Input tax credit on imports should not be denied solely because IGST is absent from the GST portal where the apparent cause is an ICEGATE-GSTN integration failure and the taxpayer has no role in transmitting the data. Documents supporting payment of tax should be considered, and IGST paid on imports reconciled and duly reflected in the electronic credit ledger. Non-reflection caused by a systemic lapse does not itself determine credit entitlement; the merits and other contentions remain open for fresh consideration.

GST registration cancellation notices must disclose the specific contravention and material particulars needed for an effective reply. Where wrongful input tax credit is alleged, relevant particulars may include the suppliers and the period involved. Fundamental omissions cannot be cured by invoking statutory provisions on appeal or relying on particulars in separate proceedings. Additional evidence in GST appeals must comply with Rule 112 and its procedural safeguards. An inquiry report relied on adversely must be open to an effective and reasonable opportunity for rebuttal.

Confiscation for stock discrepancies requires independent proof of the statutory ingredients, including intent to evade tax; a discrepancy alone does not establish clandestine supply or deliberate evasion. Visual estimates unsupported by actual weighment and internally contradictory verification sheets do not reliably establish excess stock. Stock-accounting discrepancies must be examined under the regular demand and assessment provisions rather than treated as grounds for automatic confiscation. Departmental appeals involving interpretation of the GST Act fall outside prescribed monetary limits, including disputes over whether confiscation or regular demand provisions apply to stock discrepancies.

Rule 138(3) exempts qualifying intra-State feeder movements of up to 50 kilometres from furnishing e-way bill Part-B conveyance details when goods move from the consignor's business to the transporter's business for further transportation. The e-way bill remains valid, and an automated portal warning cannot override the exemption. A minor procedural omission unconnected with intent to evade tax cannot sustain a penalty under section 129(3). Route deviation alone does not establish evasion without corroborating evidence, which the Revenue must produce. Recurring legal issues fall outside the prescribed monetary limits for departmental appeals.

Specialised ophthalmic chairs, stools, refraction chair units, operating tables, instrument tables and trolleys fall under heading 9402 as medical or surgical furniture, rather than heading 9018 for medical or ophthalmic instruments and appliances. The HSN Explanatory Notes exclude medical and surgical furniture from heading 9018 and cover specialised operating and examination tables, eye-treatment seats and medical instrument tables and trolleys under heading 9402. Motorised surgeon's chairs, doctors' stools and refraction chair units fall under subheading 94021090; operating tables and instrument tables and trolleys fall under 94029090. Their supplies attract 18% GST, comprising 9% CGST and 9% SGST.

Advertisement, marketing and promotion expenditure can be treated as an international transaction only where an agreement, arrangement or understanding with the associated enterprise is established. Incidental enhancement of brand value and comparisons with other companies' expenditure do not establish such a transaction, and the Bright Line Test is not a prescribed method for determining the arm's length price. Management support fee cross-charges included in a cost-plus service base must be examined alongside their effect on related service revenue; section 92(3) prevents transfer pricing provisions from reducing taxable income. Challenges directed solely at the initiation of penalty proceedings under sections 270A and 271AA are premature at that stage.

Carry bags made from compostable polymers or biodegradable plastic substitutes fall under Chapter 39 as plastic articles, rather than Chapter 48 as paper articles. Where headings 3901 to 3925 do not apply and no specific entry covers the product under heading 3926, residual HSN 39269099 applies. Entry 319 of Schedule I to Notification No. 09/2025-Central Tax (Rate) covers biodegradable plastic bags and provides a 5% GST rate, strictly subject to their biodegradability. Interim testing indicated conformity with IS/ISO 17088, while the final test report remained pending.

Tea packaged with spoons, glass cups or wooden honey dippers for a single price constitutes a mixed supply where the items are independently marketable and not naturally bundled in the ordinary course of business. Tea's predominance alone does not establish a composite supply. A mixed supply attracts the highest GST rate applicable to its components: 18% for tea paired with stainless steel or plastic spoons or glass cups, and 5% for specified teas paired with wooden honey dippers. For these combinations, the HSN code corresponds to the higher-rated component; where both components attract the same rate, either component's code may be used.

Rice husk composite board made from extracted fibres bonded with PVC resin exceeding 15% by weight falls under heading 4411 as fibreboard, rather than heading 4410 as particle board. The HSN notes to heading 4410 exclude boards with organic binder exceeding that threshold. Classification depends on the interpretative rules, tariff notes and HSN, having regard to composition, manufacturing process and essential character; Indian Standard specifications are not mandatory for primary tariff classification. Specific GST rate entries for rice husk board apply across Chapter 44 or any other chapter: the rate was 12% before 22 September 2025 and 5% from that date.

Escaped income of at least Rs. 50 lakh is a jurisdictional condition for reassessment beyond the ordinary three-year period under Section 149(1)(b). Time allowed to respond to a show-cause notice and periods covered by a court-ordered stay may be excluded when computing limitation, while the sixth proviso provides a consequential minimum seven-day period. These provisions do not enlarge substantive jurisdiction. Approval under Section 151 requires independent consideration of the assessee's reply, the escaped-income quantum and the permissible reopening period. An order must stand on its recorded reasons, which cannot be supplemented for the first time in writ proceedings.

