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HC : Gujarat High Court: Belated Return Cannot Be Rejected Mechanically Where Refund Claim Arises from Omitted TDS; Section 119(2)(b) Delay Condonation to Be Reconsidered

ITAT : Mumbai ITAT Nullifies Section 200A Demand for Short TDS Deduction Linked to Seller’s PAN Inoperability, Citing Timely PAN Regularization and Tax Payment by Seller

ITAT : Addition Under Section 69C Restricted to Profit Element Where Purchases Substantiated by Documentary Evidence

HC : Madras High Court Upholds Section 69 Addition for Unexplained Investment Due to Lack of Registered Title; Dismisses Writ Challenging Assessment and Penalty Orders

ITAT : Hyderabad ITAT Upholds Weighted Deduction for R&D Expenditure Despite Delay in Furnishing Form 3CLA—Substantial Compliance Under Section 35(2AB) Recognized

ITAT : Mumbai ITAT Upholds Reassessment Post-Search under Revised Section 147: AO’s Reliance on “Information” Deemed Sufficient for Jurisdiction

ITAT : ITAT Mumbai Remands Share Capital Addition Under Section 68: CIT(A) Faulted for Not Inquiring Creditworthiness and Genuineness Despite AO’s Detailed Findings in High-Premium Share Allotment

ITAT : Mumbai ITAT Upholds CPC’s Power to Adjust Return Based on Tax Audit Report under Section 143(1)(a)(iv), But Strikes Down Mechanical Section 14A Disallowance Absent AO’s Dissatisfaction

ITAT : Mumbai ITAT Rules Ex-Gratia Severance from Employer’s India Exit as Non-Taxable Capital Receipt, Not ‘Profits in Lieu of Salary’

ITAT : Mumbai ITAT Rules Repayment of Business Liabilities Not Taxable as Unexplained Expenditure under Section 69C in Absence of Actual Outflow or P&L Deduction

ITAT : Mumbai ITAT Affirms Allowability of Business Development Expenses and Depreciation on Director-Registered Vehicles in Absence of Contradictory Evidence

ITAT : ITAT Chennai Rules Web Hosting Fees Not Royalty: No Right to Use Equipment or IP Transferred Under India-USA DTAA

ITAT : Chennai ITAT Exonerates Sundaram Finance from Penalty under Section 270A: Bona Fide Reliance on Jurisdictional High Court Precedent Shields Assessee on Bad Debt Recovery Issue

ITAT : Delhi ITAT Clarifies: No Doctrine of Merger Between Orders u/s 143(1) and 143(3); Dismisses Appeal for Lack of Grievance

ITAT : ITAT Chennai Orders Grant of Section 80G Approval to Trust Engaged in Rural Empowerment and Skill Development Despite Revenue Generation

ITAT : Mumbai ITAT Allows Full Deduction for NBFC’s Debenture Issue Expenses Under Section 37(1); Disallows Amortisation Under Section 35D

ITAT : ITAT Ahmedabad Quashes Disallowance under Section 37: Death of Proprietor and GST Cancellation Not Sufficient Grounds for Purchase Addition

ITAT : Mumbai ITAT Rules Rs 50 Lakh Development Rights Payment as Capital Gains, Not “Other Sources”; Section 50C Inapplicable in Absence of Land Transfer

ITAT : Chennai ITAT Quashes Reassessment for Failure to Issue Mandatory Section 143(2) Notice Despite Belated Return Filed in Covid Circumstances

ITAT : Mumbai ITAT Affirms SEBI-Registered VCF’s Entitlement to Multiple Section 10 Exemptions on Distinct Income Streams

ITAT : Chennai ITAT Quashes PCIT’s 263 Order: Reassessment Restored as Mutual Fund Dividend Taxed Appropriately and No Sham Proven

ITAT : Chennai ITAT Quashes Fresh Addition by AO Exceeding Tribunal’s Remand Scope; Restricts AO to Tribunal’s Directions Only

ITAT : Mumbai ITAT Orders Fresh Examination on Taxability of Software Sales by McAfee Singapore, Stresses No Royalty Without Copyright Transfer

ITAT : Retrospective Application of Amended Rule 11UA for Share Valuation Disallowed under Section 56(2)(vii)(c); Additions Set Aside

ITAT : ITAT Holds Deferred Revenue for Unexpired Warranty Period Recognizable Over Warranty Tenure; Affirms Consistent Accounting Policy as Per AS-9 and ICDS-IV

ITAT : Delhi ITAT Rules Penalty under Section 271(1)(c) Inapplicable Where Full Tax Paid Prior to Notice under Section 148 – Assessment Accepted Without Variation

ITAT : Mumbai ITAT Special Bench Affirms 16-Year Reassessment Limitation for Non-Residents under Section 149(1)(c) in Foreign Asset Cases; Addition Deleted for Lack of Source Provenance

ITAT : Delhi ITAT Invalidates Reassessment for Lack of New Evidence; Reopening Held as Mere Change of Opinion Where Assessment Was Previously Concluded After Survey

ITAT : Mumbai ITAT Upholds Section 10(46) Exemption for Prior Period and Ancillary Regulatory Incomes: Nature of Income Prevails Over Timing and Classification

HC : Madras High Court Upholds Validity of Assessment Order under Section 143(3) r.w.s 153A, Rejects Assessee’s Plea on Settlement Commission Jurisdiction Post-Finance Act, 2021

HC : Delhi High Court: Closure of State GST Proceedings Under Section 73 Does Not Bar Central GST Action Under Section 74 Where Statutory Appeal Is Available

HC : Madras High Court Quashes GST Assessment for AY 2024–25: SCN Issued Under Section 74 Held Without Authority Where Proceedings Had to Be Under Section 74A

AAR : Karnataka AAR Restricts ITC on Factory Canteen Services to Statutory Portion Borne for Regular Employees; Contract Labour and Employee-Recovered Costs Excluded

SC : Supreme Court Declines to Entertain Constitutional Challenge to Section 16(2) CGST Act, Upholds High Court’s Direction to Pursue Statutory Appeal, but Expressly Reserves Assessee’s Rights

AAR : Brake Hoses Used in Vehicle Braking Systems Classified as Vulcanized Rubber Tubes under HSN 4009; Haryana AAAR Rules 18% GST Applicable, Overturning Earlier AAR Ruling

HC : Allahabad HC Quashes ITC Blocking for Lack of “Reason to Believe” Under Rule 86-A of UP GST Rules in Mohan Milkfoods Case

HC : Bombay High Court Sets Aside GST Refund Rejection for IT Exporter Due to Absence of Reasoned Order; Remands Case for Fresh Adjudication

HC : Gauhati High Court Quashes GST Demand on Bona Fide Purchaser Where Supplier Defaults on Tax Deposit, Reiterates Department’s Remedy Against Defaulting Seller

HC : Kerala High Court Upholds Detention of Arecanut Consignment and Vehicle Pending Title Adjudication Under GST Law

HC : Kerala High Court Rules ISD Registration Not Mandatory for ITC Distribution Prior to April 1, 2025; Quashes GST Demand and Penalty on Cross-Charge Transactions

HC : Gauhati High Court Quashes GST Assessment for Lack of Proper Show Cause Notice: Summary DRC-01 Held Insufficient to Initiate Proceedings under Section 73

HC : Orissa High Court Quashes GST Appellate Order for Failure to Consider Assessee’s Timely Reply on Limitation Issue

HC : Gauhati High Court Affirms Retrospective Penalty on Partners for GST Evasion: Partners Held Personally Liable under Section 122(1A) CGST Act

HC : Allahabad High Court Declares Arrest and Remand under CGST Act Illegal for Absence of Mandatory DIN and Procedural Safeguards

GSTAT : GSTAT Upholds Rs. 13.61 Crore Profiteering by Lifestyle International Pvt. Ltd. for Failing to Pass on GST Rate Reduction to Customers; No Interest or Penalty Levied

GSTAT : GSTAT Delhi Affirms No Profiteering by Arun Excello Constructions LLP in “Compact Homes-Narmada” Project Due to Absence of Incremental ITC Benefit

HC : Gauhati High Court Upholds Validity of Consolidated Notices and Orders for Multiple Financial Years under GST; Assessees' Plea on Prejudice and Limitation Rejected

