Transfer-pricing benchmarking requires comparable companies to be functionally similar and reasonably comparable in scale. When implementing a DRP direction to recompute margins from annual reports, the TPO must remain within that direction and cannot exclude expenses as non-operating without a corresponding direction; margins require recomputation without those exclusions. High-turnover companies may be excluded where turnover disparity makes them unsuitable comparables for captive software-development services. Companies providing diversified, high-end technology, product-development, artificial intelligence, cloud, blockchain and specialised services are not functionally comparable with routine captive software-development and testing services. The arm's-length price requires redetermination after applying these comparability filters.

Unsecured-loan additions are unsustainable where loans are repaid with interest in the same assessment year and evidence establishes each creditor's identity and existence. PAN details and corporate registration supported the creditors' existence. The appellate factual findings did not raise a question of law warranting interference, resulting in deletion of the addition in favour of the assessee.

Special Additional Excise Duty (SAED) on exports of aviation turbine fuel (ATF) outside India is revised to Rs. 11 per litre. The revised rate replaces the entry in column (4) against serial number 1 of the table in Notification No. 08/2026-Central Excise, which was issued on 26 March 2026 and last amended on 30 September 2026. The revised rate takes effect on 31 October 2026, the date of publication in the Official Gazette.

Special Additional Excise Duty rates on exports of petrol and diesel outside India are revised through changes to the duty entries in column 4 of the table under Notification No. 06/2026-Central Excise. The entry against serial number 1 is replaced with nil, and the entry against serial number 2 with Rs. 11.5 per litre. The revised entries take effect on 31 October 2026, the date of publication in the Official Gazette.

Government Departments, establishments, agencies, local authorities and public sector undertakings registered solely as Tax Deductors at Source are registered persons for GST purposes. Supplies to them are B2B supplies, including B2G supplies reported as B2B, rather than B2C supplies. Registered suppliers meeting the prescribed aggregate-turnover condition must issue e-invoices for such supplies by reporting invoice particulars to an Invoice Registration Portal and obtaining an Invoice Reference Number. Where e-invoicing applies, an invoice, credit note or debit note without the required Invoice Reference Number is not legally valid.

Electronically filed GST registration-cancellation requests remain effective despite acknowledged portal technical issues where portal records establish timely submission. The cancellation process must be completed, with a hard copy and fresh electronic application furnished where necessary. Cancellation is to operate from 31 December 2019, and, upon acceptance, GST returns filed after that effective date are void and non est.

Under the Odisha Goods and Services Tax Act, 2017, three central GST clarifications apply mutatis mutandis for uniform administration. They address export-of-services requirements, determination of place of supply, and GST taxability of personal and corporate guarantees. The clarifications apply across designated tax formations and first appellate authorities as clarificatory guidance, with implementation difficulties capable of being referred to the Commissioner of State Tax.

Customs Broker licensing requires applicants to submit a single complete online application through the CBLMS portal, select the Policy Section having jurisdiction over their intended place of business, and pay the prescribed fee. The Regulation 6 written examination is a computer-based bilingual multiple-choice examination and a prerequisite for grant of a Customs Broker licence. Applicants meeting the written-examination qualifying standard must appear for an oral examination. Candidates with benchmark disabilities may request appropriate arrangements with supporting evidence. False or forged application materials may cause rejection, licence cancellation, and action under applicable law.

GST on renting passenger motor vehicles with an operator depends on whether fuel cost is included in the consideration. Fuel-inclusive rental service is taxable at 5% subject to restricted input tax credit, or at 12% with input tax credit subject to statutory conditions. Where fuel cost is excluded from the consideration and paid separately based on actual consumption, the service is taxable at 18%.

Natural justice in GST scrutiny and adjudication requires an opportunity of personal hearing where a written request is made by the person chargeable with tax or penalty, or an adverse decision is contemplated. This applies to proceedings under sections 61, 73 and 74 of the OGST Act. Proper officers must provide a meaningful hearing before an adverse assessment and must activate the personal-hearing fields in the back-office portal to record the date, time and venue of hearing.

