Pre-deposit requirements for statutory tax appeals are governed by the regime in force when adjudicatory proceedings commence, namely the date of the show-cause notice; a later substituted requirement does not apply to earlier notices. Challenges to an officer's authority require assessment under function-specific proper-officer provisions, delegated powers and rank-based notifications. Where those instruments do not reveal a patent jurisdictional defect, and challenges involve disputed evidence, natural justice, party roles, quantification or penalties, the statutory appellate remedy remains the appropriate forum.

GST proceedings commenced against an amalgamating company after its merger are void from inception because the entity no longer exists. Section 87 of the CGST Act does not authorise proceedings against a non-existent entity or cure the resulting jurisdictional defect. The GST order was set aside on that basis, and the Supreme Court declined to interfere by dismissing the special leave petition.

GST appeal pre-deposit requirements are governed by the law in force when adjudicatory proceedings commence; consequently, appeals arising from show-cause notices issued before 1 October 2025 remain subject to the earlier Section 107(6) regime despite later Orders-in-Original. A proper officer's authority for penalty proceedings is function-specific, but objections concerning officer competence, evidentiary material, hearing, cross-examination, penalty quantification and individual noticees' roles require record-based examination through the statutory appeal. Writ jurisdiction is not invoked where that appellate remedy is complete and efficacious. Whether Section 122(1) applies to a person who is not a taxable person remains unresolved.

Vicarious liability under Section 141 of the Negotiable Instruments Act requires a person's actual role in and responsibility for the company's business when the cheque was dishonoured; a designation asserted in the complaint is insufficient. Uncontroverted Ministry of Corporate Affairs records showing that the impleaded individual was never a director, combined with no pleaded or disclosed role in company affairs, justified quashing the complaint and consequential proceedings against that individual as an abuse of process. For prospective cheque-dishonour complaints against companies, complainants must annex corporate identification details and certified Form DIR-12, unless unavailability despite due diligence is affirmed and the Magistrate records reasons before cognizance.

Pending representations seeking GST payment for road construction and improvement works require examination of tender conditions, individual bills and invoices, payments already made, and applicable GST liability. The asserted inclusion of GST in final bills requires a proper and intelligible breakup of amounts paid. High Court required the competent authorities to independently consider the supporting records and issue reasoned speaking orders within the stipulated period. The claimant's substantive entitlement to GST was left open for determination in accordance with law.

Section 75(7) of the UPGST Act prohibits confirmation of a tax demand exceeding the amount proposed in the show cause notice. An adjudication order confirming higher demands on both disputed counts therefore contains a fundamental and incurable defect. The order was set aside and the matter remitted for fresh adjudication, without allowing issuance of a fresh notice.

Refund of accumulated input tax credit under the inverted duty structure extends to higher-taxed packing materials used for marketing packaged tea. Section 54(3)(ii) applies where input tax rates exceed the output supply rate, and the plural term "inputs" does not distinguish between principal and ancillary inputs. Packing materials used in the course or furtherance of business therefore qualify as eligible inputs, notwithstanding that bulk tea and packaged tea attract the same GST rate. Circular No. 135/5/2020-GST addresses credit accumulation caused by GST-rate reductions on the same goods over time; it does not cover accumulation arising from higher-taxed packing materials and cannot curtail a refund otherwise available under the Act.

Actual electricity charges separately recovered at the same amount charged by the electricity distribution company, without markup, are treated as pure-agent recoveries under clause 3.3 of Circular No. 206/18/2023-GST. Electricity supplied with premises maintenance is ordinarily ancillary to the maintenance service and forms part of a composite supply despite separate billing. The circular's deeming rule nevertheless applies to separately metered HVAC and non-HVAC consumption and proportionately allocated common-area consumption recovered at actual cost. Those recoveries are excluded from the value of the maintenance service and do not attract GST, even where the independent pure-agent test is not otherwise met.

The first proviso to section 98(2) bars admission of an advance-ruling application where the question raised is already pending or has been decided in proceedings under the GST Act concerning the applicant. Classification and applicable-rate questions for dried and cured tobacco leaves had already been decided in enforcement proceedings involving the applicant. The application for advance ruling was therefore rejected as inadmissible.

Ruled or lined loose paper sheets produced by cutting uncoated paper remain within Heading 4802, rather than Heading 4820, because loose sheets cut to size are excluded from the finished-stationery heading. Paper is classified under tariff item 48026190 in rolls and 48026290 in sheets. The end-use exemption for paper used in specified notebooks depends on actual use by the manufacturer; supplies through intermediaries remain independently taxable. Recipients of uncoated paper reels have no reverse-charge liability because the goods are not notified for reverse charge, while input tax credit remains subject to statutory conditions. Documentary requirements cannot be imposed where the exemption notification does not prescribe them.

