Without-prejudice deposits in Section 7 insolvency proceedings cannot, by themselves, constitute an unconditional admission of liability where objections to maintainability and to the existence of debt and default remain pending. Such a deposit may indicate solvency but cannot replace the required determination of financial debt, default and maintainability. A subsequent demand containing materially different components does not independently establish a financial debt, and permission to pursue legally maintainable claims is not an adjudication of them. Closure of the insolvency application without deciding these objections was set aside, and the matter was remanded for fresh consideration subject to re-deposit of the released amount.

Death of a natural-person resolution applicant after committee of creditors approval does not automatically render a resolution plan unimplementable or permit liquidation. A resolution applicant acts as a promisor, not an office-holder with non-heritable obligations, and liquidation remains confined to specified statutory contingencies. The resolution request and plan terms should govern continuation; if silent, inherent powers may require the committee of creditors to examine implementation by an eligible, competent and willing heir or reconsider earlier plans before forced liquidation. A pending CIRP withdrawal application based on settlement with the sole committee member must be considered and cannot be denied merely because liquidation was ordered. Liquidation was set aside, CIRP revived, and the withdrawal application directed for consideration.

Section 32A protection extends the clean slate principle to a corporate debtor sold as a going concern during liquidation, subject to fulfilment of statutory conditions. Unclaimed past liabilities, pending or future proceedings, and pre-existing non-compliances cannot continue against the purchaser after completion of the sale where the statutory protection applies. This consequence arises by operation of law rather than as a discretionary waiver or concession. Purchasers seeking waivers or concessions concerning past liabilities must pursue those requests before the relevant statutory authorities.

Section 37A seizure of equivalent domestic assets was upheld where foreign proceedings and control of overseas entities gave reason to believe that foreign exchange derived from those entities remained held abroad in contravention of FEMA. Confirmation of seizure operates as an interim protective measure pending adjudication, particularly where no repatriation or disclosure of the foreign exchange is shown. Applying Section 37A to foreign exchange acquired after its commencement and continuing to be held abroad does not constitute retrospective application. Foreign employment permits alone do not establish non-resident status without evidence of year-wise Indian stay or an intention to remain abroad indefinitely; an administratrix's personal residential status does not determine the Estate's alleged foreign holding.

Prior release of frozen property for failure to file a prosecution complaint within the prescribed period does not decide the merits or bar a subsequent attachment. Orders quashing predicate-offence and money-laundering proceedings for particular individuals do not prevent continuation of proceedings against a firm or adjudication of attachments concerning other individuals. Compensation paid for environmental-clearance and forest-law violations neither compounds money-laundering offences nor offsets proceeds of crime from alleged illegal mining. Bank deposits representing available proceeds of crime, or their equivalent value, remain attached pending finality of the PMLA trial.

Provisional attachment of alleged proceeds of crime represented as long-term capital gains from share sales continued because the share purchasers appeared to have been funded from sources other than their own. Funds were routed through banking channels to acquire shares in non-functioning companies at highly appreciated prices, without an apparent commercial basis for the valuation. The investment explanation was treated as unconvincing, including in light of the appellant's role in the trust operating the university. As the scheduled-offence and money-laundering trials remained pending, the attachment was retained to secure the alleged proceeds of crime until trial conclusion.

Leasehold transfers of land to approved Special Economic Zone units qualify as transfers of land for stamp duty and registration fee exemptions intended to promote industrial establishment. A lease conveys a transferable interest in land for the stipulated term and is not confined to an outright sale. Promissory estoppel protects SEZ fiscal incentives promised under State policy where a lease was executed before the implementing Ordinance, because the Ordinance gave statutory effect to the existing policy. Denial based solely on the timing of the Ordinance would defeat the governmental promise and create unequal treatment of similarly situated SEZ units. The exemption consequently extends to the leasehold transfer, requiring refund processing.

GST reimbursement for ongoing works may cover the net additional burden arising from GST introduced after bidding where tender rates were inclusive only of taxes applicable at that time. Government measures addressing GST impact on continuing contracts support compensation once the additional liability is verified. A pre-bid clarification concerning future taxes cannot supersede inconsistent tender terms. Refusal of verified reimbursement, particularly where similarly placed contractors receive different treatment, raises arbitrariness and equality concerns under Article 14.

Territorial appellate jurisdiction allocated by a CBDT circular to the Commissioner of Income-tax (Appeals)-18, Chennai for Tamil Nadu and Puducherry cases is indispensable to the valid exercise of quasi-judicial authority. An appellate authority not vested with jurisdiction over an assessee's dispute, including an authority at Delhi, cannot validly decide it. Orders issued without the requisite territorial jurisdiction are null and void and liable to be quashed.

