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ITAT : Ahmedabad ITAT Upholds Denial of TDS Credit to Commission Agent under Section 194Q Due to PAN Mismatch; TDS Rightly Attributable to Actual Sellers (Farmers)

SC : Supreme Court Bars Amalgamated Companies from Setting Off Accumulated Losses of Amalgamating Entities Under Kerala Agricultural Income Tax Act, Citing Procedural Lapses

HC : Delhi High Court Upholds Reassessment Notice under Section 148 Issued Within Limitation Despite Procedural Corrections

ITAT : Mumbai ITAT Rules Interest on Fixed Deposits for Bank Guarantee Must Be Capitalized as Work-in-Progress Where FDs Are Mandatorily Linked to Slum Redevelopment Project

ITAT : Rajkot ITAT Affirms Exemption of Income from Modern Agricultural Activities on Leased Land: Seed Production Held as Agricultural Income Despite Technological Advancements

ITAT : Mumbai ITAT Upholds Section 11 Exemption for Charitable Hospital; Incidental Benefits to Directors Not Sufficient for Full Denial of Tax Relief

ITAT : Rajkot ITAT Nullifies Addition for Alleged On-Money Based Solely on Third-Party Excel Sheet Lacking Direct Link and Cross-Examination Opportunity

ITAT : ITAT Chennai Quashes Penalty for Concealment Where Income Was Voluntarily Disclosed in Return Filed Pursuant to Section 148 Notice

HC : Bombay High Court Invalidates Notices under Section 153C for Inordinate Delay in Recording Satisfaction Post Search Assessment

HC : Gujarat High Court Validates Assessee’s Switch to WDV Depreciation via Revised Return, Emphasizes Taxpayer’s Bona Fide Choice under Rule 5(1A)

PBPTAT - Benami Nature of Transactions Upheld by SAFEMA Tribunal: Disclosure of Income Not a Shield Against Attachment Orders

ITAT : Delhi ITAT Nullifies Assessment: Notice under Section 143(2) Issued by Incompetent AO Renders Proceedings Void

ITAT : Reassessment Quashed by Delhi ITAT for Lack of Independent Inquiry and Procedural Lapses; Section 147 Invoked Instead of Proper Section 153C in Case Based on Investigation Wing Report

ITAT : ITAT Bangalore Grants Section 80P Deduction on Interest from Cooperative Bank Deposits; Follows Supreme Court and Jurisdictional High Court Precedents

ITAT : Tax Deducted at Source (TDS) Credit Cannot Be Denied Solely Due to Mismatch in Timing of Revenue Recognition and TDS Deduction, Subject to Factual Verification

ITAT : Hyderabad ITAT Nullifies Penalty Under Section 271(1)(c) Due to Fundamental Defect in Show Cause Notice and Penalty Initiation

ITAT : Delhi ITAT Asserts No Addition for Bona Fide Disclosure Error: Charitable Society’s Foreign Contribution Misclassification Deemed Procedural, Not Substantive Lapse

ITAT : Delhi High Court Rules Interest from Temporary Parking of Project Funds as Capital Receipt: Not Taxable as Income from Other Sources

HC : Bombay High Court Upholds Substantive Right to Concessional Tax under Section 115BAA; Condonation Granted for 13-Day Delay in Filing Form 10-IC Due to Chairman’s Demise

ITAT : ITAT Ahmedabad Rules Co-operative Bank Under Liquidation Remains Taxable Entity; Bad Debts Write-Off Allowed as per CBDT Circular

ITAT : Mumbai ITAT Reaffirms Section 11 Exemption for Trust’s Rental and Ancillary Income, Citing Predominant Charitable Purpose

ITAT : Status Change from AOP/BOI to Co-operative Society Beyond Scope of Section 143(1) Adjustments

ITAT : Ahmedabad ITAT Remands Dividend TDS Matter: Opportunity Granted to Furnish Relevant Form 10F and TRC for DTAA Benefit under India-Mauritius Treaty

HC : Madras High Court Orders Reconsideration in India Cements Case: Advances to Subsidiaries and Bad Debt Write-off to be Re-examined by CIT(A) After Procedural and Legal Lapses

HC : Madras High Court Reaffirms CIT’s Plenary Power under Section 263 for Erroneous Assessments, Block Assessment Income Disclosure After Search Not a Shield for Assessee

HC : Bombay High Court Upholds ITAT’s Quashing of Section 263 Revision: Assessee’s Project Completion Method Vindicated After Detailed AO Verification

HC : Gujarat High Court Upholds Exclusion of Search-Based Assessments from DTVsV Scheme, Despite Clarificatory Circulars

HC : Delhi High Court Rules Accommodation Entry Providers Not Taxable on Unexplained Credits; Tax Liability Rests with Beneficiaries—Section 68 Invoked Only on Real Recipients

HC : Delhi High Court Quashes TDS Demand Order as Barred by Limitation under Section 201(3) Despite Prior Writ in Assessee’s Case Involving EDC Payments to HUDA

HC : Delhi High Court Upholds Validity of Reassessment Notice under Section 148A in Absence of Proof of Goods Movement for Purchases Worth Rs. 52.68 Lakhs

HC : Punjab & Haryana High Court Nullifies Show Cause Notice Under Section 73 for Lack of Concrete Details and Specific Allegations on ITC Discrepancies

HC : Bombay High Court Allows Fresh Refund Application for Time-Barred Excise Rebate under GST Transitional Provisions

HC : Bombay High Court Nullifies GST Registration Cancellation for Lack of Reasoned Order; Directs Fresh Adjudication with Proper Examination of ITC Claims

HC : Orissa High Court Quashes GST Demand, Interest, and Penalty for Reversed ITC on Alleged Bogus Supplier, Citing Lack of Independent Inquiry and Double Taxation

HC : Rajasthan High Court Upholds Denial of GST Registration in Rajasthan Due to Non-Filing of Returns in Tamil Nadu: Parallel Compliance Obligations Reaffirmed for Multi-State Registrants

HC : Bombay High Court Quashes Arbitrary Bank Account Attachment Under GST, Citing Non-Compliance with Provisions and Supreme Court Guidelines

HC : Bombay High Court Quashes Arbitrary Bank Account Attachment Under GST, Citing Non-Compliance with Provisions and Supreme Court Guidelines

HC : Jharkhand High Court Declines Blanket GST Immunity for Local Bodies, Directs Them to Exhaust Statutory Appeals

AAR : Contribution of Developed Leasehold Land and Hotel Project to LLP for Partnership Interest Constitutes Taxable Supply of Service under GST

AAR : Karnataka AAR Rules GST Not Applicable on Bank Rebates for Excise Duty Payments via Corporate Card in Liquor Manufacturing Sector

HC : Bombay High Court Quashes State’s Provisional Bank Account Attachment for Parallel Proceedings in GST Fraud Case; Reaffirms Primacy of Central Authority under Section 6(2)(b) of CGST Act

HC : Madras HC Orders Reconsideration of GST Amnesty Waiver Application; Human Error in Penalty Allocation Not a Bar to Merits-Based Review

HC : Madras High Court Overturns ₹159.85 Crore GST Demand on City Union Bank, Orders Reassessment After Exempt Supply Mismatch and Double Taxation Allegations

HC : Gujarat High Court Quashes GST Demand for Failure to Grant Statutory Personal Hearing Despite Assessee’s “No” Selection in SCN Reply

HC : Madhya Pradesh High Court Denies Writ Relief to Construction Contractor for Non-Participation in GST Proceedings, Reaffirms Need for Exhaustion of Statutory Remedies

AAR : Maharashtra AAR Rules "Pooja Oil" Blended for Ritual Use as Inedible, Classifies Under CH 1518 for 5% GST Due to Intended Non-Edible Application

