Issues: Whether the petitioner's arrest and subsequent remand were illegal for alleged violation of Article 22(2) of the Constitution of India, and whether the grounds of arrest were unsupported by material collected during investigation.

Analysis: The arrest followed a search authorised under the GST law, repeated summons, recording of statements, and collection of material showing the petitioner's alleged role in an organised online gaming and tax evasion syndicate. The Court accepted the respondents' chronology that the search concluded in the early hours of 27.02.2026 and that the petitioner was arrested at 5:50 am the same day. The contention that arrest commenced earlier, from the time officials entered the premises, was rejected. On that basis, production before the Magistrate at 8:30 pm on 27.02.2026 was held to be within the 24-hour requirement. The Court also held that the grounds of arrest disclosed sufficient material connecting the petitioner with the alleged offences and that the case involved economic offences where investigative coercive steps could be justified on the facts placed before the Court.

Conclusion: The arrest and remand were not held illegal, and no violation of Article 22(2) was made out.

Final Conclusion: The writ petition failed, and the challenge to the arrest and remand was rejected.

Ratio Decidendi: In a GST investigation involving economic offences, arrest is not invalid merely because officers were present at the premises earlier; the relevant point is the actual arrest, and production before the Magistrate within 24 hours from that arrest satisfies Article 22(2) if supported by recorded investigative material and lawful authorisation.

Issues: Whether the Appellate Tribunal's order directing partial pre-deposit of penalty under the Foreign Exchange Management Act, 1999 called for interference, and whether the pre-deposit condition required modification.

Analysis: The second proviso to Section 19 permits dispensation of penalty pre-deposit only in a particular case where undue hardship is shown, subject to conditions the Appellate Tribunal considers fit. The record showed that the Tribunal had already exercised that discretion and granted substantial relief by reducing the deposit requirement to 10% of the penalty. The challenge to the petitioners' prima facie case was not sufficient to dislodge the Tribunal's assessment, and the scope of interference under Article 227 remained narrow. At the same time, the Court found no infirmity in the Tribunal's exercise of discretion, but considered it appropriate in the interests of justice to further reduce the deposit requirement.

Conclusion: The Tribunal's order was sustained in principle, but the pre-deposit condition was modified from 10% to 5% of the penalty amount, with the balance to be secured by bank guarantee or surety to the satisfaction of the Appellate Tribunal.

Issues: Whether the petitioner was entitled to have its claim for GST budgetary support benefit considered in light of Notification No. 20/2007 and the clarification dated 22-02-2023, and whether, on verification, it should receive the same benefit as similarly situated units covered by the earlier coordinate Bench order.

Analysis: The petitioner's unit had commenced commercial production after modernization on 30-03-2017, which brought the claim within the temporal scope of the notification relied upon. The earlier coordinate Bench had already held, on the basis of the clarification dated 22-02-2023, that units who had paid tax dues under the earlier exemption arrangement through CENVAT credit, but had not yet reached the stage of cash payment, were to be treated as having availed the benefit of the exemption notification. In view of that precedent and the parties' consensus, the present claim required verification only to ascertain whether the petitioner was similarly situated.

Conclusion: The petitioner was not granted an unconditional direction for release of benefit, but was entitled to verification of its claim and, if found similarly situated, to the same benefits as those granted in the coordinate Bench decision.

Final Conclusion: The writ petition was disposed of with a direction for verification and consequential extension of benefits upon satisfaction of the similarity test.

Ratio Decidendi: Where a later clarification and an earlier coordinate Bench ruling treat certain industrial units as having availed exemption benefits, a similarly situated unit is entitled to verification and consequential extension of the same benefits.

Outcome: The writ petition was disposed of with liberty to the petitioner to submit a detailed representation with supporting documents, and the respondent authority was directed to consider it in accordance with law within a reasonable time. No opinion on the merits was expressed.