Wealth-tax appellate jurisdiction lay with the Commissioner of Income-tax (Appeals)-18, Chennai under the applicable jurisdictional framework. Orders issued by the Commissioner of Income-tax (Appeals)-31, Delhi lacked legal jurisdiction and were therefore invalid. Because the competent appellate authority had not adjudicated the assessee's substantive grounds, the appeals required remand for fresh consideration. The appeals were restored to the Commissioner of Income-tax (Appeals)-18, Chennai for de novo adjudication on merits after hearing the assessee.

Cash refund is available under Section 142(3) of the CGST Act for CVD and SAD paid after 1 July 2017 on de-bonding of capital goods where those duties were eligible for CENVAT credit but could not be carried forward into GST. Section 140(1) permits transition only of eligible credit reflected in the return immediately preceding the appointed day; post-GST duty payments cannot appear as such closing credit. Section 142(3) therefore applies to refund claims under the existing law and requires cash payment, subject to exclusion of credit already transitioned.

Pre-notice payment of service tax and interest on product support services attracted the statutory benefit for such payment, rendering the related penalty unsustainable. Transfer of the right to use software embedded in a product constituted a deemed sale of goods subject to VAT, including customised software, so licence fees were not liable to service tax. Consultancy expenditure did not attract reverse-charge service tax under the Place of Provision of Services Rules, 2012. Remuneration paid to full-time directors for services rendered as employees fell outside the definition of taxable service; reverse-charge liability therefore did not arise.

Separately recovered NSE/BSE transaction charges, SEBI fees, stamp duty, depository/DEMAT charges, bandwidth charges and securities transaction charges do not form part of taxable brokerage or commission where they are collected under statutory or regulatory requirements, not retained by the service provider, and remitted to the relevant authorities or providers. They are reimbursable pass-through expenses rather than consideration for stock-broking, commodity-broking or depository services. Extended limitation cannot apply where service tax was paid on actual charges, returns were regularly filed, and no wilful suppression with intent to evade tax was alleged or established. Tax demands, consequential interest and penalties based on including those charges cannot be sustained.

Extended limitation and penalties for service-tax non-payment require wilful suppression or intent to evade; non-declaration alone is insufficient where services, contractual arrangements and banking-channel consideration are evident. Card-customer sourcing performed by a direct selling agent, without collecting customer payments and for turnover-based commission, falls within business auxiliary service rather than payment-card services before 1 July 2012. Recipient entitlement to input credit does not remove the supplier's liability for tax and interest on its own taxable services during the normal period. Mutual fund agent services covered by reverse charge place tax liability on the service recipient, making a demand on the agent unsustainable for that period.

Corporate amalgamation required substitution of the appellant's name in the service-tax appeal cause title, from the predecessor company to the amalgamated company. Supporting documents were filed to establish the change in corporate identity. The registry was directed to amend the cause title so that the pending proceedings reflect the successor entity's current name.

Indexed cost of improvement in computing capital gains requires supporting evidence of the expenditure. Passage of time does not remove the taxpayer's obligation to substantiate a claimed improvement cost. Where no evidence supports the claim, the indexed cost of improvement is not allowable and is disallowed in computing capital gains.

Interest earned by a primary credit co-operative society on deposits with co-operative, scheduled and nationalised banks qualifies for deduction under sections 80P(2)(a)(i) and 80P(2)(d), where the relevant statutory conditions are met. The treatment applies to interest income arising from deposits held with both co-operative and other banking institutions. Interest received on an income-tax refund is also included within the deduction available under section 80P(2)(c)(ii). The deductions claimed under these respective provisions are consequently available to the society.

Cash deposits arising from the sale of rural agricultural land were satisfactorily explained by registered sale records, the sale agreement, cash received instead of the cheque recorded in the sale deed, and additional sale consideration. As the land was not a capital asset and sale income was exempt, the stated sale proceeds constituted an acceptable source for both deposits. No addition as unexplained money was sustainable where the Revenue did not dispute the land's rural agricultural character or the exempt nature of the sale income.

Government securities held by banks are treated as stock-in-trade, so diminution in their value, when recorded under banking norms, is allowable as revenue expenditure. An additional depreciation claim raised during assessment may be determined from material already on record. Mutual-fund dividend income is exempt where a revised computation and supporting evidence establish its receipt and no factual rebuttal arises. Taxable income is consequently recomputed after allowing the securities depreciation and exempt-dividend claims.

Penalty for concealment under Section 271(1)(c) cannot survive where it is founded on an unexplained cash-deposit addition that has been deleted in quantum proceedings. The penalty attributable to that deleted addition was therefore removed. However, where an interest-income addition remained unchallenged in the quantum appeal, the penalty corresponding to that undisclosed income remained sustainable.