Issues: Whether dismissal of the statutory appeal as time-barred was sustainable where the show-cause notice and adjudication order were uploaded only under the 'Additional Notice and Orders' tab without separate intimation.

Analysis: The materials indicated that the relevant notice and adjudication order were uploaded only in the specified portal tab and that no separate intimation was given. This prevented the petitioner from responding to the proceedings. As the appellate authority dismissed the appeal solely on limitation without considering its merits, the circumstances disclosed a violation of the principles of natural justice warranting interference.

Conclusion: The limitation-based appellate order was quashed, and the appeal was required to be admitted and decided afresh on merits after affording an opportunity of hearing.

Issues: Whether the penalty of Rs. 25,00,000 imposed for non-realisation of export proceeds could be sustained under Section 50 of the Foreign Exchange Regulation Act, 1973.

Analysis: Section 50 of the Foreign Exchange Regulation Act, 1973 prescribes only the maximum permissible penalty and requires the adjudicating authority to exercise its discretion reasonably, judicially, and with reasons demonstrating proportionality to the contravention. The Tribunal retained the original penalty despite excluding two guaranteed remittance forms already adjudicated and noting the RBI write-off of another form, without providing a reasoned basis for retaining the same quantum. The remaining contravention involved US$ 44,796.50, while an earlier adjudication concerning US$ 17,460 had attracted a penalty of Rs. 1,00,000.

Conclusion: The penalty of Rs. 25,00,000 was set aside as unreasoned and disproportionate, and was substituted with a penalty of Rs. 3,00,000.

Issues: (i) Whether an appeal under Section 35G against a procedural implementation direction issued under Rule 41 was maintainable, and whether the Tribunal exceeded its jurisdiction by issuing that direction; (ii) Whether service tax paid on the drinking-water project was a payment under mistake of law, disentitling the Revenue from invoking the limitations applicable to duty refunds; (iii) Whether interest on the refund was payable from three months after the original refund applications rather than from submission of subsequent administrative documents; (iv) Whether compensatory interest at 9% was valid notwithstanding Notification No. 24/2014-C.E. (N.T.).

Issue (i): Whether an appeal under Section 35G against a procedural implementation direction issued under Rule 41 was maintainable, and whether the Tribunal exceeded its jurisdiction by issuing that direction.

Analysis: Section 35G permits an appeal only from an order passed by the Tribunal in appeal under Sections 35B and 35C. A direction under Rule 41 to implement an earlier final order is procedural and connected with securing the ends of justice; it is not an order passed in appeal. Rule 41 validly enabled consequential directions necessary to ensure that the final refund order was effective.

Conclusion: The appeal under Section 35G was not maintainable, and the Tribunal acted within its jurisdiction in issuing the Rule 41 direction, in favour of the assessee.

Issue (ii): Whether service tax paid on the drinking-water project was a payment under mistake of law, disentitling the Revenue from invoking the limitations applicable to duty refunds.

Analysis: Laying potable-water pipelines for a statutory water authority under a public-welfare project did not constitute taxable commercial or industrial construction service. The amount paid consequently lacked the character of tax or duty and was paid under a mistake of law. Such collection is inconsistent with Article 265, and the restrictive procedural limitations applicable to duty refunds under Section 11B do not govern its restitution.

Conclusion: The payment was made under a mistake of law and was refundable without application of the restrictive limitation framework for duty refunds, in favour of the assessee.

Issue (iii): Whether interest on the refund was payable from three months after the original refund applications rather than from submission of subsequent administrative documents.

Analysis: Liability for interest under Section 11BB commences automatically on expiry of three months from receipt of the original refund application, not from an appellate order or a later implementation request. The later communication and documents were follow-up material for implementing the original claims and did not constitute fresh refund applications.

Conclusion: Interest was payable from expiry of three months after the original 2012 refund applications, in favour of the assessee.

Issue (iv): Whether compensatory interest at 9% was valid notwithstanding Notification No. 24/2014-C.E. (N.T.).

Analysis: Since the refundable amount was paid under a mistake of law and did not bear the character of duty, the statutory 6% rate under the notification did not restrict the compensatory interest payable. The prolonged withholding of the amount justified the 9% rate awarded for compensation.

Conclusion: Compensatory interest at 9% was valid and was not contrary to Notification No. 24/2014-C.E. (N.T.), in favour of the assessee.

