Rule 164 establishes an electronic application process for persons eligible for waiver of interest, penalty, or both under Section 128A in relation to specified Section 73 notices, statements, and orders. FORM GST SPL-01 applies to notices or statements; FORM GST SPL-02 applies to orders. Payments against orders must be credited to the Electronic Liability Register, and payments made through FORM GST DRC-03 require FORM GST DRC-03A adjustment before FORM GST SPL-02.

Insurance intermediary compliance requirements broaden the categories of professionals who may issue prescribed certificates. An IIIO must submit a paid-up capital and net-worth certificate half-yearly. Insurance intermediaries must also furnish, with audited accounts, a compliance certificate confirming adherence to the regulations. Form B requires an applicant's certificate confirming compliance with applicable regulatory requirements. Certificates may be issued by statutory auditors, practising Chartered Accountants, Company Secretaries, Cost Accountants, or other appropriately qualified persons specified by the Authority.

Insurance business registration compliance certification is amended in Form B and Form C of the First Schedule. Applicants must submit a certificate from a practising Chartered Accountant, Company Secretary, Cost Accountant in India, or another appropriately qualified person specified by the Authority. The certificate must confirm compliance with the applicable Act, the Registration of Insurance Business Regulations, 2021, and notifications issued under section 2CA of the Act.

Input tax credit for goods delivered at the supplier's place of business under ex-works contracts is to be implemented in Goa in accordance with the corresponding central GST clarification. The clarification concerns the requirement of receipt of goods for claiming input tax credit under Section 16(2)(b) of the CGST framework. Uniform application is directed under the Goa GST Act by extending the central clarification mutatis mutandis.

Limitation is the central issue in proceedings concerning a CESTAT determination that the show cause notice and Order-in-Original were barred by time. The High Court has issued notice to the respondent and fixed the matter for further listing before the Joint Registrar and subsequently before the Court. No final determination on the limitation issue has been made at this stage.

Writ petitions seeking refund of amounts debited from bank accounts are not ordinarily entertained where a statutory appeal concerning the same cause of action is already pending. The appellate authority must adjudicate the grievance in accordance with law after hearing all concerned parties. Parallel writ proceedings should not bypass the statutory appellate remedy; the pending appeal should instead be decided expeditiously, preferably within six months.

Fresh provisional attachment order issued while a writ petition remained pending was treated as an attempt to alter the subject matter under challenge and as inconsistent with the judicial discipline expected of quasi-judicial authorities. The departmental representative undertook not to press that order and acknowledged that specified provisional attachment orders, including an extension order, lacked the requisite approval or were otherwise not issued in accordance with law. The hearing was not concluded, and no final adjudication on the validity of the attachment measures was made; the matter was adjourned for further hearing.

Valid registration under section 12AA establishes that a society is constituted for charitable purposes. Where its charitable objects or activities are not disputed, that registration supports eligibility for approval under section 80G. Approval should not be denied merely despite the society holding valid section 12AA registration; the approval application requires fresh consideration in accordance with law.

Reasonableness of jewellery explanations in search assessments must be evaluated against family status, customary gifts and household circumstances; the jewellery addition was eliminated after the items were treated as nominal and reasonably explained. Watch valuation requires a fair opportunity for independent valuation where seized items remain in departmental custody and their genuineness or nature is disputed; the watch addition requires fresh examination. Foreign currency claimed to arise from overseas travel or prior non-resident status requires cogent supporting evidence, such as customs declarations or purchase records; the unexplained-money addition remained enforceable.

An intimation under section 143(1) requires prior issuance of the show cause notice mandated by its proviso. Where the record shows that no such notice was issued to the assessee, the statutory precondition for making the adjustment is not met. The intimation is therefore invalid in law and liable to be quashed.

