Issues: (i) Whether the delay of 738 days in filing the appeal should be condoned; (ii) Whether rejection of the trust's application for regular registration was valid where its trust deed contemplated application of income for persons residing outside India.

Issue (i): Whether the delay of 738 days in filing the appeal should be condoned.

Analysis: The affidavit established a reasonable and bona fide cause for the delayed filing, arising from the absence of the person responsible for the trust's administrative and tax affairs. A liberal approach to limitation was applied to enable adjudication on merits.

Conclusion: The delay was condoned in favour of the assessee.

Issue (ii): Whether rejection of the trust's application for regular registration was valid where its trust deed contemplated application of income for persons residing outside India.

Analysis: The trust deed extended the intended application of income to persons residing outside India. Exemption for charitable expenditure was treated as confined to charitable activity in India, and the contemplated overseas application was therefore inconsistent with the statutory requirements for registration. No infirmity was found in the rejection of the application.

Conclusion: Rejection of regular registration was upheld against the assessee.

Final Conclusion: The trust remained ineligible for the sought regular charitable registration on the terms of its deed.

Ratio Decidendi: A trust seeking charitable registration must satisfy the statutory requirement that its exempt charitable application is confined to India; an object permitting application of income for persons outside India is incompatible with that requirement.

Issues: Whether the delay of 426 days in filing the appeal against cancellation of GST registration could be condoned and the appeal directed to be heard on merits despite the statutory limitation under the GST law.

Analysis: The delay was stated to have occurred due to bona fide and unavoidable financial hardship, and the Court accepted that the inability to file the appeal within time was beyond the petitioner's control. It also noted the consistent view taken in earlier decisions that, in appropriate cases, writ jurisdiction may be invoked to prevent denial of a remedy where rigid application of limitation would cause grave prejudice. The Court further relied on the principle that cancellation of GST registration can result in loss of livelihood, and that the statutory appellate authority has no unrestricted discretion beyond the prescribed ceiling under Section 107, but constitutional courts may grant relief in appropriate cases.

Conclusion: The delay was condoned, the appellate order rejecting the appeal as time-barred was set aside, and the appellate authority was directed to entertain the appeal and decide it on merits.

Issues: Whether imported lighting fixtures falling under CTH 9405 were entitled to the benefit of Sl. No. 226 of Notification No. 1/2017-Integrated Tax (Rate) dated 28.06.2017 describing "LED lights or fixtures including LED lamps", and whether the expression "including" permitted denial of the exemption on the ground that the goods were not fitted with LED lamps.

Analysis: The description in Sl. No. 226 was read according to its plain wording. The expression "including" was held to be enlarging in nature and not restrictive, so the entry could not be confined only to fixtures fitted with or containing LED lamps. The rejection of the benefit by importing words not found in the notification was found to be impermissible. Applying the settled rule that exemption notifications in fiscal law must be construed strictly on their own wording, the Tribunal concluded that the goods imported as lighting fixtures were covered by the notification.

Conclusion: The appellant was held entitled to the benefit of Notification No. 1/2017-Integrated Tax (Rate) dated 28.06.2017, and the denial of exemption was unsustainable.

Final Conclusion: The impugned demand and penalty were set aside and the appeal succeeded with consequential relief.

Ratio Decidendi: In a fiscal exemption entry, the word "including" is ordinarily expansive, and the notification must be applied on its plain language without adding words that restrict the stated coverage.

Issues: (i) Whether the provisional attachment of the properties of the appellant companies was justified on the basis that the funds and assets were traceable to proceeds of crime generated from the ABG Shipyard group transactions; (ii) Whether the plea based on corporate debt restructuring, the deed of assignment, and the assertion that the monies came from independent or surplus sources rebutted the statutory burden under the Prevention of Money Laundering Act, 2002.

Issue (i): Whether the provisional attachment of the properties of the appellant companies was justified on the basis that the funds and assets were traceable to proceeds of crime generated from the ABG Shipyard group transactions.