AAR : Karnataka AAR Affirms GST on Villas Built Under Joint Development Agreements Even if Construction is Outsourced; Land Value Statutorily Capped at One-Third

GSTATDEL : GSTAT Delhi Orders Seamless Digital Transfer of Appeal to State Bench, Emphasizes Registry’s Duty to Facilitate Justice

AAR : Karnataka AAR Determines GST Classification of Biodiesel-HSD Blends by Petroleum Content, Distinct Tariff for Each Blend Ratio

AAR : Karnataka AAR: Margin Scheme for GST on Second-Hand Cars Subject to Factual Proof—Benefit Denied for Lack of Documentary Evidence

HC : Bombay High Court Rules Against Consolidated GST Show Cause Notices Across Multiple Years; Mandates Year-wise Notices for Alleged Fraudulent ITC Availment

AAR : Tamil Nadu AAAR Confirms ITC Block on Lease Assignment for Construction of Non-Qualifying Manufacturing Facility

AAR : Gujarat AAAR Affirms Technical Textile Classification for HDPE Geomembranes, Rejects Revenue’s Reliance on Raj Packwell and Similar Rulings

GSTATDEL : GSTAT Delhi Affirms No Profiteering in Sobha Limited’s International City Project: Full Transaction in Post-GST Era Excludes Section 171 Liability

HC : Karnataka High Court Rules B2B E-Commerce Operators Not Liable for TCS Deduction under Section 52 When Not Collecting Consideration

AAR : Gujarat AAR Decides ITC Availability on RCC Foundations and Structural Supports Integral to Plant & Machinery for API Manufacturing

AAR : Gujarat AAR Affirms ITC Eligibility for Foundation and Structural Supports of Process Equipment Under Section 17(5)(c) CGST Act

AAR : Gujarat AAR Clarifies GST Exemption for NSDC-Affiliated Digital Marketing Training Partners, Addresses Exemption Gap Period and Tax Regularisation

CESTAT : CESTAT Allahabad Confirms Non-Taxability of Construction Services Rendered to Educational and Charitable Institutions; Residential Housing for Weaker Sections Held Outside Service Tax Net

CESTAT : Delhi CESTAT Classifies Transformation of Bare Structures into Commercial Showrooms as ‘Original Works’; Quashes Service Tax Demand Beyond Normal Period, Allows Partial CENVAT Credit Reversal

Tribunal Affirms FEMA Violations in Hawala Case: Retracted Statements Upheld with Reduced Penalties Due to Hardship and Evidence Corroboration - The decision affirms that retracted statements are not automatically excluded from consideration in FEMA proceedings. Such statements can form the basis of liability if the voluntariness is not disproved and they are corroborated by independent evidence. The Tribunal partially allowed the appeals solely on the aspect of penalty, reducing the quantum in consideration of financial and humanitarian circumstances, while fully upholding the finding of contravention under Section 3(b) and 3(c) of FEMA.

Income tax – Sections 144C, 153 - Delhi ITAT Quashes Assessment Orders for Breach of Limitation: Non-Obstante Clause in Section 144C(13) Restricts AO to One-Month Period Despite Section 153 - In light of the above findings, the ITAT Delhi categorically held that the final assessment orders passed beyond the stipulated period under section 144C(13) read with section 153 of the Income Tax Act are barred by limitation and therefore liable to be quashed. The Tribunal’s decision is actionable in that it directs AOs to strictly comply with the one-month time limit post-DRP directions, irrespective of any broader timeframes otherwise available under section 153.

Income Tax - Sections 234A, 234B, 234C - ITAT Delhi Rules Stock Derivatives Gains of Mauritius FPI Not Taxable in India under Article 13(4) of India-Mauritius DTAA: AO’s Equivalence with Shares Rejected - The Tribunal decisively held that stock derivatives are not equivalent to shares for the purpose of Article 13(3A) of the India-Mauritius DTAA. Therefore, gains from such derivatives are taxable only in the jurisdiction of the taxpayer’s residence, i.e., Mauritius, under Article 13(4). The addition made by the AO was deleted, and the appeal was partly allowed, with the issue of levy of interest left open as consequential.

Income tax – Sections 14A, 263 - ITAT Upholds PCIT’s Section 263 Revision: AO’s Failure to Inquire on Rule 8D Disallowance for Strategic Investments and Accommodation Entries Renders Assessment Order Erroneous - On the facts and in law, the ITAT confirmed that where the AO fails to properly scrutinize the computation of disallowance under section 14A read with Rule 8D—specifically in relation to strategic investments—and fails to investigate credible information of accommodation entries linked to the assessee, such an assessment order is both erroneous and prejudicial to the Revenue. Accordingly, invocation of section 263 by the PCIT to direct further inquiries is fully justified and valid in law. Assessees must ensure that the AO’s acceptance of their submissions is supported by demonstrable inquiry and verification in line with binding judicial precedents.

Income tax – Sections 144C, 153 - ITAT Hyderabad Quashes Assessment Order Passed Beyond Statutory Limitation Despite DRP Proceedings Involving Section 144C(13) - The ITAT Hyderabad has conclusively held that the time limits prescribed under Section 153 for completing assessments are mandatory and cannot be overridden or extended by the procedural timelines in Section 144C(13), even where DRP proceedings are involved. The non-obstante clause in Section 144C(13) is only applicable to the interval between DRP directions and the AO’s final order, not to the overall limitation period. Consequently, any assessment order passed beyond the extended time limit under Section 153(4) is barred by limitation and must be quashed.

Income tax – Sections 144C, 153 - ITAT Hyderabad Declares Final Assessment Order Time-Barred: Section 153 Prevails Over Section 144C(13) Non-Obstante Clause in DRP Cases - In light of the Tribunal’s findings, it is now clear that, where assessment is made pursuant to DRP proceedings for an "eligible assessee," the outer time limit set by Section 153(1) read with Section 153(4) of the Income Tax Act remains applicable. Section 144C(13) merely requires expeditious action by the Assessing Officer post-DRP, but does not extend or override the general limitation. Any final assessment order issued beyond the time prescribed under Section 153 is invalid, even if it is within one month of DRP directions.

Income tax – Sections 148A, 149 - ITAT Bangalore Quashes Reassessment for AY 2015-16: Notice under Section 148 Held Invalid Due to Expiry of Limitation, Regardless of Procedural Compliance - The ITAT Bangalore decisively held that a reassessment notice issued under Section 148 for AY 2015-16 after March 31, 2022, is invalid and barred by limitation as per the first proviso to Section 149(1), even if procedures under Section 148A are followed or if the Revenue seeks to exclude time under other provisos. The extended limitation under Section 149(1)(b) cannot be invoked unless the escaped income in the form of assets actually meets or exceeds the Rs. 50 lakh threshold, supported by clear evidence at the time of issuance of notice. This is a fundamental jurisdictional defect that cannot be remedied by subsequent procedural compliance.

Income tax – Sections 144C, 153 - ITAT Delhi Rules Final Assessment Orders Invalid for Breach of Limitation—Non-Obstante Clause in Section 144C(13) Does Not Override Section 153 - Based on the above, the ITAT concluded that the limitation period for passing a final assessment order under Section 144C(13) must be ascertained through a combined and harmonious reading of Section 144C and Section 153. The non-obstante clause in Section 144C(13) does not entirely override Section 153; rather, it enforces a more stringent deadline on the Assessing Officer. Any assessment order issued after expiry of the limitation period, as calculated under both sections, is without authority and is liable to be set aside.

Income tax – Sections 144B, 144C - ITAT Delhi Declares Final Assessment Order Void for Being Time-Barred: Section 153’s Outer Limit Prevails Over Section 144C Non-Obstante Clause - The ITAT Delhi has decisively held that the statutory time limit under Section 153 for passing a final assessment order is sacrosanct, even when the provisions of Section 144C relating to DRP proceedings are in play. The non-obstante clause in Section 144C(13) does not override or extend the limitation period prescribed by Section 153. Any final assessment order passed beyond this period stands void and unenforceable in law.

