Sustainability of a disallowance under section 43B and the taxability of subsidy received from the Government of Haryana are the identified questions. Notice has been issued only on those issues, requiring further consideration of whether the statutory disallowance applies and whether the government subsidy constitutes taxable income. The matter is listed for further hearing.

Special procedures require registered manufacturers of scheduled pan masala and tobacco goods to electronically register packing machines in FORM GST SRM-I, report installations, capacity changes and disposals within prescribed periods, and obtain a system-generated machine registration number. They must upload a Chartered Engineer certificate for declared machines and a fresh certificate following amendments. FORM GST SRM-II must be filed monthly by the prescribed deadline, reporting input stocks and use, machine-wise production, package and product particulars, and electricity, generator and solar-power consumption.

Rescission of S.R.O. No. 523/2023 under the special-procedure power in section 148 of the Odisha Goods and Services Tax Act, 2017 withdraws the earlier Finance Department measure. Acting on Goods and Services Tax Council recommendations, the State Government gives the rescission deemed effect from 1 January 2024, without prescribing a replacement procedure, transitional arrangement, or separate condition.

Proposed questions in the tax appeal required factual enquiry and therefore did not raise a question of law or substantial question of law. The High Court found no substantial question of law warranting admission of the appeal, so the tax appeal was not admitted.

For refunds of unutilised input tax credit arising from exports without payment of tax, supplies to a special economic zone unit or developer without payment of tax, or accumulation under an inverted tax structure, no claim under the same category may have been filed for any subsequent period. For all other refund categories, a subsequent-period claim does not prevent reapplication. Eligible persons may submit the claim under the "Any Other" category instead of the original category, with all supporting documents required for that refund claim.

Before supply, the recipient must send a serially numbered Form A intimation to the supplier and the jurisdictional GST officers of both parties, identifying the supplier and the goods pre-approved by the Development Commissioner. The supplier must issue a tax invoice for the goods. Upon receipt, the recipient must endorse the invoice and send a copy to the supplier and both jurisdictional GST officers. The endorsed invoice serves as proof of the deemed export supply. Recipient units must maintain accurate, complete digital records in Form B with an audit trail, update them immediately when goods are received, used or removed, and keep them available for verification at the unit.

Extruded or expanded savoury or salted products, excluding un-fried or un-cooked snack pellets manufactured through extrusion, fall under HS 1905 90 30 and attract 12% GST from 10 October 2024; the lower treatment is prospective and earlier supplies attract 18% GST. Roof Mounted Package Unit air-conditioning machines for Railways fall under HS 8415 and attract 28% GST. Car seats under HS 9401 attract 28% GST prospectively from 10 October 2024, while two-wheeler seats under HS 8714 attract 28% GST.

Disputed title to alleged religious-institution property cannot be resolved in writ jurisdiction and requires civil adjudication through a declaration and consequential injunction. A patta in the name of a Bhajanai Kovil does not by itself establish title. Section 34(1) of the Tamil Nadu Hindu Religious and Charitable Endowments Act lists exchange, sale, mortgage and lease, and does not extend to gifts or settlement deeds under the plain meaning rule. Registration restrictions apply only after the property is established as belonging to or endowed for a covered religious institution.

Reassessment limitation under TOLA is a jurisdictional restraint. Transitional notices issued between 1 April 2021 and 30 June 2021 are treated as Section 148A(b) show-cause notices, but only the surviving time remaining until 30 June 2021 is available for completing the reassessment process. Periods for supply of material and the assessee's response are excluded, but the Section 148A(d) decision, statutory approval and final Section 148 notice must issue within the remaining period. For Assessment Year 2015-16, post-1 April 2021 notices are treated as time-barred.

Margin waiver for subsequent cash-segment buy or sell positions applies where a client has a net sell obligation and an Early Pay-In request for sold securities has been accepted. The clearing corporation shall not collect margin from the trading member or clearing member on subsequent client positions up to the accepted EPI amount. Available EPI value is the lower of the EPI completed and securities sold value. Squaring off an EPI-backed sale position removes the EPI value, with resulting margin shortfall blocked from proprietary collateral, except for trade-for-trade securities.

Comprehensive advertising services supplied on an agency's own account to a foreign client constitute principal-to-principal supplies rather than intermediary services, even where the agency procures media space from media owners. The foreign client remains the recipient; an Indian representative or target audience does not. As the services are not performance-based, the default place-of-supply rule applies, locating supply with the foreign recipient and allowing export treatment subject to applicable conditions. A mere agent facilitating a direct media-owner and foreign-client supply is an intermediary, with place of supply at the agency's location.