Analysis: The material on record showed a traced money trail from the alleged diversion of bank funds to group entities, paper companies, and finally to the assets and accounts of the appellants. The Tribunal relied on the investigation material, forensic audit findings, and statements recorded under the Act to hold that the properties were acquired through layered transactions and that several recipient entities had no genuine business activity. In respect of the family-linked assets, the Tribunal accepted that the attached properties represented proceeds or value equivalent of diverted funds used for purchase of flats and other immovable properties. The appellants failed to produce reliable material to dislodge the traced flow of funds.

Conclusion: The provisional attachments were upheld as being linked to proceeds of crime or their equivalent value.

Issue (ii): Whether the plea based on corporate debt restructuring, the deed of assignment, and the assertion that the monies came from independent or surplus sources rebutted the statutory burden under the Prevention of Money Laundering Act, 2002.

Analysis: The Tribunal held that restructuring documentation and the deed of assignment did not erase the underlying laundering trail, because the investigation disclosed circular fund movements, layering, and misuse of group entities. The statutory burden under Section 24 remained on the appellants, and the explanation that the transfers originated from surplus or independent sources was found unsubstantiated. The Tribunal further noted that the attachment could not be defeated merely by relying on subsequent internal adjustments or by characterising routed transactions as genuine when the surrounding material indicated laundering activity.

Conclusion: The defences based on restructuring and alleged independent source of funds were rejected.

Final Conclusion: The appellate challenge failed in entirety, and the confirmation of provisional attachment was sustained.

Ratio Decidendi: Where the investigation establishes a traced money trail, layering through group or paper entities, and the appellants do not discharge the burden of proving a legitimate source, provisional attachment under the money-laundering law is sustainable, and subsequent restructuring or internal assignment arrangements do not by themselves negate proceeds of crime.

Issues: (i) Whether zircon sand imported by the appellant was to be treated as "ore" or "concentrate" for the purpose of eligibility to the exemption under Notification No. 4/2006-CE dated 01.03.2006; (ii) Whether penalty under Section 112(a) of the Customs Act, 1962 was sustainable.

Issue (i): Whether zircon sand imported by the appellant was to be treated as "ore" or "concentrate" for the purpose of eligibility to the exemption under Notification No. 4/2006-CE dated 01.03.2006.

Analysis: The relevant tariff heading covered both zirconium ores and concentrates, but the exemption notification extended only to "ores". The meaning of "ore" and "concentrate" was drawn from Note 2 and Note 4 to Chapter 26 of the Central Excise Tariff Act, 1985, the HSN Explanatory Notes, and the Board's circulars. On that framework, concentrates are ores from which foreign matter has been removed by special treatments, and the statutory scheme treated conversion of ore into concentrate as manufacture. The imported goods were found to be zircon concentrate and not ore. The claim based on chemical composition alone was not accepted as the test.

Conclusion: The imported goods were correctly treated as concentrate and the appellant was not entitled to the exemption under Notification No. 4/2006-CE; the finding was against the appellant on this issue.

Issue (ii): Whether penalty under Section 112(a) of the Customs Act, 1962 was sustainable.

Analysis: The dispute turned on interpretation of the exemption notification and classification of the goods. The denial of cross-examination of the Chemical Examiner did not vitiate the order, but the case did not justify penal consequences because the controversy was essentially one of legal interpretation regarding eligibility to exemption.

Conclusion: Penalty under Section 112(a) was set aside and the appellant succeeded on this issue.

Final Conclusion: The classification and duty demand were upheld, but the penalty was deleted, resulting in only partial relief to the appellant.

Ratio Decidendi: For exemption notifications, the burden lies on the claimant to prove strict eligibility, and where the tariff scheme and HSN notes distinguish ore from concentrate, imported material that has undergone special treatment removing foreign matter is to be treated as concentrate and cannot claim an exemption limited to ores.

Issues: (i) Whether a recall application filed against an order passed on merits after participation of the appellant in the proceedings was maintainable, and whether the plea of non-impleadment, want of notice and denial of hearing could be sustained; (ii) Whether the appeal against the order rejecting recall and the appeal against the original order were barred by limitation and whether the benefit of Section 14 of the Limitation Act, 1963 could be invoked.

Issue (i): Whether a recall application filed against an order passed on merits after participation of the appellant in the proceedings was maintainable, and whether the plea of non-impleadment, want of notice and denial of hearing could be sustained.