Final Conclusion: The Tribunal's implementation direction for refund interest remained legally effective, with the assessee entitled to restitution and compensatory interest calculated from the original refund claims.

Ratio Decidendi: A procedural direction under Rule 41 for implementation of a final Tribunal order is not appealable under Section 35G, and interest on a refund claim accrues from expiry of three months after the original application where the delayed refund arises from a payment made under mistake of law.

Issues: Whether ex parte appellate orders passed after the company's winding up, without notice to or hearing through the liquidator, could be sustained.

Analysis: Section 279 of the Companies Act, 2013 provides that pending legal proceedings by or against a company in winding up cannot be proceeded with except with the Tribunal's leave. The provision expressly encompasses proceedings pending on the date of the winding-up order. Following winding up, the liquidator steps into the company's position, and an effective opportunity to prosecute the pending appeals must be afforded through the liquidator. The appellate orders had been passed ex parte without considering the company's case.

Conclusion: The ex parte appellate orders were set aside, and the appeals were remitted for fresh adjudication after notice and personal hearing to the liquidator.

Outcome: The Special Leave Petition was disposed of without interference, with clarification that the Appellate Authority shall decide the case on its own merits.

Issues: (i) Whether the Order-in-Original was barred by limitation under Section 28(9) read with Section 28(9A) of the Customs Act, 1962; (ii) Whether writ jurisdiction should be exercised despite the available statutory appellate remedy and the petitioners' conduct during adjudication.

Issue (i): Whether the Order-in-Original was barred by limitation under Section 28(9) read with Section 28(9A) of the Customs Act, 1962.

Analysis: For a notice issued under Section 28(4), Section 28(9)(b) prescribes a one-year determination period, extendable under its first proviso. Section 28(9A) independently provides that, where an enumerated circumstance prevents determination, the statutory period runs from cessation of that circumstance. The pending writ concerning extension of the export-obligation period and substitution of duty-free inputs, together with the operative interim protection, was directly germane to the customs adjudication and fell within Section 28(9A)(b). The transfer to the Call Book was consequential and did not itself create the statutory exclusion. The noticees had themselves sought deferment on that precise basis and were fully aware of the reason for non-determination; thus, the purpose of the communication requirement stood substantially fulfilled. An administrative Call Book circular could not displace the statutory consequence under Section 28(9A).

Conclusion: The Order-in-Original was passed within the statutory period reckoned from cessation of the circumstance under Section 28(9A)(b); the limitation challenge fails against the assessee.

Issue (ii): Whether writ jurisdiction should be exercised despite the available statutory appellate remedy and the petitioners' conduct during adjudication.

Analysis: Writ jurisdiction under Article 226 is discretionary and equitable, particularly where an efficacious statutory appeal is available. The petitioners did not contest the substantive adjudicatory findings, sought deferment of adjudication because of the pending writ proceedings, reserved a right to file a substantive reply thereafter, and did not communicate the cessation of the circumstance on which deferment was sought. The principle against approbation and reprobation precluded an equitable advantage from the delay occasioned by their own request for deferment.

Conclusion: Extraordinary writ relief was declined against the assessee, who may pursue available merits-based contentions before the statutory appellate authority.

Final Conclusion: The customs adjudication remains legally operative, with the merits of the duty demand open for examination through the prescribed appellate mechanism.

Ratio Decidendi: Where an enumerated circumstance under Section 28(9A) prevents customs adjudication, the limitation period under Section 28(9) runs from cessation of that circumstance; a consequential Call Book entry or administrative circular cannot override that statutory consequence.

Issues: Whether written acceptance of enhanced customs valuation dispenses with a speaking order and precludes the importer from challenging the reassessment and rejection of the declared transaction value.

Analysis: Written acceptance under Section 17(5) is confined to dispensing with the procedural requirement of a speaking order on reassessment; it does not amount to an unconditional waiver of the statutory right to appeal under Section 128 or to contest the legality and merits of the enhancement. Rejection of transaction value requires compliance with Section 14 and Rule 12(2), including written communication of grounds for doubting the declared value. Consent letters referring generally to contemporaneous imports, without disclosure of comparable data concerning quantity, quality and contemporaneity, do not establish a voluntary abandonment of valuation rights. Acquiescence cannot defeat rights conferred by statute, and the ruling concerning mandamus for a speaking order does not bar an appeal challenging reassessment.

