Reopening under sections 147 and 148 requires the assessing officer to evaluate investigation information against the relevant facts and independently form a reason to believe that taxable income has escaped assessment. Where the recorded reasons misstated exempt income disclosed in the return, the reopening notices were invalid and the consequential assessments were quashed. A binding jurisdictional ruling addressed materially similar reasons and circumstances.

The deemed-income addition under section 56(2)(vii)(b) for the jantri-value difference on jointly purchased property was deleted on parity grounds where no corresponding addition was made in the co-owner's hands. This treatment was confined to the particular facts and small amount involved and did not establish a general rule. For filing delays, a family medical emergency may constitute sufficient cause. Sufficient cause is construed liberally to advance substantial justice in the absence of mala fide conduct, and the length of delay does not preclude condonation where the explanation is sufficient.

Permanent establishment profits require no further attribution where arm's length remuneration of the Indian associated enterprise fully accounts for the multinational group's Indian functions, assets and risks, even if a dependent agency permanent establishment exists. A unilateral advance pricing agreement covering marketing support binds its applicant and the tax department for the covered transactions and years, although it does not bind the foreign enterprise. Interest under section 234B is mandatory and consequential. A challenge to the initiation of penalty proceedings under section 270A is premature at the initiation stage.

Failure to verify an importer's KYC documents against the originals can expose a G-Card holder who independently files Bills of Entry to a penalty under section 112(a)(i) of the Customs Act, even where physical verification of the importer's address is not expected. Relief from revocation of the Customs Broker's licence does not automatically extinguish the holder's separate penalty. Financial hardship, including a low salary and corroborated family medical circumstances, may justify reduction of an excessive penalty.

Reasonable belief for the seizure of gold under Section 110 requires tangible material and objective circumstances existing at the time of seizure; suspicion alone is insufficient. Without that belief, Section 123 does not shift the burden to the possessor, and the Department must establish the gold's foreign origin and smuggled character. Unmarked gold and purity comparable to domestically available gold do not establish foreign origin; procurement records can support a domestic source. Retracted customs statements require independent corroboration, and reliance on statements recorded under Section 108 is subject to Section 138B. Where confiscation liability is not established and evidence of smuggling or abetment is absent, penalties on an owner or carrier lack a basis.

Provisional release of distillate marine oil raises questions about bank guarantees where laboratory reports do not conclusively identify the goods as diesel or high-flash high-speed diesel. Diesel fractions include both high-flash high-speed diesel and other distillate oils, and cloud point alone cannot justify seizure when test reports are inconclusive. In these circumstances, the bank guarantee requirement is inconsistent with applicable directions. Return of the guarantee requires a bond and production of the required end-use certificates, including any outstanding certificates.

Under Section 123 of the Customs Act, 1962, GST invoices recording gold of matching purity, supported by supplier and purchaser accounts and courier evidence, can establish a preceding domestic supply link. Where the authenticity of the invoices and the actual supply are unchallenged, the burden shifts to the customs department to verify suppliers and establish that the supply chain is vitiated before it can shift back to the purchaser. Foreign-marked bullion can lawfully enter domestic circulation through authorised channels. Without supplier verification or material displacing the documentary evidence, a reasonable belief of smuggling is not established.

Customs broker penalties under Sections 112(a)(iii) and 114AA of the Customs Act, 1962 require proof of knowledge of the offending nature of goods or their misdeclaration. Repeated handling of import documents or participation in the documentary and delivery process alone does not establish the required knowledge or attract penalties. In the ordinary course, a person handling import documents is not required to verify their authenticity or the contents of the consignment.

Provisional release of seized perishable walnuts under Section 110A of the Customs Act requires security conditions that balance revenue protection against the importer's interests and the risk of decay. A bank guarantee set at 132% of the goods' value, in addition to a bond, was considered onerous. For these imports, the guarantee was reduced to 20% of the duty involved, with a bond for the full duty amount. Origin certificates and supporting documents had been produced, and the certificate of origin had not been shown to be inauthentic. The customs allegations remained open to investigation and adjudication.

Registered persons receiving specified goods from another registered person are designated as a class of recipients for tax deduction at source under section 51 of the Odisha Goods and Services Tax Act, 2017. The specified goods are used cooking oil classified under Customs Tariff heading 1518; plastic waste and scrap under heading 3915; tyre waste and scrap under heading 4004; metal scrap under Chapters 72 to 81; and electrical and electronic waste and scrap under heading 8549. These classifications refer to the First Schedule to the Customs Tariff Act, 1975. The substitution takes effect on 1 November 2026.