Schedule I treats supplies of goods between a principal and an agent as deemed supplies without consideration only where the agent acts representatively by supplying or receiving goods on the principal's behalf. The decisive indicator is whether the agent issues the relevant invoice in its own name and has authority to transfer or receive title to the goods. Pure procurement or auctioneering services, where invoicing remains in the principal's name, do not fall within this treatment. Representative agents may require compulsory registration, subject to exemptions for qualifying agricultural-produce commission-agent services.

Unpaid GST not debited to the profit and loss account and not claimed as a deduction cannot be disallowed under Section 43B. Section 43B requires actual payment as a condition for allowing a claimed deduction for tax, duty, cess or fee; it does not create an addition where no deduction has been claimed. Precedents supporting an adjustment were distinguishable on their facts. Accordingly, unpaid GST outside the profit and loss account does not attract a Section 43B disallowance.

Regulation 4G requires the resolution professional, with prior committee approval, to appoint independent qualified professionals for project-wise technical and cost-to-complete assessments of real estate projects. The assessment covers construction status, approvals, inventory, completion costs, funding needs, delivery timelines, and material risks. It must be completed before inviting expressions of interest, included in the information memorandum for prospective resolution applicants, and treated as an insolvency resolution process cost.

Only input tax credit accumulated on inputs because of an inverted duty structure is liable to lapse for supplies received up to 31 July 2018, limited to the unutilised balance after payment of GST through July 2018. Input services and capital goods are excluded. The lapsed amount is calculated under the prescribed inverted-duty refund formula, subject to the available balance. Credit relating to closing stock may be excluded, while credit attributable to zero-rated supplies, including exports, does not lapse. The self-assessed reversal must be reported in the August 2018 GSTR-3B return.

Where a corporate debtor has multiple real estate projects, the resolution professional must place project-wise RERA registration, completion, possession, occupancy, and completed and incomplete unit details before the committee of creditors at its first meeting. The committee may, by at least sixty-six per cent voting share and with recorded reasons, recommend excluding a project from the corporate insolvency resolution process. The resolution professional must then apply to the Adjudicating Authority with those reasons.

Uniform implementation of the Odisha GST Act extends CBIC clarifications to State GST administration on a mutatis mutandis basis. The clarifications address special procedures, place of supply, related-party service valuation, reverse-charge input tax credit, discount-compliance evidence, employee share reimbursements, insurance-related taxability and credit reversal, optical-fibre network credit eligibility, custodial services, and time of supply for annuity payments and spectrum allotment. They are clarificatory in nature, and implementation difficulties may be brought to the Commissioner of State Tax.

Private ITIs receive GST exemption only for approved vocational education courses relating to designated trades. The exemption covers vocational training, entrance examinations conducted for entrance fees, and specified admission or examination services supplied to educational institutions. Services relating to non-designated trades, including training, entrance examinations, and admission or examination-related services, attract GST. Government ITIs are exempt for vocational training and examinations supplied to individual trainees or students as government services to individuals.

Fertilizers under headings 3102, 3103, 3104 and 3105 attract 5% GST where supplied for direct agricultural use or as inputs for manufacturing complex fertilizers intended for soil or crop use. Simple fertilizers, including muriate of potash, remain eligible when used to manufacture such complex fertilizers. The exclusion for goods clearly not intended to be used as fertilizers applies to goods used for non-fertilizer industrial purposes, which attract GST at the higher rate.

Service tax deposited for duty-free-shop operations where indirect tax was not legally leviable attracts restitutionary interest from the date of deposit. Statutory refund provisions do not restrict compensation where the amount was retained without authority of law rather than constituting an ordinary duty refund. Interim interest paid at 6% does not discharge the obligation to provide appropriate compensation for wrongful retention. Interest is payable at 15% per annum from the date of deposit, subject to credit for interest already paid.

GST on petroleum gases supplied continuously to petrochemical and chemical manufacturers is payable by the refinery only on the net quantity retained by the recipient for manufacture. Where residual material is returned, GST becomes payable by the refinery when the returned petroleum gases are subsequently supplied to another person. The same treatment applies to comparable supplies where feedstock is retained and residual material is returned, with net billing based on the retained quantity.