invalidate a direct demand proceeding. Interest and penalty remain consequential to sustainable tax liability. The disputed credit was remanded for verification and fresh adjudication after hearing.

Misreporting eligible IGST input tax credit under CGST and SGST heads is a technical classification error where aggregate eligible credit has not been exceeded and underlying eligibility is undisputed. Electronic credit ledger balances across IGST, CGST and SGST must be assessed collectively before sustaining an excess-credit demand. Limited verification of unclaimed eligible IGST credit is required; if available, the demand, interest and penalty must be dropped, with consequential ITC restoration or adjustment according to law.

Reassessment initiation against a deceased assessee is jurisdictionally defective where the show-cause notice is issued after death. Service of a show-cause notice is a condition precedent to an order under Section 148A(3) and a reassessment notice under Section 148; a notice issued to a dead person is non-est and cannot be cured through later proceedings against the legal representative. Section 159 requires reassessment proceedings concerning a deceased person's income to be instituted against the legal representative and does not validate proceedings begun against the deceased, particularly where the Department knew of the death. Participation after a jurisdictional objection does not confer jurisdiction. Consequential proceedings may be quashed, without barring fresh lawful proceedings within limitation.

Section 270AA immunity from penalty is unavailable where proceedings concern under-reporting arising from misreporting of income under Section 270A(9). A show-cause notice need not identify the precise misreporting subcategory where the assessment order has already disclosed the basis for treating the income as misreported; the notice is therefore not arbitrary or contrary to natural justice on that ground. As the immunity application falls outside the statutory framework, the Department is not required to decide it within the prescribed period. Objections based on denial of hearing and delayed disposal do not alter the rejection of immunity.

Compensation payable to land losers under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 is not subject to income-tax deduction or payment. Tax deducted at source from such compensation is refundable. Where a refund claim is affected by non-filing of the return or delay, the prescribed condonation application and return must be filed to enable processing of the refund. The stated position treats the statutory land-acquisition compensation as outside the scope of taxable income for TDS purposes.

Retention of seized cash under Section 132B cannot continue after completion of the searched person's assessment where no demand remains against that person. Subsequent reassessment proceedings against a non-searched assessee, without a warrant of authorisation, do not permit continued withholding of cash accepted as belonging to that assessee. The cash must be released after adjustment against the assessee's tax liability. Interest calculated on the amount must remain in an interest-bearing deposit pending determination of entitlement to interest by a Larger Bench. Pending disposal of the appeal, retention beyond tax adjustment was prohibited.

Enhanced exemption for leave encashment under section 10(10AA)(ii), notified with effect from 1 April 2023, is claimed by retired employees who superannuated before the notification came into force. Since the petitions were filed before expiry of the period for filing revised returns, the employees may pursue revised returns and other remedies available under the Act. Eligibility for the enhanced exemption, including its application to pre-notification superannuation, remains open for consideration in those proceedings.

Charitable registration requires examination of both the stated charitable objects and prima facie evidence that genuine charitable activities are being carried on. Educational objects in a trust deed are insufficient where the trust does not itself establish, manage, or impart education through a recognised educational institution. Leasing school and hostel premises to another educational entity and earning lease rent does not, by itself, demonstrate that the lessor trust conducts educational charitable activity. In the absence of evidence that rental income was applied to the trust's own charitable purposes, the registration application was rejected.

Section 144B did not apply where the assessment was made by the jurisdictional Assessing Officer outside the faceless-assessment framework and mandatory notices had been issued; procedural non-observance therefore did not invalidate the assessment. Rejection of books of account and profit estimation in online share trading require substantial accounting discrepancies and adherence to best judgment principles. Absence of matching bank credits or an adverse turnover-to-expense ratio alone was insufficient where broker-mediated pay-ins and payouts, regular accounting methods, and transactional evidence were not properly considered. Profit estimation must have a rational, business-specific basis rather than rely on guesswork; the estimated profit addition was deleted.

Section 12AB(4) requires an inquiry and satisfaction of a specified violation before a notice proposing cancellation of charitable-trust registration. A notice must identify the statutory basis and alleged violation, and must give a reasonable opportunity to respond; failure to do so renders cancellation and refusal of renewal unsustainable. Cash deposits during demonetisation could not support non-genuineness where they had already been accepted as reported fee receipts. Related-party payments connected with protecting hospital-asset interests did not establish diversion of funds or a non-genuine activity. A section 13(1)(c) issue is not itself a specified violation for cancellation and may instead affect exemption at assessment. Renewal and consequent section 80G approval were directed.

