Duty-free status limits fiscal levies but does not exempt imported goods warehoused, re-exported or sold through airport duty-free shops from domestic regulatory or public-health requirements. Goods entering Indian territorial waters remain imported goods even without clearance for home consumption, and restrictions under other laws may make them prohibited under the customs regime. Nicotine pouches require product-specific assessment of composition, intended use, statutory drug classification and any available exemption. Where product particulars are unavailable, classification and any import-licensing or registration requirement remain for reasoned determination by the appropriate authority upon submission of supporting material.

Goods and Services Tax on rental dues for land used as a Sumo Taxi Stand applies only from 08.07.2017, when the levy came into operation; payment for an earlier period cannot be compelled. The demand was consequently restricted to liability accruing from that date, with outstanding dues recoverable accordingly. The land-allotment claim was not determined on its merits and must be decided by the competent respondent through a reasoned speaking order in accordance with law within three months.

E-way bill delivery to an address not declared as the recipient's principal or additional place of business constitutes a contravention attracting penalty under Section 129, even where tax has been paid. The e-way bill tracking framework requires the declared delivery location to be a registered business address at the time of supply and interception. Subsequent registration of that location as an additional place of business does not cure the earlier contravention. The penalty order therefore remained undisturbed, while the supplier retained the option to seek recovery of the penalty from the recipient through appropriate remedies.

Writ jurisdiction may remain available for recovery of a GST component withheld from contractual dues where contractual performance, bills and the underlying transaction are undisputed, and the issue can be resolved from the acceptance letter and record. A term providing that GST is payable in addition to quoted rates binds the paying authorities and cannot be displaced by later calculations or correspondence. The contractor's independent payment of GST does not justify deduction from contractual consideration. Reconsideration of dues may defeat delay and laches objections, while GST and other authorities need not be joined where the dispute concerns the payment-processing authority's contractual liability. Release of the withheld GST component with interest was directed.

Relevant date for refund of Kerala Flood Cess mistakenly paid through GSTR-3B is the date of subsequent remittance into the correct account. Where the cess was initially paid with GSTR-3B and later deposited through the prescribed mechanism, the two-year refund limitation under Section 54 runs from the latter payment rather than the erroneous earlier payment. The refund application is therefore treated as timely, requiring the competent authority to reconsider it and issue orders within one month.

Printing on paper and content owned by a GST-registered customer constitutes job work under Heading 9988; where the customer is unregistered, it is a service of treatment or processing of goods belonging to another person under the same heading. Concessional GST treatment applies only to specified printing and to qualifying goods under Chapters 48 or 49 that themselves attract the prescribed concessional or nil rate; other printing services fall under residual entries. Printing religious books using the printer's paper and consumables is a composite supply in which printing is the principal supply. It is classifiable as a printing service under Heading 9989, rather than as a supply of printed books, and attracts the residual GST rate.

Centage-based project management services for construction projects, including project reports, technical sanctions, tendering, supervision, monitoring and coordination, are classifiable as construction project management services under SAC 998339 and taxable at 18% GST. The pure-services exemption does not apply because State and coastal highways and tourism corridor roads were not established as roads or bridges within functions entrusted to Panchayats or Municipalities. The concerned Government Administrative Department is the recipient because it owns the projects, requisitions the services and assigns implementation. A funding agency that only disburses consideration, reviews and monitors does not become the recipient; invoices must be issued to the Administrative Department.

GST exemption applies from 10 October 2024 to NSQF-aligned vocational training supplied by a training body accredited with an Awarding Body recognised by NCVET, where NCVET has approved the relevant qualification package. Training in handheld-device repair and telecom-product assembly meeting those conditions falls within item (e)(iii) of Entry 69. Such structured, nationally recognised skill training is distinguished from generic commercial coaching and is classifiable as other education and training services not elsewhere classified under SAC 999294.

Fermented Nata De Coco is classified under Tariff Item 21069099 as a food preparation not elsewhere specified or included, rather than under Chapter 20. Heading 2007 covers fruit jellies made by cooking or concentrating fruit juice or pulp with sugar, and a jelly-like appearance alone is insufficient. Microbial fermentation produces a distinct edible preparation, while Heading 2008 requires retention of the identity and essential character of an edible plant part. GST applies at 18% from 1 July 2017 to 21 September 2025 and at 5% from 22 September 2025.

Condonation of a 30-day delay in furnishing Form No. 10B for charitable-exemption purposes may be granted under section 119(2)(b) where refusal would cause genuine hardship. Genuine hardship must be construed liberally, with substantial justice preferred over technical non-compliance, absent deliberate delay, culpable negligence or mala fides. A bona fide misunderstanding of an advanced filing due date during the COVID-19 period, coupled with filing before the extended return due date, supported condonation. A pending condonation application did not require the charitable institution to await its disposal. Form No. 10B was treated as timely filed, and the return was to be processed accordingly.