GST paid on an advance for a cancelled service contract, where an invoice was issued before the service, is addressed through a credit note under section 34 of the Tamil Nadu Goods and Services Tax Act, 2017. The same mechanism applies when invoiced goods are returned. The supplier must declare the credit note in the return for the month of its issue and adjust tax liability subject to section 34. A separate refund claim is unnecessary where adjustment is available; if there is no output liability against which to adjust the credit note, a registered person may claim excess tax paid through FORM GST RFD-01. Where GST was paid on an advance for a cancelled service but no invoice was issued, the supplier must issue a refund voucher under section 31(3)(e), read with rule 51, and may apply for a refund of excess tax paid using FORM GST RFD-01.

Provisional release of an unseized imported food consignment is not mechanically governed by Section 110A, which applies to goods seized under Section 110. Customs may examine, test, verify and reassess imports, but indefinite retention without a seizure memorandum or disclosed reasons connecting the goods with confiscation is not justified. Food sampling should follow the specialised food-safety process through an authorised officer. A valid food-safety report may support conditional clearance, while classification, duty liability, confiscation and adjudication remain open. Revenue may be protected through proportionate security.

GST transit-state jurisdiction permits interception, document verification and authorised physical inspection of inter-State consignments, but physical passage through an intermediate State does not itself establish a place of supply, tax liability or penalty jurisdiction. Section 129 detention and penalty require contravention linked to a taxable nexus; where documented origin and destination are outside the transit State and there is no diversion, local supply, false documentation or mismatch of goods, an e-invoice defect alone should be addressed by authorities connected with the supplier or recipient. Cross-empowerment under the CGST and IGST regimes facilitates administration but does not create independent territorial taxing authority. Discrepancies may be recorded and communicated to competent jurisdiction.

Shareholder ratification cannot retrospectively validate diversion of preferential-issue proceeds from the objects disclosed in the explanatory statement where the conduct breaches securities-market disclosure duties and constitutes fraud or an unfair trade practice. Issue-specific objects, rather than broad memorandum objects, govern whether proceeds were deployed as represented. Immediate use of funds for undisclosed loans or share investments, without a substantiated commercial explanation, may support an inference that the disclosed objects were never intended to be performed. Prospectus-based variation mechanisms do not apply to private placements or cure completed diversions. Continuing disclosure requirements promote transparency but do not authorise post-facto deviations, while later amendments to corporate objects remain prospective only.

Section 195 requires withholding on payments to non-residents only where the remittance contains income chargeable in India. Where a DTAA is more beneficial, treaty definitions govern royalty and fees for technical services. Software payments are not royalty where the recipient receives only a restricted right to use a copyrighted product, rather than rights to reproduce, exploit, distribute or otherwise exercise copyright. Services must be separately tested under any treaty make-available requirement. Amounts falling outside royalty and FTS may constitute business profits, taxable only under applicable permanent-establishment and profit-attribution rules. Composite arrangements require component-wise classification, with proportionate withholding available for genuinely mixed remittances.

Unpaid anti-dumping duty omitted during self-assessment may be pursued through the customs recovery procedure without prior appellate modification of the self-assessment. The recovery framework applies to anti-dumping duty through statutory incorporation of provisions concerning assessment, non-levy, short-levy, interest and recovery. Where anti-dumping duty is chargeable, it forms part of the aggregate value used to compute IGST on imports, potentially creating a consequential IGST short-payment. Recovery requires accurate assessment of notification coverage, product, origin, rate, valuation, limitation and procedural safeguards.

The six-year limitation for condoning delay in filing revised returns did not apply where the departmental intimation triggered representations, rectification proceedings and a rectification order. Treating the application as time-barred without accounting for that factual sequence was unsustainable. Delay in filing the revised returns was therefore to be condoned, and the related refund claim required consideration in accordance with law.

New rule 164 creates an electronic process for waiver of interest or penalty, or both, under section 128A for qualifying tax demands. Applications against notices or statements are made in FORM GST SPL-01, while applications against demand orders are made in FORM GST SPL-02 after required payment adjustment in the Electronic Liability Register. Applicants must satisfy payment conditions and withdraw pending appeals or writ petitions. The process provides for notice in FORM GST SPL-03, reply in FORM GST SPL-04, acceptance in FORM GST SPL-05, rejection in FORM GST SPL-07, appellate acceptance in FORM GST SPL-06, and deemed approval if no order is issued within the prescribed period.

The filing deadline for a registered person to opt for payment of Tamil Nadu State GST at 3% under the specified notification was changed from 30 April 2019 to 31 July 2019. The option is exercised by filing an intimation in FORM GST CMP-02 under rule 3(3), selecting "Any other supplier eligible for composition levy" at serial number 5(iii) of that form. The registered person must also furnish a statement in FORM GST ITC-03 in accordance with rule 3(3).