Section 153C proceedings require a satisfaction note to be recorded when proceedings against the searched person are initiated, during those proceedings, or immediately after their completion. Recording satisfaction more than four years after completion of the searched person's assessment does not meet the requirement of immediate recording. Pandemic-related disruption and the faceless assessment scheme do not justify that delay. Consequently, the delayed satisfaction note invalidates the proceedings against the person other than the searched person, requiring the notice, consequential assessment order and demand notice to be quashed.

Priority under section 26E of the SARFAESI Act places a secured creditor's registered security interest ahead of government revenues, taxes and cesses. An income-tax attachment predating CERSAI registration can displace that priority only where it was validly enforced and publicly proclaimed as required by law. Failure to establish the required proclamation or registration of the revenue claim or attachment with CERSAI prevents the attachment and resulting encumbrance from prevailing. The secured creditor's dues therefore take priority, and the unproclaimed income-tax attachment is liable to be removed.

Deductions under Sections 80-IA and 80-HHC are governed by the distinction between computing a deduction and allowing it. Deduction under Section 80-HHC must be computed on gross total income before deduction under Section 80-IA is allowed; therefore, the Section 80-IA deduction is not reduced from business profits when calculating the Section 80-HHC deduction. The combined deductions remain subject to the ceiling that they cannot exceed the profits and gains of the eligible business.

Sufficient cause under section 260A(2A) of the Income-tax Act can encompass a short filing delay where record movement, legal advice, administrative approval, appeal preparation and execution collectively show bona fide diligence rather than negligence or inaction. The provision contains no language barring condonation after expiry of the limitation period. Assessment of the proposed appeal's merits remains outside delay-condonation review. On these principles, the 31-day delay in filing the income-tax appeal was condonable.

Challenge to an intimation under section 143(1) was not pursued through the writ route because an alternative statutory remedy was available. The Special Leave Petition was dismissed, while preserving liberty to approach the ITAT under that remedy and to seek condonation of delay. The matter highlights appellate recourse and delay-condonation relief where writ proceedings are affected by inordinate delay and laches.

Condonation of delay in filing a Special Leave Petition requires reasons that are satisfactory and legally sufficient. A 900-day delay relating to an income-tax dispute involving unexplained credits, a Section 153C notice, and search proceedings was not condoned because the stated reasons failed that standard. The Special Leave Petition therefore did not proceed on its substantive issues.

Reopening proceedings raised the issue whether reasons to believe rested on borrowed satisfaction or the assessing authority's independent satisfaction, concerning expense disallowances for purchases treated as bogus. The Supreme Court dismissed the SLP after condoning delay, finding no ground to interfere with the High Court judgment and order. The challenge to the reopening and related disallowances therefore did not proceed further before the Supreme Court.

Rectification of a mistake in apportioning available input tax credit is addressed through the applicable Standard Operating Procedure dated 14 October 2025 and Section 161 of the Telangana GST Act, 2017. The proper officer is required to rectify the ITC apportionment in accordance with that framework. A rectification order remains subject to the appropriate appellate remedy, enabling the affected party to challenge the corrected determination through an appeal.

Section 107(8) requires a personal hearing before a statutory appeal is dismissed as time-barred where a delay-condonation application is pending. Dismissing the appeal without hearing the applicant on the reasons for delay breaches the mandatory hearing requirement and denies an opportunity to explain the delay. Such dismissal is legally unsustainable, requiring the delay-condonation request to be considered after affording a personal hearing.

Rectification under the applicable GST enactments is limited to patent errors apparent from the record. Where supporting documents were not furnished and no apparent error in the original order was established, rectification of an under-declaration of ineligible input tax credit could not be granted. The rejection of the rectification request was therefore valid, leaving the finding of under-declared ineligible input tax credit unchanged.

Revocation of cancelled GST registration may warrant a further opportunity where a show-cause notice remained unanswered for medical reasons and outstanding tax liabilities were not addressed. Rejection of the revocation application was set aside subject to filing a reply and furnishing the undertaking required under Rule 23 to pay outstanding tax, interest and penalty. The competent authority must then determine the revocation application in accordance with law.