Income Tax - Sections 143(1), 154 - ITAT Delhi Permits Additional Evidence, Directs AO to Reconsider TDS Credit Denial Due to Technical Lapse in AY 2020-21 for Swiss Company - The ITAT’s decision establishes that assessees should not be penalized for bona fide, technical lapses in procedural compliance when there is no mala fide intent. The Tribunal’s directive to allow submission of additional evidence and remand the matter to the AO for verification ensures that substantive justice prevails over mere procedural technicalities. Assessees facing denial of TDS credit due to documentary mismatches or technical errors should proactively seek to submit necessary evidence at the earliest opportunity and may rely on this precedent for relief.

Tribunal Upholds Vicarious Liability of Managing Director for FEMA Contravention; Exonerates Sleeping Directors and Reduces Penalty to Extent of Pre-Deposit - The Tribunal’s decision partially allowed the appeals of M/s. Vipin Print Services Pvt. Ltd. and its Managing Director by reducing their penalty obligation to the amount of pre-deposit already made with accrued interest. The appeals filed by Janak Khajuria and Varun Khajuria were allowed in toto, resulting in their complete exoneration from the alleged violations. This outcome underscores the necessity for companies to clearly demarcate the roles and responsibilities of their directors, as liability under FEMA will hinge on actual participation and control over the company’s affairs.

Income tax – Sections 144C, 153 - ITAT Delhi Bars Final Assessments Passed Beyond Limitation Period Under Section 144C(13) r/w Section 153: Reliance on Madras HC Roca Bathroom Products Precedent - Based on the Tribunal’s findings, it is actionable and prudent for eligible assessees to closely monitor the date of receipt of DRP directions and ensure that the final assessment order is passed by the AO within one month from the end of the month of receipt, as mandated by section 144C(13). Any final order issued beyond this period stands exposed to being quashed as time barred, in line with the binding precedent of the Madras High Court in Roca Bathroom Products (P) Ltd., unless and until the Supreme Court expressly overrules this position.

Income Tax - Sections 40(a)(ia), 147, 263 - ITAT Delhi Quashes PCIT’s Revision—Disallowance on Foreign Payments Must Align with India-USA DTAA Non-Discrimination Clause - In light of the above, the ITAT Delhi held that the AO’s order, though containing a computational anomaly, was not prejudicial to the interests of the Revenue since it adhered to the non-discrimination clause of Article 26(3) of the India-USA DTAA. The Tribunal quashed the PCIT’s revisionary order under section 263, establishing that differential treatment in quantum of disallowance for payments to non-residents, as compared to residents, is impermissible in cases covered by the DTAA.

Income tax – Sections 144C - ITAT Delhi Quashes Final Assessment Orders for Exceeding Limitation Period under Section 144C(13) Read with Section 153 in Camfil India and Toshiba India Cases - The ITAT Delhi has reaffirmed that the final assessment orders passed beyond the stipulated period under Section 144C(13) read with Section 153 are invalid and must be set aside. The Tribunal’s decision underscores that both provisions are to be read harmoniously and the shorter limitation period under Section 144C(13) prevails, restricting the Assessing Officer’s time frame for passing the final order. The absence of a Supreme Court stay against the Madras High Court’s Roca Bathroom Products judgment solidifies its binding nature, allowing the ITAT to quash the impugned assessment orders as time-barred.

Income Tax - Sections 90, 91, 139(1), 143(1) - ITAT Pune Rules Delay in Filing Form 67 is Not Fatal to Foreign Tax Credit Claim for Indian Resident Taxpayer on German Income - In light of the ITAT Pune’s decision, it is clear that a delay in filing Form 67 for FTC purposes is not fatal to the taxpayer’s substantive right to claim credit for foreign taxes paid, provided all other conditions are met and the claim is otherwise valid under the Income Tax Act and DTAA. Taxpayers facing similar disallowances due to delayed Form 67 can seek relief by demonstrating bona fide compliance and reliance on settled judicial precedents.

Income tax – Sections 144C, 153 - ITAT Delhi Quashes Final Assessment Order Passed Beyond Limitation Period: Section 153 Applies to Section 144C(13) Orders - The ITAT Delhi’s decision establishes that final assessment orders under Section 143(3) read with Section 144C(13) must adhere strictly to the time limits prescribed in Section 153. The non-obstante clause in Section 144C(13) is limited in scope and does not override the statutory period of limitation. Where a High Court’s decision on a legal issue remains unstayed and uncontradicted, it continues to bind lower authorities and Tribunals. Accordingly, any final assessment order passed beyond the statutory deadline is liable to be quashed as time-barred, providing clear guidance for both assessees and tax authorities.

Delhi ITAT Invalidates TP Adjustment Using Bright Line Test for AMP Expenses in Bose Subsidiary Case: High Gross Margins Subsumed AMP Compensation - The ITAT’s decision makes it clear that the Bright Line Test cannot be the basis for determining either the existence of an international transaction or the arm’s length price for AMP expenses. Without tangible evidence of an agreement or understanding for brand promotion, high AMP expenditure alone does not give rise to an international transaction between a distributor and its AE. Further, where the distributor’s gross margins are demonstrably higher than those of comparable companies, it is presumed that the distributor is fully compensated for its AMP functions, obviating the need for any separate TP adjustment.

Income Tax - Sections 92CC, 92CD, 144C & 154, 244A - ITAT Mumbai Directs Correction of Typographical Error in Assessment Arising from Unilateral APA; Upholds Binding Nature of APA and Modified Return Under Section 92CD - In conclusion, the Tribunal directed the AO to rectify the typographical error in the rectification order under section 154 by correctly reflecting the income offered under the modified return filed pursuant to the APA. The AO must ensure that the DRP’s directions regarding the binding effect of the APA and the consideration of the modified return are faithfully executed. The Tribunal also held that the computation of tax, interest under section 244A, and grant of tax credits must be aligned with the final, correct figures as per the modified return under section 92CD.

Income tax – Section 92F - ITAT Delhi Quashes Transfer Pricing Adjustment on Commission Income: Controlled vs. Controlled Transaction Benchmarking Held Invalid - The ITAT Delhi concluded that the adjustment made by the TPO to the commission paid by benchmarking it with the commission received from another Associated Enterprise is not sustainable in law. The addition was deleted, and the Tribunal directed the Assessing Officer to verify and apply the correct legal procedure for consequential interest. Assessees must ensure that benchmarking for transfer pricing purposes is done only with reference to comparable uncontrolled transactions, as required by Section 92F(ii) of the Income-tax Act.

Income Tax - Sections 80IA, 92C - ITAT Ahmedabad Upholds Taxpayer’s Royalty Payments and Section 80IA Deduction Despite Revenue’s NIL ALP Adjustment and Typographical Error in Agreement - In light of the above findings, the ITAT Ahmedabad affirmed the CIT(A)’s deletion of the royalty adjustment and the disallowance under section 80IA(4). The Tribunal’s order underscores that the TPO/AO must apply prescribed methods and provide cogent reasons when making ALP adjustments or denying deductions. Mere conjecture or procedural errors, unsupported by substantive evidence, cannot form the basis of adverse tax adjustments.

NCLAT Overturns Oppression and Mismanagement Claims: Participation and Consent by Substituted Petitioner Bar Relief against Share Allotment and Related Transactions - The Appellate Tribunal conclusively held that Respondent No. 1, having consented to and participated in the impugned transactions, and having failed to amend the pleadings or assert its own case as an aggrieved member, could not maintain allegations of oppression and mismanagement against the company. The Tribunal reversed the findings of illegality relating to share allotment at par, absence of valuation, connection of allottees, and the alleged Section 77 breach, along with securities law objections. Relief under Sections 397-398 was accordingly denied, and the impugned order was set aside.