Issues: (i) Whether the appellant could appropriate the security deposit made in lieu of letter of credit after commencement of the corporate insolvency resolution process towards pre-CIRP dues; (ii) Whether the deposit could be treated as a bank guarantee or letter of credit so as to permit set-off or enforcement notwithstanding the moratorium under the Insolvency and Bankruptcy Code, 2016.

Issue (i): Whether the appellant could appropriate the security deposit made in lieu of letter of credit after commencement of the corporate insolvency resolution process towards pre-CIRP dues.

Analysis: The deposit of Rs. 108.44 crores remained the property of the corporate debtor till a lawful adjustment was made. Once the insolvency commencement date was reached, the moratorium under Section 14 of the Insolvency and Bankruptcy Code, 2016 barred unilateral appropriation of amounts towards dues that had arisen before commencement of the CIRP. The claimed amount had already been part of the insolvency claim process, and the unilateral post-commencement adjustment against pre-CIRP bills was contrary to the scheme of insolvency resolution and the pari passu treatment of claims.

Conclusion: The appropriation towards pre-CIRP dues was impermissible and was rightly disallowed.

Issue (ii): Whether the deposit could be treated as a bank guarantee or letter of credit so as to permit set-off or enforcement notwithstanding the moratorium under the Insolvency and Bankruptcy Code, 2016.

Analysis: The record showed a security deposit made in lieu of a letter of credit, not an independent bank guarantee or a security interest created in favour of the appellant. The authorities on bank guarantees and letters of credit did not assist the appellant because no such enforceable instrument existed in the present form, and even an equivalent enforcement after commencement of CIRP would conflict with the moratorium when directed against the corporate debtor for pre-CIRP liabilities. The appellant's plea of set-off also failed because there were no mutual cross-claims of the kind that justify set-off in insolvency, and the adjustment sought was inconsistent with the statutory scheme.

Conclusion: The deposit could not be treated as an enforceable bank guarantee or letter of credit permitting set-off against pre-CIRP dues.

Final Conclusion: The impugned orders were affirmed, and the appeal failed on the ground that the unilateral adjustment of the security deposit against pre-CIRP dues was inconsistent with the insolvency moratorium and the resolution process.

Ratio Decidendi: A security deposit retained by the corporate debtor cannot be unilaterally appropriated after commencement of CIRP towards pre-CIRP dues, and neither a claimed set-off nor an attempted enforcement of a non-equivalent security arrangement can override the moratorium under the Insolvency and Bankruptcy Code, 2016.

Issues: Whether the offence under Section 138 of the Negotiable Instruments Act could be compounded after conviction on the basis of a post-conviction compromise and payment of the entire compensation amount.

Analysis: The petitioner was convicted under Section 138 of the Negotiable Instruments Act and the conviction had already been affirmed in appeal and revision. The parties subsequently entered into a compromise, and the respondent acknowledged receipt of the entire compensation amount. The Court relied on the statutory power of compounding under Section 147 of the Negotiable Instruments Act and the settled principle that such compounding can be permitted even after conviction, as recognised in binding precedent. In view of the compromise and full satisfaction of the awarded amount, no impediment remained to grant relief.

Conclusion: The offence was held compoundable after conviction, and the petitioner was entitled to be acquitted on the basis of the compromise.

Issues: Whether pre-CIRP income tax and TDS demands could survive and be enforced after approval of the Resolution Plan under the insolvency process.

Analysis: The Resolution Plan had been approved by the Adjudicating Authority under the Insolvency and Bankruptcy Code, 2016, and the Court treated the legal position as settled that claims not forming part of the approved plan stand extinguished. On that basis, the Revenue could not continue to enforce demands relating to the period prior to approval of the Resolution Plan, whether appearing on the Income Tax Portal or the TDS portal. The Court also directed consequential recomputation of liability and refund after giving effect to the NCLT orders.

Conclusion: The issue was answered in favour of the assessee. The pre-Resolution Plan demands were held not to survive and the Revenue was directed to extinguish them and grant consequential relief.

Issues: Whether the declared transaction value of the imported goods could be discarded and the assessable value enhanced merely on the basis of NIDB data without complying with the valuation procedure under the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007.