HC : Madras High Court Nullifies GST Assessment on Seigniorage Fees, Directs Fresh Proceedings Subject to Supreme Court Verdict

HC : Bombay High Court Declares Consolidated GST Show-Cause Notice and Recovery Order Void for Lack of Jurisdiction—Permits Fresh Proceedings under Proper Provisions

HC : Madras High Court Remands GST Penalty Order under Section 74 for Fresh Review; Opportunity Allowed to Prove Genuine Supply and Wrongful Invocation

HC : Madras High Court Quashes ITC Demand, Orders Fresh Inquiry Where Supplier’s Tax Compliance is Evident Despite Missing Transport Documents

HC : Madras High Court Quashes ITC Denial for Late Return Filing in Light of Section 16(5) Amendments; Orders Passed Under Section 16(4) Limitation Held Unsustainable

HC : Madras High Court Nullifies GST Demand and Penalty under Section 74 Owing to Lack of Hearing and Prima Facie Non-Applicability of Registration Threshold

ITAT : Madras High Court Quashes Best Judgment Assessment under Section 62, Directs Revenue to Reassess Considering Subsequently Filed Returns

HC : Madras High Court Invalidates Assessment Order Issued Against Deceased Taxpayer; Permits Fresh Proceedings Against Legal Heirs

HC : Meghalaya High Court Denies Writ Relief on GST Annuity Demand, Directs Jorabat Shillong Expressway Ltd. to Exhaust Statutory Appeal Route

HC : Gauhati High Court Restores GST Registration Citing Failure to Issue Proper 30-Day Show Cause Notice under Rule 21A(2A)(b) for Violation of Rule 10A

AAR : Kerala AAAR Confirms GST Liability on Wetland Conversion Fees, Restricts Advance Ruling to Prospective Transactions Only

HC : Rajasthan High Court Upholds DGGI Authority to Seal Premises and Attach Bank Accounts in Absence of Assessee’s Cooperation During CGST Investigation

HC : Allahabad High Court Upholds Validity of CGST Authority’s Show-Cause Notice under Health Security and National Security Cess Rules Despite Rubber Stamp Error: Pan Masala Manufacturer Denied Pre-emptive…

Income Tax - Sections 69, 115BBE, 142(1), 147 - ITAT Ahmedabad: Investments from Sufficiently Explained Foreign Income by NRI Cannot be Deemed Unexplained Solely Due to Documentation Gaps - In light of the ITAT’s findings, once an assessee establishes with credible evidence that foreign income has been duly earned, taxed abroad, and subsequently remitted to India via banking channels, such remittances and resulting investments cannot be classified as unexplained merely due to certain documentation lapses at the assessment stage. Tax authorities must consider the holistic financial trail and avoid narrow year-to-year income matching, especially in the case of non-residents with accumulated savings. Assessees in similar circumstances should ensure comprehensive documentation of foreign income, tax residency, remittance trail, and investment linkage to avoid such disputes.

Income tax - Sections 9(1)(vii), 90 - Delhi ITAT Rules Offshore Aircraft Engine Repairs by US Company Not Taxable as FTS under India-US DTAA for Lack of ‘Make Available’ of Technical Knowledge - In light of the above findings, the ITAT’s decision establishes that income from offshore repair and overhaul services, where technical know-how is not 'made available' to the recipient, cannot be taxed as FTS either under section 9(1)(vii) of the Income Tax Act or Article 12(4)(b) of the India-US DTAA. Taxpayers providing similar offshore services should meticulously demonstrate that their activities do not involve the transfer of technical knowledge, know-how, or skills in a manner that enables the Indian customer to perform such services independently in the future.

Income tax – Sections 40(a)(i), 44C, 195 - ITAT Mumbai Holds Internal Cost Allocations Not Disallowable Under Section 40(a)(i); Transfer of Business Undertaking as Lump Sum Premium Constitutes Slump Sale Under Section 50B - The ITAT Mumbai's decision reinforces settled judicial principles across multiple tax provisions:

No interest disallowance arises under section 14A when own funds cover tax-free investments.
Head office expenses incurred abroad for Indian operations are subject to section 44C limitations, regardless of their common or exclusive nature, provided they fit the statutory description.
Deductions under section 36(1)(viia) must be applied before the ceiling under section 44C.
Internal allocations between branches do not attract withholding tax or disallowance under section 40(a)(i) in the absence of payment or credit.
The transfer of an undertaking for a lump sum and book value adjustment, without specific asset-wise valuations, is a slump sale under sections 2(42C) and 50B.

Income tax – Sections 144B, 153 - ITAT Delhi Quashes Final Assessment Orders Passed Beyond Statutory Limitation: Non-Obstante Clause in Section 144C(13) Does Not Override Section 153 Time Limits - The ITAT Delhi decisively held that the non-obstante clause in Section 144C(13) does not exclude the application of the limitation provisions in Section 153. Therefore, final assessment orders under Section 143(3) read with Section 144C(13) and Section 144B must adhere to both the DRP-specific and the general statutory time limits. As the orders in question were issued beyond the permissible period, they were quashed as being time-barred.

Income tax - Sections 144C, 153 - ITAT Delhi Declares Final Assessment Order Void Due to Breach of Statutory Limitation under Section 153 Read with Section 144C - Based on the established judicial principle that statutory time limits for assessment are sacrosanct, and in light of the binding precedents from the Madras High Court and supportive orders from the Supreme Court and various ITAT benches, the final assessment order passed under Section 143(3) read with Section 144C(13) for AY 2020-21 was declared void ab initio for being time-barred. The Tribunal directed that such orders, passed beyond the period prescribed under Section 153, be quashed, and no further proceedings be continued on the basis of such time-barred orders.

Income tax - Sections 144C, 153 - Delhi ITAT Rules Final Assessment Order under Section 143(3) r.w.s. 144C(13) Barred by Limitation Due to Mandate of Section 153 - Based on the current judicial position, the ITAT Delhi categorically concluded that the Final Assessment Order passed under section 143(3) read with section 144C(13) for the Assessment Year 2020-21 is time-barred as per the limitation prescribed by section 153. The Tribunal set aside the assessment order as invalid and non est in law, emphasizing the necessity for strict adherence to statutory timelines for assessment proceedings, irrespective of a "notwithstanding" clause in section 144C(13).

Income Tax - Sections 92CA, 144C - Delhi ITAT Quashes Assessment for Absence of Draft Order: Non-Issuance Under Section 144C(1) Held Fatal in Transfer Pricing Case - The ITAT’s decision underscores that the procedural mandate of issuing a draft assessment order under section 144C(1) is inviolable for eligible assessees in transfer pricing cases. Any assessment made in contravention of this requirement is liable to be struck down as invalid and without jurisdiction. This position is fortified by consistent judicial authority and statutory interpretation.

ITAT Mumbai Rejects Transfer Pricing Adjustments Where Foreign AEs Selected as Tested Party but Benchmarking Relied on Indian Comparables; Clarifies Principles for Capital Contributions, Inter-Company Loans, and Delayed Receivables - The ITAT’s decision underscores the critical importance of selecting the correct tested party based on reliable and geographically relevant comparables in transfer pricing analyses. Benchmarking foreign AEs using Indian comparables is unsustainable and invites reversal. Capital infusions into wholly owned subsidiaries cannot be re-characterized as loans absent concrete debt characteristics. Inter-company loans in foreign currency should be benchmarked against LIBOR plus an appropriate spread, supported by defensible internal CUPs. Adjustments for delayed receivables must follow invoice-level computation and adhere to the accepted credit period, using LIBOR-based benchmarks. Transfer pricing methodologies must reflect the true functions performed by the entities involved, and CUP cannot be deployed unless there is genuine functional comparability.

Gauhati High Court Upholds Private Bank’s Right to Refuse Foreign Exchange Transaction Amid Sanctions Concerns: Judicial Review Limited Where Bank Acts Under FEMA-RBI Regime and Contractual Compliance - The Gauhati High Court concluded that the writ petitions were maintainable given the presence of a public law element in the bank’s regulatory actions. However, on merits, the Court found the bank’s refusal to process the transactions was justified under statutory, regulatory, and contractual frameworks. The Court declined to interfere under Article 226, affirming that the bank acted within its mandate under FEMA, RBI directions, and the express terms of the facility agreement. Petitioners facing refusal of transactions by Authorised Dealer Banks should ensure ongoing accuracy of declarations and be prepared for enhanced regulatory scrutiny, especially in transactions potentially implicating international sanctions.

