Issues: (i) Whether revisionary jurisdiction could be exercised over purchase disallowances already forming the subject matter of a pending first appeal; (ii) Whether the assessment order was erroneous and prejudicial to the interests of the Revenue because the Assessing Officer estimated profit on disputed purchases rather than adding the entire amount as unexplained expenditure, and did not treat an outstanding supplier balance as ceased liability.

Issue (i): Whether revisionary jurisdiction could be exercised over purchase disallowances already forming the subject matter of a pending first appeal.

Analysis: The disallowance relating to purchases from the two suppliers, including the genuineness of such purchases and the estimation of profit embedded therein, was already under challenge before the first appellate authority. Clause (c) of Explanation 1 to Section 263 confines revisionary power, where an assessment is the subject of an appeal, to matters not considered and decided in that appeal. The subject of the revision was part of the larger purchase-disallowance issue pending in appeal; the authorities relied upon for the contrary position concerned matters not appealed or a period preceding the relevant statutory amendment.

Conclusion: Revision under Section 263 in respect of the disputed purchases was barred and the revisionary order was invalid to that extent, in favour of the assessee.

Issue (ii): Whether the assessment order was erroneous and prejudicial to the interests of the Revenue because the Assessing Officer estimated profit on disputed purchases rather than adding the entire amount as unexplained expenditure, and did not treat an outstanding supplier balance as ceased liability.

Analysis: The assessment record showed that the Assessing Officer had called for and considered invoices, ledger accounts, transport and e-way bill records, bank-payment details, confirmations, and GST-related material before estimating the profit element on the purchases. A detailed inquiry followed by adoption of a legally plausible view cannot be revised merely because the Principal Commissioner prefers addition of the entire purchase amount under Section 69C. The decision supporting full addition on different facts was distinguishable. Further, the alleged non-genuineness of the supplier did not by itself establish remission or cessation of the outstanding trading liability; no material showed a write-back, waiver, remission, or cessation during the relevant year.

Conclusion: The assessment was not amenable to revision on either the purchase addition or the outstanding liability; the Principal Commissioner could not substitute a different view under Section 263, and no addition under Section 41(1) was warranted, in favour of the assessee.

Final Conclusion: The revisionary action failed both because it intruded into an issue pending in first appeal and because the original assessment reflected inquiry and a sustainable view, with no factual basis for treating the creditor balance as ceased.

Ratio Decidendi: Revisionary power cannot be used to revisit an issue pending in appeal or to substitute the revisional authority's view for a plausible view adopted after inquiry; a trading liability cannot be taxed as ceased without material establishing remission or cessation.

Issues: Whether interim stay of the order declaring the earlier advance ruling void ab initio should be granted pending final adjudication of the appeal.

Analysis: The questions concerning the scope of the power to declare an advance ruling void ab initio, the alleged misrepresentation of material facts, and procedural fairness require detailed examination at the final hearing. At the interim stage, staying the impugned order would revive the earlier ruling despite the finding of misrepresentation recorded in the impugned order.

Outcome: The appeal was admitted for final hearing, and the interim-stay application was dismissed.

Issues: (i) Whether the imported powdered Pelargonium sidoides root extract containing Maltodextrin as a carrier is classifiable as a vegetable extract under Customs Tariff Item 1302 19 19 or as a medicament under Customs Tariff Item 3003 90 90; (ii) Whether the goods qualify for the exemption under Serial No. 37 of Notification No. 45/2025-Customs dated 24.10.2025.

Issue (i): Whether the imported powdered Pelargonium sidoides root extract containing Maltodextrin as a carrier is classifiable as a vegetable extract under Customs Tariff Item 1302 19 19 or as a medicament under Customs Tariff Item 3003 90 90.

Analysis: Classification is governed by Rule 1 of the General Rules for Interpretation, read with the relevant heading terms, Chapter Notes and HSN Explanatory Notes. Heading 1302 covers vegetable extracts, including solid extracts produced by removal of extraction solvent; the addition of an inert material for handling, drying or standardisation does not alter the extract's classification. The manufacturing process comprised hydro-ethanolic extraction, filtration, vacuum drying and addition of Maltodextrin, without chromatographic purification, ultrafiltration, additional extraction cycles or other high-refinement processes. Vacuum drying was merely removal of solvent and did not constitute concentration or purification.

Analysis: The product consisted of one botanical extract and Maltodextrin functioning as an inert carrier, rather than two or more active therapeutic constituents mixed for therapeutic or prophylactic use. It was imported in bulk as raw material, not in measured doses or retail packs. Its intended use in pharmaceutical manufacture could not determine classification where the tariff description at import governed. The prior finding that the extract underwent concentration was unsupported by the record and was an apparent error of fact.