Conclusion: Written acceptance waived only the speaking order and did not foreclose the statutory challenge to enhanced valuation; the reassessment and appellate rejection founded solely on such acceptance were unsustainable. The issue is decided in favour of the assessee.

Issues: Whether a warrant of arrest could be issued against accused persons already on bail, without first issuing summons after transfer of the complaint to the Special Court.

Analysis: The accused persons were on bail and had not been given an opportunity to appear before the transferee Special Court. The statutory transfer of jurisdiction to the Special Court did not justify immediate issuance of an arrest warrant. The proper course was to issue summons initially and thereafter adopt lawful coercive measures to secure attendance only if required.

Conclusion: The arrest warrant issued without first serving summons was illegal and was set aside.

Issues: (i) Whether the financial creditor's application under Section 7 was barred by limitation; (ii) Whether the failed revival scheme and pending winding-up proceedings precluded continuation of the insolvency proceedings.

Issue (i): Whether the financial creditor's application under Section 7 was barred by limitation.

Analysis: Although Article 137 prescribes a three-year limitation period from default, the corporate debtor's continuing failure to deliver possession or refund the amounts constituted a continuing breach and subsisting default. The revival scheme also acknowledged the financial creditor's claim, furnishing acknowledgment of liability and supporting extension of limitation.

Conclusion: The Section 7 application was not time-barred; this issue is decided in favour of the respondent.

Issue (ii): Whether the failed revival scheme and pending winding-up proceedings precluded continuation of the insolvency proceedings.

Analysis: The revival scheme had become unworkable and was set aside. The High Court thereafter directed revival of proceedings under the Insolvency and Bankruptcy Code, 2016, and granted liberty to pursue further proceedings before the NCLT. Proceedings under Section 7 operate independently and were not barred by the earlier winding-up and revival-scheme proceedings.

Conclusion: The failed revival scheme and winding-up proceedings did not prevent continuation of the Section 7 insolvency proceedings; this issue is decided in favour of the respondent.

Final Conclusion: The corporate debtor remains subject to the insolvency resolution process initiated on the established debt and default.

Ratio Decidendi: A continuing failure to deliver possession or refund amounts, coupled with acknowledgment of liability, keeps a financial creditor's insolvency claim within limitation despite an earlier default.

Issues: Whether bail should be granted in a money-laundering prosecution despite the restrictions under Section 45 of the Prevention of Money Laundering Act, 2002.

Analysis: The allegations of impersonation, forgery and extortion were serious, and the material did not establish satisfaction of the statutory restrictions ordinarily applicable to bail. However, custody exceeding one year could outweigh the rigours of the twin conditions in an appropriate case. Relevant mitigating circumstances were that bail had already been granted in the predicate-offence case, investigation of that case remained pending, and parts of the material relied on in the money-laundering case concerned matters not necessarily forming part of the predicate offence. The progressing trial and potential risk to witnesses warranted safeguards to secure attendance and protect the proceedings.

Conclusion: The prolonged custody and mitigating circumstances justified grant of bail subject to safeguards for the trial.

Issues: (i) Whether renting of vacant land for business or commerce was taxable before and after 01.07.2010; (ii) Whether a one-time lease premium or salami was taxable as consideration for renting of immovable property; (iii) Whether the extended period of limitation and penal action could be invoked against a governmental authority in the absence of evidence of intent to evade tax.

Issue (i): Whether renting of vacant land for business or commerce was taxable before and after 01.07.2010.

Analysis: The pre-01.07.2010 statutory scheme excluded vacant land from taxable renting of immovable property. The amended scheme brought leasing or licensing of vacant land for construction of structures used in business or commerce within the taxable service from 01.07.2010.

Conclusion: Renting of vacant land was not taxable before 01.07.2010, but became taxable from that date. The conclusion is in favour of the assessee for the pre-01.07.2010 period.

Issue (ii): Whether a one-time lease premium or salami was taxable as consideration for renting of immovable property.

Analysis: A lease transfers the right to enjoy immovable property for consideration; the upfront price is premium and the recurring payment is rent. Since renting of immovable property includes leasing, the consideration in the form of a one-time premium forms part of the taxable value of the leasing transaction.