Analysis: The order sought to be recalled recorded that the appellant's counsel had participated in the proceedings, advanced submissions, and the impugned order itself was directed to be communicated to the SRA. On that basis, the appellant was treated as having knowledge of the proceedings and having been heard. A recall is not available to reopen a merits order merely by asserting absence of formal impleadment or service where participation and hearing are evident from the record.

Conclusion: The recall application was not maintainable and its rejection was upheld.

Issue (ii): Whether the appeal against the order rejecting recall and the appeal against the original order were barred by limitation and whether the benefit of Section 14 of the Limitation Act, 1963 could be invoked.

Analysis: The challenge to the original order was raised beyond the prescribed period under Section 61(2) of the Insolvency and Bankruptcy Code, 2016. The appellant had first chosen the remedy of recall after expiry of the appeal period, and therefore could not claim exclusion of time under Section 14 of the Limitation Act for the earlier stages. The delay in filing the appeal against the original order was not condonable, while the appeal against the recall order failed on merits because the recall itself was impermissible.

Conclusion: The delay condonation plea failed, and both appeals were liable to be dismissed.

Final Conclusion: The Tribunal held that the appellant had participated in the proceedings, could not seek recall of a merits order on the pleaded grounds, and could not overcome the statutory limitation for challenging the original order, resulting in dismissal of both appeals.

Ratio Decidendi: A party who participated in proceedings and was heard cannot seek recall of a merits order on the ground of absence of notice or impleadment, and the statutory appeal limitation under the insolvency framework cannot be circumvented by first pursuing an impermissible recall remedy and then seeking exclusion of time.

Issues: Whether the impugned orders should be kept in abeyance to facilitate implementation of the approved settlement scheme for payment to investors, and what consequential directions were for effective implementation.

Analysis: The scheme had been approved by the concerned tribunals and this Court, and its stated object was to ensure payment of the settlement amount to entitled investors through an escrow mechanism under supervisory control. The Court noted that continued operation of the impugned orders and the need for further orders from designated courts and authorities could impede implementation. Considering the appellants' stated willingness to carry out the scheme in earnest, the Court directed that the impugned orders be kept in abeyance and that all concerned courts and authorities act expeditiously to enable implementation. The Court also fixed a timeline for deposit or transmission of the settlement amount into the escrow account after de-freezing of the relevant accounts.

Conclusion: The impugned orders were kept in abeyance and directions were issued to facilitate prompt implementation of the settlement scheme, which was in favour of the appellants.

Final Conclusion: The order enabled implementation of the approved settlement mechanism for investor payment by suspending the operation of the impugned orders and issuing coordinating directions to the concerned courts and authorities.

Ratio Decidendi: Where an approved settlement scheme is intended to secure payment to entitled stakeholders, the Court may keep conflicting orders in abeyance and issue ancillary directions to ensure timely implementation of the scheme.

Issues: (i) Whether EClerx Services Limited and Infosys BPO Limited were liable to be excluded from the final list of comparables for transfer pricing benchmarking; (ii) whether the arm's length rate of interest on overdue receivables from associated enterprises was to be computed at LIBOR plus 200 basis points; (iii) whether a 120-day credit period could be allowed for benchmarking interest on outstanding receivables.

Issue (i): Whether EClerx Services Limited and Infosys BPO Limited were liable to be excluded from the final list of comparables for transfer pricing benchmarking.

Analysis: The exclusion of the two companies was sustained on the footing that the assessee's functional profile had not materially changed and that the jurisdictional Tribunal had consistently excluded these comparables in earlier years in the assessee's own case. EClerx Services Limited was treated as a KPO concern and Infosys BPO Limited was treated as unsuitable because of huge turnover and related functional dissimilarities. The retention of one other comparable did not justify remand, as the exclusion of these two comparables was based on settled year-specific and case-specific reasoning already applied in the assessee's case.

Conclusion: The exclusion of EClerx Services Limited and Infosys BPO Limited was justified and is upheld in favour of the assessee.

Issue (ii): Whether the arm's length rate of interest on overdue receivables from associated enterprises was to be computed at LIBOR plus 200 basis points.