Conclusion: The goods are classifiable under Customs Tariff Item 1302 19 19 as other vegetable extracts, and not under Customs Tariff Item 3003 90 90, in favour of the assessee.

Issue (ii): Whether the goods qualify for the exemption under Serial No. 37 of Notification No. 45/2025-Customs dated 24.10.2025.

Analysis: Upon classification under Customs Tariff Item 1302 19 19, the goods fell within the relevant exemption entry. Availability of the concession remains dependent upon compliance with the notification conditions and assessment-stage verification.

Conclusion: The goods are eligible for the exemption under Serial No. 37 of Notification No. 45/2025-Customs dated 24.10.2025, in favour of the assessee.

Final Conclusion: The earlier advance ruling was modified by correcting the erroneous factual premise concerning concentration and by recognising the product as a simple vegetable extract with an inert carrier.

Ratio Decidendi: A single botanical extract remains classifiable as a vegetable extract where solvent removal and addition of an inert carrier do not amount to purification or create a medicinal mixture; downstream pharmaceutical use does not itself render it a medicament.

Issues: Whether the security-service provider could pursue its unpaid service claim in the ongoing corporate insolvency proceedings before the NCLT.

Analysis: The company is now undergoing the Corporate Insolvency Resolution Process before the NCLT. The claim for payment for security services may therefore be placed before that forum for consideration in the insolvency proceedings.

Conclusion: The petitioner may join the NCLT proceedings and submit its claim for unpaid security-service charges.

Issues: Whether dismissal of the applications seeking replacement of the interim resolution professional and consequential restraint on further Committee of Creditors proceedings warranted appellate interference.

Analysis: Appointment, continuation, or replacement of an interim resolution professional or resolution professional is governed by the statutory process under Sections 22 and 27 of the Insolvency and Bankruptcy Code, 2016, which entrusts the decision primarily to the requisite voting majority of the Committee of Creditors. The interim resolution professional is required to receive, verify and collate claims and maintain the creditor list; admission of claims of homebuyers resulting in reduction of other creditors' voting share, or admission of a claim for less than the amount claimed, does not by itself establish lack of integrity or justify removal. The professional entity's appointment and fees had been approved by the Committee of Creditors, and the resolution concerning the contract terms had not been acted upon pursuant to the earlier protective direction.

Analysis: Although conflict existed among creditor groups, the creditors in a class holding the majority voting share supported the interim resolution professional. The subsequent appointment of the interim resolution professional as resolution professional was not adjudicated because it arose after the impugned order, leaving parties to pursue available remedies before the appropriate forum. Replacement of the insolvency professional remains a Committee of Creditors-controlled process, and tribunal intervention is warranted only in exceptional circumstances; such circumstances were not established.

Conclusion: No ground was made out to interfere with rejection of the applications for replacement of the interim resolution professional or the consequential interim restraint.

Issues: Whether an adjudication order could be sustained where, after cancellation of registration, the show-cause notice was served only through the common portal and the assessee consequently remained unaware of the proceedings.

Analysis: The registration had been cancelled before issuance of the show-cause notice, which was uploaded solely through electronic mode more than three years later. The applicable departmental circular required physical service of notices where adjudication proceedings are initiated after cancellation of registration. Electronic portal service alone in those circumstances did not afford the assessee an effective opportunity to respond. A fresh opportunity was required to submit a reply, seek relied-upon documents or cross-examination, and participate in a personal hearing.

Conclusion: The ex parte adjudication order was unsustainable for want of effective service and adequate opportunity of hearing, in favour of the assessee.

Issues: Challenge to prohibition orders sealing the petitioner's premises pending GST search proceedings.

Outcome: The writ petition was disposed of by consent, without adjudicating the merits; the premises were directed to be de-sealed in the petitioner's presence and any search was to proceed in accordance with the applicable statutory procedure.

Outcome: Delay condoned and the Special Leave Petition dismissed; pending applications disposed of.

Issues: Whether the classification and duty consequences of imported sorbitol under the Advance Authorisation Scheme require fresh adjudication in light of the asserted fulfilment of export obligation and subsequently cited decisions.

Analysis: The appellant stated that sorbitol, imported for providing moisture to paste, was claimed under Chapter 2905, while certain import documents reflected Heading 382460 because of an admitted supplier error. The appellant relied on decisions said to establish that, where goods are imported under the Advance Authorisation Scheme and the export obligation is fulfilled, the department cannot dispute the goods imported. The Revenue did not oppose reconsideration of the matter in light of those decisions. Fresh examination by the adjudicating authority was therefore considered necessary.