Conclusion: One-time lease premium or salami received for leasing immovable property is chargeable to service tax both before and after 01.07.2012. The conclusion is against the assessee.

Issue (iii): Whether the extended period of limitation and penal action could be invoked against a governmental authority in the absence of evidence of intent to evade tax.

Analysis: Invocation of the extended limitation period requires a conscious and deliberate suppression or misstatement with intent to evade tax. The governmental status of the assessee, absence of positive evidence of mala fide intent, and its bona fide understanding regarding taxability precluded an inference of wilful suppression. Penal action is not warranted for a technical or venial breach arising from a bona fide belief.

Conclusion: The extended period was not invocable and the related demands and penal proceedings were rightly dropped. The conclusion is in favour of the assessee.

Final Conclusion: The deletion of the demands pertaining to the extended period and the consequential penalty proceedings remains undisturbed.

Ratio Decidendi: Extended limitation and penalties require proof of conscious, deliberate suppression with intent to evade tax; mere non-compliance founded on a bona fide belief, without such evidence, is insufficient.

Issues: (i) Whether the service-tax liability for the disputed years was required to be recomputed by treating the consideration received as cum-tax consideration; (ii) Whether the service-tax demand for 2017-18, computed from contractual amounts in the absence of returns and balance sheets, was sustainable.

Issue (i): Whether the service-tax liability for the disputed years was required to be recomputed by treating the consideration received as cum-tax consideration.

Analysis: Where service tax has not been paid and there is no evidence that it was separately collected from service recipients, the consideration received must be regarded as inclusive of service tax. The tax component must consequently be worked out by extending cum-tax benefit.

Conclusion: Cum-tax benefit was available to the assessee for the relevant disputed years.

Issue (ii): Whether the service-tax demand for 2017-18, computed from contractual amounts in the absence of returns and balance sheets, was sustainable.

Analysis: In the absence of income-tax returns and balance sheets for the period, and without any figures from the assessee showing services rendered or consideration received, the available contractual amounts constituted the proper basis for best-judgment determination of liability. Such computation nevertheless required extension of cum-tax benefit.

Conclusion: The determination based on contractual amounts was sustained, subject to recomputation after granting cum-tax benefit to the assessee.

Final Conclusion: The service-tax liability, interest and mandatory penalty require recalculation on a cum-tax basis, while the contractual-value basis for the 2017-18 demand remains valid.

Ratio Decidendi: In the absence of evidence of separate recovery of service tax, consideration received for taxable services must be treated as cum-tax consideration; where the assessee provides no contrary financial particulars, liability may be determined from the best available contractual material.

Issues: (i) Whether skill-development services rendered through an NSDC-approved training partner qualified for exemption under paragraph 9A(iv) of Notification No. 25/2012-ST; (ii) whether distance-learning degree courses conducted under a university curriculum qualified for the education exemption under Section 66D(l)(ii) of the Finance Act, 1994; (iii) whether the extended period of limitation could be invoked for the demand relating to Financial Year 2015-16.

Issue (i): Whether skill-development services rendered through an NSDC-approved training partner qualified for exemption under paragraph 9A(iv) of Notification No. 25/2012-ST.

Analysis: The exemption applies to services provided by an NSDC-approved training partner in relation to the specified NSDC programmes. The appellant was an authorised learning centre of an NSDC-approved training partner, but was not itself approved by NSDC and had provided services to that training partner. There was no tripartite arrangement establishing direct authorisation under the NSDC scheme. The exemption entry was required to be construed strictly, with the burden resting on the claimant to establish fulfilment of its conditions.

Conclusion: The exemption was unavailable, and the demand on the skill-development services was sustainable for the normal period. This issue was decided against the assessee.

Issue (ii): Whether distance-learning degree courses conducted under a university curriculum qualified for the education exemption under Section 66D(l)(ii) of the Finance Act, 1994.

Analysis: Section 66D(l)(ii) exempts education forming part of a curriculum leading to a qualification recognised by law. The provision does not require that the educational service must be provided by the university itself. The courses conducted by the appellant formed part of degree programmes run by the university and led to recognised qualifications.

Conclusion: The distance-learning educational services qualified for exemption under Section 66D(l)(ii) of the Finance Act, 1994, and the related demand was set aside. This issue was decided in favour of the assessee.

