A consolidated demand-cum-show cause notice covering multiple financial years is not barred under the CGST Act, whether issued under the ordinary demand provision or the provision concerning fraud, wilful misstatement or suppression. The article notes that the selection of the latter provision depends on factual findings about conduct intended to evade tax and ordinarily cannot be decided in writ proceedings at the notice stage; affected persons must respond before the Proper Officer and use statutory appellate remedies. Where a fresh reply opportunity is granted, adjudication is restored to the notice stage, with the court-directed period excluded when calculating the time available for adjudication.

Payment of admitted GST liability in instalments falls within the Commissioner of State Tax's power. Where the taxpayer did not dispute the liability and sought permission to pay it in instalments, the appropriate course was to apply to the competent authority for consideration under applicable law. The High Court permitted the taxpayer to make that application and directed the Commissioner of State Tax to consider it within the stipulated period, disposing of the writ petition.

For claims seeking only interest on GST refunds already sanctioned and disbursed, Rule 89(2)(m) CGST Rules certification was stated to be unnecessary because interest cannot be passed on to an end consumer. The Proper Officer was directed to examine the refund particulars and decide the interest claims under law without insisting on certification that the incidence had not been passed to another person. The petitions were disposed of with directions to complete scrutiny and determine the claimed interest within the stipulated period.

Writ jurisdiction against a GST demand was not considered appropriate where allegations of fraudulent registration, identity theft and forgery created disputed factual questions requiring evidence. As the impugned order addressed the taxpayers' submissions after a hearing, its factual findings were suitable for review by the statutory appellate authority. The High Court therefore declined to examine the merits and directed the taxpayers to pursue the available statutory appeal, with liberty to seek exclusion of the time spent prosecuting the writ petition for limitation purposes.

Rule 86A(2) permits an authorised officer to allow debit from a blocked electronic credit ledger when satisfied that the conditions justifying the input tax credit restriction no longer exist. The High Court directed the taxpayer to provide a copy of its unblocking application after the respondents stated it was unavailable. The application must be considered and decided expeditiously on its merits in accordance with law. Records must be returned unless required, in which case copies must be supplied.

Anti-profiteering provisions did not require a price reduction for homebuyers in the Digangana Housing Complex because the eligible input tax credit-to-purchase-value ratio decreased after GST implementation. The investigation compared eligible pre-GST credit, transitional credit, post-GST input tax credit, purchase value, and reversals attributable to exempt supplies for the project continuing across both tax periods. As no additional input tax credit benefit accrued, no contravention of the requirement to pass on such benefit through commensurate price reduction was established. The Tribunal accepted the final investigation report and disposed of the proceedings without further directions.

Characterisation of flat-sale proceeds depends primarily on the taxpayer's intention, determined from the totality of circumstances, including the stated objects, consistent investment treatment, period of holding, leasing efforts, absence of other projects, and lack of regular trading activity. Although book treatment is not conclusive, it is relevant. Sales over different years after unsuccessful efforts to obtain tenants did not amount to an adventure in the nature of trade. Where the Revenue had accepted capital-gains treatment in earlier years and no distinguishing facts or incriminating material existed, consistency required the same treatment. The proceeds were therefore assessable as capital gains rather than business income, and the Revenue's appeal was dismissed.

Government grants earmarked for specified purposes and subject to utilisation restrictions do not constitute the recipient's income; accordingly, an unspent micro-irrigation scheme grant was not taxable. Interest payable on unutilised grant under applicable Government resolutions was treated as an allowable liability. Under the block-of-assets principle, depreciation remains available where business assets form part of a used block, even if individual assets have been retired from active use; simultaneous use of every asset is unnecessary. The related depreciation disallowance was deleted, and the capital-gains issue was treated as academic.

Revision under section 263 cannot extend to matters already considered in an appeal: where the appeal covered the genuineness of purchases and profit estimation, Explanation 1(c) barred revision on those purchases. Revision also cannot substitute the Commissioner's view for the Assessing Officer's plausible view after inquiry; having examined supporting documents and estimated only the profit element in unverifiable purchases, the assessment could not be revised to tax the entire purchases as unexplained expenditure. Further, a supplier's non-genuineness alone does not establish remission or cessation of a trading liability, so the outstanding credit could not be taxed on that basis. The revisionary order was set aside and the appeal allowed.

Rejection of books of account for failure to maintain quality-wise diamond stock records requires material showing that the accounts are incorrect or incomplete. The note states that absence of particulars such as size, clarity, colour and shape, without specific defects in books, registers, inventory, vouchers or primary documents, does not justify invoking section 145(3). It further notes that consistently followed accounting methods, supported by stock valuation reports and audit records and accepted in other scrutiny assessments, undermine a best-judgment profit estimate lacking a rational basis. On these stated facts, the rejection of books was treated as unsustainable and the consequential estimated-profit addition was deleted.

