Revenue appeals withdrawn after being filed below the prescribed monetary limit without sufficient reason or exceptional circumstances may justify litigation costs payable by the appellant to the respondent. Such filing can consume tribunal time and cause unnecessary litigation expense. Section 120 of the Central Goods and Services Tax Act, 2017 permits monetary limits for departmental appeals; the applicable circular prescribes a Rs. 20 lakh limit for GSTAT appeals.

The specified works-contract GST concession requires a qualifying government recipient and predominantly non-commercial, non-industrial use. Government supervision or funding alone does not establish recipient status, and social objectives do not alter a factory's industrial use. Interest on unpaid tax is compensatory and does not depend on bona fide conduct; the non-fraud penalty applies unless tax and interest are paid within the prescribed period after notice. Promissory estoppel cannot override statutory liability. Cum-tax recomputation is unavailable where invoices and sales records show receipts as tax-exclusive. Input tax credit claimants must establish eligibility, including payment of tax on the supplies; supplier return-filing records alone do not establish such payment. Interest applies to wrongly availed and utilised credit.

GST paid under the CGST and SGST heads for a transaction subsequently held to be inter-State may be transferred and credited to the IGST head through the refund and adjustment provisions. No interest is payable on the IGST in those circumstances. Proceedings and penalties under Section 74 require fraud, wilful misrepresentation or suppression causing the relevant shortfall, with foundational facts apparent from the notice. Payment under the wrong head alone, without a deliberate attempt to evade tax, does not justify those proceedings or penalties. Any IGST liability beyond the amount already paid remains undetermined.

Eligible transitional input tax credit cannot be denied solely because it was declared under an incorrect provision or column in Form TRAN-1. Section 140 of the Central Goods and Services Tax Act, 2017 and Rule 117 of the Central Goods and Services Tax Rules, 2017 govern the transition of eligible credit. Unutilised credit is a vested right that cannot be defeated on a technical ground when eligibility and quantum are undisputed and the declaration is filed within time.

Under Section 107 of the Central Goods and Services Tax Act, 2017, an appeal against cancellation of GST registration must be filed within three months, with a further month available on sufficient cause. The appellate authority has no power to condone delay beyond that extension. The right of appeal is statutory, and writ jurisdiction cannot be used to bypass the limitation period merely because a taxpayer's own omission has caused the appellate remedy to lapse. Lack of familiarity with the GST portal does not make a writ challenge maintainable in these circumstances.

Under Section 169 of the GST Act, sufficient service and effective service of notices are distinct considerations where portal-based communication does not give the recipient an opportunity to respond. When portal-based service is ineffective and the recipient is denied a hearing, failure to use an alternative statutory mode of service violates natural justice and vitiates the proceedings. This also affects the sustainability of related recovery action.

Rule 96(10) of the Central Goods and Services Tax Rules, 2017 was omitted on 8 October 2024 without a saving clause. Section 6 of the General Clauses Act, 1897 does not apply to the omission of a rule; proceedings under an omitted rule can continue only if preserved by an express provision or other legal device. Show cause notices issued after the omission without such preservation lack statutory backing and are legally ineffective.

Writ jurisdiction may be exercised in appropriate circumstances to reopen a statutory GST appeal dismissed as time-barred, notwithstanding the statutory limit on the appellate authority's power to condone delay. Reopening restores the opportunity for a hearing and decision on the merits where the tax computation was not adjudicated because the appeal was dismissed on limitation.

Objections to GST prosecution based on prior sanction and a monetary threshold may be pursued before the writ court or at an appropriate subsequent stage. The FIR also alleged offences under the Bharatiya Nyaya Sanhita, 2023, and interim protection against it was not warranted. The merits of the GST-related contentions remain open.

The assessment years specified in the English version of the notification for the Andhra Pradesh Electricity Regulatory Commission under section 10(46) of the Income-tax Act, 1961 are corrected from the period 2019-20 through 2023-24 to the period 2020-21 through 2024-25. This removes assessment year 2019-20 and adds assessment year 2024-25. The Hindi version remains unchanged.