Conclusion: The classification and consequential duty dispute is remitted for fresh adjudication after considering the cited decisions and further submissions of the appellant.

Issues: Whether the writ jurisdiction under Article 226 could be exercised to challenge a provisional attachment order under the Prevention of Money Laundering Act, 2002 on the alleged absence of a scheduled offence and alleged excess in the quantification of proceeds of crime.

Analysis: The statutory scheme provides a time-bound adjudication of provisional attachment, followed by appeals to the Appellate Tribunal and the High Court. Writ jurisdiction despite that remedy is confined to exceptional cases of patent arbitrariness, mala fides, or manifest lack of jurisdiction. The provisional attachment order referred to FIRs alleging cheating, which is a scheduled offence, and the Enforcement Directorate had contemporaneously transmitted information to the jurisdictional police under Section 66(2). A pre-registered case concerning the scheduled offence is not indispensable for provisional attachment under Section 5. The objections concerning advertisements directed outside India and the amount treated as proceeds of crime concern quantification and disputed facts, appropriately examinable in the statutory proceedings.

Conclusion: No manifest lack of jurisdiction was established; the challenges to the attachment, including the predicate-offence and quantification objections, must be pursued through the statutory remedies under the Prevention of Money Laundering Act, 2002.

Issues: Whether the appellant's documents concerning road repair and maintenance services required reconsideration for determining entitlement to service-tax exemption.

Analysis: The certificates and documents produced related to repair and maintenance of roads and were material to the exemption claim. Since those documents went to the root of the matter, the exemption claim required fresh examination by the original authority. The issue of limitation was not examined.

Outcome: The appeal was allowed and the matter was remanded to the original authority for de novo consideration on merits within three months.

Issues: (i) Whether the extended period of limitation could be invoked for demand of Service tax on royalty paid for mining rights; (ii) Whether Service tax was leviable on royalty paid after 01.04.2016 where the mining rights had been allotted before that date.

Issue (i): Whether the extended period of limitation could be invoked for demand of Service tax on royalty paid for mining rights.

Analysis: The entire demand for April 2016 to June 2017 was raised through a notice dated 20.10.2021 beyond the normal limitation period. Taxability of royalty for assignment of natural-resource rights was a contentious interpretational issue marked by conflicting views. The mining lease, royalty payments and relevant transactions were disclosed in statutory records, and the demand was based on the assessee's records. A bona fide belief regarding non-taxability did not establish suppression, fraud, wilful misstatement or intent to evade tax.

Conclusion: The extended period was not invocable; the demand was barred by limitation, in favour of the assessee.

Issue (ii): Whether Service tax was leviable on royalty paid after 01.04.2016 where the mining rights had been allotted before that date.

Analysis: The right to use natural resources was allotted and agreed to be provided on 03.02.2015, when the relevant Government service remained within the negative list. Execution of the formal lease deed after 01.04.2016 only continued the concluded arrangement and did not alter the date on which the mining rights were assigned. The Point of Taxation Rules could not enlarge the charging provision or make taxable a service that was not taxable when provided or agreed to be provided.

Conclusion: No Service tax was leviable on royalty paid after 01.04.2016 pursuant to mining rights allotted before that date; the tax demand, consequential interest and penalties were unsustainable, in favour of the assessee.

Final Conclusion: Royalty attributable to mining rights assigned before their exclusion from the negative list cannot be subjected to Service tax merely because payment was made subsequently, and the extended limitation period is unavailable absent suppression or intent to evade.

Ratio Decidendi: Taxability of assignment of natural-resource rights is determined when the right is provided or agreed to be provided; subsequent payment cannot attract Service tax where the assignment was then in the negative list, and a bona fide interpretational dispute does not justify extended limitation.

Issues: (i) Whether Cenvat credit of service tax could be denied merely because it was availed on a proforma invoice; (ii) Whether the extended period of limitation could be invoked for recovery of the Cenvat credit.

Issue (i): Whether Cenvat credit of service tax could be denied merely because it was availed on a proforma invoice.

Analysis: The service was admittedly rendered, the service provider had discharged the service-tax liability, and the proforma invoice contained the material particulars, including service-tax registration details, assessable value and tax amount. Subsequent regular invoices covering the same service and tax were also issued. Rule 9 requires material statutory particulars for credit, and credit cannot be denied where the underlying service, tax payment and requisite particulars are undisputed merely because the document is styled as a proforma invoice.

