Accommodation services are exempt where the monthly value per person does not exceed the prescribed threshold and the stay is continuous for at least 90 days, with qualifying past supplies regularised on an "as is where is" basis. A consolidated PG charge for residential stay and daily meals may be a composite supply, with accommodation as the principal supply; the exemption then governs the full bundle, but related input tax credit is unavailable. Non-exempt or short-term accommodation is taxable according to the per-unit daily tariff under the accommodation-services rate structure, subject to input tax credit conditions and blocked-credit restrictions.

Show cause notices under Section 74 of the CGST Act issued to an amalgamating company after its dissolution are without jurisdiction and invalidate proceedings founded on them. Section 87 applies only to the intervening period between the effective date and date of the amalgamation order; it does not keep the transferor company alive for post-amalgamation proceedings. Section 85 may permit recovery from a successor but cannot cure a notice issued to a non-existent entity. The position is particularly applicable where the tax department was informed of the amalgamation.

Rule 141 of the CGST Rules, 2017 regulates the forthwith release of seized goods or things that are perishable or hazardous in nature. Release is conditional upon the taxable person paying the lower of the market price of the goods or things and the tax, interest and penalty payable or that may become payable. Upon proof of payment, the proper officer must issue a release order in FORM GST INS-05.

Judicial record accessibility requires each proceeding to be retrievable through every assigned case identifier, party name, date, bench-related search criteria and free-text search. Searches based on different identifiers, judgment dates, judge names and free text may produce incomplete results or omit relevant orders, while case-status records may contain those same materials. Integrated linking between case-status, order and judgment databases, timely indexing, and transparent pendency-counting criteria are needed to ensure reliable access to judicial records and to distinguish principal proceedings from ancillary applications.

For the period before 14.05.2015, service-tax valuation under Section 67 covered the amount charged as consideration for the taxable service, and Rule 5 could not enlarge that scope by including genuine third-party expenditure incurred for a client. Recovery of such payments was not automatically taxable merely because it passed through the service provider. Tax treatment depended on the true character of the receipt: charges for the provider's own service formed part of taxable value, while genuine client reimbursements required separate examination. Cargo-space resale margins also required assessment of whether the arrangement was principal-to-principal or agency-based.

Vintage motor vehicle import eligibility under Chapter 87 of the ITC (HS) now follows the Rule 81A CMVR classification rather than the former manufacture-before-1950 test. Qualifying vehicles are free for import by Actual Users, subject to applicable conditions and other laws. This import-policy status does not exempt the importer from customs classification, valuation, duties, taxes, Bill of Entry requirements, or other clearance conditions. Registration and lawful road use are separate matters governed by the Motor Vehicles Act and CMVR, including the special vintage-vehicle framework and use restrictions.

Section 74 of the CGST Act permits extended limitation only where fraud, wilful misstatement, or suppression of facts with intent to evade tax is established through allegations contained in the show cause notice itself. These are jurisdictional preconditions, not formal recitals. A notice cannot rely on a mechanical reference to "fraud or concealment of facts" without disclosing the material supporting that inference, and a counter affidavit cannot cure omissions in the notice. For legacy periods, a demand otherwise barred under Section 73 can proceed under Section 74 only on a properly pleaded statutory foundation.

ISO 39001:2012 establishes a Road Traffic Safety Management System for organisations to reduce road traffic deaths, serious injuries and incidents through risk-based transport management. It requires organisational context and scope assessment, leadership commitment, safety policies, defined responsibilities, measurable objectives and controls for driver competence, vehicle maintenance, speed management, journey planning and emergency response. Performance must be monitored through accident, near-miss, driver and vehicle data, supported by internal audits, management review, incident investigation, corrective action and continual improvement. Certification involves gap assessment, implementation, training, staged external audits and periodic surveillance.

ISO 37301:2021 establishes a Compliance Management System framework for identifying, implementing, monitoring and improving compliance with legal, regulatory, contractual, industry and internal-policy obligations. It requires organisational context and CMS scope to be defined, a documented compliance policy and measurable objectives to be established, and leadership support, accountability and appropriately supported compliance functions to be maintained. A risk-based approach covers compliance obligations, risk assessment, controls, training, reporting, monitoring, internal audits, management review and corrective action for non-conformities. The framework supports integration with other management systems.