Natural justice was prima facie breached where an unexplained-expenditure addition based on import data was made without meaningful invoice-wise or bill-of-entry-wise particulars. Recorded imports supplied by the assessee exceeded the aggregate data relied on, and apparent duplication in departmental data prevented reconciliation. The High Court treated the addition as raising strong triable issues and stayed recovery pending first appeal, while requiring the appellate authority to decide independently on merits. Administrative directions concerning deposit of a prescribed demand percentage did not fetter the Court's stay power; Revenue's insistence on a 20% payment was rejected. The assessment observations remained confined to the prima facie stay determination.

Settlement applications filed by 30 September 2021 required only that the relevant assessment case be pending on the application date; no statutory requirement imposed eligibility by an earlier date. The Board's deadline-relaxation power could not add a prior-eligibility condition absent from the statutory scheme. Where live, unadjudicated notices under sections 153A or 143(2) existed, eligibility could not depend on delayed notice issuance, and differing treatment of years arising from the same search lacked a rational basis. Paragraph 4(i) and the corresponding press release were read down; rejected applications were restored for decision on merits, with consequential assessments subject to that decision. The constitutional challenge to section 245C(5) remained open.

Faceless assessment procedures must provide the NFAC-prescribed minimum seven working days for a response and a meaningful opportunity of personal hearing. Allowing only one working day to reply, scheduling a hearing within less than 24 hours and before the reply deadline, and refusing a reasonable one-day adjournment denied natural justice. The assessment order, demand and penalty show-cause notices were quashed, with proceedings remanded to the show-cause-notice stage for fresh reply and hearing opportunities. Merits and other challenges remained open.

Concurrent factual findings on cash credits recorded in an impounded diary did not give rise to a substantial question of law in the income-tax appeals. The credits recorded in a partner's name were treated as unaccounted funds introduced by the partner into the partnership firm after considering the stated unaccounted sources. A plea to assess the entire diary amount in the partner's hands required reconsideration of those factual findings rather than resolution of a legal issue. The challenges therefore failed for want of a substantial question of law.

Limitation for a fresh assessment ordered through a rectification order is computed from the rectification order where it forms part of the appellate order and directs a de novo assessment; assessments completed on that basis remain timely. For the alleged LOC-scam income addition, submission of periodic status reports on the related CBI prosecution was required. Because the required information was not fully supplied, the addition required fresh assessment after consideration of a detailed status report, existing material, and further evidence. Continued non-compliance permits the Assessing Officer to draw an adverse inference.

Revisionary jurisdiction under section 263 may be invoked where the assessment record gives a prima facie basis to regard an assessment as both erroneous and prejudicial to Revenue; final determination follows inquiry and hearing. A co-operative society deduction requires examination of the timely-return condition under section 80AC. Queries into cash deposits do not satisfy that obligation where they do not address the separate statutory eligibility condition, and a return furnished only after a reopening notice does not meet the prescribed filing requirement. Reassessment may examine the deduction when claimed co-operative income is offered to explain the cash deposits that prompted reopening. The revision was sustained and the appeal dismissed.

Cloud-based communication platform subscription fees are not royalty where subscribers receive only limited, non-exclusive access and no copyright, source code, intellectual property, or embedded process is transferred. The provider's use of technology and processes to deliver the service does not give subscribers a right to use those processes. Such receipts constitute business income and are not taxable in India absent a permanent establishment. Tax deducted at source credit requires factual verification before it may be allowed in accordance with law.

Penalty for under-reported income is excluded where the taxpayer provides a bona fide explanation and fully discloses supporting material facts. Uploading audit records, paying relevant taxes before reassessment, and filing income accepted without additions supported cancellation under section 270A. Delayed tax-audit reporting does not attract penalty where reasonable cause is established: director disputes during the pandemic delayed account finalisation, while prompt upload after finalisation and absence of prejudice supported cancellation under section 271B.

Regular scrutiny assessment under section 143(3) requires the Assessing Officer to exercise quasi-judicial discretion independently. Absent statutory authority, consultation with and prior approval from an Additional Commissioner during the assessment process constitutes unauthorised superior-officer participation and negates the Assessing Officer's independent application of mind. Such assessments are void ab initio and liable to be quashed. A superior officer may consult subordinates without displacing the superior officer's discretion, but subordinate consultation with a superior officer displaces the discretion vested exclusively in the Assessing Officer.

Section 115BAA concessional corporate tax option requires cumulative compliance with prescribed conditions; claiming additional depreciation, which the regime prohibits, while calculating tax under the normal regime invalidates the option despite filing Form 10-IC. However, disallowance of additional depreciation through section 143(1) return processing is not permissible where it turns on a disputed legal position, particularly where the taxpayer's clarification was not considered. The invalid option therefore did not sustain the adjustment, which was deleted.