Karnataka High Court Affirms FEMA Residency Status in Immovable Property Purchase by Foreign Nationals on Business Visa; Sets Aside Confiscation and Penalty - On the facts and law, the Karnataka High Court decisively held that foreign nationals residing in India for more than 182 days on a business visa and conducting business are to be treated as persons resident in India under Section 2(v) of FEMA. Consequently, the specific FEMA regulations applicable to non-residents do not restrict their acquisition of immovable property in India. The decision of the Appellate Tribunal to quash the confiscation and penalty was upheld, and the related writ petition was disposed of as infructuous.

Tribunal Overturns FEMA Penalty: Timely FC-GPR Submission by Company, Delay Attributed to Bank’s Lapse, Refund Ordered - Based on the documentary evidence and admissions on record, the Tribunal concluded that the appellant fulfilled its obligation of reporting foreign investment by submitting Form FC-GPR to the authorised dealer within the prescribed period. The subsequent delay in transmission to the RBI was solely attributable to the bank’s internal processes. As such, the alleged non-compliance with FEMA regulations was not established, and all consequential penalties were set aside with an order for refund of the pre-deposit. Entities in similar positions should ensure strong documentation of submission to the authorised dealer to establish compliance.

Income tax – Sections 115JB - ITAT Delhi Holds Proceeds from Renewable Energy Certificates to be Capital Receipts; Not Taxable as Revenue Income under Income Tax Act - The ITAT, Delhi, has reaffirmed that sale proceeds from Renewable Energy Certificates (RECs) are to be treated as capital receipts and are not taxable as revenue income. The Tribunal also clarified that RECs, by their legal character, do not fall within the ambit of “carbon credits” as defined in section 115BBG and, therefore, cannot be taxed under this provision. The Tribunal further held that such receipts are to be excluded from the calculation of book profits under section 115JB. In cases where the DRP has issued binding directions, strict compliance is required from the Assessing Officer, and any disregard of such directions renders the assessment order unsustainable. Enhanced or corrected claims for deduction under section 80-IA, if already claimed, must be duly examined on merits as per judicial precedents.

Income tax – Sections 94B - ITAT Chennai Rules Thin Capitalisation Norms under Section 94B Cannot Discriminate Against Indian Subsidiaries Borrowing from Denmark: Disallowance Struck Down under India-Denmark DTAA - The ITAT Chennai has decisively held that the thin capitalisation restriction under Section 94B, which applies only to non-resident AE borrowings and not to resident AE borrowings, is discriminatory when tested against the non-discrimination clause in Article 24(4) of the India-Denmark DTAA. Accordingly, the entire disallowance made under Section 94B was deleted. The decision stresses that unless the DTAA contains a specific carve-out permitting thin capitalisation rules, such restrictions cannot override treaty protection. Taxpayers with similar treaty protection and facts may rely on this decision to challenge Section 94B disallowances.

ITAT Bangalore Upholds Exclusion of High-Turnover and Functionally Dissimilar Comparables in Software and Marketing Support Transfer Pricing - The ITAT Bangalore’s decision reaffirms that in transfer pricing comparability analysis, both the turnover filter and functional similarity are paramount. Companies with substantially higher turnover than the assessee, or those engaged in multi-functional or product-based activities without reliable segmental data, are not appropriate benchmarks for captive service providers. The Tribunal’s approach mandates that comparables must be similar not only in terms of functions but also in scale and segmental focus. Taxpayers should meticulously review their comparables in light of these principles and be prepared to justify their selections with segmental and functional data.

Income-tax - Sections 144C(13), 144B - ITAT Delhi Remands TP Adjustment on Intra-Group Management Fees: Commercial Expediency Not to Be Questioned if Service Rendered; Factual Verification Directed - The ITAT has clarified that while the TPO is not empowered to challenge the commercial rationale of an expense shown to have been incurred for business purposes, the taxpayer must establish, through credible and contemporaneous evidence, that the alleged intra-group services were actually rendered. The onus is on the assessee to prove the nature and extent of services received from the AE. Inadequate substantiation will result in the matter being remanded to the lower authorities for proper verification. Taxpayers must be prepared to furnish detailed and transaction-specific documentation to support their claims in transfer pricing matters.

Income Tax - Sections 143(3), 144C(13), 144B - ITAT Delhi Directs Inclusion of Previously Accepted Comparables in Transfer Pricing Assessment for Lubricants Manufacturer - Based on the current ruling, it is actionable for both taxpayers and the Department to ensure that comparables found functionally similar and accepted in prior years should ordinarily be continued in subsequent years for transfer pricing analysis, unless there is a demonstrable change in facts or circumstances. The Tribunal has reinforced the need for consistency and fairness in the selection of comparables, particularly when Revenue has not raised any objection in the past.

Income Tax - Sections 143(3), 144C(13), 144B - Delhi ITAT Directs TPO to Apply Internal CUP for Benchmarking Interest on NCDs Issued to AEs: Ignores Inadmissible TP Adjustment on Opening Balances - The ITAT has categorically directed that the TPO must apply the Internal CUP method for benchmarking the interest paid on the PPFC03BV Bond issued to the AE during the relevant year. The Tribunal’s decision reinforces that transfer pricing adjustments cannot be sustained by overlooking relevant internal comparables, especially when such comparables have been accepted in other assessment years and are specifically directed to be considered by the DRP. The TPO is required to reassess the transaction using Internal CUP as the Most Appropriate Method and pass a reasoned, speaking order.

Income tax – Sections 144C, 153 - ITAT Delhi Quashes Final Assessment Orders Exceeding Section 153 Limitation Despite Section 144C Non-Obstante Clause in Transfer Pricing Cases - The ITAT Delhi has unequivocally held that, in cases involving transfer pricing and the DRP procedure under Section 144C, the final assessment order must be passed within the limitation period stipulated under Section 153. The non-obstante clause in Section 144C(13) does not override or exclude the operation of the limitation period. Final assessment orders passed beyond the statutory timeline are invalid and must be quashed. Assessees and tax practitioners must vigilantly track the expiry of the Section 153 time limit, irrespective of the DRP and draft order process, to ensure legal compliance and protect their rights.

Income Tax - Section 271(1)(c) - ITAT Delhi Directs Amortization of Goodwill to be Treated as Non-Operating Expense Under TNMM, Rejects DRP’s Interpretation - In this decision, the ITAT Delhi has unequivocally held that, for transfer pricing analysis under the TNMM, amortization of goodwill arising from a slump sale constitutes an extraordinary expense and must be treated as non-operating while computing the PLI. The Tribunal has directed the AO/TPO to exclude such amortization from the operating costs for the relevant assessment year and to recompute the transfer pricing adjustment accordingly. Assessees facing similar facts should ensure that extraordinary items like goodwill amortization are appropriately characterized in the PLI computation and should contest any contrary adjustment by lower authorities with reference to this order.

FEMA Adjudication Upheld Despite Customs Settlement: Tribunal Clears Exporters Over Foreign Commission Issue Due to Lack of Repatriation Obligation and Hearsay Evidence - In light of the above findings, the Tribunal allowed the appeals and quashed the penalties, holding that the commission paid overseas by a foreign buyer to a foreign agent does not represent export proceeds due to the Indian exporter under FEMA. The Tribunal further concluded that the principal evidence relied upon by the authorities was hearsay and inadequate to sustain the alleged violations.

Sections 241, 242 of the Companies Act, 2013 - Kerala High Court Halts Arbitration Over Company Restructuring, Citing NCLT’s Exclusive Jurisdiction Under Companies Act - The Kerala High Court decisively held that where disputes pertain to statutory restructuring or management of companies, as governed by Sections 241 and 242 of the Companies Act, 2013, such matters are non-arbitrable and fall exclusively within the NCLT’s jurisdiction. The Court’s intervention under Articles 226 and 227 of the Constitution was deemed appropriate to prevent arbitral overreach into matters reserved for a statutory forum. Parties and arbitrators must therefore carefully distinguish between contractual and statutory disputes to avoid futile arbitration proceedings.

