SHRI S.S.GODARA, JM AND SHRI DR. DIPAK P. RIPOTE, AM For the Assessee : Shri Sarvesh Khandelwal For the Revenue : Shri S. P. Walimbe ORDER PER S. S. GODARA, JM : 1. This assessee's appeal for A.Y. 2006-07 is directed against the CIT(A)-6, Pune's order dated 22/03/2017 passed in case No. PN/CIT(A)-V/ITO Wd.8(1)/96/2014-15 involving proceeding u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961; in short "the Act". Heard both the parties. Case file perused. 2. We notice at the ... ... ...

Where the Tribunal follows binding High Court precedent and identical Revenue appeals have already been dismissed, no substantial question of law arises unless contrary material distinguishes or displaces the settled position. The Revenue's challenge failed because it identified no basis to depart from the governing precedent, and the issue remained decided in favour of the assessee.

Global investment access is integrated into IFANOW's wealth-management platform through Appreciate's technology infrastructure, enabling advisors and clients to access Global Funds and US Stock Baskets within existing workflows. Assisted and DIY journeys support onboarding, KYC, remittance and investment execution. Appreciate provides infrastructure for execution, payments, distribution, advisory and exchange connectivity through APIs and SDKs. Global investments are facilitated through regulated GIFT City IFSC and FEMA-compliant Liberalised Remittance Scheme routes, with supported banking channels for funding.

Orange Retail Finance India Private Limited completed a listed non-convertible debenture issuance as the first tranche of its listed debt programme. The issuance is part of a broader debt-fundraising plan to diversify funding sources, establish an institutional capital-raising platform and support asset-liability management. It accompanies a transition from legacy two-wheeler lending to secured retail finance focused on gold loans and MSME loan against property in semi-urban and rural markets.

Pending completion of role mapping on the Boweb Portal, existing officer assignments continue despite changes in office nomenclature or territorial jurisdiction. Officers must continue to perform tasks allocated before the revised jurisdictional allocation, including registration, refund, scrutiny, audit, enforcement, adjudication, appeals and related functions, until the portal mapping is updated.

Territorial jurisdiction under the Rajasthan Goods and Services Tax Act, 2017 is assigned to corresponding levels of proper officers exercising jurisdiction under the Rajasthan Value Added Tax framework. The assignment aligns GST officer jurisdiction with jurisdiction allocated under specified provisions of the RVAT Rules, 2025 and the RVAT Act, 2003. The revised arrangement replaces the earlier departmental assignment and takes effect from 15 August 2026.

Resolution-plan approval requires the prescribed compliance certification, creditor approval, provision for insolvency-resolution costs and stakeholder payments, and arrangements for management, implementation and supervision. Eligibility of the resolution applicant, feasibility and viability of the plan, and compliance with resolution-plan requirements and applicable law are necessary conditions. Where provision is made for disputed statutory claims, they are addressed under the plan; claims excluded from an approved plan stand extinguished. A plan meeting these conditions becomes binding on the corporate debtor and stakeholders covered by it.

GST jurisdiction is determined by the date on which statutory power is invoked. Proceedings validly undertaken by the officer having jurisdiction at that time remain valid after taxpayer migration. The transferee jurisdictional authority must take over pending matters from their existing stage, implement prior valid action, and conduct all further and consequential proceedings. The transferor authority cannot initiate action after migration and must communicate subsequently noticed matters to the transferee authority.

Reorganized field formations commence regular functioning after system mapping of newly created Zones, Circles and Wards, corresponding officers and territorial jurisdictions. Officers must immediately undertake statutory, administrative and other duties in their newly assigned jurisdictions. Additional Commissioners responsible for administration, BAW, enforcement wing and appeals must ensure a smooth transition and uninterrupted disposal of work.

Section 258(1)(b) of the Income-tax Act, 2025 authorises the Central Government to specify the Secretary, ITE&C, Government of Andhra Pradesh, as the official for sharing information concerning income-tax payers. Such information sharing is connected with identifying persons eligible for the various welfare schemes implemented by the Government of Andhra Pradesh.