Municipalities' service-tax liability for renting immovable property requires fresh adjudication where jurisdictional High Court rulings on local-authority taxability reflect divergent views and related appeals remain pending. Judicial discipline and consistency with an earlier decision require the adjudicating authority to re-examine the Municipality's taxability rather than retain the appellate determination. The impugned appellate order was set aside, and the issue was remanded for a fresh decision.

Ex parte assessment and appellate treatment of cash deposits under Sections 68 and 115BBE require fresh determination where the taxpayer has not received an effective opportunity to establish the deposits' source. Deposits claimed as service charges from a material-handling and transportation business were supported by regular banking entries and certain invoices, but complete evidence on the source of funds and capital introduction was not available before the lower authorities. Adequate hearing and opportunity to produce complete evidence are necessary before deciding whether the deposits constitute unexplained cash credits and attract the prescribed tax treatment.

Employees' provident fund contribution disallowance under section 36(1)(va) requires consideration of a rectified tax-audit annexure correcting typographical errors in the originally reported payment due dates. Where the rectified annexure is placed before the appellate authority but remains unexamined, the payment details require verification after adequate opportunity is afforded. The disallowance cannot be sustained without considering and verifying the corrected audit material, and the claim requires fresh adjudication by the Assessing Officer.

Reassessment notices issued more than three years after the end of the relevant assessment year require prior approval from the authorities specified under section 151(ii): the Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General. Approval by a Principal Commissioner does not meet this mandatory jurisdictional requirement. Consequently, a notice under section 148 issued with such approval is invalid, and the consequential reassessment order under section 147 is liable to be quashed.

Penalty for concealment of income or furnishing inaccurate particulars does not arise where prior-period expenses were disclosed in the return, added back in the income computation, and tax was paid after that disallowance. A data-entry error in the returned-income figure did not negate the correct computation and tax particulars or establish concealment. Mere making of an incorrect claim, without concealment of income or furnishing inaccurate particulars, does not attract penalty. The penalty was therefore not leviable.

Further relief from an estimated net-profit addition was considered after rejection of the books of account. The decline in net profit had already been partly accepted as explained by reduced handling charges, higher salary expenses and balances written off. Claimed variations relating to rent, VAT, depreciation, finance charges, interest on fixed deposits and incentives supported additional relief from the residual estimated addition.

Revision of unabated assessments completed under section 153A cannot rest solely on bank-account credits where no incriminating material was found during the search. For search assessments, incriminating material is necessary to disturb an unabated assessment; bank statements alone do not support revisional jurisdiction under section 263. The section 263 revision orders were therefore without jurisdiction and quashed for all relevant assessment years.

Penalty for non-compliance with notices under Section 142(1) is not sustainable where reasonable cause is established. Notices sent to the auditor's email address did not come to the elderly taxpayer's knowledge, and the faceless assessment environment supported the existence of reasonable cause for the failure to respond. The penalty imposed under Section 272A(1)(d) was therefore deleted.

Condonation of bona fide delay in appeals challenging late fees for delayed TDS statements filed before 1 June 2015 should favour substantial justice where the levy is prima facie without jurisdiction under binding jurisdictional decisions. A pragmatic rather than technical approach is appropriate when taxpayers act promptly after learning of those decisions. Appeals rejected solely as time-barred should be restored for merits adjudication where limitation prevented examination of the challenge.

Reassessment initiated after an assessee's death is invalid where the Assessing Officer had been informed of the death and neither substituted the legal heir nor proceeded against the estate through that heir. Completing reassessment in the deceased person's name amounts to proceedings against a non-existent person. The reassessment proceedings and resulting order were quashed, and the proposed addition consequently did not survive.

Post-amendment section 80JJAA extends to additional employees and does not require engagement as regular workmen. Fixed-term personnel deputed to customers remain employees of the staffing provider where it retains appointment, remuneration, deployment, disciplinary and termination powers, and fulfils tax-withholding and social-security obligations; customer supervision at its premises is operational only. A marginal Covid-period delay in filing Form 10DA may not defeat the deduction where the reporting requirement is treated as directory. Second- and third-year claims require verification of statutory conditions. Transfer-pricing comparables require functional similarity and adequate segmental information, including for KPO, IT and ITeS providers.