End-use-based GST exemption for uncoated paper and paperboard under tariff heading 4802 depends on established actual use in manufacturing exercise books, graph books, laboratory notebooks or notebooks. Classification turns on actual use rather than intended use, paper grade or specifications; supplies used for other purposes remain taxable. Questions on supplier verification, documentary requirements and liability for a purchaser's misuse fall outside an advance ruling on notification applicability where the notification contains no such mechanisms. Revised Central and corresponding State GST rate entries take effect from 22.09.2025, leaving no stated ambiguity on the rate transition date.

Reassessment sanction under the extended limitation regime depended on the date by which the three-year period from the end of the relevant assessment year expired. Where that period expired during the TOLA-covered period, the authority under section 151(i) could grant sanction only until 30 June 2021. Orders under section 148A(d) and consequential reassessment notices issued later required sanction from the competent specified authority under section 151(ii). Approval by the Principal Commissioner under section 151(i) after that date invalidated jurisdiction to revive reassessment proceedings, resulting in the order being quashed.

Section 179 director-liability proceedings must comply with natural justice before a company's tax dues are fastened on a director. Determining liability without considering the director's reply and supporting documents breaches that requirement. The High Court quashed the liability order because the response and accompanying material had been overlooked, and remanded the matter for a fresh decision in accordance with law and natural justice within 12 weeks.

Section 54F applies only where the transferred long-term capital asset is not a residential house; exemption is therefore unavailable when both the original and replacement assets are residential properties. Section 54 requires the same assessee to sell the original residential property and purchase or construct the new property within the stipulated period. Investment solely in a spouse's name does not satisfy this requirement, as spouses are distinct legal entities and the husband's sale cannot be clubbed with the wife's sole acquisition. Consequently, capital-gains exemption under sections 54F and 54 was denied.

Live sports broadcasting rights do not transfer copyright in a live telecast capable of generating royalty income; therefore, consideration attributable to the live feed is not royalty. Repeat or other non-live telecast rights remain within royalty treatment. Composite media-rights consideration is apportioned using established viewership data: 93% for live broadcasting and 7% for non-live broadcasting. Tax-disallowance for failure to deduct tax applies only to the payment allocated to non-live rights, requiring consequential recomputation of the disallowance.

The deductee-paid-tax exception applies to non-deduction of tax on External Development Charges where the payee has filed its return, included the relevant receipt in income, and paid the tax due. Verification of these statutory conditions is required before imposing liability for tax default and consequential interest. Liability for non-deduction and interest does not arise if the prescribed conditions are satisfied. The assessment was set aside and remanded for verification of the payee's compliance with those conditions.

Section 50C(1)'s proviso permits stamp-duty valuation on the date consideration was fixed rather than the registration date where the two dates differ. In a rehabilitation-related land transfer, statutory proceedings, resolutions, banking-channel advance receipt and a sanctioned scheme may collectively establish that consideration crystallised before registration, even without a conventional sale agreement. Later increases in guideline value or stamp-authority valuation cannot retrospectively replace that agreed consideration absent independent evidence of higher fair market value. The beneficial proviso operates retrospectively to relieve hardship. Accordingly, valuation applicable when consideration was fixed was adopted and the long-term capital gains addition was deleted.

Internal comparable uncontrolled transactions should be preferred over external comparables for benchmarking fixed-rate Masala Bond interest where they arise in the same period and offer greater comparability. A floating external benchmark is inconsistent with the strict comparability required under the CUP method, resulting in deletion of the related transfer-pricing adjustment. Specialised operational and maintenance services received from an associated enterprise are not shareholder activities; where receipt and need are evidenced, their arm's length price cannot be fixed at nil without comparable uncontrolled transactions. The related adjustment was deleted. TDS credit requires factual verification, while interest for advance-tax deferment is chargeable only on returned income, not assessed income.

Revision proceedings require the designated statutory authority to issue the notice in the correct official capacity. A Chief Commissioner issuing a notice as Principal Commissioner, without an express Board order authorising exercise of that function, lacks jurisdiction and invalidates the resulting revision. Revision for notional annual letting value of professionally used properties also cannot rest on a change of opinion where the Assessing Officer examined ownership, use and house-property treatment and adopted a plausible view. Explanation 2 to section 263 does not apply where genuine inquiry and verification occurred. Properties transferred by gift are not assessable in the transferor's hands. The revisional order was quashed.

MEIS duty credit scrips received under the Foreign Trade Policy 2015 are treated as revenue receipts taxable as income from assessment year 2016-17. Applying the purpose test, the rewards offset export-related costs and infrastructure inefficiencies and enable more profitable conduct of export business. Their computation by reference to completed exports, recurring nature, transferability and unrestricted usability support their revenue character; they are not linked to capital investment, establishment or expansion, nor earmarked for a capital purpose. Government assistance "by whatever name called" covers MEIS rewards, including grants or cash incentives, without limitation by ejusdem generis.