Issues: Whether deletion of the addition for an alleged accommodation entry and consequential commission was justified where the addition rested on a third-party statement without cross-examination despite documentary proof of a short-term loan and its repayment.

Analysis: The addition was founded substantially on the statement of the alleged entry provider, while the assessee furnished lender details, ledger records, bank evidence and an affidavit supporting the identity, creditworthiness and genuineness of the short-term advance. The advance was repaid through banking channels within 32 days. The statement could not be used against the assessee because the requested opportunity to cross-examine its maker was not provided; excluding that statement, no cogent material remained to displace the documentary evidence. An addition for unexplained credit cannot rest on suspicion where the primary evidentiary burden has been discharged and no independent contrary enquiry or material is produced.

Conclusion: The deletion of the alleged accommodation-entry addition and consequential commission was sustained in favour of the assessee.

Issues: (i) Whether penalty for concealment could be levied on additional income voluntarily disclosed in the return filed under Section 153A and accepted without variation; (ii) Whether penalty could be levied on an estimated addition made in an unabated assessment without incriminating material found during search.

Issue (i): Whether penalty for concealment could be levied on additional income voluntarily disclosed in the return filed under Section 153A and accepted without variation.

Analysis: A return filed in response to notice under Section 153A is to be treated as a return furnished under Section 139. The additional income disclosed during search was included in that return and was accepted after payment of tax, with no difference between the returned and assessed income. No incriminating material connected with the disclosure was found. The conditions for levy of penalty under Section 271(1)(c), including deemed concealment under Explanation 5A, were therefore not met.

Conclusion: Penalty on the voluntarily disclosed and accepted income was not leviable, in favour of the assessee.

Issue (ii): Whether penalty could be levied on an estimated addition made in an unabated assessment without incriminating material found during search.

Analysis: In an unabated assessment, an addition pursuant to search requires incriminating material seized during the search. The further addition was made on an estimated basis without such material and was consequently unsustainable. Penalty could not survive on an unsustainable estimated addition.

Conclusion: Penalty on the estimated addition was not leviable, in favour of the assessee.

Final Conclusion: The deletion of penalties for both assessment years remains effective.

Ratio Decidendi: Penalty for concealment cannot be imposed where income disclosed in a Section 153A return is accepted without variation, or where the underlying addition in an unabated search assessment lacks incriminating material.

Issues: Whether an adjudication order imposing customs penalty can be sustained when it relies on non-existent, falsely cited, or hallucinated AI-generated precedents.

Analysis: Reliance on unverified AI-generated material presented as judicial precedent undermines the sanctity and integrity of adjudication. AI may be used only as an assistive tool and cannot replace adjudicatory responsibility; any precedent generated through AI must be independently verified before being relied upon.

Conclusion: An order tainted by reliance on fake, non-existent, or hallucinated AI-generated precedents is unsustainable and requires fresh adjudication by a different officer of equivalent rank.

Issues: Whether writ jurisdiction should be exercised against a customs adjudication order despite the statutory appellate remedy and substantial delay.

Analysis: Exercise of jurisdiction under Article 226 despite an alternative statutory remedy is exceptional and should not defeat the statutory appellate scheme or its limitation period. The contemporaneous record indicated participation in the adjudication process, including an acknowledgment of an oral show cause notice and waiver of written notice and personal hearing. The allegations concerning coercion, the validity of the statements, procedural compliance and service of the order involved disputed factual questions suitable for the statutory appellate authority. Dispatch by speed post was also relevant under the statutory deeming provision, and no exceptional circumstance was established despite the delay.

Conclusion: No exceptional ground warranted bypassing the appellate remedy under Section 128 of the Customs Act, 1962.

Issues: Whether release of the detained gold was warranted under Section 110(2) upon expiry of the initial six-month period for issuance of a show-cause notice.