Foreign tax credit for overseas legal and consultancy receipts is examined under the India-Japan DTAA and Rule 128. The notes state that Article 14 on independent personal services applies to individuals, while the Article 12(4) exclusion for professional services is confined to payments made to individuals; therefore, a partnership firm's Japanese legal-service receipts are not excluded from foreign tax credit on the basis that Article 14 exclusively governs them. Where gross overseas receipts are included in Indian taxable income and supported by Form 67 and authenticated foreign tax-deduction certificates, Rule 128 contains no stated restriction on credit for overseas taxes withheld.

Higher depreciation was allowed for commercial vehicles acquired during the specified period and included in the relevant asset block. Warranty provisions were allowed because they were scientifically determined, consistently applied and inextricably linked to sales rather than contingent liabilities. For approved in-house research facilities, approval of the facility was treated as material, while the difference between approved and incurred expenditure was remitted for limited verification. Expenditure disallowance relating to exempt income was deleted: joint-venture investments produced no exempt income, and interest-free funds exceeded investments yielding exempt income. The deduction for employing new workmen was allowed consistently with earlier years. Both appeals succeeded, subject to limited verification of the research deduction.

Foreign life-insurance policy maturity proceeds were not treated as undisclosed foreign income or an undisclosed foreign asset where the investment source was satisfactorily explained. Premiums had been paid from income not chargeable to tax during non-resident status and later from salary already taxed in India; CBDT clarifications on explained foreign assets were stated to apply. The discussion also states that the life-insurance exemption does not confine its benefit to policies issued by Indian insurers. A definition of "insurer" in another provision could not be imported where the exemption provision did not adopt it or distinguish foreign insurers. Accordingly, the maturity proceeds were described as exempt and outside assessment under the Black Money Act.

Section 80P deduction for interest and dividend income from compulsory, fixed and savings-bank deposits is discussed as available where the deposits are attributable to a credit co-operative society's business of providing credit facilities to members. The note distinguishes investment income treated as business income from the contrary context of investments with co-operative banks. It also addresses reassessment beyond three years, stating that the extended limitation period requires strict satisfaction of statutory conditions and cannot rest on cash-deposit allegations that do not survive; a deduction disallowance alone must meet the applicable threshold. Consequential under-reporting penalty proceedings may require fresh consideration where the underlying assessment is restored.

A return filed in response to a notice under section 148, when filed within the period specified in that notice, is treated under section 148(2) as a return furnished under section 139. Read together, sections 148 and 80AC permit a deduction claim where the reassessment return is timely, notwithstanding that no original return was filed under section 139(1). The text also explains that revision under section 263 is not warranted where the assessment record shows that the deduction claim was examined and allowed after application of mind; the assessment order must be both erroneous and prejudicial to Revenue interests.

Sale consideration from inherited residential property is addressed as taxable under "Capital gains" where title documents, society records and devolution support the taxpayer's ownership. The material emphasises that doubts about a transfer deed based on unverified signature comparison, without expert evidence or independent enquiry, cannot displace documentary title; suspicion cannot substitute cogent evidence. It further notes that receipt of gross sale proceeds alone does not establish taxable income under "Income from other sources" if ownership is disputed. The described treatment requires computation of long-term capital gains and consideration of the residential-property reinvestment deduction, subject to arithmetical verification.

Cross-examination is required in benami adjudication where a retracted income-tax statement is the foundational evidence for alleging that another person provided the purchase consideration; reliance without testing the statement can undermine findings with confiscatory or penal consequences. Income-tax assessment and benami proceedings operate independently, so acceptance of an investment's source does not conclusively negate benami ownership, but an assessment addressing the same fund flow must be considered. For company-owned property, the Initiating Officer must establish that another person supplied consideration and would benefit from the property, and must give reasoned consideration to documented explanations based on reserves, loans and advances.

Pending representations for provisional release of seized imported glass beads and currency must be considered by the Proper Officer after affording the petitioner an opportunity of hearing. The HC directed the Proper Officer to decide the existing representation and any additional representation concerning the subsequent seizure by a reasoned order in accordance with law within three weeks. The writ petition was disposed of without adjudicating the merits of the parties' rival contentions.

Declared customs transaction value may be rejected only on cogent evidence of extra consideration or reliable contemporaneous imports of comparable goods at higher prices. The notes state that unsupported statements, uncertified electronic records, and uniform loading without consignment-specific comparability do not establish undervaluation. Where final assessments were made and no fraud, collusion, wilful misstatement, or suppression with intent to evade duty is proved, the extended demand period is unavailable. If the valuation-based demand fails, consequential duty, confiscation, interest, and penalty cannot stand; seized currency lacking a proven nexus must be released, and investigation deposits must be refunded with applicable interest.

Belated re-testing of remnant iron ore samples cannot displace contemporaneous representative-sample results without objective, legally sustainable grounds. The notes state that samples analysed at export were corroborated by load-port and discharge-port reports, contractual price adjustments and realised sale proceeds. A re-test conducted more than a year after export was considered unreliable because storage and laboratory drying could affect moisture content and could not recreate the goods' condition at export. The delayed re-test and final assessment based on it were set aside, and the exported iron ore fines qualified for export duty and cess exemption on evidence of iron content below the prescribed threshold.