Income-tax claims arising before approval of a resolution plan and excluded from it are extinguished, and reassessment for those dues cannot be initiated or continued against the corporate debtor. The approved plan binds government creditors, and the Insolvency and Bankruptcy Code overrides inconsistent laws. Rejection of a waiver of statutory obligations does not preserve excluded claims or permit fresh demands for the earlier period. Clean-slate protection bars reassessment itself, not merely recovery. Reassessment powers cannot be used against the resolved debtor solely to collect evidence against former promoters or third parties; other available powers may be used to pursue permissible action against them.

Pre-approval income tax claims omitted from an approved resolution plan stand extinguished, and the plan binds government creditors. The Insolvency and Bankruptcy Code overrides inconsistent Income Tax Act provisions, preventing reassessment to pursue those claims. Refusal to waive statutory obligations in the plan approval order does not preserve an excluded claim. Reassessment provisions address income that has escaped assessment and cannot be used merely to collect evidence against former management or third parties. Lawful action against them may be pursued under separate statutory powers.

Charitable exemption for fee-based citizen services requires an annual examination of whether charges are significantly above service costs and, if so, whether the applicable receipts threshold is exceeded under the first proviso to Section 2(15). Charges at cost or nominally above cost do not constitute trade, commerce or business, and registration under Section 12AA does not preclude the enquiry. Application of income under Section 11 is a separate enquiry: once accounts and relevant material are produced, denial must rest on their scrutiny rather than general observations. Operating expenditure ordinarily qualifies if the activity advances general public utility without attracting the proviso. A penalty under Section 271(1)(c) cannot survive independently of its foundational addition.

Sales-tax incentives for industrial development are capital receipts when their purpose is to attract investment and generate employment; their source or delivery mechanism does not determine their character. For the export deduction under section 80HHC, sales tax and excise duty are excluded from total turnover despite section 145A, while 90% of net interest is excluded from business profits. Interest relating to Deep Discount Bonds Series A and B was deductible.

Interest under section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsory acquisition of agricultural land forms part of the compensation and is treated as a capital receipt, not income from other sources. Amendments governing taxation of interest on compensation do not alter its compensatory character. The interest is not taxable under section 56(2)(viii) read with section 57(iv). Where the addition treating the interest as taxable is deleted, a consequential penalty under section 270A based on that addition loses its foundation and is deleted.

Section 41(1) applies when remission or cessation of a trading liability confers a benefit in the relevant year. A creditor balance that remains outstanding in that year does not cease merely because it is written back and offered to tax in a subsequent year; a separate debit relating to another entity does not establish cessation without a link to the creditor. Under the project completion method, income from sales in a completed tower of an approved composite real estate project may be recognised when the entire project is completed. Assessment of proposed additions for maintenance charges and GST requires a due and reasonable opportunity to respond.

Form 10-IC's assessment-year mismatch, attributed to portal difficulties, does not by itself defeat a domestic company's concessional tax option where the option was exercised in a timely return and the form was filed within the relaxed deadline. The filing relaxation addressed genuine hardship for assessment year 2021-22. Concessional taxation remains subject to the other substantive conditions under section 115BAA. Section 115JB(5A)(ii) excludes minimum alternate tax where the section 115BAA option is exercised, with liability computed under the concessional regime and other applicable provisions and interest recomputed consequentially.

Direct expenses should be attributed to the relevant segment, while common expenses may be allocated by segment revenue; segmental results require examination before rejection. For the software development and ITeS segments, a Rs. 200 crore upper turnover filter reflects differences in functions, assets and risks; knowledge-intensive services are not comparable to routine ITeS. Foreign-currency receivables were benchmarked at LIBOR plus 200 basis points, with a 30-day credit period. No section 14A disallowance arose without exempt income for the relevant year; the Finance Act 2022 amendment operates prospectively from assessment year 2022-23. Consultancy fees for integrating related companies' operations were not accepted as business expend.....

Market value for the section 80-IA deduction on captive power transfers is the State Electricity Board's tariff for industrial consumers, not the rate paid to generating units. For capital-intensive power units, head-office common expenses are appropriately allocated by fixed assets rather than profitability. An appellate authority may consider an additional claim even without a revised return. Merchandise Exports from India Scheme incentives are taxable revenue receipts and assistance included in income under section 2(24)(xviii): they offset infrastructure inefficiencies and export costs without requiring capital investment, expansion or a new unit.

Jewellery previously disclosed under the Voluntary Disclosure of Income Scheme and reflected in earlier income-tax returns and balance sheets was not treated as unexplained where the Revenue did not dispute the disclosure, despite the absence of a scheme certificate. Marriage photographs showing jewellery being worn did not establish the source of its purchase. Jewellery beyond the allowance already granted under CBDT Instruction No. 1916 remained unexplained because no evidence substantiated the source of the remaining jewellery.