Conclusion: Cenvat credit was admissible on the proforma invoice. The issue is decided in favour of the assessee.

Issue (ii): Whether the extended period of limitation could be invoked for recovery of the Cenvat credit.

Analysis: The credit had been disclosed in the ER-1 return for March 2011, and the audit report of December 2012 had already quantified the disputed credit and recorded the tax payments and subsequent invoices. No material established suppression, nor was further investigation shown before issuance of the show-cause notice more than three years later. Disclosure in returns and departmental knowledge precluded invocation of the extended period.

Conclusion: The demand was barred by limitation, and the extended period was not invocable. The issue is decided in favour of the assessee.

Final Conclusion: The credit remains available and the proposed recovery cannot be sustained on limitation.

Ratio Decidendi: Where taxable service, payment of tax and material prescribed particulars are established, Cenvat credit cannot be denied solely because the supporting document is a proforma invoice; the extended limitation period requires evidence of suppression despite disclosure and departmental knowledge.

Issues: Whether compression of natural gas into cascades solely to transport it to customers, followed by decompression and sale as natural gas, constitutes manufacture of compressed natural gas liable to central excise duty; and whether penalties on the company and its Chairman-CEO consequently survive.

Issue (i): Whether compression of natural gas into cascades solely to transport it to customers, followed by decompression and sale as natural gas, constitutes manufacture of compressed natural gas liable to central excise duty.

Analysis: Note 5 to Chapter 27 deems compression of natural gas to be manufacture only where it is undertaken for marketing the gas as CNG. The established factual position was that compression was used solely to facilitate transportation in cascades; at the customers' premises the gas was decompressed through pressure-reducing skids and sold as natural gas at normal pressure. The Tribunal's earlier decision on identical facts and the analogous decision concerning compression of coal-bed methane for transport were applicable.

Conclusion: Compression solely for transportation, where the product is marketed and sold as natural gas rather than CNG, does not amount to manufacture under Section 2(f) of the Central Excise Act, 1944 read with Note 5 to Chapter 27 of the Central Excise Tariff Act, 1985. The excise-duty demand, interest and company penalty were set aside in favour of the assessee.

Issue (ii): Whether penalties imposed on the Chairman-CEO survive after the excise-duty demand against the company is set aside on merits.

Analysis: The personal penalties were consequential to the demand against the company, which was unsustainable on merits.

Conclusion: The penalties on the Chairman-CEO do not survive and were set aside in favour of the assessee.

Final Conclusion: The compression and transport arrangement did not create an excisable manufacture of CNG, and no consequential personal penal liability remained.

Ratio Decidendi: Compression of natural gas constitutes deemed manufacture only when undertaken for marketing the gas as CNG; compression exclusively to enable transportation, followed by sale after decompression as natural gas, is not manufacture.

Issues: (i) Whether umbrella panel fabric cut into triangular shape and size is classifiable as made-up textile articles under Heading 6307 or as woven synthetic filament fabric under Heading 5407; (ii) Whether the extended period under Section 28(4) could sustain the differential-duty demand.

Issue (i): Whether umbrella panel fabric cut into triangular shape and size is classifiable as made-up textile articles under Heading 6307 or as woven synthetic filament fabric under Heading 5407.

Analysis: Section Note 7 of Section XI treats articles cut otherwise than into squares or rectangles as "made-up". The imported triangular panels had acquired the essential character and commercial identity of umbrella panels rather than textile fabric. Heading 6307 specifically covers made-up textile articles, whereas Heading 5407 is a general heading for woven fabrics of synthetic filament yarn; the specific heading prevails.

Conclusion: The goods are classifiable under Heading 6307 as made-up textile articles and not under Heading 5407. The finding is in favour of the assessee.

Issue (ii): Whether the extended period under Section 28(4) could sustain the differential-duty demand.

Analysis: The goods' description and classification were fully declared in the Bills of Entry and the assessments were completed without objection. No suppression or misdeclaration was established; consequently, a classification dispute could not justify invocation of the extended period.

Conclusion: The entire demand was barred by limitation. The finding is in favour of the assessee.

Final Conclusion: The reclassification, differential customs duty, interest and penalty could not be sustained either on classification or limitation.

Ratio Decidendi: Textile fabric cut into non-rectangular panels that acquires the essential character and commercial identity of a finished made-up article is classifiable under the specific heading for made-up textile articles; an extended limitation period requires established suppression or misdeclaration and cannot rest on an openly declared classification dispute.

