Digi - Legal Insights

Impugned order declaring Petitioner liable for reassessment concerning a property purchase of Rs. 83,87,386 was deemed outside jurisdiction and set aside.

Assessing Officer, CIT (Appeals), and ITAT correctly determined that subsidy in question is a revenue receipt provided after establishment of an industrial unit and commencement of production.

Omission of a statutory rule without a saving clause obliterates it completely, and restrictions under the omitted rule cannot be kept alive for pending proceedings.

Goods sold in powder form remain classified accordingly at taxable event, thus not qualifying as beverages for tax purposes.

A final settlement order passed by Income Tax Settlement Commission precludes Assessing Officer from initiating reassessment proceedings.

Delayed payment of Foreign Travel Tax cannot be equated with absolute failure to pay, and imposition of penalty is not automatic but requires judicious exercise of discretion.

Petitioner, having the statutory right to receive refund of ₹3,14,58,422 along with interest after demand was set aside, same cannot be denied this by Respondent No.3 hence, impugned order is set aside and application for refund to extent of Rs.3,14,58,422/- Crores be processed expeditiously.

Assessee must maintain application filed under Section 245C, while Revenue can oppose continuation based on new findings and settlement serves as a compromise, allowing Revenue to collect tax on undisclosed income while Assessee avoids penalties.

Interest payable on refund was applicable from three months after application filed on 20th May 2015, not from favorable order by Appellate Tribunal dated 8th December 2025 hence, Respondent No. 3 is directed to refund an amount of Rs.53,05,173/- along with statutory interest to Petitioner.

Demand-cum-Show Cause Notice issued on 19.12.2012 is barred by limitation as it was raised nearly two years after the relevant transaction.

In accordance with Section 26(6A)(c) of Act, statutory pre-deposits for appeals, amounting to 10% of disputed tax, are extinguished by NCLT-approved Resolution Plan.

Non-residents are liable for tax on income deemed to arise in India, regardless of a permanent office.

Revenue and Tribunal misinterpreted these contracts, as they are not generally understood to fall under category of event management, which implies overall management and organization of events.

Mere mention of suppression does not suffice to justify an extended limitation period hence, SCN is deemed unsustainable, along with consequential order.

Tribunal addressed taxability issue in impugned judgment, identifying referral charges from HDFC Bank, ICICI Bank, and Oriental Insurance Company as Business Auxiliary Services hence, despite income not being disclosed in service tax returns, penalty imposed was set aside by Tribunal, along with penalty under Section 78.

Petitioner acted bona fide, paying taxes and interest and resolving outstanding amounts prior to filing of Complaint hence, impugned Order and pending criminal case are quashed and set aside.

Mere assembly or kitting of imported components to meet customer specifications without bringing a new, distinct commercial commodity into existence does not amount to manufacture under the Central Excise Act.

Assessee is entitled to seek deduction of amount of interest paid in respect of capital borrowed to tune of Rs.3,80,00,000/- for purposes of business.

Karnataka Act No. 5 of 2001, which retroactively modified exemption for imported sugar under Karnataka Sales Tax Act, is constitutionally valid and within state legislative competence.

Respondent-Department failed to satisfy specific condition, resulting in illegal seizure of INR 1 crore from Petitioner, who has proven ownership of cash and it, also did not provide adequate reasoning or documentation to justify seizure, making it unauthorized under CGST Act.