Tax deduction at source under section 194C applies to External Development Charges paid to the urban development authority, rendering the payer liable for non-deduction, subject to the pending Supreme Court proceedings. Payments later characterised as administrative charges for changes in beneficial interest and development rights require verification of the supporting evidence, the applicable State scheme, the payments' nature, and any resulting obligations under Chapter XVII-B. Those disputed payments require de novo determination by the Assessing Officer after admission of evidence and an adequate hearing. The Revenue's position succeeded on External Development Charges, while the remaining TDS issue was restored for fresh adjudication.

Reopening beyond four years may be sustained where subsequent survey information indicates bogus purchase and sale transactions and the original assessment did not examine those transactions. Production of records does not establish full and true disclosure when the transactions themselves are allegedly non-genuine, and fresh information with a live nexus to income escaping assessment is not a change of opinion. For unproved business transactions, banking-channel payments alone do not prove genuineness without evidence of physical movement of goods. Where both purchases and corresponding sales are treated as bogus, income should be estimated by applying a gross-profit rate to turnover rather than adding the entire purchases, with credit for profit already disclosed.

Section 270AA penalty immunity cannot be rejected without identifying the statutory condition not met and giving the assessee an opportunity of hearing. The immunity application requires fresh consideration so that compliance with the prescribed conditions can be demonstrated; where immunity is available, consequential penalty proceedings become infructuous. Where no original return was filed and income was disclosed only in response to a reassessment notice, the disclosed income constitutes under-reported income in the absence of an explanation for the initial non-filing. If immunity is denied, penalty proceedings require a speaking order after hearing the assessee.

Revision under section 263 must be initiated within two years from the end of the financial year in which the assessment order was passed. The limitation expired before the first revisionary notice and order were issued, rendering the revisionary order time-barred and liable to be quashed. Independently, revision of the assessment treating integrated hardware systems with embedded software as non-royalty was unwarranted because the Assessing Officer had examined the agreements, copyright rights, software and services, and the India-United Kingdom tax treaty. Consistent earlier decisions and the Supreme Court's Engineering Analysis ruling supported the non-royalty treatment, so the assessment order was not erroneous or prejudicial to Revenue interests.

Souharda Sahakaris registered under the Karnataka Souharda Sahakari Act, 1997 are treated as co-operative societies for deduction under section 80P. Where credit facilities are provided exclusively to members, income from that activity is attributable to the eligible business under section 80P(2)(a)(i), and dealings confined to members preserve mutuality. Interest earned by placing surplus funds, not immediately required for member lending, in bank deposits remains attributable to the credit-facility business rather than constituting a separate business. Such interest consequently forms part of the qualifying profits for the section 80P deduction.

Interest on borrowings used to acquire or maintain controlling interests through strategic investments may qualify as business expenditure where the taxpayer's objects, investment pattern, conduct and disclosures establish that strategic investment is part of its business. The business-purpose requirement extends beyond immediate profit generation; dividend being taxed under another head or investments not producing direct business receipts does not by itself defeat deductibility where commercial expediency exists. Separately, where available interest-free funds exceed investments and interest-free advances, investments are presumed to have been made from those funds. Absence of a direct fund-wise nexus therefore does not justify disallowing interest on borrowings.

Functional comparability of IT-enabled BPO service providers requires exclusion of entities with materially different business models, including providers that outsource most services, operate at a substantially larger branded scale, perform high-end KPO or engineering-design functions, or lack relevant segmental information. A consistently accepted comparable may remain included where no material distinction exists. These principles supported deletion of the transfer-pricing adjustment. IT-enabled back-office and data-processing services covered by notified activities qualify as export of computer software for the claimed deduction. Where identical deductions were allowed in earlier years and circumstances remain unchanged, the consistency principle supports allowance. The Revenue's appeal was dismissed.

Section 80JJAA deduction for additional employee cost was allowed to a manpower-services provider because it remained the employer of personnel deployed at customers' premises. Eligible claims for the second and third consecutive years require verification and remain subject to the gross-total-income limit. Chapter VI-A deduction cannot be claimed against income enhanced through an arm's length price adjustment, as the statutory prohibition applies even where the deduction is employee-cost based. Transfer-pricing issues concerning KPO characterisation, Salesforce intra-group service charges, and GAP/GSS programme revenue require fresh examination of functional comparability, supporting documentation, transaction nature and the appropriate pricing method.

Commercially genuine exclusivity payments, transition-fee reimbursements and upfront discounts made to associated enterprises cannot be disregarded merely because their commercial structure is unusual or their expediency is questioned. Arm's length pricing cannot be fixed at nil without applying a prescribed transfer-pricing method; where the underlying primary adjustment fails, consequential notional interest also fails. Secondary-adjustment provisions do not apply to primary adjustments preceding 1 April 2016. Interest on a foreign-currency associated-enterprise loan is benchmarked at LIBOR plus 80 basis points. For exempt-income disallowance, only income-yielding investments are relevant and sufficient own interest-free funds preclude in.....