Where fraud, wilful misstatement or suppression is not established in a section 74 demand, section 75(2) requires the notice to be treated as issued under section 73. The consequential order of redetermination must be issued within two years from communication of the appellate or judicial direction. However, the redetermined demand is limited to tax, interest and penalty relating to periods for which the original notice was issued within the section 73 limitation period of two years and nine months. For multi-year notices, only timely covered financial years may be redetermined.

Foreign exchange market movement saw the rupee depreciate marginally against the US dollar amid higher global crude oil prices, heightened West Asia tensions, a stronger dollar environment and weaker domestic equity markets. Central-bank intervention and foreign fund inflows provided support. Adequate foreign-exchange reserves and stronger-than-expected FCNR(B) scheme inflows were identified as factors limiting the scope for sharp depreciation.

ITC claimed in FORM GSTR-3B but absent from FORM GSTR-2A for FY 2017-18 and FY 2018-19 may be examined under section 16 rather than automatically treated as ineligible. The proper officer must verify tax documents, receipt of supplies, payment to the supplier, required reversals, and the statutory time limit. Supplier-wise discrepancies exceeding Rs 5 lakh require a UDIN-based Chartered Accountant or Cost Accountant certificate; lower discrepancies require a supplier certificate. The procedure applies to ongoing, including pending adjudication or appeal, proceedings and not completed matters.

Spectrum allocation involving an instalment option is a continuous supply of services, with GST payable by the telecom operator under reverse charge. The Frequency Assignment Letter is a bid-acceptance and allocation instrument, not an invoice-equivalent document for applying the sixty-day reverse-charge rule. GST on upfront payment is payable when payment is made or becomes due, whichever is earlier; for deferred payments, GST is payable when each instalment is due or paid, whichever is earlier. This treatment also applies to similar government allocations of natural-resource usage rights.

ITC is available to motor insurers for repair services settled through reimbursement where the garage invoice is issued in the insurer's name. The insurer is the recipient to the extent of its approved repair liability, notwithstanding that the insured initially pays the garage. Where repair charges exceed the approved claim cost, credit is limited to the amount reimbursed by the insurer; separate invoicing permits credit on the invoice issued to the insurer. No ITC is available if the repair invoice is not in the insurer's name.

Time limit for filing FORM GSTR-7 for March 2019 was extended until 12 April 2019 for registered persons required to deduct tax at source under the Telangana Goods and Services Tax framework. The extension applies to the prescribed return-filing procedure for tax deducted at source.

FORM GSTR-1 outward supply reporting for March 2019 must be furnished electronically through the common portal by 13 April 2019. The requirement operates within the framework for furnishing outward-supply details under the Telangana Goods and Services Tax Rules and is made under the Telangana Goods and Services Tax Act, 2017.

Limitation rules promote public policy and prevent dilatory conduct, but should not defeat substantial justice where delay is bona fide and adequately explained. Belated receipt of a certified copy, obtaining legal opinion, and sanctioning substantial court fees explained the delay in filing a land-acquisition appeal. Negligence by government counsel and officials did not establish callousness or absence of bona fides, and public interest should not suffer because of that lapse. A pragmatic approach, particularly where arguable merits exist, supports condonation subject to costs.

Rule 138E of the Telangana Goods and Services Tax Rules, 2017, inserted through rule 12 of the Telangana Goods and Services Tax (Fourteenth) Amendment Rules, 2018, came into force on 21 June 2019. The State Government appointed this commencement date under its rule-making power under the Telangana Goods and Services Tax Act, 2017.

Land development, sale and rental activities undertaken by a statutory development authority as part of implementing development plans, town planning schemes and planned urban development remain incidental to its public-development objects. The proviso to Section 2(15), and consequently Section 13(8), applies only where such activities are in the nature of trade, commerce or business. In the absence of material showing that the authority operated solely on commercial lines, pursued profit as its real object or departed from its statutory objects, the proviso does not apply. The authority consequently remains eligible for exemption under Section 11.

Extension of the GSTR-1 filing deadline applies to registered persons whose principal place of business is in specified districts of Odisha. The earlier State Tax notification was amended to permit electronic furnishing of April 2019 outward-supply details in FORM GSTR-1 through the common portal by 10 June 2019.

GSTR-3B filing due date for April 2019 is extended to 20 June 2019 for registered persons whose principal place of business is in specified districts of Odisha. The return must be furnished electronically through the common portal. The extension is effected through a proviso inserted into Notification No. 11/2019 State Tax under the State Goods and Services Tax framework.

Rule 138E notification under the Telangana Goods and Services Tax Rules, 2017 is deferred by substituting 21 June 2019 with 21 August 2019 as the effective date. The amendment is made by the State Government under section 164, on the Council's recommendations and in the public interest.

Section 80-IA(4) deduction may be claimed for the first time in a return filed in response to a Section 153A notice because that provision overrides Section 139 and requires assessment of total income. The return-filing requirements under Sections 80A(5) and 80AC do not bar such a Chapter VI-A claim, whether the earlier assessment is abated or unabated. However, the statutory Explanation excludes government-awarded works contracts from the infrastructure deduction. Civil works performed under government contracts, without evidence of developer-level entrepreneurial or financial risk, remain works contracts despite mobilisation advances, periodic payments, retention amounts or performance guarantees. The deduction therefore fails where the activity is substantively contractual execution rather than eligible infrastructure development.

GST does not apply where an overseas holding company directly issues ESOPs, ESPPs or RSUs to employees of its domestic subsidiary and the subsidiary reimburses only the cost of the securities on a cost-to-cost basis. Securities are neither goods nor services, and employee compensation under an employment arrangement is outside supply. However, any additional fee, markup, commission or similar recovery above the securities cost is consideration for facilitating or arranging the transaction. GST applies to that additional amount under reverse charge as an import of services by the domestic subsidiary.

FORM GST ITC-04 filing deadline is extended until 31 August 2019 for declarations concerning goods dispatched to, or received from, a job worker during July 2017 to June 2019. The extension supersedes the earlier deadline notification while preserving actions already taken or omitted before supersession.

RoSCTL Scheme amendments remove specified conditions concerning transferee-holders of duty credit scrips by deleting paragraph 4(2), paragraph 5(5), and the reference to "the transferee" in paragraph 6. Corresponding amendments to the Electronic Duty Credit Ledger Regulations extend the validity of RoSCTL scrips from one year to two years from their date of generation.

Place of supply for goods supplied to an unregistered person is the recipient's address recorded on the invoice, or the supplier's location where no recipient address is recorded. Recording the recipient's State name is deemed to be recording an address. Where billing and delivery addresses differ, including e-commerce supplies, the delivery address recorded on the invoice determines the place of supply. The supplier may record the delivery address as the recipient's address for this purpose.

Employees' provident fund contribution was treated as timely where payment was initiated through a challan and debited from the employer's bank account before the statutory due date. A reversal on the due date, caused by technical glitches in the EPFO portal or bank account, followed by remittance after the due date did not justify disallowance where sufficient funds were available and the employer was not responsible for the short delay. The disallowance was therefore directed to be deleted.

Indian Customs EDI System (ICES 1.5) processing for import and export clearance commences at ICD Hirnoda, Jaipur (INHDA6), enabling computerized processing of Bills of Entry and Shipping Bills. M/s Hasti Petro Chemicals and Shipping Ltd. is appointed custodian and Customs Cargo Service Provider for the ICD and is permitted to commence operations after fulfilling applicable customs and cargo-area requirements. State Bank of India, SMS Highway Branch, is authorised to collect customs duty and make duty drawback and refund payments under the EDI system.