Bombay High Court Orders Injunction and Heavy Costs Against Manufacturer for Infringing 'UltraTech' Trademark in Cement Sector - The Bombay High Court’s decision establishes that unauthorized use of marks identical or deceptively similar to registered trademarks, especially when compounded by deliberate non-compliance and dishonest conduct, will not only attract injunctive relief but also significant punitive costs. The order for destruction of infringing goods and award of actual litigation costs serves as a strong deterrent against willful infringement in the commercial sector.

Supreme Court Clarifies Arbitrator’s Powers on Forfeiture and Damages in Builder-Owner Dispute: Contractual Clauses and Proof of Actual Loss Decisive - In summary, the Supreme Court’s decision underscores the sanctity of contractual terms, especially where parties have allocated rights and remedies for delay and breach under separate clauses. Arbitrators must honor the allocation of remedies as per the agreement and cannot substitute or limit reliefs where the contract provides otherwise. Further, stipulated penalties for breach or delay in construction contracts can be enforced without strict proof of actual loss, as long as the contract prescribes clear consequences. However, parties must be vigilant in challenging all parts of an award they object to, as unchallenged aspects become final and unalterable. Courts will also limit the scope of interest claims and may prefer modification of awards over setting aside in the interest of finality when litigation is protracted.

Kerala High Court: Prospective Amendment to Limitation Period Bars Reassessment for AY 2011-12 under KVAT Act - In conclusion, the Kerala High Court has categorically held that the amendment to Section 25(1) of the KVAT Act by the Kerala Finance Act, 2017, extending the limitation period for reassessment, operates only prospectively from 01.04.2017. Any attempt to reopen assessments for periods where the limitation had already expired prior to the amendment is without jurisdiction. Tax authorities must strictly adhere to the limitation period prevailing at the time the assessment became final, unless the amending provision expressly provides for retrospective operation.

Supreme Court Directs Arbitration in Class Action Dispute, Sets Aside NCLT and NCLAT Orders on Maintainability under Section 245 - In light of the Supreme Court’s directions, the class action petition under Section 245, though initially found maintainable by the NCLT and NCLAT, will not proceed in those forums. Instead, the disputes will be adjudicated in arbitration, with all contentions as to maintainability, scope of reliefs, and liability of third parties expressly left open. Companies and stakeholders must take note that while statutory thresholds and prima facie standards may be satisfied at the Tribunal stage, ultimate resolution—including the forum and maintainability—may be subject to further judicial or consensual intervention.

Calcutta High Court Upholds Suo Motu Transfer of Winding Up Proceedings to NCLT: No Mandatory Precondition for Party Application Required - In conclusion, the Calcutta High Court dismissed the appeal and endorsed the suo motu transfer of pending winding up proceedings to the NCLT. The decision establishes that a Company Court can, after due judicial consideration, direct the transfer of proceedings at any stage prior to the process becoming irreversible, without a mandatory requirement for a party to apply for such transfer. This affirms the primacy of judicial discretion and procedural propriety over rigid adherence to the formality of applications.

SEBI Bars REL and Promoter for Non-Disclosure and Misleading Financials: Foreign Confidentiality Cannot Override Indian Securities Law Mandates - The decision underscores that listed entities operating in the Indian securities market are under a non-negotiable obligation to maintain and furnish all relevant information, irrespective of any private confidentiality or foreign data protection constraints. Companies consolidating overseas subsidiaries’ results into their financials must ensure full transparency, including the continuous maintenance and timely disclosure of underlying subsidiary data. Non-compliance, obstruction, or misleading disclosures will invite regulatory action, including restrictions on dealing in securities and personal liability for key managerial personnel.

Delhi High Court Sets Aside Arbitral Award for ADC Dispute: Tribunal Found to Have Exceeded Contractual Terms and Granted Relief Without Proper Evidence - The Delhi High Court set aside the arbitral award on the grounds that the Tribunal exceeded its mandate by altering the contract’s terms, failed to rely on proper evidence for quantification, and rendered a contradictory award. Practitioners must ensure that arbitral awards strictly adhere to contractual terms and are based on cogent evidence, as deviation is likely to be struck down for patent illegality.

Bombay High Court Directs State to Refund Octroi to SEZ Developer; State’s Inaction Held Contrary to SEZ Policy Despite Absence of Enabling Rules - In this case, the Bombay High Court clarified that while municipal authorities cannot be directed to refund taxes in the absence of enabling legislation, the State Government, which had committed to an exemption in its own policy and admitted as much in court, was duty-bound to honor that commitment. The actionable takeaway is that SEZ developers have a right to enforce State policy commitments where such commitments are not honored through necessary legislative or administrative action, and may seek remedies directly against the State Government for reimbursement in such scenarios.

Delhi High Court Holds Coal Beneficiation May Constitute ‘Manufacture’ for Cost Audit Purposes; Quashing of Prosecution Rejected Pending Trial Evidence - Based on the analysis of Supreme Court judgments and statutory provisions, the Delhi High Court held that coal beneficiation, particularly through wet processes, may constitute “manufacture” or “production” for the purposes of cost audit obligations under the Companies Act, 2013 and the Companies (Cost Records and Audit) Rules, 2014. The Court dismissed the petitioner’s plea for quashing the criminal complaint, clarifying that the determination of the true nature of the activity—manufacture/production or mere processing—requires evidence and adjudication at trial.

NCLAT Upholds Binding Nature of Sanctioned Scheme: Assignment of Creditors’ Claims to 63 Moons Group Precludes Separate Civil Suits Against Consenting Brokers - Based on the above, the NCLAT dismissed the appeal, holding that the sanctioned scheme—already judicially affirmed—binds all specified creditors, including dissenters. The appellants are precluded from pursuing separate civil proceedings in respect of claims covered under the scheme, as those claims are now solely vested with the 63 Moons Group following the assignment.

Calcutta High Court Clarifies: Winding Up Proceedings Can Be Transferred to NCLT Unless Irreversible Stage is Reached—Unpaid Official Liquidator Expenses Not a Bar - The Division Bench of the Calcutta High Court upheld the orders transferring the winding up proceedings and connected applications to the NCLT. It has been conclusively held that unresolved claims for services rendered under the Official Liquidator do not, on their own, prevent the transfer of winding up matters, unless the winding up has reached an irreversible or irretrievable stage. Parties with statutory claims retain the right to pursue those claims before the NCLT post-transfer.

Sections 213, 212 of the Companies Act, 2013 - NCLAT Upholds Directors’ Liability for Fraudulent Transfer of Overseas Subsidiary Shares without Consideration; Sets Aside Direct SFIO Probe, Refers Investigation to Central Government - Given the appellants’ inability to provide a satisfactory and credible explanation for the transfer of subsidiary shares without consideration and the failure to establish how the penalty to Aero Steel was settled, the NCLAT upheld the Adjudicating Authority’s direction requiring the directors to contribute to the assets of the corporate debtor. Furthermore, the appellate tribunal clarified that the Tribunal cannot directly order an SFIO investigation and appropriately referred the matter to the Central Government for further investigation as per the Companies Act, 2013. This decision is actionable in nature, highlighting the need for directors to maintain transparent records and proper documentation for all major transactions, especially during insolvency proceedings.

NCLAT Affirms Limitation Bar and Dismisses Fresh Grounds in Directorship and Shareholding Dispute: Appellant’s Challenge to 2012-2013 Corporate Actions Time-Barred, Valuation Exercise Upheld - The NCLAT’s decision reiterates that challenges to corporate actions such as removal from directorship and share allotments must be brought within the statutory limitation period, commencing when the aggrieved party first becomes aware of the impugned acts. Attempts to raise new grounds for the first time in appellate proceedings will not be entertained, and parties must avail themselves of all opportunities provided at the original stage, particularly in matters involving valuation of shares. The appeal was accordingly dismissed in its entirety.

Supreme Court Clarifies: Derivatives Above Position Limits Not Voided; No Proof of Manipulation in RPL Promoter’s Futures Trades - The Supreme Court’s decision affirms that exceeding position limits under the 2001 SEBI Circular does not void derivative contracts but mandates disclosure and penalizes only non-disclosure. It also holds that a breach of position limits by way of non-disclosure can attract penal action but does not amount to fraud or manipulation per se, absent tangible evidence of market abuse. The Court’s finding that there is no requirement for a perfect hedge and that legitimate market conduct—such as selling to capitalize on price increases—does not constitute manipulation sets a high threshold for establishing fraud or manipulation under SEBI’s anti-fraud regulations. This approach emphasizes the need for clear, cogent evidence before penalizing market participants for complex trading strategies.