Revocation of cancellation of registration applications filed beyond 60 days but within 90 days from service of the cancellation order are governed by the extended revocation procedure. The prescribed standard operating procedure applies mutatis mutandis. Special Commissioner-I is responsible for Zones 1 to 6 and Special Commissioner-II for Zones 7 to 12. All other conditions governing revocation of cancellation of registration remain unchanged.

Emerging financial technologies should be evaluated by the financial need they address rather than by novelty alone. Their benefits depend on inclusive design choices such as interoperability, common standards and accessibility. Prudence requires safeguards against risks arising from automation speed, concentration in technology dependencies and opacity in advanced models. Institutions remain accountable for customer fairness and risk management despite algorithmic decision-making or third-party technology provision. Policy should apply proportionate governance, validation, oversight and intervention requirements, while allowing controlled experimentation and adaptive supervision to support responsible innovation.

Input tax credit time limits under Section 16(4) for reverse-charge supplies received from unregistered persons are addressed for Delhi GST purposes by the corresponding central GST clarification. The clarification is adopted mutatis mutandis for application under the Delhi Goods and Services Tax framework. The position is clarificatory in nature.

Rupee depreciation against the US dollar was linked to Brent crude prices exceeding USD 100, persistent dollar demand and concern over India's import bill. India's substantial dependence on crude imports makes sustained oil-price increases a source of pressure on the import bill, current account and rupee. FCNR-related dollar inflows have largely faded, while movement above the 95 USD/INR level generated additional dollar demand and was viewed as technically significant.

Valuation of imported services supplied by a related person to a recipient eligible for full input tax credit is clarified for implementation under the DGST Act, 2017. The corresponding central clarification applies mutatis mutandis to such related-party import-of-service supplies, with the stated objective of uniform implementation.

The National Industrial Corridor Development Programme spans industrial corridors and greenfield industrial smart cities designed as plug-and-play manufacturing ecosystems with serviced land, utilities, ICT infrastructure and multimodal connectivity. India-Russia engagement covers manufacturing investment, technology cooperation, localisation, business matchmaking and possible industrial clusters. NICDC also supports PM MITRA Parks, BHAVYA industrial parks, GIS-enabled industrial land information and digital logistics platforms to improve site selection, container visibility, logistics efficiency and data-driven decision-making.

Zero-rated exports permit input tax credit through export under a Letter of Undertaking or Bond without payment of integrated tax, followed by refund of accumulated unutilized credit, or through the permitted integrated-tax payment route. Export proceeds must be realized within applicable foreign-exchange timelines. Deemed exports to specified export-promotion entities remain taxable domestic supplies and use invoice-based refund procedures. Advance Authorisation enables duty-free import of export-production inputs subject to value-addition and actual-user conditions. An LUT requires payment of tax and interest if export or service-remittance conditions are not met.

Input tax credit under section 16(2)(c) of the CGST Act is conditioned on actual remittance of tax to the Government by the supplying person. A purchaser who has paid the tax component to the supplier may consequently be denied credit where the supplier defaults in payment. Purchaser concerns require revenue authorities to focus recovery efforts on defaulting suppliers and to make appropriate enquiries before placing the burden on purchasers. Technology-driven mechanisms for tracking supplier compliance are identified as necessary to reduce disproportionate hardship to genuine purchasers.

GST inspection of goods in movement permits interception of a conveyance carrying goods in transit for verification of prescribed documents, devices and goods. The person in charge must carry the required transport records, including applicable invoice, bill of supply, delivery challan and e-way bill, produce them on interception, and allow inspection. Documentary deficiencies or supplies contrary to GST requirements may result in detention, seizure, confiscation and penalties. A transporter may upload portal details where verification holds up a consignment beyond 30 minutes.

Rule 110(5) of the CGST Rules, 2017 bases GSTAT appeal fees on tax or input tax credit involved, the difference in tax or input tax credit involved, or fine, fee or penalty determined in the appealed order, subject to prescribed limits. Its repeated use of "or" supports alternative, rather than automatically cumulative, computational bases. The applicable limb must follow the actual dispute, grounds and relief in appeal, not the appellant's preference. Interest, though mentioned in the no-demand proviso, is omitted from the main proportional formula. Amounts accepted and not challenged should be distinguished from amounts actually involved in appeal.