Analysis: The issue was treated as covered by the assessee's own earlier year decision, where the Tribunal had accepted LIBOR plus 200 basis points as the appropriate benchmark for interest on outstanding receivables from associated enterprises. The Tribunal found no reason to depart from that approach and rejected the Revenue's challenge to the use of the SBI short-term deposit rate as the benchmark.

Conclusion: The benchmark of LIBOR plus 200 basis points for interest on overdue receivables was upheld in favour of the assessee.

Issue (iii): Whether a 120-day credit period could be allowed for benchmarking interest on outstanding receivables.

Analysis: The Tribunal declined to accept a uniform 120-day credit period merely by reliance on other cases, holding that the credit period is fact-sensitive and cannot be applied mechanically across matters. It also rejected the alternative argument that section 92CE and Rule 10CB justify a 90-day credit period for ordinary receivables, as those provisions govern secondary adjustment after primary transfer pricing adjustments and do not prescribe the normal credit period for interest benchmarking. The appropriate credit period was directed to be taken from the assessee's own earlier year treatment.

Conclusion: The 120-day credit period was not approved, and the matter was directed to be aligned with the credit period applied in the assessee's own earlier year case.

Final Conclusion: The Revenue's appeals succeeded only in part. The exclusion of the disputed comparables and the LIBOR-based interest benchmark were sustained, while the assessee's claim for a blanket 120-day credit period was not accepted as such.

Ratio Decidendi: In transfer pricing matters, comparables may be excluded where binding precedent and unchanged functional profile show material dissimilarity, interest on delayed receivables may be benchmarked with LIBOR-based rates where earlier year decisions so hold, and the credit period for receivables must be determined on case-specific facts rather than by mechanical application of a uniform period.

Issues: Whether reassessment proceedings under sections 147 and 148 were valid when the approval under section 151 was neither manually nor digitally signed.

Analysis: The reassessment was founded on approval under section 151 granted electronically. The approval produced on record contained no manual signature and no digital signature certificate. The Tribunal held that signature on such approval is a mandatory safeguard, whether the document is issued physically or electronically. An unsigned approval does not constitute valid sanction for reopening, and the reassessment initiated on that basis fails for want of jurisdiction. As the reassessment was quashed, the merits of the addition did not require adjudication.

Conclusion: The reassessment proceedings were invalid and were quashed, and the addition was deleted in favour of the assessee.

Issues: (i) whether the production of FDG F-18 amounted to manufacture and whether the product was marketable so as to attract excise duty; (ii) whether FDG F-18 was correctly classifiable under Chapter Heading 2844 4000 or under Chapter Heading 3006 3000; (iii) whether the extended period of limitation and the valuation adopted in the impugned order were sustainable.

Issue (i): whether the production of FDG F-18 amounted to manufacture and whether the product was marketable so as to attract excise duty.

Analysis: The existence of third-party clearances established that the product had a market. Limited shelf life did not by itself negate marketability when evidence showed actual sale of the product. The process undertaken therefore resulted in manufacture of an excisable product.

Conclusion: This issue is decided against the assessee.

Issue (ii): whether FDG F-18 was correctly classifiable under Chapter Heading 2844 4000 or under Chapter Heading 3006 3000.

Analysis: FDG F-18 was treated as a radiopharmaceutical used in medical imaging and as a diagnostic reagent administered to patients. Such goods fall within Chapter 30 and not within the chapter covering radioactive elements and isotopes relied upon in the impugned order.

Conclusion: The impugned classification under Chapter Heading 2844 4000 is unsustainable and the product is classifiable under Chapter Heading 3006 3000, in favour of the assessee.

Issue (iii): whether the extended period of limitation and the valuation adopted in the impugned order were sustainable.

Analysis: The assessee acted under bona fide belief and there was no suppression warranting invocation of the extended period. The valuation methodology adopted for captive consumption and clearances to own branches and patients was not in accordance with the proper valuation framework, which required reference to the price at which goods were sold to independent buyers.

Conclusion: The extended period and the valuation adopted in the impugned order are unsustainable, in favour of the assessee.

Final Conclusion: The demand, classification, limitation, valuation, penalty, confiscation, and redemption fine did not survive, and the impugned order was set aside.