Where a Bill of Export is filed under a claim of drawback or a similar scheme under the Customs and Central Excise Duties Drawback Rules, 2017, the SEZ unit, developer or Domestic Tariff Area supplier must claim the benefit from the Specified Officer. If the unit or developer does not intend to claim the benefit, it must give the supplier a disclaimer so that the supplier may claim it. The substituted rule takes effect from its publication in the Official Gazette on 30 October 2026.

Resident individual status and transaction value determine deemed export declaration and service import reporting requirements. A resident individual, defined as a natural person resident in India, is deemed to submit an Export Declaration Form for services upon providing the authorised dealer with the required payment receipt information for crediting the exporter's account. Other service exporters receive the same treatment where the inward remittance does not exceed Rs. 10 lakh or its foreign currency equivalent. For service imports by persons other than resident individuals, authorised dealers must enter details in IDPMS within five working days of receiving them if the invoice or contract value exceeds Rs. 10 lakh or its equivalent. The amendments take effect from 1 October 2026.

Indian Missions abroad must take up quality complaints and trade disputes with the relevant authorities for appropriate redress, whether the complaints are filed by applicants or referred by the concerned Foreign Trade divisions. The Missions and the divisions must periodically update the action taken and status of each complaint on the DGFT portal until resolution or final disposal. Complainants must be able to access all updates through the portal, with timely updates continuing until the matter is resolved, closed or otherwise disposed of under the prescribed procedure.

Individual persons resident outside India may complete digital KYC from Financial Action Task Force (FATF)-compliant countries, with the revised framework effective from 3 December 2026. Intermediaries must verify identity, collect an overseas address and undertake in-person verification or, where physical verification is not feasible, video verification with an authorised official present and concurrent audit. KYC Registration Agencies must tag attributes verified against official or source databases as validated, but all KYC records remain portable regardless of validation status. Intermediaries may rely on eligible third-party KYC records but remain ultimately responsible for KYC and risk-based enhanced due diligence. Existing KYC requir.....

Interim resolution professionals or resolution professionals must ensure compliance with real estate regulation during the corporate insolvency resolution process (CIRP) of debtors with real estate projects. They must obtain available project information from the relevant regulator's portal and may use it to prepare the information memorandum, verify claims and assess project status. Reliance on portal records where debtor records are incomplete, unavailable or inconsistent is subject to verification and reconciliation. The resolution professional may invite the regulator's written views on resolution plans and must share any views received with the committee of creditors and prospective resolution applicants. Within seven days of appointme.....

Commercial suits require disclosure of documents under Order XI Rule 1 of the Code of Civil Procedure; reliance on undisclosed documents requires leave and reasonable cause for non-disclosure. Where an error in the original board resolution was known at institution, a replacement created during final arguments after an objection did not justify leave. A foundational absence of authority to institute a suit differs from a curable procedural defect: a later resolution replacing the original basis of authority cannot ratify that absence or establish the signatory's authority to represent the company.

Cost-to-cost reimbursement of interest expenditure among group entities does not attract tax deduction at source under section 194A when it contains no income element. Where entities share collectively borrowed funds, allocate third-party interest according to their use, and reimburse the expenditure without markup, the payments represent recovery of expenditure rather than income. Tax is deducted on interest paid to third-party lenders; no default or consequential interest liability arises from the reimbursements.

Charitable exemption for advancing general public utility remains available for non-commercial, government-funded railway infrastructure activities, despite recovery of administrative costs and interest earned on temporarily deposited project funds. The distinction is between commercial activity and activities conducted at cost or with a nominal mark-up. Relevant features include transfer of the resulting assets to the railways and no dealings with the public. Under Rule 27, a respondent who obtained complete relief at the first appellate stage may raise an alternative jurisdictional ground where the relevant facts are on record. Admission of that ground does not determine its constitutional merits.

Commission income from accommodation entries was calculated on reduced turnover rather than total debit and credit entries after payment details identified debit entries as loan repayments. The assessment had applied a commission rate to total transactions, but no material contradicted the distinction supported by the payment details. The commission addition was consequently restricted, with the same approach applied to the connected matter.

Section 69A of the Income-tax Act, 1961 governs additions for unexplained money. Demonetisation-period cash deposits were disputed where the assessee's historical cash sales accounted for most total sales, and November cash deposits were lower than in the corresponding month of the preceding year. The addition of the deposits was deleted in favour of the assessee.