Issues: Whether penalty could be imposed on a customs broker's G-card holder under Section 112A for alleged involvement in the importation of restricted goods concealed in a consignment.

Analysis: The appellant had returned the import documents without clearing the goods after a mismatch between the declared description and the cargo was noticed, and had intimated Customs of the return. The cash credited to the appellant's account was explained as being used for customs duty, transportation and logistical expenses. The record did not establish that the appellant knew of, abetted, did, or omitted any act rendering the goods liable to confiscation.

Conclusion: Penalty under Section 112A was not sustainable and was set aside.

Issues: Whether weld mesh manufactured exclusively as top, bottom, side, door and partition components of poultry battery cages is classifiable as parts of poultry-keeping machinery under CETH 84369100 or as iron and steel structures under CETH 73089090.

Analysis: The goods were manufactured from galvanised iron wire to specified designs and were exclusively used as identifiable components of poultry battery cages. The proposed entry for iron and steel structures covers structural articles of the nature specified therein, whereas the Revenue did not provide convincing material or reasoning showing how the specialised weld-mesh cage components fell within that entry. Reliance on an earlier decision concerning poultry equipment was misplaced, since the subsequent appellate proceedings accepted classification under CETH 84369100.

Conclusion: The declared classification under CETH 84369100 is correct; rejection of that classification and proposed classification under CETH 73089090 are unsustainable.

Issues: (i) Whether the accused rebutted the statutory presumptions arising from admitted execution of the dishonoured cheque and disproved the legally enforceable debt; (ii) Whether the High Court could, in revisional jurisdiction, reverse concurrent findings of conviction by reappreciating the evidence.

Issue (i): Whether the accused rebutted the statutory presumptions arising from admitted execution of the dishonoured cheque and disproved the legally enforceable debt.

Analysis: Admission of the signature on the cheque attracted the mandatory presumptions of consideration and discharge of debt or liability. The complainant established compliance with the requirements for dishonour of cheque, including timely presentation, demand notice and non-payment. The defence that a blank cheque had been furnished as security for a different loan lacked supporting contemporaneous evidence; the later notice demanding return of the cheque was treated as an afterthought. The complainant's evidence concerning the loan and financial assistance received from others remained credible after cross-examination. Financial incapacity was not established merely from the complainant's monthly income, particularly when evidence showed other investments and financial assistance. The accused had neither replied to the demand notice raising that defence nor adduced cogent material to displace the presumptions.

Conclusion: The accused failed to rebut the presumptions or disprove the legally enforceable debt; the conviction for dishonour of cheque was justified.

Issue (ii): Whether the High Court could, in revisional jurisdiction, reverse concurrent findings of conviction by reappreciating the evidence.

Analysis: Revisional jurisdiction is supervisory and is not equivalent to appellate jurisdiction. Concurrent factual findings may be disturbed only where they are perverse, grossly erroneous, based on irrelevant or no material, or result from non-consideration of relevant material or arbitrary exercise of discretion. The High Court substituted its own assessment of the evidence without identifying any such defect in the concurrent findings.

Conclusion: The High Court exceeded its revisional jurisdiction in reversing the concurrent conviction.

Final Conclusion: The concurrent findings sustaining criminal liability for dishonour of cheque stand restored.

Ratio Decidendi: Once execution of a cheque is admitted, the statutory presumptions of consideration and discharge of liability operate unless displaced by cogent evidence; a revisional court cannot reappreciate evidence to overturn concurrent findings absent perversity or a jurisdictional defect.

Issues: Whether Notification No. 53/2023-Central Tax dated 02.11.2023 applied to an appeal filed after its issuance but before 31.01.2024, notwithstanding that the appeal had not previously been rejected as time-barred.

Analysis: Section 107 of the Central Goods and Services Tax Act, 2017 restricts the Appellate Authority's power to condone delay. Notification No. 53/2023-Central Tax, issued under Section 148, created a special procedure for appeals against orders under Sections 73 and 74 that could not be filed within the ordinary limitation period, appeals rejected solely for delay, pending appeals, and appeals filed within the extended cut-off date, subject to the prescribed payment conditions. The notification was intended to benefit taxpayers while securing collection of the admitted and prescribed disputed tax amounts. A taxpayer satisfying the payment conditions and filing before 31.01.2024 could not be denied that benefit merely because the appeal had not earlier been rejected on limitation. The Appellate Authority was required to take cognizance of the notification while deciding the appeal.

Conclusion: Notification No. 53/2023-Central Tax applied to the petitioner's appeal filed before 31.01.2024 upon fulfilment of its payment conditions; rejection solely on limitation was unsustainable.