Analysis: Section 110(2) requires return of seized goods only where notice under Section 124(a) is not issued within the prescribed period, including a period validly extended under its proviso. The extension was granted before expiry of the initial period, and the written show-cause notice was issued on 23.02.2026, before expiry of the extended period on 25.02.2026. The petition was also instituted while that extended period remained operative. The challenges to the extension, the alleged waiver, and the evidentiary status of the statement involve matters that were not required to be adjudicated for the limited relief sought and remain open for the statutory adjudication.

Conclusion: Release under Section 110(2) was not available because the show-cause notice was issued within the extended statutory period.

Issues: Whether the winding-up of the company should be permanently stayed under Section 466 of the Companies Act, 1956 on the basis of the proposed revival and redevelopment scheme.

Analysis: Section 466 of the Companies Act, 1956 requires the revival proposal to satisfy the requirements of public interest, commercial morality and bona fides. The proposal provided for settlement of creditor and workmen dues, including benefits to categories of workers otherwise not entitled in liquidation, while retaining and redeveloping the company's land rather than alienating it. The majority shareholders and secured creditors had committed funds, the workmen supported the negotiated settlement, and prior objections were not determinative because material circumstances had changed. Objections concerning the quantum and treatment of creditor claims, receipt of dividends, security, and long-term loans were matters for claim adjudication and did not justify refusal of revival. A change in the company's objects from textile operations to real-estate development was not legally prohibited, particularly where restarting the textile business was commercially unviable. The workmen's negotiated benefits created a legitimate expectation that was a major consideration in assessing public interest and commercial morality.

Conclusion: The revival proposal satisfied the requirements of public interest, commercial morality and bona fides; the permanent stay of winding-up was warranted and the refusal of such relief was unsustainable.

Issues: (i) Whether an order of the Adjudicating Authority passed by a Bench consisting solely of its Chairperson was without jurisdiction under Section 6(2) of the Prevention of Money Laundering Act, 2002; (ii) Whether continuation of freezing and retention could be sustained without the mandatory finding under Section 8(2) that identified properties were involved in money-laundering, and whether the Appellate Tribunal could cure that omission; (iii) Whether gross business turnover and foreign remittances justified freezing the appellant's entire banking and payment infrastructure as proceeds of crime.

Issue (i): Whether an order of the Adjudicating Authority passed by a Bench consisting solely of its Chairperson was without jurisdiction under Section 6(2) of the Prevention of Money Laundering Act, 2002.

Analysis: Section 6(2) requires the Adjudicating Authority to consist of a Chairperson and two other Members possessing the stipulated fields of experience. The jurisdictional objection to the composition of the Bench was disregarded without evidence establishing that a sole-Chairperson Bench was lawfully constituted.

Conclusion: The order of the Adjudicating Authority was coram non judice and a nullity.

Issue (ii): Whether continuation of freezing and retention could be sustained without the mandatory finding under Section 8(2) that identified properties were involved in money-laundering, and whether the Appellate Tribunal could cure that omission.

Analysis: Section 8(2) requires a reasoned finding, after considering the affected person's reply and relevant material, as to whether the properties specified in the notice are involved in money-laundering. A statement that retention or freezing is required for adjudication does not satisfy that requirement. The original order neither identified the properties found to be involved in money-laundering nor established their nexus with criminal activity. An appellate body may assess a finding made below, but cannot undertake the original statutory exercise or supply a mandatory finding omitted by the original authority. The validity of a statutory order must be judged by the reasons recorded in that order. The failure to communicate the requisite reasons to believe under the statutory scheme also vitiated the proceedings.

Conclusion: The continuation of freezing and retention was unsustainable, and the Appellate Tribunal could not cure the Adjudicating Authority's failure to record the mandatory finding under Section 8(2); the issue is in favour of the appellant.

Issue (iii): Whether gross business turnover and foreign remittances justified freezing the appellant's entire banking and payment infrastructure as proceeds of crime.