Corporate Voting Rights Dispute: NCLAT Allows EOGM but Stays Implementation of Resolutions Pending NCLT Decision on Shareholder Authority - In summary, the NCLAT disposed of the appeal by allowing the EOGM to take place, thereby upholding corporate democracy and shareholder rights, but expressly directed that implementation of any resolution passed at the EOGM be kept in abeyance pending the outcome of the company petition before the NCLT. This ensures that the rights of the parties are preserved and that no irreversible actions are taken until the fundamental questions regarding the corporate shareholder’s voting authority and amendments to the Articles are judicially resolved.

Supreme Court Upholds Expansive Supervisory Powers of Election Commission Under Article 324 and Section 21(3) RP Act: Special Electoral Roll Revision and Documentation Regime Validated - The Supreme Court’s decision affirms that the Election Commission enjoys wide-ranging supervisory and procedural powers for electoral roll management, provided these are exercised within the legislative framework. Special revisions, documentation requirements, and inquiries into citizenship undertaken by the Commission are valid and constitutionally sound, so long as they are rooted in statutory authority and rational criteria.

Bombay High Court Upholds Bona Fide Sale Post-Winding Up Petition: First Transaction Validated Under Section 536(2); Second Private Transfer Excluded - The Bombay High Court, through this decision, allowed the interim application in part by validating only the first transaction under Section 536(2) of the Companies Act, 1956, and dismissed the Official Liquidator’s report as far as it sought to challenge this transaction. The second, purely private, transaction was excluded from the scope of these proceedings, with the Court leaving open the possibility of action against the ex-directors in respect of any statutory dues, should the relevant authorities choose to pursue such action.

NCLAT Upholds Dismissal of Interim Relief, Orders Status Quo on Asset Sale and Fresh Merits Hearing on Related Applications in Oppression and Mismanagement Dispute - In sum, the NCLAT affirmed the dismissal of IA No.21/2023, declining to interfere with the EOGM or blanketly restrain asset disposal. However, the Tribunal continued the status quo order on asset sales to protect the interests of stakeholders until final resolution of the main petition. Additionally, the Tribunal mandated that interlocutory applications relating to earlier incidents be reconsidered afresh and decided on their own merits following a fair hearing.

Calcutta High Court Affirms Bar on Civil Courts in Director Removal Dispute; Sets Aside Ex Parte Injunction for Want of Reasoned Order - The Calcutta High Court allowed the appeal, setting aside the ex parte ad interim injunction that had restrained the company from proceeding under Section 169 of the Companies Act, 2013. The Court held that only the NCLT, and not the civil court, could entertain disputes regarding removal of directors, irrespective of shareholding status. Furthermore, any interim relief—particularly of an ex parte nature—must be supported by a reasoned and case-specific judicial application of the settled legal tests, failing which such orders are unsustainable.

Calcutta High Court Rules Post-Withdrawal Transposition Impermissible: Stringent Limits on Review and Representative Capacity in Oppression and Mismanagement Appeals - The Calcutta High Court’s decision firmly establishes that transposition of parties under Order XXIII Rule 1-A CPC requires an active application pending at the time of withdrawal or abandonment of proceedings; post-withdrawal applications for transposition are not maintainable. The Court also clarified that appeals under Section 10F of the Companies Act, 1956, are available only to persons individually aggrieved and not by way of representative capacity for non-appellants. The scope of review remains strictly limited to patent errors or new evidence, not as a means to reopen concluded matters or to circumvent procedural defaults. Assessees and parties must, therefore, take timely procedural steps and cannot rely on review to remedy lapses or omissions after the underlying proceeding has been terminated.

Supreme Court Declines to Interfere: Company Court’s Authority under Section 446(2) Upheld, MIDC’s Differential Premium Claim Rejected in Liquidation Transfer Case - The Supreme Court’s refusal to intervene upholds the High Court’s clear delineation of the Company Court’s powers under Section 446(2) of the Companies Act, 1956, affirming that such courts are empowered to decide all claims and questions relating to the assets of companies in liquidation. This includes the power to determine the character of transfers (voluntary or involuntary) and the consequent liabilities, such as differential premium or extension charges.

Calcutta High Court Quashes Look Out Circular Post-Investigation: Upholds Right to Travel Abroad under Article 21 Absent Pending Prosecution - The Calcutta High Court set aside the Single Judge’s order and quashed the Look Out Circular, holding that its continuation after the completion of the SFIO investigation and in the absence of any pending prosecution or court proceedings was arbitrary and disproportionate. The Court’s decision was conditioned upon the appellant providing a notarized affidavit in the prescribed form, ensuring future cooperation with the authorities if required. This decision firmly reinforces the requirement that any restriction on the right to travel abroad must not only be based on concrete material but must also be proportionate and the least restrictive means available.

Bombay High Court Clarifies Discretion in Penalty Quantification Under Section 39(5) of Companies Act: Technical Breach in Return of Allotment Attracts Mitigated Joint and Several Penalty - The Bombay High Court’s decision establishes that the penalty provisions under Section 39(5) of the Companies Act, 2013 do not operate in a mechanical fashion. Adjudicating authorities must evaluate the proportionality of the penalty by considering the nature, gravity, and circumstances of the default, as mandated by Rule 3(12) of the Companies (Adjudication of Penalties) Rules, 2014 and in line with Supreme Court precedent. In cases of technical or minor breaches—such as failure to separately certify an annexure when the main form is affirmed—penalty may be warranted but should be mitigated. Additionally, unless specifically justified, penalties should be imposed jointly and severally and not multiplied across all directors.

Supreme Court Stays Prior Orders to Expedite Investor Settlement Scheme; Time-Bound Escrow Deposit Mandated - The Supreme Court has, by this order, stayed the operation of impugned orders to smoothen the path for implementing the court-approved settlement scheme for investors. It directed designated courts and authorities to take all necessary steps without delay and prescribed a strict two-week timeline for the transfer of the settlement funds to the escrow account post de-freezing. The order offers an actionable roadmap for the prompt resolution of investor claims under the approved scheme.

Calcutta High Court Quashes Bank’s Fraud Classification: Reliance on Discredited Audit Report and Undisclosed Lenders’ Meeting Violates Natural Justice - The Calcutta High Court’s order unequivocally sets aside the show cause notice and the fraud classification order, on the basis that the decision was predicated on previously discredited material and undisclosed information from the Joint Lenders Meeting, in violation of the principles of natural justice. The bank is permitted to undertake fresh proceedings, provided that they adhere strictly to legal requirements, including disclosure of all relied-upon material and provision of a fair opportunity to respond.

NCLAT Upholds Waiver of Threshold Requirement under Section 244 in Guarantee Company: Prima Facie Oppression and Mismanagement Sufficient for Relief - On a careful appraisal of the impugned order and the submissions advanced, the NCLAT dismissed the appeal, holding that the adjudicating authority had articulated sufficient prima facie reasons for the grant of waiver under Section 244. These reasons included the persistence of alleged acts of oppression and mismanagement, the challenge to membership actions, and the violation of the Articles of Association. The order, therefore, stands affirmed, and the company petition may proceed without requiring compliance with the statutory threshold.

Sections 241, 242 of the Companies Act, 2013 - NCLT Ahmedabad Orders Restoration of Corporate Governance Amidst Deadlock and Mismanagement in Closely Held Company - The NCLT’s decision underscores that in cases where company management is paralyzed due to deadlock and mutual distrust, even without concrete proof of oppression, the Tribunal can intervene under section 242 to address mismanagement and protect the company’s interests. Actionable steps include facilitating access to records and ensuring ongoing statutory compliance, while purely financial or time-barred reliefs may be declined unless substantiated by cogent evidence.

Supreme Court Upholds Void Nature of Post-Winding-Up Property Transfers; Delay Condoned but No Relief Granted to Appellant - The Supreme Court’s order confirms that any disposition of company property after the commencement of winding up proceedings, absent explicit court validation, is void in law as per Section 536(2) of the Companies Act, 1956. Despite condoning procedural delay, the Court emphasized the necessity of judicial sanction for such transfers and declined to interfere with the High Court’s application of the statutory provision.

