In an appeal under Section 260A, the High Court cannot reappreciate seized loose sheets, visitors' slips and diary entries merely to replace the Tribunal's factual conclusions. The Tribunal had examined the documents, accepted the assessee's explanations, and noted the absence of verification from students, parents or other independent sources. The material did not justify extrapolating alleged unaccounted fee collections across years, estimating receipts for unverified seats, or equating COMED-K cancellation-seat fees with management-quota fees. As the Revenue showed no ignored material, lack of evidence or perversity, deletion of the additions remained undisturbed.

Appeals under Section 19 of the Black Money and Imposition of Tax Act, 2015 are to be classified and registered as Tax Appeals under Rule 1(3A) of the High Court of Karnataka Rules, 1959, because the Act provides for the levy of tax. Section 19 provides for an appeal to the High Court from a Tribunal order and requires consideration by a Division Bench. The appeal was therefore permitted to be converted and registered as a Tax Appeal.

Reassessment after processing under Section 143(1) still requires recorded reasons based on tangible, relevant material establishing a rational live link to income escaping assessment. Although no prior opinion is formed through such processing, the absence of change of opinion does not remove this jurisdictional condition. Treating client funds received by a regulated stock-broker as its income merely because they exceeded reported turnover, without material showing conversion into proprietary income, reflects suspicion and an erroneous understanding of the transactions. The reassessment notice and consequential reassessment were therefore invalid for lack of jurisdiction.

The proviso to Section 142(2D), which places liability for a Special Auditor's fee on specified income-tax authorities, was applied to require the Union of India to bear the fee despite the auditor's appointment before the proviso took effect. The special audit had been completed, making the challenge to the audit direction infructuous. The stated legislative policy, completion of the audit under the Assessing Officer's order, and the assessee's non-appearance supported closure of the proceedings with the fee borne by the Union of India.

Section 69C requires the assessee to explain the source of expenditure; an addition cannot rest merely on an unsupported allegation that transactions were accommodation entries. Documentary support including stock statements, tax assessment material, purchaser details, sales confirmations, recovery proceedings and bank-funded encashment of letters of credit established the stated source. Rejecting that material without independent inquiry, document verification, examination of beneficiary entities or cogent contrary evidence does not establish unexplained expenditure. Consequently, addition of outstanding letters of credit as unexplained expenditure and consequential taxation under section 115BBE were unsustainable.

The Supreme Court declined to interfere with the High Court's judgment concerning tax treatment of payments received by a US tax resident for cloud computing services from Indian entities. The dispute concerned whether the payments constituted royalty or fees for technical services under domestic tax law and the India-US DTAA, including issues relating to equipment use, non-exclusive licences, the "make available" condition and withholding tax. The Supreme Court dismissed the Special Leave Petitions, leaving the High Court's judgment undisturbed.

The Supreme Court declined to interfere with the High Court order concerning the availability of deduction under section 80P to Regional Rural Banks as co-operative societies, including the statutory deeming fiction under the Regional Rural Banks Act. The Special Leave Petition was dismissed, while any questions of law were expressly kept open.

Loading railway-owned ballast into stationary railway wagons using JCB loaders is treated as an independent cargo-handling service, not a works contract or composite supply. A works contract requires specified activity relating to immovable property and transfer of property in goods, which was absent. Ballast supply was completed on delivery and transfer of ownership, while subsequent loading was separately instructed, priced and invoiced; the activities were not naturally bundled and no principal supply arose. As loading involved no transportation, wagon movement, shunting, towing or other railway operation, it is classified as cargo handling under SAC 996719 and taxable at 18%.

Ineffective electronic communication of pre-show-cause notices, show-cause notices, reminders and the adjudication order solely through the 'Additional Notices and Orders' tab did not satisfy the communication required under Section 73(1). Fixing the personal-hearing date before expiry of the period for responding to the show-cause notice also denied an effective opportunity to defend. A separate appeal dismissed as time-barred concerned a different intimation and did not affect the writ petition's maintainability. The ex parte adjudication order was therefore quashed for breach of natural justice.

Alleged forced GST payment was not prima facie sustainable at the interim stage because the withdrawal pursis recorded that reasonable amounts had been deposited and the proceedings concerning payment indicated voluntary payment. Non-disclosure of the anticipatory-bail application and its withdrawal was treated as material suppression requiring explanation. The petitioner was directed to deposit costs and file an affidavit explaining the suppressed facts, with the matter listed for further hearing.