Interim protection from arrest in a GST investigation was granted pending interrogation, subject to the petitioner appearing before the Investigating Officer. Relevant considerations included the petitioner's claimed resignation before the alleged transactions, the absence of notice identifying him as an accused, the documentary nature of the material, and willingness to cooperate. The investigating side indicated that arrest could not be made under the notices issued to the petitioner. Further time was allowed for a response before the next hearing.

Post-determination recovery under the CGST Act extends to negative blocking of an electronic credit ledger. The recovery framework permits multiple recovery modes and is distinguished from provisional credit restrictions, which operate before liability is determined. An interim direction keeping recovery proceedings in abeyance is confined to preventing debits from ledger balances for recovery and does not, by itself, displace a pre-existing ledger-blocking measure. Accordingly, interim protection against recovery debits does not invalidate existing negative blocking, which remains available as a recovery measure after determination of liability.

Section 49(4) permits electronic credit ledger balances to be used for output-tax payments only in the prescribed manner and subject to prescribed conditions and restrictions. Although such credit may ordinarily be used towards liabilities including an appellate pre-deposit under Section 107, that facility is unavailable while a valid Rule 86A credit-blocking order remains in force. Rule 86A operates as a provisional measure, requires recorded reasons, allows an application for unblocking, and cannot continue beyond one year. Blocked electronic credit ledger amounts therefore cannot be utilised for appellate pre-deposit during the blocking order's operation.

Rule 86A permits protective blocking of an Electronic Credit Ledger where material prima facie supports a belief that suppliers are non-existent and their registrations have been cancelled. To preserve audi alteram partem, the affected taxpayer must receive a post-decisional personal hearing and independent, reasoned consideration of documentary material supporting the input-tax-credit claim. The taxpayer must submit a representation, which the competent authority must decide through a reasoned order after granting a personal hearing.

Uploading a show-cause notice only under the portal's 'Additional Notice and Orders' tab, without separate intimation, may deny the taxpayer an effective opportunity to reply and breach principles of natural justice. Where this prevents participation in adjudication, the notice and resulting adjudication cannot be sustained. The appropriate corrective process requires fresh notice, an opportunity to file a reply, a personal hearing, and reasoned adjudication.

Availability of a functional GST Appellate Tribunal restores the statutory appellate remedy under Section 112 where a writ petition was entertained solely because the Tribunal was non-functional. The petitioner must pursue the statutory appeal before the GST Appellate Tribunal, which must entertain the appeal without raising a limitation objection. No merits of the underlying penalty proceedings were adjudicated.

Rule 86A-blocked input tax credit cannot be treated as payment or appropriation towards the statutory pre-deposit under section 107(6), because the restriction prevents debit of that credit for discharging liability. Only credit lawfully available and capable of debit may be used, unless the competent authority removes or modifies the restriction. Rectification of an erroneous FORM GST DRC-07 that caused incorrect portal computation of the pre-deposit supports preservation of the statutory appellate remedy. Appeal filing may proceed upon compliance with the pre-deposit requirement, with electronic assistance and manual filing where portal difficulties continue. Challenges to the tax demand and Rule 86A restriction remain for determination by the competent forum.

Uploading a show-cause notice solely under the portal's "Additional Notice and Orders" tab, without separate intimation, deprived the assessee of an effective opportunity to respond and breached principles of natural justice. The adjudication and appellate orders were therefore unsustainable, particularly because the appellate authority rejected the appeal solely on limitation without examining the merits. The assessee must be permitted to file a reply, be heard, and receive a fresh reasoned determination.

Special Leave Petitions concerning GST proceedings were dismissed, with petitioners retaining liberty to raise all grounds before the GSTAT. They may also seek exclusion of time under Sections 5 and 14 of the Limitation Act, 1963, in pursuing the GSTAT remedy. The writ petition was disposed of as withdrawn.