Prima facie jurisdictional objections to reassessment, including sanction and statutory limitation, supported interim protection while the pending appeal remained undecided. Because 20% of the disputed demand had already been deposited, recovery was limited to that amount: adjusted refunds exceeding the deposit were to be returned, and further refund adjustment was barred pending appellate disposal. The appellate authority was required to determine the appeal within 12 weeks.

TNMM comparability depends on functional, asset and risk profiles; entity size may justify a turnover filter even without a prescribed ceiling. Operating-margin analysis may use a cash PLI excluding depreciation where asset types, technology and investment levels cause material depreciation differences. Provisions for bad and doubtful debts ordinarily form operating costs unless demonstrated to be extraordinary. Equipment supplied without charge by an associated enterprise does not constitute a taxable business perquisite where ownership remains with that enterprise, the recipient neither capitalises nor depreciates it, and its use is limited to testing software for the owner.

Section 119(2)(b) provides a statutory remedy to seek condonation for delayed return filing where the appellate authority has no such power. Completion of assessment and pendency of an assessment appeal do not, by themselves, bar that remedy. Genuine hardship requires a liberal assessment of a delay explanation, particularly where a short COVID-19-period delay is substantially similar to a previously accepted delay. Rejection solely on the basis of completed assessment or pending appeal is unsustainable, and the related deduction claim requires consideration on merits in accordance with law.

Absence of an effect-giving order and continued seizure of a locker require prompt administrative consideration while the petition remains pending. The Assessing Officer must provide a personal hearing and issue appropriate effect-giving orders within the stipulated period. Arrangements must also be made to open the seized locker and prepare an inventory of its contents. No final determination has been made on tax liability, refund entitlement, or release of the seized articles; the matter remains listed for further hearing.

Prior approval for an order under Section 148A(d) and a reassessment notice must be obtained from the authority prescribed by the elapsed period from the end of the relevant assessment year. The temporary extension allowing approval by the authority applicable within three years, where that period expired during the 2020 relaxation regime, operated only until 30 June 2021. Approval obtained in July 2022 from a Principal Commissioner did not satisfy the requirement applicable after that period; approval from the higher authority under Section 151(ii) was required. Absence of approval from the statutorily competent authority invalidates the order, notice, and resulting reassessment proceedings.

Assessment validity was questioned where it was issued on a PAN allegedly neither obtained nor used by the petitioner. Material differences between two PAN records, including date of birth and addresses, left unresolved how substantially similar PANs were issued and why one was later deactivated. Original PAN application records, verification material, profile details, and deactivation records were required to be produced for further examination. No final determination was made.

Section 264 revision requires the Commissioner to examine an assessee's grounds and supporting material on merits, even where the assessee did not participate in reassessment proceedings. The Commissioner may call for records and make or direct inquiries, but must pass an order not prejudicial to the assessee. Non-compliance with reassessment notices does not remove the duty to give reasoned consideration to the revision claim. Rejecting revision through a bare assertion that the assessment order is well reasoned, without addressing submissions, is a non-speaking and unsustainable exercise of revisionary jurisdiction.

Under the pre-1 April 2021 reassessment framework, a return filed in response to reopening is treated as a return under Section 139, with scrutiny initiated through Section 143(2). Recorded reasons must be supplied on request, and reopening objections must first be resolved by a speaking order because they may challenge jurisdiction to reopen. Assessment cannot proceed through a scrutiny notice or a Section 142(1) information notice until that disposal. Following rejection of objections, a mandatory four-week interval must elapse before further reassessment action, preserving the taxpayer's opportunity to challenge the rejection.

Monetary-limit policy for Revenue litigation before the High Court applied to appeals arising from revision proceedings; the claimed exception did not automatically require disregard of tax effect. Because the tax difference was substantially below the applicable policy threshold and the transactions showed no recurring or multiple disputes, the appeals were dismissed as below the monetary limit. The questions of law remained open.

Disallowance of expenditure under section 14A where no exempt income is earned was the central issue. The Supreme Court declined to interfere with the High Court's application of an earlier unchallenged High Court ruling and dismissed the special leave petition. Revenue expenditure incurred as compensation for tenancy rights was also identified as part of the dispute.

Failure to cure fundamental and technical defects notified by the Registry through the online filing portal rendered the appeal liable to rejection as defective. Despite repeated effective opportunities to rectify the objections, the appellant neither appeared nor took corrective steps. Procedural compliance required rectification of the notified filing defects within the opportunities provided.