Bombay High Court Upholds CLB’s Discretion in Oppression and Mismanagement Cases Despite Delay; Confirms Special Audit and Rejects Additional Evidence Plea - In summary, the Bombay High Court dismissed both the appeal under Section 10F and the application for additional evidence. The Court affirmed the CLB’s findings on continuous oppression and mismanagement, rejected pleas of limitation, and validated the appointment of a special auditor. The judgment reinforces the principle that ongoing acts of oppression are not protected by delay or laches, that the CLB is empowered to examine issues of fraud when evident from the record, and that attempts to introduce additional evidence without due diligence and clean hands will not be entertained.

NCLAT Upholds NCLT’s Interim Status Quo in Director Removal Dispute; No Grounds Found for Appellate Intervention - The NCLAT declined to intervene in the NCLT’s interim arrangement, holding that such orders serve the essential function of preserving the status quo and protecting the subject matter of the dispute until a final determination is reached. The Tribunal found no manifest error or perversity in the exercise of the NCLT’s discretion and, accordingly, allowed the interim order to stand with the previously modified directions concerning the operation of the bank accounts.

SAT Upholds SEBI’s Stand: No Mandate to Disclose Internal Tax Reports in IPO Amid Informed Oversubscription - The SAT concluded that, in the absence of any statutory notice, reassessment proceedings, or tax demand, there was no requirement under Clause 12(A)(1) of the ICDR Regulations to disclose internal Income Tax reports. SEBI had not erred in its regulatory oversight, as the issuer made all relevant disclosures regarding the complaints raised. Since the IPO was heavily oversubscribed after these disclosures, suggesting that investors (including institutional ones) had made informed decisions, no interference with the IPO process was warranted.

NCLAT Chennai Refuses to Condon Delay of 471 Days in Refiling Appeal: Appellants’ Medical Grounds Deemed Insufficient Without Substantiating Evidence - In light of the above findings, the NCLAT, Chennai, categorically declined to condone the 471-day delay in refiling the appeal. The Tribunal held that unsupported and unsubstantiated medical grounds, especially in the absence of proper documentary evidence, do not suffice to justify such an extraordinary delay. As a result, the interlocutory application was rejected, and the company appeal stood dismissed.

Supreme Court Grants Statutory Bail for Prolonged Pre-trial Detention in Financial Fraud Case Involving Extended Judicial Custody and Delay in Framing of Charges - The Supreme Court’s decision underscores that where an accused has been subjected to prolonged incarceration—particularly exceeding one-third of the maximum prescribed sentence—and where trial delays are substantial, the statutory entitlement to bail under Section 479 of the BNSS must be accorded. This is especially so where the accused is a first-time offender, assets are attached to secure alleged losses, and parity with other accused favors release. The actionable outcome is that the appellant’s continued detention was unwarranted, and he is to be released on bail upon fulfillment of conditions set by the Trial Court.

NCLAT Sets Aside NCLT Order: Fresh Scrutiny Mandated on ‘Place of Business’ and ‘Foreign Company’ Status Under Companies Act, 2013 - The NCLAT’s decision underscores that the determination of a company’s status as a ‘foreign company’ under Section 2(42) of the Companies Act, 2013, is a jurisdictional fact that must be thoroughly examined based on evidence. The appellate decision directs the NCLT to conduct a fresh inquiry, considering all documentation and arguments from both parties, before deciding on the maintainability of the petition. The matter is thus remanded for de novo adjudication on the foundational issue of ‘place of business’ and ‘business activity’ in India.

SAT Mumbai Reduces Enhanced SEBI Penalties for Alleged Price Manipulation in Ponni Sugars (Erode) Ltd. Scrip Due to Lack of New Evidence - The SAT’s decision underscores that while the appellants’ trading conduct was found to be in violation of Regulations 3 and 4 of the PFUTP Regulations, any enhancement of penalty post-remand must be underpinned by new facts, evidence, or reasoning. In the absence of such, the AO’s action was held to be legally untenable. The penalties were thus reduced to Rs. 5 lakh (Pat) and Rs. 7.5 lakh (Gandiv), providing a clear actionable precedent that penalty enhancement on remand requires a substantive basis distinct from the original findings.

NCLAT Quashes Tribunal-Ordered Probe into Company Affairs for Lack of Recorded Reasons and Overlooking Locus Standi Requirement - Based on the above findings, the NCLAT allowed the appeal and quashed the order directing investigation under Section 213(b) of the Companies Act, 2013. The matter has been remanded to the NCLT for a fresh determination, with explicit instructions to first adjudicate the applicant's locus standi before considering the application on its merits. This decision reinforces the necessity for Tribunals to strictly adhere to statutory requirements of reasoned satisfaction and proper adjudication of preliminary objections.

Section 185 of the Companies Act, 2013 - Supreme Court Cancels Bail and Orders Forfeiture of ₹50 Crores for Director’s Misuse of Company Funds in Violation of Companies Act and IBC Provisions - The Supreme Court’s order decisively establishes that directors cannot utilize company funds or funds from related entities to satisfy personal obligations, such as bail conditions, without adhering to statutory procedures under Section 185 of the Companies Act, 2013. Transactions in violation of these provisions remain open to challenge under Sections 49 and 66 of the IBC even after the expiry of the look-back period, especially where the misuse of company assets is clear and ongoing in the context of insolvency proceedings. Further, non-compliance with bail conditions—especially those aimed at protecting stakeholder interests—will result in the cancellation of bail and forfeiture of the entire security deposit.

Sections 178, 454 of the Companies Act, 2013 - High Court Upholds Penalty for Non-Compliance in Board Committee Constitution: Subsequent Rectification Does Not Excuse Prior Breach under Companies Act - The Rajasthan High Court’s judgment clarifies that subsequent compliance with statutory requirements cannot absolve an entity from liability for prior violations, especially where the breach is admitted and pertains to the composition of mandatory board committees under the Companies Act, 2013. The imposition of penalty by the Registrar and its affirmation by the Regional Director were found to be legally sustainable, as the statutory violation was neither cured for the relevant period nor was the penalty shown to be disproportionate or based on irrelevant considerations. Companies must, therefore, ensure ongoing compliance with governance mandates, as post-facto rectification will not shield them from consequences of earlier lapses.

Telangana High Court Mandates Proportionate Reserve for Secured Creditors and Due Process before Recovery of Excess Interim Dividend in Liquidation - The Telangana High Court’s decision mandates strict compliance with due process before recovering excess interim disbursements from secured creditors in liquidation. The OL must issue notice and provide a hearing before seeking refund and interest from any creditor. Furthermore, reserves for belated secured creditors must be proportionate, consistent with the amounts paid to timely claimants, and not for the entire claim amount unless condonation for delay is obtained. This ensures parity and fairness in distribution among all similarly-situated creditors.

NCLAT Chennai Directs Reconsideration of Struck-Off Company’s Restoration: Improper Assessment of Business Operations and Material Documents under Section 252(3) of Companies Act, 2013 - On a detailed review, the Appellate Tribunal invalidated the order refusing restoration of the company’s name, holding that the lower authority had misapprehended the factual and legal context and failed to properly appreciate the documentary evidence. The Tribunal’s direction to re-examine all pertinent materials and re-adjudicate the application reflects the correct application of Section 252(3), emphasizing the need for a reasoned approach to restoration of companies struck off under the Companies Act, 2013.