Sections 241, 188 of the Companies Act, 2013 - NCLT Ahmedabad Orders Reversal of Slump Sale of ‘Tea Post’ Brand Due to Lack of Unanimous Approval and Transparency in Asset Valuation - Given the absence of a unanimous resolution and a credible valuation report, the NCLT, Ahmedabad Bench, has directed that the amount realized from the business transfer be reverted to Respondent No. 9. Moreover, it has mandated that Respondent No. 9 must retain an interest in Respondent No. 10, ensuring continued oversight and participation in the business. A new memorandum of agreement is to be executed, delineating the rights, obligations, and profit/loss sharing between the group company and the SPV. This decision highlights the necessity for procedural compliance, transparency, and protection of minority interests in intra-group business transfers.

CESTAT Delhi Holds Pre-SCN Reversal of Cenvat Credit on Capital Goods and Duty-Paid Clearance of Inputs as Such Suffices; Extended Limitation Period Rejected Due to Lack of Suppression - The CESTAT, Delhi, ruled that voluntary reversal of Cenvat credit on capital goods before issuance of a show cause notice and payment of excise duty on spare parts cleared as such constitute sufficient legal compliance under the Cenvat Credit Rules, 2004. Consequently, any further demand for reversal is unsustainable. Furthermore, in the absence of any deliberate suppression or intent to evade, the extended limitation period under Section 11A cannot be invoked. As a result, the order confirming demand, interest, and penalty was set aside.

CESTAT Chandigarh Declares Abatement of Indirect Tax Appeal Post-Resolution Plan Approval: Statutory Dues Not Covered in Insolvency Plan Extinguished - The CESTAT Chandigarh, adhering to the Supreme Court’s directions and subsequent CESTAT precedents, ruled that statutory dues not included in an approved IBC resolution plan are extinguished by law. As such, it held that the Tribunal has no authority to proceed further on such matters, resulting in the abatement of the pending appeal concerning excise dues allegedly arising from wrongful CENVAT credit utilization. Assessees and tax authorities must recognize that post-resolution plan approval, only claims forming part of the plan survive; all others are rendered non-justiciable.

Allahabad High Court Quashes Criminal Prosecution in Excise Duty Evasion Case Following Finality of CESTAT’s Exoneration - Following the finality of the CESTAT’s exoneration and the dismissal of the departmental appeal, the Allahabad High Court has unequivocally held that prosecution under Sections 9 and 9AA of the Central Excise Act, 1944, cannot continue on the same set of facts. The criminal complaint and all related proceedings were quashed, underscoring that once the foundational departmental order is set aside, criminal prosecution loses its legal basis.

CESTAT Kolkata Rules Refund Claims for IGST by International Organisations Timely; Limitation Period to Run from Date of Clarification and Excludes COVID-19 Suspension - The CESTAT Kolkata has held that the right to claim refund of IGST by specified International Organisations cannot be defeated by limitation when the authority to whom such claims must be made was unclear until clarified by Circular No. 23/2019-Customs dated 01.08.2019. Furthermore, the exclusion of time during the COVID-19 pandemic as per Supreme Court directions ensures that claims filed after the clarification remain within limitation. Accordingly, the rejection of refund claims as time-barred was quashed.

CESTAT Chennai Rules Appeal Abates Following Appellant’s Death: No Continuation Permissible Without Application by Legal Heirs - The CESTAT Chennai has reaffirmed that, pursuant to Rule 22 of the CESTAT (Procedure) Rules, 1982, an appeal automatically abates upon the death of the appellant unless the legal representatives or successors-in-interest apply for continuation of the appeal within the prescribed period. The decision underscores that no proceedings can be continued against a deceased person in the absence of such an application, in consonance with the Supreme Court’s ruling in Shabina Abraham & Ors. The Tribunal, therefore, lawfully disposed of the appeal as abated.

CESTAT Chennai Declines Jurisdiction Over Appeal Against Common Mumbai Adjudication Order; Directs Transfer for Unified Bench Under Notification No. 1/2022 - In summary, the CESTAT Chennai held that when an appeal arises from a common adjudication order passed by an authority outside its territorial jurisdiction and involves multiple noticees, it is improper for the Bench to decide the matter on merits merely because one noticee is situated within its jurisdiction. Appellants in such circumstances must seek transfer under the relevant notification, namely Notification No. 1/2022, so that the President can constitute a suitable Bench to hear all related appeals together. Parties seeking remedy should promptly move for such transfer to ensure uniformity and judicial efficiency.

Mumbai CESTAT Upholds Duty Demand and Penalties for Embroidery Thread Imports: Importer and Director Penalized for Undervaluation via Suppressed Invoices and Extra-Commercial Payments - The CESTAT, Mumbai, upheld the re-determined assessable value and sustained the differential customs duty demand along with penalties imposed on both the importer and the Director. The Tribunal found that the presence of direct evidence of undervaluation via supplementary invoices and extra-commercial payments justified both the duty demand and associated penalties. The appeals filed by the importer and its Director were thus dismissed.

High Court Quashes Criminal Prosecution under Central Excise after Appellate Tribunal Finds No Contravention: Fresh Cause of Action Recognized Despite Earlier Withdrawal of Petitions - In sum, the High Court held that the present quashing petition was maintainable due to the absence of a decision on merits in prior withdrawn petitions and the emergence of a fresh cause of action through the appellate tribunal’s order. With the tribunal categorically ruling in favour of the assessee and setting aside the demand that formed the basis of prosecution, the criminal proceedings were deemed to be without legal foundation and were accordingly quashed as an abuse of process.

CESTAT Ahmedabad Affirms Denial of Cenvat Credit for Failure to Verify Supplier Authenticity; Extended Limitation and Equal Penalty Upheld for Fraudulent Availment on Bogus Invoices - The CESTAT Ahmedabad decisively rejected the appellant’s claim to Cenvat credit on invoices issued by spurious or non-existent suppliers, holding that the obligation to undertake reasonable verification under Rule 7(2) is mandatory and non-compliance justifies denial of credit. The Tribunal further upheld the invocation of the extended limitation period, imposition of interest, and an equal penalty under the applicable rules and statutes, finding that the appellant's conduct evidenced knowledge and participation in the fraudulent availment of credit. The belated objection regarding non-supply of documents was found to be devoid of merit. The appeal was accordingly dismissed in its entirety.

CESTAT Hyderabad Confirms CENVAT Credit on Duty-Paid Capital Goods for Air Separation Plant: Lease Arrangements, Plant Immovability, and Extended Limitation Clarified - The decision of the CESTAT Hyderabad decisively affirms the right to CENVAT credit for capital goods and inputs used in the assembly and operation of an Air Separation Plant, even where such goods are integrated into an immovable plant and acquired through lease arrangements. The ownership of the goods and the status of the lessor as a financing company are immaterial for credit eligibility. Additionally, restrictive amendments to input definitions cannot be applied retrospectively, and demands based on new grounds not cited in the show cause notice are unsustainable. Where disputes are interpretational and facts are disclosed, the extended limitation period is not available to the Department. This judgment provides clear and actionable guidance for manufacturers in similar scenarios.

CESTAT Chennai Upholds Concessional CVD for Importers on Parity Principle, Dismissing Departmental Appeal Against Benefit on Imported Mobile Phones - On the basis of the above legal analysis, it is concluded that importers are entitled to claim the concessional CVD under Notification No. 12/2012-CE in respect of imported goods, provided that the like domestic goods enjoy such a concession and the only bar is the inability to demonstrate non-availment of CENVAT credit due to the trader-importer’s status. The requirement must be interpreted in light of the statutory fiction under Section 3(1) of the Customs Tariff Act, ensuring parity with domestic manufacturers. Actionable step: Importers should ensure that their claims for concessional CVD are backed by reference to the SRF Ltd. ratio and prepare to rebut any departmental objection based solely on technical non-compliance with the CENVAT credit condition.

CESTAT Mumbai Affirms Re-import Exemption for Frozen Buffalo Meat: Simultaneous Exemption Claims and Compliance with Notification Conditions Upheld; Duty Demand and Penalties Quashed - Based on the Tribunal’s findings, it is clear that where an assessee has fully complied with the conditions prescribed under Customs exemption notifications for re-import (including proper disclosure, repayment of drawback, and adherence to procedural formalities), the benefit of such exemptions cannot be denied, nor can penalties or fines be imposed merely on technical or procedural grounds. Actionable takeaway: assessees should ensure rigorous documentation and compliance at every stage of re-import and re-export to avail statutory exemptions and withstand departmental scrutiny.