Ratio Decidendi: Actual third-party sales establish marketability despite a short shelf life, radiopharmaceutical diagnostic reagents are classifiable under Chapter 30, and absence of suppression precludes the extended period where the assessee acts under bona fide belief.

Issues: Condonation of a 720-day delay in filing the appeal against cancellation of GST registration and the consequential direction to the Appellate Authority to hear the appeal on merits.

Analysis: The delay occurred due to stated financial hardship and circumstances beyond the petitioner's control. The Appellate Authority is bound by the limitation structure under Section 107 of the Rajasthan Goods and Services Tax Act and cannot extend limitation beyond the statutory ceiling, but constitutional courts may in appropriate cases grant relief to avoid denial of the appellate remedy. The Court followed its earlier consistent view that where cancellation of GST registration affects business continuity and livelihood, a strict refusal to condone delay would cause grave prejudice.

Conclusion: The delay was condoned and the Appellate Authority was directed to entertain the appeal and decide it on merits, in favour of the assessee.

Outcome: The special leave petitions were dismissed on the grounds of delay and merits.

Issues: Whether the petitioner's refund claim arising from an inverted duty structure required reconsideration in light of the Supreme Court's ruling on the scope of Rule 89(5) of the Central Goods and Services Tax Rules, 2017, and whether the writ court should decide the refund computation on merits.

Analysis: The dispute concerned refund of unutilized input tax credit under Section 54(3) of the Central Goods and Services Tax Act, 2017, including the effect of the Supreme Court's decision in VKC Footsteps on the exclusion of input services from "Net ITC" under Rule 89(5). The Court noted that the matter was no longer to be examined on merits in the writ proceedings, and that the competent authority would have to consider the claim afresh in the light of the Supreme Court's decision. It further indicated that, if the authority disagreed with the computation, a speaking order with reasons should be passed expeditiously.

Outcome: The petition was disposed of with liberty for the petitioner to pursue a fresh decision before the competent authority.

Issues: (i) whether income from hybrid seed production carried on on leased land under seed production agreements was agricultural income exempt under section 10(1); (ii) whether the outstanding amounts of Rs. 23,643 could be added as unexplained cash credit under section 68; (iii) whether the balance difference of Rs. 8,95,024 in creditors' accounts could be taxed as unexplained expenditure.

Issue (i): whether income from hybrid seed production carried on on leased land under seed production agreements was agricultural income exempt under section 10(1).

Analysis: The agreements showed that the assessee had exclusive use of the land for seed production, bore the cultivation expenses and risk, and supervised the agricultural operations through coordinators and production supervisors. The activity covered land preparation, sowing, fertilisation, irrigation, pest control, harvesting and post-harvest handling, and the use of scientific or technical methods did not change the agricultural character of the operation. The definition of agricultural income under section 2(1A) was held wide enough to include income from such cultivation on leased land.

Conclusion: The issue was decided in favour of the assessee and the receipt was held to be agricultural income exempt under section 10(1).

Issue (ii): whether the outstanding amounts of Rs. 23,643 could be added as unexplained cash credit under section 68.

Analysis: The disputed amounts related to trade and professional creditors for expenses, not to loans or capital credits. The assessee had produced ledger confirmations and the payments were made in the subsequent year through banking channels, which supported the genuineness of the liabilities and showed that the section 68 conditions were not met.

Conclusion: The issue was decided in favour of the assessee and the addition under section 68 was deleted.

Issue (iii): whether the balance difference of Rs. 8,95,024 in creditors' accounts could be taxed as unexplained expenditure.

Analysis: The differences in balances were explained by discounts, freight adjustments, loss of goods and invoices recorded in the subsequent year. There was no material to show actual remission or cessation of liability, and the necessary foundation for invoking section 41(1) or treating the difference as unexplained expenditure was absent.

Conclusion: The issue was decided in favour of the assessee and the addition was deleted.

Final Conclusion: The appeal succeeded on the substantive additions relating to agricultural income, cash credits and creditor balance differences, while the disallowance ground that was not pressed was left undisturbed.