Partial Relief Granted by SAT: SEBI Penalties on Board Composition and Annual Report Non-Compliance Set Aside Where No Time Limit Existed or COVID Extensions Applied - The SAT’s order provides actionable clarity: listed companies cannot be penalized for board composition non-compliance for periods before the introduction of a specific compliance timeline by SEBI in 2023. Further, where statutory or regulatory extensions (such as those issued during the COVID-19 pandemic) cover the period of delay, fines for such non-compliance cannot be sustained. However, admitted delays where neither extension nor relaxation applies (such as secretarial compliance reports and delayed related party transaction disclosures) will continue to attract penalties.

Sections 430, 241, 242, of the Companies Act, 2013 - Calcutta High Court Upholds Maintainability of Suit for Partition and Declaration Against Family Companies; Rejects Application for Summary Rejection Under Order VII Rule 11 - The Calcutta High Court concluded that the plaint disclosed a substantial cause of action for partition and declaration of rights over ancestral properties, in addition to company-related claims. The issues of limitation and jurisdiction raised by the defendants involved factual disputes requiring trial and could not be adjudicated summarily at the stage of Order VII Rule 11. Consequently, the application for rejection of the plaint was dismissed, and the plaintiff was allowed to proceed with his suit.

NCLAT Affirms Beneficial Ownership and Upholds Non-Compete Obligation on Auctioned Shares in Hydropower JV: Flovel’s Membership Linked to Compliance with Shareholder Agreements - The Tribunal confirmed Flovel’s locus standi to maintain proceedings under Sections 241–242 and Section 59, rejected technical objections to the EOGM notice, and clarified that registration of Flovel’s shareholding must be inseparably linked to the obligations attached to those shares, specifically the non-compete clause in the JVSPA. Flovel must be admitted as a shareholder, but only upon executing the non-compete undertaking; until then, the non-compete obligation is statutorily binding by virtue of the Appellate Tribunal’s order.

Supreme Court Upholds Delhi High Court Ruling, Condoning Delay and Declining Interference in Tax Litigation - The Supreme Court’s decision reinforces that condonation of delay is a discretionary relief and does not guarantee success on the merits of the case. While courts may be liberal in condoning delays upon satisfactory explanation, such condonation does not prejudice the substantive scrutiny of the case. Once the apex court finds no substantial question of law or manifest injustice, it declines to interfere with the lower court’s order.

NCLAT Chennai Quashes Cost Imposition on Litigant for Counsel’s Lapse; Upholds Principle Against Penalizing Parties for Advocate’s Negligence - In light of the findings, the NCLAT allowed the appeal in part, specifically to the extent of setting aside the imposition of costs against the appellant. The Tribunal directed that the main company petition be taken up for hearing and disposed of expeditiously. All pending interlocutory applications were ordered to be closed. The actionable takeaway is that parties must monitor their counsel’s conduct but, in the event of counsel’s lapse, may seek protection from adverse cost orders if there is no evidence of personal dereliction.

NCLAT Chennai Clarifies: Section 420 of Companies Act Does Not Permit Review or Recall of Orders on Merits by Parties - The NCLAT, Chennai, has categorically stated that Section 420 of the Companies Act, 2013, enables the Tribunal to correct only those mistakes which are patent and apparent from the record, and not to recall or review orders on their merits. Applications by parties seeking reconsideration of the merits of an order under the garb of rectification are not maintainable. The appeal was therefore dismissed, reinforcing the limited scope of Section 420.

Sections 241, 242 of the Companies Act, 2013 - NCLT Mumbai Orders Buyback of Minority Shares After Uncovering Siphoning of Funds and Lack of Transparency by Controlling Directors - The NCLT Mumbai, after a detailed examination of statutory provisions, audit findings, and the conduct of the respondents, concluded that there was clear oppression and mismanagement within the respondent company. In light of the siphoning of funds, lack of proper disclosure, and absence of Board approvals as mandated by law, the Tribunal exercised its equitable jurisdiction to protect the interests of the minority shareholders. The actionable remedy provided was the compulsory purchase of the petitioners’ shares at the original issue price—a measure that restores the petitioners to their pre-investment position and serves as a deterrent against future breaches of fiduciary duty by company controllers.

Minority Shareholders’ Direct Stake Recognized: Bombay High Court Mandates Their Inclusion in SEBI Settlement Revocation Writs - The Bombay High Court has unequivocally held that minority shareholders, who are directly affected by the outcome of writ petitions challenging SEBI’s revocation of a Settlement Order, must be impleaded as necessary and proper parties. This ensures that their independent rights and interests are adequately protected and adjudicated, rather than being subsumed under the broader regulatory oversight of SEBI. The actionable takeaway is that any stakeholder with a direct and substantial legal interest in SEBI settlement or enforcement proceedings should proactively seek impleadment in relevant judicial proceedings to safeguard their rights.

NCLAT Quashes Tribunal’s Overreaching Observations Made After Withdrawal of Application, Restricts Relief to Pleadings - The NCLAT’s decision makes it clear that, after an application is withdrawn, the Tribunal’s jurisdiction comes to an end with respect to that matter, and no further observations or liberties should be recorded that go beyond the scope of the withdrawal. Any such observations or directions are liable to be quashed as being without jurisdiction and constituting judicial overreach. Parties remain free, however, to pursue any remedies otherwise available to them under law, unaffected by the withdrawn proceedings.

NCLAT Affirms NCLT’s Jurisdiction Over Disputed Company Deposits Pending Probate: Protective Proceedings by Claimant-Beneficiaries Allowed - The NCLAT allowed the appeal and remitted the matter to the NCLT with explicit directions to adjudicate both the interlocutory application and the main company petition on their own merits—specifically regarding the status and protection of the alleged deposit. The pendency of probate proceedings is not a bar to the NCLT’s jurisdiction in these matters. Moreover, claimant-beneficiaries are entitled to pursue proceedings before the NCLT for protective measures over estate assets, pending the final outcome of the probate dispute.

NCLAT Bars Reopening of Approved Scheme: No Fraud Proven, Supreme Court Affirmation Triggers Merger Doctrine - The NCLAT categorically dismissed the appeal seeking to set aside the scheme of arrangement, holding that the alleged incorrect recording did not constitute fraud. The prior affirmation of the scheme by the Supreme Court resulted in the merger of the Tribunal’s order into that of the Supreme Court, thereby foreclosing any further review or reopening of the scheme’s merits by the Tribunal. The decision is actionable in that parties cannot re-agitate matters already affirmed by the Supreme Court except on a clear and substantiated case of fraud, which must meet a high evidentiary threshold.

Calcutta High Court Asserts Company Court's Post-Winding Up Jurisdiction Despite Delay and Alleged Fraud by Special Officer – Refuses Interim Stay - In sum, the Calcutta High Court held that, prima facie, the Company Court retains the jurisdiction to scrutinize post-winding up arrangements and allegations of fraud, even after management control has shifted from the Official Liquidator. The Court refused to grant an ad-interim stay, holding that limitation is a mixed question of law and fact in the context of continuing fraud, and that no circumstances warranted a change from earlier interim orders.

Appellate Tribunal Reinstates Composite Scheme: Separate Demerger Application Unwarranted, Commercial Wisdom Upheld - The Appellate Tribunal's decision reinstates the composite character of the scheme, affirming that a demerger, as part of a composite arrangement with amalgamation, does not require independent sanction through a separate application under Sections 230 to 232 of the Companies Act, 2013. The decision reaffirms judicial deference to the commercial wisdom of stakeholders, provided the scheme meets statutory requirements. Companies are advised to ensure their schemes are drafted with precise identification of all entities and undertakings involved, and to maintain compliance with all statutory dues and procedural requirements, as Tribunal approval does not override such obligations.