Imports into India of alloy steel chisels/tools and hydraulic rock breakers in fully assembled condition exported from Malaysia are subject to provisional assessment pending a decision on an anti-circumvention investigation. The assessment also covers seven specified assemblies, sub-assemblies or components of hydraulic rock breakers exported from Malaysia: the front head, back head, piston for a hydraulic cylinder or rock breaker, cylinder body or hydraulic unit, bracket, frame, and cylinder for a hydraulic rock breaker. The proper customs officer determines the guarantee to be furnished for any anti-dumping duty that may become payable following the designated authority's recommendations and the Central Government's decision.

Applicants must provide a scheduled-bank solvency certificate for Rs 25 lakh, a general bond for Rs 10 lakh and security for Rs 10 lakh by cash deposit, bank guarantee, postal security or National Savings Certificate; bank guarantees must contain an auto-renewal clause. For renewal, all fresh-application documents and a self-attested copy of the existing licence must be submitted at least 90 days before expiry. For overseas outsourcing, permission may not be required for specified non-core activities, but the applicant or authorised courier must intimate the department and provide the service agreement, the overseas entity's authorised signatory's authorisation and identity proof, and an affidavit accepting responsibility for that entity's acts and conduct.

Sections 2, 3 and 4 of the Odisha Goods and Services Tax (Amendment) Act, 2026 (Odisha Act 7 of 2026) come into force on 1 November 2026. The Odisha Government appointed that commencement date on 30 October 2026, exercising the power conferred by section 1(2) of the amendment Act. The appointment was made by order of the Governor.

Working body chairs and vice-chairs discussed work plans and matters proposed for plenary consideration, including draft administrative decisions, responsible sourcing initiatives, improvements to statistical reporting, institutional governance and participant compliance. Further discussions addressed potential reform of the conflict diamond definition, digitalisation of certification and statistics, sustainable funding and continuity of the secretariat, and effective reporting and peer review. Participants also considered artisanal and alluvial production, the sustainability of producing countries and communities, and compliance with scheme minimum requirements.

Estimated commission additions based on alleged bogus job-work entries were deleted for both assessment years because the underlying job-work expenses had been found genuine. The commission estimate depended on the premise that the assessee supplied bogus entries. Coordinate-bench reasoning rejected the revival of protective additions where the underlying transactions were genuine.

Post-supply discounts under section 15(3)(b) require a supplier to issue a credit note and the recipient to reverse the input tax credit attributable to the discount in accordance with section 34. Section 34(1) is extended to cover such discounts as a basis for issuing credit notes. Refund provisions in section 54(6) are extended to unutilised input tax credit allowed under clause (ii) of the first proviso to section 54(3).

Priority sector lending targets and classification are the subject of proposed consolidated directions following a review of existing instructions. Separate drafts are proposed for commercial banks, small finance banks, local area banks, regional rural banks and urban co-operative banks. The proposals consolidate existing instructions on an entity-specific basis; instructions omitted from the consolidated drafts are to be repealed following issuance of the directions, with the repeal to be notified separately. Public comments or feedback on the drafts may be submitted by 26 November 2026 through the Connect 2 Regulate section of the Reserve Bank's website, using the relevant link for each draft, or by email.

Clarifications issued by the Central Board of Indirect Taxes and Customs on goods classification and the applicability of GST to certain goods and services apply mutatis mutandis in implementing the Odisha Goods and Services Tax Act, 2017. Their application is intended to ensure uniformity. Circular No. 265/11/2026-GST concerns classification and GST applicability for supplies of certain goods, while Circular No. 266/12/2026-GST concerns GST applicability to certain services. Difficulties in implementing these clarifications may be brought to the attention of the Commissioner of State Tax, Odisha.

Central GST clarifications issued on 26 October 2026 apply mutatis mutandis in implementing the Odisha Goods and Services Tax Act, 2017, to promote uniformity. They cover demand, adjudication and appeal proceedings, as well as amounts paid as pre-deposit under sections 107(6) and 112(8) of the Central GST Act. The clarifications also address Input Service Distributors and the provisions of section 17(4) of the Central GST Act. Further topics include input tax credit admissibility for authorised agents appointed by manufacturers for the sale of motor vehicles, receipt of payment for exports of goods or services, and the omission of rule 96(10) of the Central GST Rules.

The proper officer may issue an electronic notice in FORM GST REG-03 where an application has not been identified by the system for physical verification of the place of business. Where the system identifies the application for physical verification, or the proper officer considers verification necessary, the notice must be issued within thirty days of submission of the application. Implementation difficulties may be brought to the attention of the Commissioner of State Tax, Odisha.