Ratio Decidendi: Income from hybrid seed production on leased agricultural land, carried on under the assessee's supervision with borne cultivation risk and agricultural operations, constitutes agricultural income; trade-credit balance differences explained by documentary reconciliation cannot be treated as unexplained cash credit or unexplained expenditure absent proof of remission or cessation of liability.

Issues: (i) Whether the goods cleared as packaged commodities meant for industrial or institutional consumers were liable to valuation under Section 4A of the Central Excise Act, 1944, or under Section 4 of that Act. (ii) Whether the demand was barred by limitation and the penalty was sustainable.

Issue (i): Whether the goods cleared as packaged commodities meant for industrial or institutional consumers were liable to valuation under Section 4A of the Central Excise Act, 1944, or under Section 4 of that Act.

Analysis: The goods were cleared with the declaration that they were not for retail sale and were meant for industrial or institutional use only. Rule 3 of the Legal Metrology framework excludes packaged commodities meant for industrial consumers or institutional consumers from the Chapter requiring MRP declaration. Where MRP declaration is not required, valuation on MRP basis under Section 4A does not apply, and the appropriate basis is transaction value under Section 4.

Conclusion: The goods were not liable to valuation under Section 4A and were correctly assessable under Section 4. This issue is decided in favour of the assessee.

Issue (ii): Whether the demand was barred by limitation and the penalty was sustainable.

Analysis: The show cause notice covered a period much earlier than its issuance, and the dispute turned on interpretation of the valuation provisions and the legal metrology exclusions. In the absence of sustainable grounds for extended limitation, the consequential penalty could not survive.

Conclusion: The invocation of the extended period was not sustainable and the penalty was also not sustainable. This issue is decided in favour of the assessee.

Final Conclusion: The valuation adopted by the appellant was upheld, and the demand, interest, and penalty were set aside with consequential relief.

Ratio Decidendi: Packaged commodities cleared exclusively for industrial or institutional consumers, and not required to bear MRP declaration under the applicable legal metrology rules, are not assessable under Section 4A of the Central Excise Act, 1944; in such cases, valuation must proceed under Section 4 on transaction value, and an extended limitation-based demand and penalty cannot be sustained on that footing.

Issues: Whether addition could be sustained solely on the basis of an unsigned seized excel sheet found from a third party's premises without corroborative material and without affording cross-examination.

Analysis: The seized excel sheet was treated as a dump document because it was unsigned, was not shown to bear the assessee's name, and was recovered from a third party. No independent material was brought on record to show actual receipt of unaccounted cash over and above the recorded contractual receipts. The denial of cross-examination of the person from whose premises the material was seized offended natural justice. The Tribunal also rejected the request to remand the matter for project valuation, holding that valuation was unrelated to the core controversy of alleged on-money receipts and had not been raised in the assessment proceedings. In the absence of corroboration, the seized material by itself was insufficient to justify the addition.

Conclusion: The addition based only on the seized excel sheet was deleted and the assessee obtained relief.

Final Conclusion: The revenue's challenge failed, while the assessees succeeded on the substantive issue relating to alleged unrecorded receipts; the remaining grounds were rendered academic.

Ratio Decidendi: An unsigned third-party document, unbacked by corroborative evidence and used without cross-examination, cannot by itself sustain an addition of undisclosed income.

Issues: Whether the inordinate delay in filing the appeals deserved condonation and whether any interference with the impugned orders was warranted on merits.

Analysis: The appeals were filed with an inordinate delay of 2626 and 2104 days. No justifiable reason was found to excuse the delay, and the request for condonation was rejected. The material on record was also examined and no basis for interference with the impugned orders was found.

Conclusion: The delay was not condoned and the appeals were dismissed both on the ground of delay and on merits.

Issues: (i) Whether the subject goods, described as a foam production line with 32 station conveyors including dry side and metering machine, are classifiable under Tariff Item 8477 10 00 as injection-moulding machines or under any alternative residuary heading; (ii) Whether Anti-Dumping Duty is payable on the subject goods under Notification No. 21/2025-Customs (ADD) dated 26.06.2025.

Issue (i): Whether the subject goods, described as a foam production line with 32 station conveyors including dry side and metering machine, are classifiable under Tariff Item 8477 10 00 as injection-moulding machines or under any alternative residuary heading.