Expiry of an e-way bill, by itself, is a procedural or documentary lapse and does not sustain a penalty for movement of goods where no independent evidence establishes an intention to evade tax. Valid tax documents, interception near the declared destination, and absence of discrepancies in the goods or underlying transaction weigh against penalty. Diversion of goods, fictitious transactions, suppressed tax liability, or other deliberate evasion must be supported by material evidence.

Uncured registry defects in a GST appeal may warrant dismissal at the threshold where the appellant fails to rectify them despite the opportunity available. Failure to address the defects can indicate inadequate attention to the appeal, particularly where the appeal appears meritless. Further time to cure procedural defects need not be granted when it would not serve the interests of justice. The appeal was therefore treated as liable to dismissal without allowing an additional opportunity for rectification.

GSTR-1/GSTR-3B mismatch alone does not establish short-payment of GST; differential figures require reconciliation with returns, electronic records, payment particulars, annual returns and other relevant material. Where a demand includes input-tax-credit reversal under Rules 42 and 43, its statutory basis and computation must be separately identified and established. Ex parte appellate proceedings may continue after valid hearing opportunities, but a reasoned determination remains necessary for pleaded claims concerning rectification, subsequent payment, interest, penalty, communication, duplication and statutory waiver. Appellate affirmation without reconciliation and examination of these material claims is legally unsustainable.

Penalty under Section 129(3) for goods in transit requires a legally established contravention supported by cogent and reliable evidence. Where goods are accompanied by a tax invoice and e-way bill and no quantity or quality discrepancy exists, an inconsistency in the address or business particulars alone does not establish mens rea or an intention to evade tax. Such a technical or procedural breach cannot justify penal action without independent proof of tax evasion. The penalty and the appellate order sustaining it were unsustainable for insufficient evidence of a penal contravention.

Anti-profiteering re-investigation may validly follow a remand to apply a project-wide, per-square-foot apportionment of GST savings where an earlier methodology was legally unsustainable. The original reference remains operative, and the investigating authority is not functus officio where no final adjudicatory order followed the flawed report. Rule 129(6)'s reporting period is directory rather than mandatory, and delay arising from non-production of records does not bar re-investigation. Re-investigation does not breach natural justice where notice, access to the report, and opportunities for objections are provided. Section 171(1) requires suppliers to prove actual transmission of input tax credit benefits through commensurate price reduction; unpassed benefits attract interest, while no penalty applies for periods before the penalty provision took effect.

Section 129 applies only while goods are in transit and cannot support detention, tax demand, or penalty after the vehicle has reached the consignee's registered premises. Where tax invoices and e-way bill Part A accompanied the goods, prompt correction of an un-updated Part B constituted a curable technical lapse without revenue loss or mens rea. Section 126, the applicable circular, proportionality, and audi alteram partem required moderation; a hearing held after the adjudication order's stated date rendered the proceedings defective. Amounts recovered under protest were refundable with statutory interest.

Input tax credit for goods and services used to construct a resort building and related civil structures is blocked where construction is on the taxable person's own account. The retrospective substitution of "plant and machinery" from 1 July 2017, read with the statutory exclusion of land, buildings and civil structures, prevents such premises from qualifying for the exception, even under a functionality approach. Taxable accommodation, restaurant, event and photo-shoot services do not establish construction for sale, lease or licence to another. Credit remains available only for separately evidenced movable assets or qualifying items. Interest applies only to wrongly availed and utilised credit, and penalty relief depends on timely payment of tax and interest.

Input tax credit under the second proviso to Section 16(2) requires payment of the supplier's consideration and tax within 180 days; proportionate credit retained after that period attracts interest until the unpaid amount is waived and recorded through a credit note. A financial or commercial credit note that does not reduce the supplier's original taxable value or tax liability allows the recipient to retain or re-avail credit, consistent with binding Board clarifications. Proceedings for fraud-based recovery and penalty require fraud, wilful misstatement, or suppression with intent to evade tax; absent those elements, the matter is to be treated under the non-fraud recovery provision.

Blocking input tax credit in the Electronic Credit Ledger under Rule 86A requires a meaningful pre-decisional opportunity. When a taxpayer seeks an adjournment, refusal should be supported by recorded reasons, particularly where the blocking order is made on the scheduled hearing date. Allegations that credit arose from transactions with non-existing suppliers do not dispense with a reasoned process. The authority must consider the taxpayer's detailed response, provide a hearing, and determine on the merits whether the credit block should continue.