CESTAT Hyderabad Upholds Duty Recovery and Confiscation for Breach of Post-Import Exemption Conditions: Strict Interpretation of Notification No. 65/88-Cus. Confirmed After DGHS Certificate Cancellation - On the basis of the above findings, the CESTAT Hyderabad has provided clear guidance: exemptions under social welfare notifications like No. 65/88-Cus. are strictly conditional and require assessees to provide continuous evidence of compliance with all post-import obligations. Failure to do so, as evidenced by cancellation of the exemption certificate by the competent authority, results in automatic disqualification from the benefit, duty recovery, and imposition of penalties. The Tribunal’s order makes it clear that mere initial eligibility is not sufficient; continued adherence is equally critical.

Supreme Court Upholds Redemption Fine and Reduces Penalties, Permits Set-Off and Re-Export of Confiscated Goods; Fast-Tracks Compounding Application - The Supreme Court’s decision provides clear affirmation that the appellate and judicial authorities are empowered to calibrate redemption fines and penalties based on the facts of the case and principles of proportionality. The directions regarding set-off of deposited amounts and prompt disposal of compounding applications aim to prevent unnecessary hardship and procedural delays for assessees. Assessees facing confiscation and penalty proceedings should ensure all statutory rights—such as compounding and re-export—are diligently pursued and that they maintain proper records of deposits to claim set-off, as permitted by judicial pronouncements.

CESTAT Allahabad Sets Aside Non-Speaking Appellate Order: Commissioner (Appeals) Directed to Independently Examine Disputed Discounts Without Expanding Scope of Appeal - The CESTAT Allahabad, finding grave procedural deficiencies in the appellate orders of the Commissioner (Appeals), set aside the impugned orders only to the extent they were challenged and remanded the matters for de novo adjudication. The Tribunal specifically instructed the Commissioner (Appeals) to restrict the scope of the fresh decision to the grounds raised by the appellant, examine all relevant evidence, and render a reasoned and speaking order in accordance with law. Deductions for freight and insurance, already allowed and not under challenge, are to remain unaffected by the fresh decision.

CESTAT Chennai Rules in Favour of ONGC: Refund of Excess OID Cess Allowed Due to Cum-Duty Valuation Error, No Unjust Enrichment Proven - In summary, the CESTAT Chennai has held that ONGC is entitled to a refund of excess OID Cess paid as a direct result of applying an incorrect (ex-duty) valuation methodology, instead of the required cum-duty valuation under Section 4 of the Central Excise Act as read with Section 15 of the Oil Industry (Development) Act. The appellant also successfully rebutted the presumption of unjust enrichment by providing comprehensive documentary evidence, including contractual terms, invoices, Chartered Accountant certification, and buyer confirmation. The Tribunal directed the Department to process the refund claim with all consequential reliefs in accordance with law.

CESTAT Kolkata Reiterates No Penalty on Supporting Manufacturer and Deemed Export Recipient for Duty-Free Import Authorisation Misuse under Section 112(a), Citing Binding Precedent - In light of the binding precedent and absent any evidence of direct complicity or active evasion, CESTAT Kolkata affirmed that penalties under Section 112(a) of the Customs Act, 1962, cannot be imposed on supporting manufacturers or deemed export recipients solely due to their association with the principal exporter. The Revenue's appeal was dismissed and the impugned order was upheld to the extent it had declined to impose such penalties.

CESTAT Chennai Invalidates Customs Undervaluation Allegations: Declared Transaction Value Upheld, Electronic Evidence and Extended Limitation Rejected - The Tribunal conclusively set aside the entire demand for differential duty, re-determined value, confiscation, redemption fine, and all penalties, including those imposed on the proprietor, for want of evidentiary foundation, procedural compliance, and statutory adherence. It reaffirmed that customs authorities must strictly adhere to the law on transaction value, evidence, and procedure, and that valuation disputes cannot be the basis for penal action absent deliberate misdeclaration or fraud.

CESTAT Kolkata Affirms Absolute Confiscation and Penalty for Smuggled Gold Concealed in Body Cavity: Burden of Proof under Section 123 Not Discharged - On a comprehensive appraisal of the evidence and statutory framework, the Tribunal dismissed the appeal in its entirety. The absolute confiscation of the seized gold under Sections 111(d), 111(i), and 111(l) was affirmed, as was the penalty imposed under Sections 112(a) and 112(b). The order of the lower authority was upheld, with clear findings that the appellant failed to discharge the burden of proof under Section 123, and the conscious concealment established requisite mens rea for both confiscation and penalty. Assessees facing similar circumstances must ensure documentary evidence is readily available to substantiate licit possession, especially where notified goods are concerned.

CESTAT Kolkata Quashes Confiscation, Redemption Fine, and Penalties on Excess Crude Soya Oil Import: No Evidence of Wilful Misstatement or Attempted Evasion - On a thorough evaluation of the facts and applicable legal provisions, the CESTAT Kolkata quashed the entire order of the lower authority. All confiscation orders, redemption fines, penalties under Section 114A, and the direction for remand relating to the custodian were set aside. This outcome was grounded on the finding that there was neither any attempted evasion of customs duty nor any collusive or fraudulent intent on the part of the importer or custodian.

Madras High Court Declares Writ Petition Not Maintainable Against CESTAT Orders: Directs Petitioner to Pursue Statutory Appeal Under Section 35G - In light of the above analysis, the Madras High Court has reaffirmed the principle that writ petitions challenging CESTAT orders are not maintainable when a statutory appellate remedy under Section 35G of the Central Excise Act, 1944 is available. Petitioners are required to exhaust the prescribed statutory remedies prior to seeking intervention under writ jurisdiction. The actionable takeaway is that litigants should carefully assess the availability of statutory remedies and pursue them as a matter of course, reserving writ petitions for exceptional circumstances only.

CESTAT Delhi Holds Consistent Classification Bars Reclassification of ‘MAMA Zarda’ as Zarda Scented Tobacco; Penalties Under Rule 26 Also Set Aside Absent Confiscation Finding - The CESTAT, New Delhi, decisively held that ‘MAMA zarda’ remained classifiable as chewing tobacco under CETI 2403 99 10, given the consistent classification by both the appellant and the Department for several years. As the Department could not validly reclassify the product and no basis for confiscation was established, all demands for differential duty, interest, and penalties, as well as penalties under Rule 26, were set aside.

CESTAT Chandigarh Bars Revenue from Reopening Cenvat Credit Deductions Post-Final Refund Order: Refund to Be Paid as Originally Quantified - The CESTAT Chandigarh decisively held that once a refund order (including the deduction of Cenvat credit) is sanctioned by the adjudicating authority and the department does not challenge the quantification, the refund amount attains finality. The department cannot, at the implementation stage or in proceedings limited to the issue of unjust enrichment, reopen or make further deductions from the refund amount. The appeals were allowed, restoring the refund quantum as originally sanctioned.

CESTAT Bangalore Overturns Penalty on Customs Broker for Alleged Regulatory Breach in Sugar Smuggling Attempt via Rice Export - The CESTAT, Bangalore, definitively ruled that penalties under the Customs Broker Licensing Regulations cannot be sustained in the absence of concrete evidence demonstrating that the Broker had knowledge of, or was complicit in, the exporter’s illegal activities, or had failed to fulfill due diligence and KYC obligations. Errors of a clerical or typographical nature, without more, do not amount to regulatory violations. The Customs Broker’s conduct was found to be in compliance with the regulatory framework, warranting the setting aside of the penalty.

CESTAT Bangalore Quashes Penalty on Customs Broker for Delay and Procedural Lapse in Issuance of Disciplinary Notice Under CBLR, 2018 - The Tribunal conclusively held that, although disciplinary action may be initiated on the basis of a show cause notice forwarded by another Commissionerate, such action must strictly comply with the mandatory ninety-day limitation and procedural requirements laid down in Regulation 17(1) of the CBLR, 2018. The failure to issue the notice within the prescribed period rendered the penalty order under Regulation 18 unsustainable, leading to its setting aside and allowing of the appeal by the Customs Broker.