Analysis: The declared invoice value is the starting point under Section 14(1) of the Customs Act, 1962. A departure from that value requires the proper officer to have a reasonable doubt about the truth or accuracy of the declared value and to follow the procedure under Rule 12 of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007 before moving sequentially to Rules 4 to 9. Mere reliance on higher values reflected in NIDB data does not by itself establish such reasonable doubt. The record did not show any independent inquiry or material indicating under-valuation, nor was the transaction value rejected in the manner required by the valuation rules.

Conclusion: The enhancement of value was unsustainable and the appeal was allowed.

Issues: (i) Whether the appellant was entitled to refund of service tax paid on construction services provided to Military Engineering Services for non-commercial governmental buildings under the retrospective exemption framework. (ii) Whether the refund claim was barred by unjust enrichment and whether the matter required reconsideration with the service recipient impleaded as co-applicant.

Issue (i): Whether the appellant was entitled to refund of service tax paid on construction services provided to Military Engineering Services for non-commercial governmental buildings under the retrospective exemption framework.

Analysis: The construction services were rendered to a department of the Ministry of Defence for infrastructure and civil structures not used for commerce, industry, or any business or profession. The exemption earlier available under Notification No. 25/2012-ST was withdrawn for a period and later reintroduced by Notification No. 09/2016-ST, while Section 102 of the Finance Act, 1994 created a retrospective exemption and refund mechanism for the interregnum. The Court treated the claim as covered by the exemption and the retrospective refund provision.

Conclusion: The appellant was entitled to refund on merits, subject to the refund being examined in accordance with the remand directions.

Issue (ii): Whether the refund claim was barred by unjust enrichment and whether the matter required reconsideration with the service recipient impleaded as co-applicant.

Analysis: The Court followed earlier decisions holding that, in such cases, the burden of tax was borne in the governmental chain of reimbursement and the recipient department could be the proper claimant. It also relied on the statutory scheme of Section 102 and the refund provisions under Section 11B of the Central Excise Act, 1944 to hold that the claim should be reconsidered with the service recipient participating in the refund process. The order of rejection on unjust enrichment was not sustained.

Conclusion: The objection of unjust enrichment did not defeat the claim, but the refund was to be re-examined after impleading MES as co-applicant.

Final Conclusion: The impugned rejection was set aside and the matter was sent back for fresh decision on the refund claim in the light of the retrospective exemption and the participation of the service recipient.

Ratio Decidendi: Where construction services are rendered to a governmental department for non-commercial use, retrospective exemption and refund provisions apply, and the refund claim cannot be rejected on unjust enrichment alone when the tax burden is shown to have been borne within the governmental recipient chain.

Issues: Whether a contractual clause empowering the administration to treat its decision as final and barring court or arbitral challenge could exclude adjudication where the manning agent disputed liability, and whether the dispute was an excepted matter outside the arbitral tribunal's jurisdiction.

Analysis: Clause 3.20 could not be read to permit one contracting party to conclusively decide whether the other had committed wilful omission, neglect, or negligence when liability itself was in dispute. Such an interpretation would offend the rule of law and the principle that no party can be a judge in its own cause. The clause had to be read harmoniously with the broad arbitration clause, and the restrictive language in Clause 3.20 could operate only in cases where liability was admitted and the administration merely quantified recovery. In a contested claim, the dispute fell within the arbitration clause and was not an excepted matter. A construction that shut out both court and arbitral remedy would also create an impermissible vacuum in legal remedies.

Conclusion: The dispute was arbitrable, the administration could not finally determine disputed liability, and the award was not without jurisdiction.

Ratio Decidendi: A contractual term cannot make one party the final judge of disputed breach or liability, and where liability is contested a broadly worded arbitration clause will prevail so that the dispute remains subject to independent adjudication.

Issues: (i) whether a show cause notice under Section 74 of the Nagaland Goods and Services Tax Act, 2017 was valid without allegations of fraud, wilful misstatement, or suppression of facts to evade tax; (ii) whether the impugned adjudication orders were sustainable when no opportunity of hearing was granted and the orders did not set out the relevant facts and basis of decision.