Issue (iii): Whether the extended period of limitation could be invoked for the demand relating to Financial Year 2015-16.

Analysis: The show cause notice issued in April 2021 sought to recover tax for Financial Year 2015-16. Following consideration of the documents subsequently produced, only a small part of the originally proposed demand survived. This did not establish fraud, wilful misstatement, or suppression of facts with intent to evade tax, which is necessary for invocation of the extended period.

Conclusion: The extended period was not invocable, and the demand for that period was set aside. This issue was decided in favour of the assessee.

Final Conclusion: Only such service-tax liability as may fall within the normal limitation period for the non-exempt skill-development services remains sustainable; the university-course demand and the time-barred demand do not survive.

Issues: Whether statutory interest on a refund is payable from the expiry of three months from the original refund application, or only from the subsequent appellate order or a later communication treated as a fresh refund claim.

Analysis: Section 11BB of the Central Excise Act, 1944 makes interest payable where a refundable amount is not paid within three months of receipt of the application under Section 11B. The deeming fiction concerning an appellate or court order granting refund does not postpone the commencement of interest. Section 83 of the Finance Act, 1994 applies this refund mechanism to the relevant service-tax claim. The original application was filed on 20 May 2015, and the later communication was merely a continuation or reminder of that claim, not a fresh application.

Conclusion: Statutory interest was payable to the assessee from 20 August 2015, being the expiry of three months from the original refund application, until the date of actual refund; the denial of such interest was unsustainable.

Issues: (i) Whether the substituted pre-deposit proviso in Section 107(6) applies to appeals arising from show-cause notices issued before 01.10.2025; (ii) Whether writ jurisdiction should be exercised despite the statutory appeal, including on the alleged incompetence of the officer initiating Section 122 proceedings.

Issue (i): Whether the substituted pre-deposit proviso in Section 107(6) applies to appeals arising from show-cause notices issued before 01.10.2025.

Analysis: The conditions governing a statutory appeal are governed by the law prevailing when the adjudicatory proceedings commence. Every show-cause notice in the batch had been issued before 01.10.2025, when the substituted proviso was brought into force. The amended pre-deposit condition therefore could not govern the resulting appeals.

Conclusion: The substituted proviso to Section 107(6) does not apply to the appeals; they are governed by the pre-deposit provision in force on the respective dates of the show-cause notices, in favour of the petitioners.

Issue (ii): Whether writ jurisdiction should be exercised despite the statutory appeal, including on the alleged incompetence of the officer initiating Section 122 proceedings.

Analysis: The proper-officer objection required construction of the function-specific definition in Section 2(91), the powers under Sections 3 and 5, Notification No. 02/2017-Central Tax, Notification No. 14/2017-Central Tax and the subsequent Circular dated 27.10.2025. The notifications investing DGGI officers with powers corresponding to their rank prevented the objection from establishing a patent lack of jurisdiction. The remaining challenges concerning evidence, natural justice, individual roles, quantification and multiple penalties involved extensive disputed factual material suitable for the appellate forum. The statutory appeal was efficacious because the amended pre-deposit requirement was inapplicable.

Conclusion: No exceptional ground justified bypassing the alternative remedy under Section 107; the jurisdictional and other challenges may be raised before the Appellate Authority, against the petitioners.

Final Conclusion: The appellate forum must determine the parties' factual and legal objections independently, while applying the pre-amendment pre-deposit regime to these appeals.

Issues: Whether the CIRP could be brought to an end in the exceptional circumstances where all creditors' claims stood settled or were agreed to be settled, but withdrawal under the prescribed Section 12A mechanism was impracticable because the CIRP costs remained undetermined and Form FA with the requisite bank guarantee could not be furnished.

Analysis: Section 12A of the Insolvency and Bankruptcy Code, 2016 read with Regulation 30A of the Insolvency Resolution Process for Corporate Persons Regulations, 2016 ordinarily requires a withdrawal proposal through the initiating applicant in Form FA, supported by the prescribed approval and security towards CIRP costs. The earlier withdrawal request did not fulfil those requirements. Subsequently, however, the sole financial creditor was paid in full, the operational creditor agreed to accept an enhanced full-and-final settlement, no resolution plan was available, and the appellant gave a binding undertaking to pay CIRP costs as determined in the pending cost-determination proceedings. The uncrystallised CIRP costs and the operational creditor's unwillingness to provide the bank guarantee created a procedural stalemate, making the statutory withdrawal route infeasible. Continued CIRP in those circumstances would not advance the insolvency resolution objective and would only increase CIRP costs.