Mushroom cultivation, including production and sale under controlled conditions, qualified as exempt agricultural income. A cold-chain facility established with new plant and machinery as an independent operation qualified for weighted deduction as a specified business because it was not formed by splitting up or reconstructing an existing business. Unaccrued machinery-sale consideration could not be included in minimum alternate tax book profit where the sale did not materialise and restated financial statements reflected real income. Delayed employees' provident fund and ESI contributions were not deductible. Sales-promotion and miscellaneous expense disallowances could not rest on unverified allegations or ad hoc estimates without identified defects or rejection of audited books.

Cash deposits during the demonetisation period were supported by bank-recorded withdrawals made before the deposits. Withdrawals of Rs. 2,50,000 and Rs. 9,00,000 were substantially traceable to deposits totalling Rs. 10,02,000, making the stated source plausible. On that basis, the addition for alleged unexplained cash deposits was deleted in favour of the assessee.

Common area maintenance charges for leased mall premises fall under Section 194C rather than Section 194-I where they are separately determined from lease rent, calculated by reference to area, and cover distinct staff and day-to-day operational services. Such charges are not an essential or integral component of consideration for use of the premises. Tax must therefore be deducted as payments for maintenance services under Section 194C, not as rent under Section 194-I.

Penalty for concealment under Section 271(1)(c) cannot stand where it is solely consequential to quantum additions that have been deleted. The underlying search-assessment additions were deleted because no incriminating material was found from the assessee, and the additions relied on a third-party statement arising from another search. As the penalty had no independent basis after deletion of the additions, it was required to be deleted.

Due dates for depositing employees' provident fund and ESI contributions may require determination by reference to the month in which salaries or wages were disbursed. Computing any remittance delay therefore depends on verifying the relevant payment facts and supporting information. Fresh factual determination was required after giving the taxpayer an adequate opportunity to substantiate the applicable salary-disbursement period, and the issue was restored to the Assessing Officer for that purpose.

Alleged bogus-purchase additions cannot rest solely on information that a supplier issued accommodation bills where purchase invoices, banking-channel payments, stock registers and books of account support the transactions. Absent rejection of books or stock records, discrepancies in manufacturing activity or accepted sales, or independent verification of the supplier, uncorroborated third-party information does not establish that purchases are non-genuine. The addition for alleged bogus purchases was therefore deleted.

Section 153C assessments for unabated years require additions to be based on specific incriminating or seized material found during the search. Allegations of non-genuine bills, without any identified search material supporting the additions, cannot sustain such assessments. The relevant Section 153C assessments were therefore invalid and quashed in favour of the assessee.

Article 16(1) of the India-Norway DTAA allocates taxing rights over salary for employment exercised in Norway to Norway; read with section 90(2), salary taxed there is not chargeable to tax in India. Such income cannot constitute undisclosed foreign income under the Black Money Act, which requires undisclosed foreign income or assets chargeable to tax in India; no foreign asset was identified. The asset-notice proviso permits assessment in the year of discovery only for undisclosed assets, not alleged income. Income pertaining to the relevant earlier assessment year therefore could not be assessed in a later year, rendering the proceedings without jurisdiction.

Long-term capital gains from share sales supported by invoices, demat-account records, registered-broker transactions and banking channels cannot be treated as unexplained income merely on a general investigation report alleging penny-stock accommodation entries. Where no independent enquiry or material links the taxpayer to price manipulation or an accommodation-entry arrangement, and the final SEBI report contains no adverse finding on the relevant scrip, documentary evidence remains unrebutted. The gains qualify for exemption under Section 10(38) of the Income Tax Act, 1961, and related additions for unexplained income and estimated commission are unsustainable.

Registration under section 12AB depends on charitable objects and the genuineness of activities carried out in furtherance of those objects. Education falls within charitable purpose. Interest-free advances to other entities while bearing interest on borrowings, or concerns about possible diversion of funds, ordinarily require assessment-stage examination and do not alone justify refusing registration where genuine charitable activities are established. Supersession of existing registration requires prescribed due process for a specified violation. Approval under section 80G(5) cannot be declined solely because of a refusal of section 12AB registration; the approval application must be considered independently in accordance with law.