GST proceedings under section 74(1) must be initiated against a person chargeable with tax. An individual proprietor is a "person" under section 2(84), but proceedings cannot validly be initiated or concluded in the name of a proprietor who died before the notice and consequential demand order were issued. Where the taxpayer's prior death is undisputed, the notice and demand order are without jurisdiction and void. The issue was resolved in favour of the assessee.

Where a person seeking release of goods detained in transit establishes ownership, the release mechanism under Section 129(1)(a) of the Central Goods and Services Tax Act, 2017 applies. For that purpose, valuation cannot be enhanced, and penalty must be determined by reference to the invoice and e-way bill. The stated position requires release of the goods in favour of the assessee under Section 129(1)(a).

Anticipatory bail was denied in an investigation into alleged wrongful availment and utilisation of input tax credit through invoices issued by non-existent entities. The applicant's role as a director remained under investigation, while a co-director had been arrested in the same matter. The need to establish the applicant's role and identify other persons involved meant that custodial interrogation could not be ruled out. The applicant was therefore not entitled to anticipatory bail.

Writ jurisdiction need not be exercised where an efficacious statutory appeal can examine jurisdictional objections, the reasonable period for issuing a notice under Section 76, and factual disputes over input tax credit and tax payment. The reasonable-period question depends on the facts of each matter, while the appellate remedy can also consider the applicable provision for the relevant financial years. Since the adjudication followed consideration of the reply and an opportunity of hearing, the writ petition was not entertained and the statutory appellate remedy remained available.

Bail in alleged fraudulent input tax credit cases may be granted where investigation is complete, the complaint has been filed, and no material establishes criminal antecedents, absconding risk, witness intimidation, or evidence tampering. For Magistrate-triable offences carrying up to five years' imprisonment, prolonged pre-trial detention where trial completion is unlikely within a reasonable period conflicts with the presumption of innocence, personal liberty, and the principle that bail is the rule. The documentary and electronic character of the evidence further reduces the risk of interference. Bail was considered appropriate subject to conditions ensuring trial attendance and protection of evidence and witnesses.

Prohibition orders sealing business premises during GST search proceedings were challenged. The writ petition was disposed of by consent without adjudication on the merits. The premises were directed to be de-sealed in the petitioner's presence, and any further search was required to proceed in accordance with the applicable statutory procedure.

Service of a show-cause notice solely through the electronic portal after cancellation of registration does not provide effective notice where the applicable departmental circular requires physical service for adjudication initiated after cancellation. Portal-only service, undertaken more than three years after cancellation, deprived the assessee of a meaningful opportunity to reply, obtain relied-upon documents, seek cross-examination and attend a personal hearing. The ex parte adjudication order was therefore unsustainable for breach of effective service and adequate opportunity of hearing, requiring a fresh opportunity for participation in the proceedings.

GST arrest powers must not be exercised routinely or mechanically. Credible material, investigatory necessity, and risks of evidence tampering or witness influence are material safeguards under the statutory scheme and departmental guidance. Recorded grounds referred to alleged use of fictitious entities for online-money-gaming transactions, suppression of taxable value, layering of funds, personal benefit, non-cooperation, and possible interference with the investigation. For cognizable special-enactment offences punishable below seven years, arrest may be justified where reasons and necessity are recorded. The recorded grounds and custody reasons were treated as sufficient, supporting the legality of arrest and judicial custody.

Arrest for cognizable and non-bailable GST offences requires credible material, recorded reasons to believe, and consideration of necessity rather than mechanical exercise of power. In alleged online gaming tax evasion involving dummy entities, suppression of taxable value and fund layering, the recorded grounds identified the petitioner's alleged role, risk of evidence tampering, and need for custodial investigation. The notes state that arrest may be justified, including for offences punishable up to five years' imprisonment, to support investigation and prevent further offence, disappearance or tampering of evidence, or witness influence. The High Court found the arrest compliant with the applicable departmental circular, dismissed the habeas corpus petition, and declined release.

Sealing of business premises during GST search proceedings was addressed through directions to de-seal the premises in the taxpayer's presence. Any further search must be conducted in accordance with the CGST Act and the CGST Rules, 2017. The writ petition was disposed of by consent without examination of the merits.