NCLAT Upholds Strict Timelines for Fast Track Mergers: Dismisses Time-Barred Objections and Appeal in Scheme of Amalgamation - Based on the Appellate Tribunal's decision, it is clear that statutory limitation periods prescribed under the Companies Act, 2013 for filing objections to fast track mergers and for filing appeals are strict and cannot be relaxed beyond what is expressly permitted by law. Objections or appeals filed beyond these prescribed periods will not be entertained, and there is no scope for discretionary condonation beyond the statutory maximum. Parties must be vigilant in adhering to these timelines to preserve their rights to be heard.

Calcutta High Court Quashes Arbitral Award Against Railways: Supplier Failed to Prove Readiness and Claim Exceeded Tender Terms - Based on a thorough examination of the contract, the evidentiary record, and statutory provisions, the Calcutta High Court concluded that the arbitral award had traversed beyond the terms agreed upon by the parties and contravened explicit contractual bars. Consequently, the award was set aside in its entirety, reaffirming the primacy of contractual terms and the necessity for strict compliance with statutory requirements in arbitration proceedings.

Calcutta High Court Upholds Deputy Registrar’s Authority to Prosecute, But Quashes Criminal Proceedings Against Auditor for Lack of Mens Rea Under Companies Act - Based on the present judgment, it is clear that complaints under Section 439(2) of the Companies Act, 2013, can be validly initiated by a Deputy Registrar, as per the inclusive definition in Section 2(75). The bar of limitation under Section 468 Cr.P.C. will not apply to offences under Section 448 when read with Section 447, given the severity of the prescribed punishment. However, for a prosecution under Section 448 to be sustainable, the complaint must set out clear and specific allegations of deliberate false statements or concealment, with evidence of the requisite mens rea. In the absence of such material, continuation of criminal proceedings will be quashed to prevent abuse of process.

Supreme Court Upholds SEBI’s Approval of WeWork India IPO: Petitioner’s Allegations on Disclosure and Regulatory Compliance Dismissed - The Supreme Court, affirming the High Court’s decision, held that WeWork India’s IPO process complied with all relevant legal and regulatory requirements. SEBI’s approval of the IPO was lawful, as the company had fulfilled the stipulations under the ICDR Regulations and Securities Contracts (Regulation) Rules. The allegations regarding non-disclosure and regulatory non-compliance were found to be baseless. The actionable takeaway for future issuers and intermediaries is the importance of transparent and comprehensive disclosures in offer documents, as well as adherence to prescribed public shareholding thresholds for listing.

CESTAT Allahabad Affirms Refund with Interest for Revenue Deposit, Not Duty, Paid Under Protest: Supreme Court Dismissal of Classification Challenge Decisive - The CESTAT Allahabad’s decision reinforces that amounts paid under protest, especially in situations where the underlying dispute is resolved in favor of the assessee, retain the character of deposits and not duty. The specific finding by the adjudicating authority, if not challenged, attains finality and binds the Department. Refund, along with interest, is thus the rightful consequence, and Departmental attempts to later re-characterize such payments as duty will not be entertained.

CESTAT Delhi Rules in Favour of Assessee: No Rule 6(3) Liability on Non-Excisable Goods When No CENVAT Credit Availed on Inputs - On the basis of the above findings, it is actionable for assessees to ensure that no CENVAT credit is availed on inputs used for non-excisable (or exempted) goods, or on common inputs, unless they wish to undertake the tax liability under Rule 6(3). Where the assessee can demonstrate—preferably by a Chartered Accountant’s certificate—that no such credit has been availed, the liability under Rule 6(3) does not arise, even after the 2015 amendment.

CESTAT Chennai Rules Appropriated Investigation Payments as Duty, Bars Refund Claim on Limitation Grounds under Section 11B - The decision of the CESTAT Chennai affirms that once payments made during investigation are appropriated against a demand established by adjudication, those amounts become duty for all legal purposes. Refund claims for such amounts, when reduced or set aside in appellate proceedings, must be filed within one year from the date of the appellate order as per Explanation (B)(ec) to Section 11B. Any delay beyond this period, irrespective of ongoing departmental appeals or defensive cross-objections, will result in the refund being barred by limitation. Taxpayers must, therefore, monitor appellate outcomes and file refund applications promptly within the prescribed limitation period to avoid loss of substantive rights.

Clandestine Removal Allegation Fails for Lack of Corroborative Evidence and Non-Compliance with Legal Requirements - The Tribunal unequivocally held that in the absence of legally admissible and corroborative evidence, allegations of clandestine removal and consequent demands for duty, interest, and penalty cannot be sustained. The impugned order was set aside, and all connected demands and penalties were quashed. This decision reinforces the principle that assumptions, presumptions, and uncorroborated private records or statements do not suffice to establish clandestine removal under Central Excise law.

CESTAT Mumbai Rules ‘Charging Case’ for Hearing Aids Not a Static Converter; Classification Under Parts/Accessories Upheld—Department’s Confiscation, Fine, and Extended Limitation Set Aside - The CESTAT Mumbai, after a thorough evaluation of evidence and legal principles, held that the imported ‘charging case without power supply’ designed for hearing aids was correctly classifiable under Tariff Item 9021 90 10 as a part/accessory of hearing aids, rejecting the Department’s attempt to treat it as a static converter or battery charger under Tariff Item 8504 40 30. The consequential demands for differential duty, invocation of the extended period, confiscation, redemption fine, and penalty were all set aside, and the importer’s appeal was allowed.

CESTAT Affirms Penalty for Misdeclaration of Counterfeit Goods: Unretracted Admission of Importer Holds Evidentiary Value - The CESTAT’s decision unequivocally upholds the penalty imposed on the importer for misdeclaration of imported goods, emphasizing that an unretracted admission by the importer is sufficient to establish liability in the absence of supporting documentation or credible rebuttal. Importers must ensure the accuracy of declarations and retain all relevant documentation to substantiate claims of bona fide error or intended warehousing. Failure to do so can result in sustained penalties based on confessional statements alone.

CESTAT Ahmedabad Sets Aside Differential Duty on Direct HMS Scrap Imports; Orders Fresh Valuation and Penalty Review for High Sea Sale Transactions - The Tribunal’s decision underscores that Customs authorities cannot reject the declared transaction value for direct imports in the absence of credible evidence or reasonable doubt as mandated by law. The adoption of higher values from unrelated high sea sale transactions, without substantiation, is legally untenable. For high sea sale imports, the onus is on the importer to establish the contract price through a complete chain of documents, failing which, the matter must be adjudicated afresh. Penalties arising from valuation disputes must be revisited if the foundational demand is set aside or remanded.

CESTAT Chennai Bars Revenue Appeal Below Monetary Threshold: Penalty Amount, Not Confiscated Goods Value, is Decisive - Based on the binding nature of the CBIC’s instructions, the Tribunal held that the maintainability of departmental appeals must be determined strictly by reference to the disputed duty or penalty amount, not the value of confiscated goods. In the absence of a specific exception in the Board’s instructions, no appeal can be entertained where the monetary threshold is not met. The Tribunal’s decision is actionable: Departments must rigorously assess the quantum of duty or penalty involved before filing appeals, and should refrain from invoking appeals based solely on the value of confiscated goods in absolute confiscation cases.

CESTAT Sets Aside Duty Demand: No Evidence of Fraud or Suppression, MODVAT-era Credits Cannot Be Denied Under Later CENVAT Rules - The CESTAT Chandigarh’s decision unequivocally holds that duty demands and penalties for alleged fraudulent availment of credit cannot be sustained in the absence of concrete evidence of suppression, non-consumption, or clandestine removal, especially where the records were regularly submitted for departmental scrutiny and no discrepancies were found contemporaneously. Furthermore, proceedings must be anchored to the statutory provisions in force during the period in question; retrospective application of subsequently substituted rules or penalties is impermissible. Both appeals were allowed, setting aside the demands and penalties in their entirety.