Issue (i): whether a show cause notice under Section 74 of the Nagaland Goods and Services Tax Act, 2017 was valid without allegations of fraud, wilful misstatement, or suppression of facts to evade tax.

Analysis: Section 74 can be invoked only where non-payment, short payment, erroneous refund, or wrongful availment or utilisation of input tax credit is attributable to fraud, wilful misstatement, or suppression of facts to evade tax. The notices issued to the petitioners merely referred to the remaining tax and interest liability and did not disclose the foundational ingredients required for invoking Section 74. In the absence of those jurisdictional assertions, the notices failed to satisfy the statutory threshold.

Conclusion: The show cause notices under Section 74 were invalid and could not be sustained.

Issue (ii): whether the impugned adjudication orders were sustainable when no opportunity of hearing was granted and the orders did not set out the relevant facts and basis of decision.

Analysis: Section 75 requires observance of the right of hearing when an adverse decision is contemplated and further mandates that the proper officer state the relevant facts and the basis of the decision in the order. The impugned orders were passed without affording a hearing and without recording the facts and reasons supporting the demand. The procedural safeguards under Section 75 were therefore not complied with.

Conclusion: The impugned adjudication orders were unsustainable and liable to be quashed.

Final Conclusion: The writ petitions succeeded, the notices and consequential orders were set aside, and the respondents were left at liberty to initiate fresh proceedings in accordance with law.

Ratio Decidendi: Proceedings under Section 74 of the Nagaland Goods and Services Tax Act, 2017 are jurisdictionally valid only when the notice expressly discloses fraud, wilful misstatement, or suppression of facts to evade tax, and any adverse tax order must comply with the hearing requirement and reasoned-order mandate under Section 75.

Outcome: Delay condoned. Special Leave Petitions dismissed. Accompanying interlocutory applications disposed of.

Outcome: Delay condoned. The Special Leave Petition was dismissed and the interlocutory application(s), if any, stood disposed of.

Issues: (i) Whether oven roasted areca nuts, roasted pistachios, roasted almond nuts and roasted cashew nuts are classifiable under the claimed Customs Tariff Items, and whether the roasting process takes them out of Chapter 8 into Heading 2008. (ii) Whether the benefit of Notification No. 46/2011-Cus dated 01.06.2011 is available for the imported goods, subject to proof of origin under the applicable rules.

Issue (i): Whether oven roasted areca nuts, roasted pistachios, roasted almond nuts and roasted cashew nuts are classifiable under the claimed Customs Tariff Items, and whether the roasting process takes them out of Chapter 8 into Heading 2008.

Analysis: The classification was determined by applying the General Rules for Interpretation, the Section and Chapter Notes, and the HSN Explanatory Notes. The decision distinguished roasting from drying and treated roasted cashew nuts as specifically covered by the tariff entry for cashew nut, roasted, salted or roasted and salted. Roasted almond nuts and roasted pistachios were treated as falling within the specific inclusion for other roasted nuts and seeds under Heading 2008. In relation to areca nuts, the ruling treated moisture content of 10% to 15% as inconsistent with the claimed roasted character and placed the goods in the areca nut entry under Chapter 8 rather than under roasted nuts.

Conclusion: Roasted cashew nuts are classifiable under CTI 20081910. Roasted almond nuts and roasted pistachios are classifiable under CTI 20081991. Areca nuts with moisture content of 10% to 15% are classifiable under CTI 080280, with the appropriate sub-classification depending on form.

Issue (ii): Whether the benefit of Notification No. 46/2011-Cus dated 01.06.2011 is available for the imported goods, subject to proof of origin under the applicable rules.

Analysis: The exemption was treated as conditional and dependent on the importer establishing origin to the satisfaction of the jurisdictional customs authority in accordance with the relevant rules of origin and the administration rules governing trade agreements.

Conclusion: The notification benefit is available only on proof of the required origin conditions.