Conclusion: In the peculiar circumstances, the inability to complete the formal Section 12A withdrawal process did not warrant continuation of the CIRP after settlement of creditor claims and protection of the Resolution Professional's entitlement to CIRP costs through their adjudication and payment.

Issues: Whether the personal guarantor's application under Section 94 of the Insolvency and Bankruptcy Code, 2016 was a bona fide invocation of the personal insolvency resolution process or an abuse of the interim moratorium to obstruct enforcement proceedings.

Analysis: Section 94 permits a personal guarantor in default to initiate an insolvency resolution process and submit a repayment plan, while Section 96 provides an interim moratorium. The process is intended for genuine resolution and cannot be used merely as a device to impede a financial creditor's lawful enforcement of security. The first application was withdrawn after the guarantor had received the benefit of interim moratorium for about two years. The second application was filed immediately after a fresh possession notice was issued following cessation of that moratorium, and no genuine repayment effort was made during the intervening period. The timing and conduct established that both applications were intended to stall possession and recovery proceedings rather than resolve the guarantor's insolvency.

Conclusion: The Section 94 application was rightly rejected as an abuse of the insolvency process and interim moratorium, against the personal guarantor.

Issues: (i) Whether the service tax demand confirmed in the impugned order is sustainable on merits? (ii) Whether the extended period and the consequential interest, late fee and penalties are sustainable?

Issue (i): Whether the service tax demand confirmed in the impugned order is sustainable on merits?

Analysis: Under Section 67 of the Finance Act, 1994, service tax liability requires identification and classification of the taxable service and determination of taxable value. Discrepancies between financial statements, income-tax records and ST-3 returns may warrant inquiry but cannot, without correlation to underlying agreements, invoices, work orders and contemporaneous records, establish that receipts are consideration for taxable services. The demand substantially rested on such accounting differences, while the explanations and reconciliation material were not objectively verified. The materially identical earlier decision concerning the same assessee was followed in the absence of any demonstrated distinguishing fact or contrary higher authority. The admitted amount was separately identifiable.

Conclusion: The disputed demand is unsustainable and is set aside in favour of the assessee; service tax of Rs.8,96,535, being the admitted liability, is sustained with applicable interest under Section 75 of the Finance Act, 1994, subject to adjustment of amounts already paid.

Issue (ii): Whether the extended period and the consequential interest, late fee and penalties are sustainable?

Analysis: The proviso to Section 73(1) of the Finance Act, 1994 requires proof of fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade tax before the extended period may be invoked. The proceedings arose from the assessee's disclosed statutory and financial records, without incriminating material or independent evidence of deliberate concealment. Transitional arrangements for ST-3 returns also meant that delay or discrepancies in return filing could not by themselves establish suppression. The earlier decision on substantially identical facts also precluded invocation of the extended period. As the statutory ingredients for suppression were not established, penalty under Section 78 could not be sustained.

Conclusion: Invocation of the extended period and penalty under Section 78 are unsustainable in favour of the assessee; interest remains payable only on the admitted service-tax liability.

Final Conclusion: The impugned order stands modified so that only the admitted tax liability, with statutory interest, survives, while the unestablished demand and suppression-based penal consequence do not.

Ratio Decidendi: A service-tax demand and extended limitation cannot rest solely on accounting discrepancies in disclosed records; the Department must establish taxable service, taxable value, and, for the extended period, deliberate suppression with intent to evade tax.

Issues: Whether the applicant should be granted bail pending investigation into alleged evasion of customs and anti-dumping duty through use of allegedly invalid certificates of origin.

Analysis: The investigation was substantially documentary in nature, the applicant had remained in judicial custody for 31 days, and his father, alleged to have handled import-related work, was also in custody. The later supplier communications and revised origin documents required verification, which could be undertaken while requiring the applicant's attendance. The apprehension that the applicant would independently tamper with evidence was found unsupported, as relevant documents had been seized and the principal connected person was in custody.

Outcome: Bail granted on conditions, including execution of bond, cooperation with investigation, attendance when called, surrender of passport, and restrictions on travel abroad.