CESTAT Allahabad Permits Provisional Release of Seized Gold on Furnishing Bond and Bank Guarantee—Gold Not Prohibited, Mere Allegations Insufficient for Denial - In conclusion, the Tribunal’s decision establishes that provisional release of gold and gold jewellery seized under Section 110A cannot be withheld merely on the basis of ongoing investigation or mere allegations of smuggling, especially where the goods are not prohibited and the person concerned is able to furnish reasonable evidence of licit procurement. The Department must release the goods upon execution of a bond for the full value and furnishing a bank guarantee for 50% of the value with an auto-renewal clause.

Delhi High Court Affirms: Import Restriction Notification Effective Only Post e-Gazette Publication—Retroactive Application to Prior Arrivals Barred - The Delhi High Court’s decision makes clear that import restriction notifications issued under delegated legislation become effective only upon their publication in the manner prescribed—here, the e-Official Gazette—and not before. Any attempt to retrospectively apply such notifications to goods that arrived prior to publication is legally unsustainable unless expressly empowered by the parent statute. Actionably, importers whose goods arrived in India before the official time of publication of such restrictions are entitled to have their consignments cleared under the previous legal regime.

No Lapsing of CENVAT Credit or 10%/5% Liability Where Separate Accounts Maintained and Exports Under Bond—Relief to Assessee on All Fronts - The CESTAT Delhi unequivocally upheld the adjudication order, dismissing departmental appeals and confirming that: (i) CENVAT credit did not lapse under Rule 11(3) where common inputs were used for both dutiable and exempt goods; (ii) no liability under Rule 6(3) arose in the absence of an exercised option and with proper maintenance of separate accounts; and (iii) Rule 6(3) did not apply to exempted goods exported under bond. This decision establishes that the department cannot enlarge the scope of demands beyond the show cause notice or ignore procedural and substantive requirements of the CENVAT Credit Rules.

CENVAT Credit Admissible on Mining, Handling, and Crushing Services in Captive Mines—Process Integral to Manufacture - Based on the Tribunal’s findings, manufacturers can legitimately avail CENVAT credit on the service tax paid for mining, handling, and crushing services in captive mines, even if a portion of ore is discarded during the process, so long as these activities are integrally connected to the manufacture of the final product. The impugned order denying such credit, along with interest and penalty, was thus set aside. Assessees should ensure that all such services are properly documented as being used in or in relation to manufacture to defend their credit claims.

CESTAT Mumbai Affirms CENVAT Credit on Re-Manufactured Machinery Cleared to New Buyer; Rebukes Adjudication Beyond Show Cause Notice - In light of the above, the CESTAT Mumbai categorically allowed the appeal, affirming that CENVAT credit is admissible under Rule 16 on duty-paid goods returned to the factory, even if the resultant product is a new machine manufactured using parts of the old machinery, and is cleared to a different buyer on payment of duty. The order of the Commissioner (Appeals) denying credit on grounds not mentioned in the show cause notice was held to be legally untenable and was set aside, with consequential relief for refund and interest as per law.

Guidelines for Compulsory Selection of returns for Complete Scrutiny during the Financial Year 2026-27

Central Government Notify the Specified business for the purposes of Schedule V [Table: Sl. No. 7] of the Income Tax Act, 2025

Approval under Section 45(4)(b) of the Income Tax Act, 2025 for 'Ramakrishna Mission Vidyamandira' Howrah

Approval under Section 45(4)(b) of the Income Tax Act, 2025 for "Regional Centre for Biotechnology, Faridabad, Haryana"

Approval under Section 45(4)(b) of the Income Tax Act, 2025 for "S. Nijalingappa Sugar Institute, Belgaum"

Operationalization of Help Desk for the GSTAT, Chennai Bench
Functioning of The Goods and Services Tax Appellate Tribunal, Mumbai Bench
Minutes of the meeting - 3rd & 4th meeting of the “Committee for Resolution of Representation received from various Trade / Bar Associations” of Goods and Services Tax Appellate Tribunal (GSTAT)
Functioning of Goods & Services Tax Appellate Tribunal (GSTAT), Andhra Pradesh State Benches located at Vijayawada and Visakhapatnam
Functioning of Goods and Services Tax Appellate Tribunal, Bengaluru Bench
Guidelines for winding up of AIFs with respect to retention of proceeds and ‘Inoperative Fund’ status
International Financial Services Centres Authority (Managing General Agents) Regulations, 2026
Norms for Base Price, Price Bands, Call Auction in pre-open session and Close-out procedure for Exchange Traded Funds (ETFs)
Seeks to bring in force provisions of relating to the Legal Metrology Act, 2009- Jan Vishwas (Amendment of Provisions) Act, 2026
Seeks to bring in force provisions of relating to the Delhi Land Holdings (Ceiling) Act, 1960- Jan Vishwas (Amendment of Provisions) Act, 2026
Seeks to amend Notification No. 21/2022-Customs (N.T.), dated the 31st March, 2022
Fixation of Tariff Value of Edible Oils, Brass Scrap, Areca Nut, Gold and Silver
Exemption of Merchant Overtime Charges (MOT) on International Cruise passengers and baggage clearance at cruise ports
Testing of samples of Export Consignments
Sensitisation of officers regarding handling of issues involving interpretation of Foreign Trade Policy (FTP) provisions and adherence to CBIC Instruction No. 07/2026-Customs dated 02.06.2026
Seeks to amend Notification No. 06/2026-Central Excise dated 26.03.2026 to revise the SAED rates on exports of diesel outside India.
Seeks to amend Notification No. 08/2026-Central Excise dated 26.03.2026 to revise the SAED rate on exports of ATF outside India.
Implementation of MeitY Notification S.O. 1246(E) dated 10.03.2026 regarding exemption for Highly Specialized Equipment (HSE) under Electronics and Information Technology Goods (Requirements for Compulsory Registration) Order, 2021.
Implementation of MeitY Notification S.O. 2204(E) dated 05.05.2026 regarding “Standalone Hard Disk Drives” under Electronics and Information Technology Goods (Requirements for Compulsory Registration) Order, 2021
Corrigendum - Notification No. 45/2025-Customs, dated the 24th October, 2025

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Article - Analysis of Sections 14 and 171 of the CGST Act in the Context of Battery Operated Vehicle Procurement: Insights from the CAG Compliance Audit Report
Article - Private Discretionary Trusts and Section 56(2)(x) – Interpreting ‘Solely for the Benefit of Relatives’
Article - Section 153C Satisfaction Note: The Foundational Jurisdictional Principle and Its Persistent Defects
Article - The Role of Adjudication in Indian Tax Tribunals
Article - Section 107 and the Prohibition of Remand: No Second Chances for the Department under GST
Article - Mastering GST Scrutiny: Strategic Handling of Form GST ASMT-10 to Prevent Litigation
Article - Reassessment Notices Issued to Deceased Assessees: Conflicting Approaches in Recent Delhi High Court Rulings on Section 148A
Article - Charitable and Religious Trusts: Interpreting Section 13(1)(b) in Light of the Jamia Osman Bin Affan Education Society Case
Article - GST Implications on 'Buy One Get One' (BOGO) Offers: Free Units, Credit Notes, and Proper Adjustment Strategies
Article - GST and Online Gaming in India: Supreme Court’s New Framework and Its Implications
Article - Comprehensive Overview of the Regulatory Regime for Virtual Power Purchase Agreements (VPPAs) in India
Article - SEBI Proposes New Guidelines for Open Market Share Buybacks: A Comprehensive Overview
Article - Directors’ Responsibility Statement (DRS) under Section 134(5): The Need for a Structured Board Assurance Protocol
Article - Elevated Status of Compliance Officer and Company Secretary: Accountability in Cases of Non-Compliance
Article - Section 50CA and Bona Fide Transfers of Unquoted Shares: Applicability and Interpretation
Article - Distinguishing Revenue Sharing and Profit Sharing in AOPs: Taxability of Members’ Income in Light of Sanand Properties Case
Article - GST Implications on Corporate Guarantees: Key Developments and Practical Guidance after D.P. Jain & Co. Infrastructure Pvt. Ltd. v. Union of India
Article - GST on Online Gaming in India: A Comprehensive Legal and Economic Overhaul
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