Final Conclusion: The advance ruling sustains the proposed classification for roasted cashew nuts, roasted almond nuts and roasted pistachios, rejects the claimed roasted classification for the areca nuts described with 10% to 15% moisture content, and leaves the exemption benefit contingent on compliance with origin requirements.

Ratio Decidendi: For tariff classification, the specific description in the tariff and the HSN Explanatory Notes prevail, and goods resulting from roasting are to be classified as roasted nuts where the tariff expressly so provides, while goods not answering that description remain within the appropriate fresh or dried nut entry.

Issues: Whether the bail granted to the respondent accused should be cancelled on the ground of alleged breach of bail conditions, need for further custodial interrogation, and alleged infirmity in the order granting bail.

Analysis: Cancellation of bail requires cogent and overwhelming circumstances, ordinarily showing interference with the administration of justice, evasion of process, abuse of liberty, absconding risk, or tampering with evidence or witnesses. The material on record showed that the respondent had complied with the conditions imposed by the trial court, had been permitted to travel abroad on earlier occasions with conditions, had returned, and had even surrendered his passport before it was later returned by the trial court. The record also indicated cooperation with the investigating agency, attendance when called, and supply of documents and login credentials. No credible material was placed to show breach of bail conditions, misuse of liberty, or any supervening circumstance justifying cancellation. The order granting bail was also treated as reasoned, and the request for further custodial interrogation was held not to furnish a sufficient ground to take away liberty already granted.

Conclusion: The prayer for cancellation of bail was rejected and the respondent's bail was not disturbed.

Issues: (i) Whether a miscellaneous application seeking recall of a non-speaking order dismissing an SLP is maintainable after disposal of the SLP. (ii) Whether subsequent developments in insolvency proceedings, including an OTS and withdrawal under Section 12A of the Insolvency and Bankruptcy Code, 2016, can justify recall of the earlier dismissal. (iii) Whether alleged suppression or fraud was made out so as to reopen the disposed of SLP.

Issue (i): Whether a miscellaneous application seeking recall of a non-speaking order dismissing an SLP is maintainable after disposal of the SLP.

Analysis: A post-disposal miscellaneous application can be entertained only in narrow situations such as correction of clerical or arithmetical errors or where directions in an executory order have become impossible to implement because of later events. Once the SLP stands disposed of, the Court becomes functus officio except within those limited contours. A mere attempt to reopen a dismissed SLP does not satisfy the settled standard of maintainability.

Conclusion: The miscellaneous application was not maintainable and was against the applicant.

Issue (ii): Whether subsequent developments in insolvency proceedings, including an OTS and withdrawal under Section 12A of the Insolvency and Bankruptcy Code, 2016, can justify recall of the earlier dismissal.

Analysis: The later events relied upon arose in a separate statutory framework and beyond the civil revision from which the SLP had arisen. Such developments could not be examined collaterally in a miscellaneous application filed in the disposed of SLP. The Court also reiterated that withdrawal under Section 12A of the Insolvency and Bankruptcy Code, 2016 depends on the commercial wisdom of the Committee of Creditors, which is not to be substituted by judicial assessment of competing offers. The applicant's attempt to compare the alleged superiority of its offer with the approved settlement was therefore outside the permissible scope of review.

Conclusion: The subsequent insolvency developments did not furnish a ground for recall and the issue was against the applicant.

Issue (iii): Whether alleged suppression or fraud was made out so as to reopen the disposed of SLP.

Analysis: Fraud may vitiate proceedings, but the exception must be specifically established. The order dismissing the SLP was non-speaking and did not rest on any representation shown to have been suppressed. The material relied upon at best disclosed a separate grievance arising from later or parallel proceedings and did not establish that the dismissal order itself had been procured by fraud.

Conclusion: Alleged suppression or fraud was not proved and no recall was warranted.

Final Conclusion: The Court declined to reopen the dismissed SLP or to enter into the merits of later insolvency proceedings, leaving the parties to pursue any available remedy before the competent forum.