CESTAT Kolkata Quashes Duty Demand: SSI Exemption Upheld Where Trading and Manufacturing Turnovers Were Improperly Clubbed - The CESTAT Kolkata categorically held that clubbing trading turnover with manufacturing turnover, without substantive investigative support, is legally impermissible for the purpose of denying SSI exemption under Notification No. 8/2003-C.E. The appellant-company was found entitled to the benefit of the SSI exemption as per the notification, and the entire demand of duty, interest, and penalties was quashed. This decision reinforces the need for the Revenue to conduct comprehensive investigations and to differentiate between manufacturing and trading activities before proceeding with demands and penal actions.

CESTAT Kolkata Quashes Excise Demand: No Clandestine Removal Proven Where Only Discrepancy in VAT and ER-1 Returns and Trading Turnover Properly Certified - The CESTAT Kolkata decisively held that the charge of clandestine removal cannot be sustained solely on the basis of a mismatch between VAT and ER-1 returns, especially when the assessee provides a Chartered Accountant’s certificate explaining the difference as arising from trading and other non-excisable activities. In the absence of any tangible, independent evidence of clandestine production or clearance, and with the Department relying only on disclosed records and audit scrutiny, both the demand and the invocation of the extended period of limitation were set aside. The appeal was allowed in favour of the assessee, with all resultant interest and penalty demands quashed.

CESTAT Hyderabad Upholds Appropriation of Paid Duty and Interest; Validates Penalty Under Rule 25 Despite Absence of Fraud in Denial of Concessional Rate - Given the findings, the CESTAT Hyderabad partly allowed the appeal. It directed that the amounts already paid toward duty and interest must be appropriated and that no further demand should be raised for those components. The imposition of penalty under Rule 25, limited to 10% of the duty, was upheld as lawful and proportionate. Assessees in similar circumstances should ensure that payments made during the pendency of appeal proceedings are promptly appropriated and that any penalty imposed is consistent with the statutory limits and requirements set out in Rule 25 and Section 11AC.

Supreme Court Affirms Preventive Detention Under COFEPOSA: No Right to Legal Representation Before Advisory Board, Substantial Compliance on Document Supply Upheld - The Supreme Court, after a comprehensive review of the factual and legal matrix, upheld the COFEPOSA detention orders. The denial of legal representation before the Advisory Board, the procedures adopted for supplying relied upon documents and electronic records, the method of communicating decisions on representations, and the formation of subjective satisfaction by the detaining authority all complied with the statutory and constitutional requirements. Consequently, both Special Leave Petitions were dismissed, affirming the validity of the preventive detention orders.

Madras High Court Quashes Customs Proceedings and Penalty: MEIS Scrips Under DGFT Jurisdiction, No Mens Rea for Customs Broker - The Madras High Court categorically set aside the order of the Tribunal, holding that customs had no jurisdiction to pursue proceedings based on the alleged wrongful availment of MEIS benefits while the scrips remained valid and unrevoked by the DGFT. The penalty imposed under Section 114AA against the customs broker was also quashed, as the element of mens rea was not established. The appeal was consequently allowed, and the customs action was declared unsustainable in law.

CESTAT Allahabad: Confiscation of Gold Set Aside Due to Lack of Reasonable Belief and Improper Reliance on Retracted Statement - The CESTAT Allahabad categorically held that the Department failed to establish a foundational reasonable belief for seizure or to substantiate its case with admissible evidence. The uncorroborated and retracted statement, relied upon by the Department, was held inadmissible in the absence of compliance with Section 138B of the Customs Act. The Tribunal dismissed the Departmental appeals, upholding the Commissioner (Appeals)’s order and disallowing confiscation and penalties against the respondents.

Bombay High Court Quashes Show-Cause Notices Against Foreign Exporter: No Customs Act Liability for Pre-Amendment Misdeclaration - The Bombay High Court set aside the show-cause notices issued to the foreign exporter and its representative, holding that the Customs Act, 1962, prior to its 2018 amendment, did not extend to foreign exporters for acts or omissions outside India. The show-cause notices and penalty proposals under Sections 112 and 114AA were quashed for lack of jurisdiction and absence of any proven act of abetment or false declaration on the part of the petitioners.

CESTAT Delhi Sets Aside Penalty under Rule 26: Absence of Proven Knowledge and Invalid Use of Section 14 Statement Fatal to Department’s Case - The CESTAT, New Delhi, conclusively held that for the imposition of penalty under Rule 26(1) of the Central Excise Rules, it is imperative to establish that the person had knowledge or reason to believe that the goods were liable to confiscation. Further, statements recorded under section 14 cannot be relied upon to impose penalty unless the mandatory procedure under section 9D is followed. The absence of these foundational requirements resulted in the setting aside of the penalty against the appellant, and the appeal was allowed.

CESTAT Chandigarh Quashes Penalty on Broker Under Rule 26(2) for Lack of Possession and Involvement in Excisable Goods - Based on the established facts and legal precedents, the CESTAT Chandigarh decisively held that a broker who neither possesses nor deals in excisable goods, nor is proven to have participated in the issuance or abetment of fraudulent invoices, cannot be subjected to penalty under Rule 26(2) of the Central Excise Rules, 2002. The derivative penalty imposed solely due to the appellant’s agency status, after the main noticees had been exonerated, was unsustainable. Accordingly, the penalty was set aside and the appellant’s appeal was allowed.

CESTAT Rejects Excise Duty on 4g and 9g Branded Spit Tobacco Pouches; Exemption Under Rule 34(1)(b) Upheld in Absence of Quantifiable Evidence for 15g Packs - Based on the foregoing analysis, the CESTAT Chandigarh allowed the appeals in toto. It held that 4g and 9g pouches of branded spit tobacco are not liable to MRP-based valuation under Section 4A due to the explicit exemption for packages of 10 grams or less under Rule 34(1)(b) of the Packaged Commodities Rules, supported by CBEC’s circulars. Furthermore, since there was no quantifiable evidence of clearances of 15g pouches, no demand for duty could be sustained. The Tribunal thus quashed all demands and consequential liabilities arising out of the show cause notice.

CESTAT Chandigarh Rules in Favour of Assessee: Polishing and Coating of S.S. Sheets/Coils Constitutes Manufacture; No Double Recovery of CENVAT Credit Permissible - Based on a comprehensive review of facts, legal provisions, and precedents, the Tribunal upheld the Commissioner’s order, dropping the demand for reversal or recovery of CENVAT credit. The Tribunal further dismissed the Revenue’s appeal, holding that the processes undertaken by the respondent amounted to manufacture, and the credit availed was lawfully utilized against duty paid on the final product. No grounds existed for invoking the extended period of limitation in the absence of suppression or intent to evade.

Importer Not Liable for Additional Customs Duty on Dealer-Initiated RSP Hike Post-Import; Rule 5 of 2008 Rules Inapplicable to Importers - On the facts and in law, the Tribunal decisively held that an importer cannot be saddled with liability for differential customs duty on account of an upward revision of RSP by downstream authorized dealers, in the absence of any evidence of involvement or knowledge on the part of the importer. Rule 5 of the 2008 Rules cannot be applied to importers in such circumstances. The Tribunal also clarified procedural safeguards concerning the use of statements under section 108, emphasizing the necessity of compliance with section 138B for evidentiary purposes. The penalty under section 114A was accordingly set aside, and the appeal was allowed, with the impugned demand quashed in its entirety.

Supreme Court Confirms Denial of Concessional Duty Under Exemption Notification No. 21/2002-Cus for Power Project Imports Classified Under Heading 9801 - Based on the Supreme Court’s decision, it is clear that assessees seeking exemption or concessional rates under customs notifications must ensure literal and complete compliance with the specific terms of the relevant notification and tariff heading. Claims not precisely falling within the language or conditions of the exemption notification will not be entertained, and judicial authorities are likely to uphold a strict interpretation.