Analysis: The subject goods constitute an integrated moulding system in which reactive liquid components are metered, injected into mould cavities, clamped, heated and cured to produce polyurethane foam. The process answers the commercial and functional description of injection moulding, including reaction injection moulding. Heading 8477 covers machinery for working plastics or for the manufacture of products from these materials, and the specific description in Tariff Item 8477 10 00 prevails over residual entries such as 8477 59 00, 8477 80 90 and 8479 89 99. As the goods are imported in CKD/SKD condition with all essential components presented together, Rule 2(a) requires treatment as complete machinery having the essential character of the finished article.

Conclusion: The subject goods are classifiable under Tariff Item 8477 10 00 as injection-moulding machines, and the alternative residuary classifications are not sustainable.

Issue (ii): Whether Anti-Dumping Duty is payable on the subject goods under Notification No. 21/2025-Customs (ADD) dated 26.06.2025.

Analysis: The notification applies to plastic processing or injection-moulding machines falling under tariff items 8477 10 00 and 8477 90 00 where the clamping force is not less than 40 tonnes and not more than 1500 tonnes, including machines imported in fully assembled, SKD or CKD form. On the facts found, each station exerts clamping force which, when assessed across the 32 integrated stations, results in an aggregate force within the notified range. The goods therefore fall within the product scope of the notification, and the producer is not among the specifically exempted listed producers.

Conclusion: Anti-Dumping Duty is applicable to the subject imports under Notification No. 21/2025-Customs (ADD) dated 26.06.2025.

Final Conclusion: The goods were held to be injection-moulding machinery classifiable under Tariff Item 8477 10 00, and they were also held liable to Anti-Dumping Duty under the cited notification.

Ratio Decidendi: A machine whose integrated function is the injection of reactive material into moulds for in-mould formation of a plastic product is classifiable under the specific injection-moulding entry, and if its aggregate clamping capacity falls within the notified range, anti-dumping duty applies notwithstanding CKD or SKD presentation.

Issues: Classification of the Integrated Dynamic Brake under heading 8708 or under the alternative headings 9032, 8413, or 8479.

Analysis: The product was found to be a 1-box electro-hydraulic brake system designed exclusively for motor vehicles, comprising sensors, ECU, valve block, motor, pump, reservoir, and related hydraulic components. The competing entries were examined against Rule 1 of the General Rules for Interpretation, the relevant Section and Chapter Notes, and the HSN Explanatory Notes. Heading 9032 was rejected because the goods did not answer the description of an automatic regulating or controlling instrument or apparatus, as the device was held not to autonomously regulate a variable at a preset value in the manner contemplated by Chapter 90. Heading 8413 was rejected because the pumping element was treated as only an integrated component of the brake module and not the essential character of the imported article. Heading 8479 was rejected because the article did not lack a specific description elsewhere and was not treated as a residual machine with an independent function. The article was held to be specifically covered by heading 8708 as a brake-related part/accessory for motor vehicles, and the exclusionary structure of Section XVII did not displace that conclusion.

Conclusion: The goods are classifiable under CTI 87089900.

Ratio Decidendi: Where an imported composite automotive unit is specifically identifiable as a motor-vehicle brake-related article and does not satisfy the conditions for Chapters 90, 84, or the residual heading, classification follows the specific vehicle-part entry under heading 8708.

Issues: Whether the moratorium under the personal insolvency resolution process had ceased so as to permit continuation of execution proceedings and attachment and sale of the judgment debtors' properties.

Analysis: Section 101 of the Insolvency and Bankruptcy Code, 2016 was construed strictly on its plain language. The moratorium is time-bound and ceases on the earlier of two events, namely expiry of 180 days from admission of the application or the date of an order on the repayment plan under Section 114 of the Insolvency and Bankruptcy Code, 2016. The provision does not contemplate extension of the moratorium beyond those contingencies. Once the moratorium ends, the statutory bar is lifted and ordinary creditor remedies revive. As the prescribed period had expired and no repayment plan order had been passed, there was no legal impediment to proceeding with the application.

Conclusion: The moratorium had ceased and the execution proceedings were maintainable. The properties, except the excluded property, were directed to be attached and sold, and the application was allowed.