Ratio Decidendi: A miscellaneous application filed after disposal of an SLP is maintainable only in exceptional post-disposal situations, and a non-speaking dismissal cannot be recalled on the basis of later events or unsubstantiated allegations of suppression, especially where the relief sought would require collateral review of a separate statutory process governed by commercial wisdom.

Issues: (i) Whether the appeal was maintainable before the Tribunal in view of the monetary limit under the second proviso to section 35B(1) of the Central Excise Act, 1944 read with section 86(7) of the Finance Act, 1994.

Analysis: The disputed tax involved was Rs. 20,112/-, with penalties aggregating to amounts below the prescribed monetary threshold, and the dispute did not involve any question relating to rate of tax or valuation. In such circumstances, the Tribunal was entitled to decline admission of the second appeal under the statutory bar governing low-value disputes.

Conclusion: The appeal was not maintainable before the Tribunal and was not admitted.

Final Conclusion: The proceeding ended at the threshold on maintainability, and no examination on merits was undertaken.

Ratio Decidendi: Where the disputed duty or penalty falls below the prescribed monetary limit and the case does not raise a rate or valuation issue, the Tribunal may refuse to admit the appeal under the statutory second proviso.

Issues: Whether interest at 12% was payable on the amount deposited during investigation and later refunded, and whether the deposit could be treated as a voluntary payment or a pre-deposit attracting the refund regime under the Central Excise Act, 1944.

Analysis: The amount was deposited during investigation at the insistence of the Department and was not a voluntary discharge of duty liability. The payment was made under a mistaken notion regarding excise liability and, on the facts recorded, could not be characterised as duty voluntarily paid. In such circumstances, the refund claim was not governed by the refund provisions applicable to duty claims under Section 11B of the Central Excise Act, 1944. Following the view already taken in the Tribunal's earlier decision, as affirmed by the High Court, interest was held payable on the refunded amount from the date of deposit till the date of refund, at the rate of 12%.

Conclusion: The appellant was held entitled to interest at 12% per annum on the refunded deposit from the date of deposit till the date of refund.

Ratio Decidendi: An amount deposited during investigation at departmental insistence, and later refunded, carries interest where it is not a voluntary duty payment but a deposit made under a mistaken notion of liability.

Issues: Whether the arbitral award suffered from patent illegality or perversity under Section 34 of the Arbitration and Conciliation Act, 1996 on the finding that the petitioner had not taken steps to avail input tax credit and that the documents furnished were sufficient.

Analysis: The challenge was confined to the narrow jurisdiction under Section 34 of the 1996 Act. The Court reiterated that an arbitral award may be interfered with only on limited grounds, including conflict with the public policy of India, patent illegality, or perversity, and that the Court does not sit in appeal over the award. The Majority Arbitral Tribunal had recorded a categorical finding that the petitioner had not made any effort to avail the input tax credit, including by approaching the concerned authorities, and had also noted that the respondent had furnished the relevant documents and that the petitioner had reimbursed amounts towards CENVAT and VAT. On that basis, the Tribunal rejected the claim of shortfall. The Court held that this was a plausible and reasonable view on the material before the Tribunal, and that the objections raised amounted only to an impermissible request for reappreciation of evidence.

Conclusion: The award did not suffer from patent illegality or perversity, and no ground for interference under Section 34 was made out.

Issues: Whether the petitioner was entitled to regular bail in a prosecution under the Central Goods and Services Tax Act, 2017.

Analysis: The petitioner had been in judicial custody since 29.01.2026, the investigation was treated as completed, and a co-accused had already been granted bail. In these circumstances, continued incarceration was not considered necessary, and bail was granted with conditions relating to bond, sureties, appearance before the investigating authorities, and compliance with the statutory conditions applicable to bail.

Conclusion: Regular bail was granted to the petitioner.

Ratio Decidendi: Where investigation is complete and the accused has remained in judicial custody for a substantial period, bail may be granted, subject to conditions, especially where parity with a co-accused also exists.