Karnataka High Court Mandates Expedited Adjudication and Enhanced Security for Provisional Release of Areca Nut Imports Amidst Classification Dispute - The Karnataka High Court, in disposing of the writ appeal, balanced the need to protect government revenue with the interests of the importer dealing in perishable goods. The Court strengthened provisional release conditions—requiring a 50% cash deposit and a 25% bank guarantee of the determined amount—and directed immediate commencement and expeditious completion of customs adjudication. By doing so, it ensured that neither party would suffer undue prejudice pending final resolution of the classification dispute.

Madras High Court Affirms Statutory Supremacy: No Time Bar for Shipping Bill Amendments under Section 149 in DFIA Code Error Cases - In summary, the Madras High Court upheld the Tribunal’s order permitting the amendment of shipping bills, holding that the statutory power under Section 149 to amend shipping bills based on contemporaneous documentary evidence is not subject to any limitation period imposed by departmental circulars. The Court further held that a mistaken entry of the export scheme code, supported by evidence of DFIA licensing at the time of export, constituted an inadvertent and rectifiable error, not a proscribed conversion of export schemes.

CESTAT Hyderabad Remands Case for Re-examination: Classification of Rough Granite Blocks, Inter-EOU Transfers, and Notification Compliance under Duty-Free Procurement - The Tribunal’s decision underscores the importance of factual and technical verification when determining the classification of granite products and the eligibility for duty exemptions under relevant notifications. The matter has been remanded to the adjudicating authority to:

Examine the precise nature of processing undertaken on granite products before DTA clearance,
Scrutinize the receipt and accountal of goods in inter-EOU transfers, and
Assess compliance with all conditions attached to exemption notifications, including NFE and proper use of procured goods.
Assessees must be prepared to provide documentary and technical evidence to support their claims on classification and exemption eligibility.

Statements Recorded under Section 14 of Central Excise Act Inadmissible without Compliance with Section 9D: CESTAT Quashes Duty Demand and Penalties in Alleged Clandestine Tobacco Case - The CESTAT’s decision establishes that statements made before central excise officers under Section 14 cannot be treated as evidence unless the strict procedure under Section 9D is followed, including the right to cross-examination. Failure by the department to corroborate allegations of clandestine manufacture and removal with documentary or physical evidence will result in the collapse of such cases. The imposition of penalties and confiscation under Rule 26 also requires specific findings, not mere assertions, regarding the liability of goods to confiscation. All demands and penalties in the present case were thus set aside, providing relief to the appellants.

Demand Set Aside as Panchnamas and Statements Discarded for Non-compliance with Mandatory Legal Procedure in Alleged Clandestine Pan Masala Manufacture - Based on the above legal and factual analysis, the Tribunal allowed the appellant’s appeal, setting aside the demand for duty, interest, penalty, and confiscation for the period April 2016 to January 2017. The department's appeal regarding the period April 2015 to March 2016 was also dismissed, as the foundational evidence for both periods was identical and equally infirm. The Tribunal’s decision was actionable: unless the department strictly complies with statutory requirements regarding search witnesses and the admissibility of statements, demands premised on such evidence cannot be sustained.

CESTAT Chandigarh Rules Bought-Out Kitchen Appliances Not Part of Assessable Value for Excise, No Extended Limitation Where Audit Reveals Dispute - Based on the evidence and legal precedents, CESTAT Chandigarh concluded that the value of bought-out items supplied and installed at the customer’s site could not be added to the assessable value of modular kitchen systems unless it was proven that these were essential components of the manufactured goods or that the installed system itself was excisable. The Tribunal also held that there was no justification for invoking the extended period of limitation, as the matter arose from an audit and involved interpretational ambiguity. The appeal was allowed on both merits and limitation, with consequential relief to the assessee.

Concessional Duty Benefit Under Notification No. 50/2017-Cus Upheld: CESTAT Delhi Quashes Demand in Absence of Proven Procedural Breach Under IGCR Rules - On a detailed appraisal of the facts and statutory framework, the CESTAT, New Delhi, unequivocally held that the department had not discharged its burden of proving any actionable breach by the appellant under the IGCR Rules. As the appellant had, in fact, used the imported goods for the intended purpose and there was no substantiation of excess imports or procedural contravention, both the demand for differential duty and the penalty imposed stood set aside. This outcome reinforces the principle that denial of concessional benefits requires clear, cogent evidence of non-compliance with statutory conditions.

CESTAT Upholds Confiscation and Penalty for Admitted Misdeclaration in Import of Goods: Importer’s Reliance on Supplier’s Error Not a Valid Defence - In light of the foregoing, the CESTAT’s decision underscores that an importer’s admitted misdeclaration—when not subsequently retracted—constitutes conclusive evidence, justifying reassessment, confiscation, and penalty. Importers must exercise utmost diligence in ensuring accuracy in import declarations, as errors attributed to suppliers will not absolve them of liability. The decision further affirms that, in the absence of identical goods data, authorities are within their rights to determine value using contemporary import data for similar goods.

Corrigendum - Notification No. 22/2026 dated 20th March, 2026

MEMORANDUM REGARDING DELEGATED LEGISLATION

Notes on Clauses

PRESIDENT'S RECOMMENDATION UNDER ARTICLES 117 AND 274 OF THE CONSTITUTION OF INDIA

THE FIRST SCHEDULE

Functioning of Goods and Services Tax Appellate Tribunal(GSTAT), Agra Bench
Goods and Services Tax Settlement of Funds Rules, 2026
Reconstitution of Division Benches of the Principal Bench, GSTAT under Section 109 of the CGST Act, 2017
Designation of Judicial Members of GSTAT as Vice Presidents of State Benches under Section 109(7) of the CGST Act, 2017
Constitution of the Authority for Advance Ruling in the Union territories - Change in Name and designation of the Member of Union territory Daman - Seeks to amend Notification No. 14/2018 dated 8th October 2018.
Securities and Exchange Board of India (Infrastructure Investment Trusts) (Amendment) Regulations, 2026.
Securities and Exchange Board of India (Real Estate Investment Trusts) (Amendment) Regulations, 2026.
Securities and Exchange Board of India (Alternative Investment Funds) (Amendment) Regulations, 2026
Commencement of the Constitution (One Hundred and Sixth Amendment) Act 2023
Securities and Exchange Board of India (Intermediaries) (Amendment) Regulations, 2026
Amendment in Appendix 4B of Handbook of Procedures, 2023
Amendment to Notification No. 65/2025-26 for inclusion of Egypt and Jordan under RELIEF
Amendment in export policy of Baryte (Natural Barium Sulphate)
Amendment in Notification No. 68/2021-Customs (ADD) dated 6th December, 2021
Appointment of Common Adjudicating Authority in the case of M/s. Control Components India (P)Ltd.
Additional Land Area Adjoining the Existing Container Freight Station Premises of M/s Ocean Gate Container Terminals Private Limited
Clarification on eligibility of new ECGC Whole Turnover Policy under Component II of the Resilience & Logistics Intervention for Export Facilitation (RELIEF) under Export Promotion Mission (EPM)
Procedure to handle export cargo containers off loaded at foreign ports and subsequently returned to India, in view of disruption in maritime routes due to closure of the Strait of Hormuz- Section 143AA of the Customs Act, 1962
Fixation of Tariff Value of Edible Oils, Brass Scrap, Areca Nut, Gold and Silver
Amendment in Import Policy of Glufosinate and its salts covered under Chapter 38 of Schedule -I (Import Policy) of ITC (HS) 2022

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Article - Cross-Border Workforce Deployment in India: Tax Implications of Secondment and Employer of Record (EOR) Models
Article - Requirement of Prior Intimation under First Proviso to Section 143(1)(a): Scope and Implications
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