Analysis: Proceeds of crime must be property derived or obtained, directly or indirectly, as a result of criminal activity relating to a scheduled offence. A company's gross turnover, overseas remittances, or ownership of bank accounts does not by itself establish that all such funds are proceeds of crime. The authorities did not establish a predicate offence or a nexus between the frozen assets and the alleged unauthorized transactions. With nine of the ten underlying FIRs closed and the remaining allegation involving a limited amount, freezing assets of approximately Rs.100 crores was excessive and unsupported by a property-specific justification.

Conclusion: The entire banking and payment infrastructure could not be treated as proceeds of crime merely on the basis of turnover and foreign remittances; the issue is in favour of the appellant.

Final Conclusion: The impugned affirmance and the underlying coercive orders lacked jurisdictional and statutory foundation, and the freezing and retention measures could not continue on the material and findings recorded.

Ratio Decidendi: A mandatory property-specific finding that assets are involved in money-laundering cannot be replaced by a general satisfaction for continuation of freezing, nor can an appellate authority retrospectively supply that omitted statutory determination.

Issues: (i) Whether the extended period of limitation for the service-tax demand could be invoked on the basis of discrepancies in statutory financial records and Form 26AS; (ii) Whether service-tax demand computed by alternately using balance-sheet turnover and Form 26AS turnover without reconciliation was sustainable; (iii) Whether remuneration paid as salary to directors constituted a taxable service.

Issue (i): Whether the extended period of limitation for the service-tax demand could be invoked on the basis of discrepancies in statutory financial records and Form 26AS.

Analysis: The data in the statutory records was available to the Department for scrutiny. No corroborative material established deliberate suppression of facts with intent to evade service tax. Mere non-disclosure of receipts or reliance on profit-and-loss accounts and Form 26AS does not establish the requisite wilful suppression.

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

Issue (ii): Whether service-tax demand computed by alternately using balance-sheet turnover and Form 26AS turnover without reconciliation was sustainable.

Analysis: The taxable value was derived from the balance sheet for one financial year and from Form 26AS for the remaining periods, without reconciliation between those sources. A demand founded on inconsistent and unreconciled turnover figures lacked a sustainable basis.

Conclusion: The demand computed on unreconciled and inconsistent turnover figures was unsustainable, in favour of the assessee.

Issue (iii): Whether remuneration paid as salary to directors constituted a taxable service.

Analysis: The remuneration was recorded as salary, tax was deducted under the salary head, and the directors disclosed it as salary in their individual income-tax returns. Such remuneration fell within the exclusion from taxable service under the negative list.

Conclusion: Directors' remuneration paid as salary was not taxable as a service, in favour of the assessee.

Final Conclusion: The impugned tax demand and its consequential interest and penalty liabilities lacked legal sustainability.

Ratio Decidendi: Extended limitation under the service-tax law requires proof of deliberate suppression with intent to evade tax; discrepancies drawn from available statutory records, without such evidence, cannot justify its invocation.

Issues: Whether delay in filing an appeal before the Commissioner (Appeals) beyond the statutorily permissible period could be condoned.

Analysis: Section 85(3A) of the Finance Act, 1994 prescribes two months for filing an appeal and permits condonation, upon sufficient cause, only for a further one month. The statutory limitation restricts the appellate authority's jurisdiction; merits of the underlying demand cannot justify condonation beyond that outer limit.

Conclusion: Delay beyond the maximum condonable period could not be condoned; the issue is decided against the assessee.

Issues: Whether a demand for excess input tax credit, interest and penalty could be sustained where the taxpayer had reversed the entire excess credit and paid applicable interest before issuance of the demand-cum-show-cause notice.

Analysis: Section 73 of the Central Goods and Services Tax Act, 2017 governs recovery proceedings for unpaid or wrongly availed input tax credit, while interest is governed by Section 50. The revenue records admitted that the taxpayer had reversed the exact excess input tax credit and paid applicable interest before initiation of the proceedings. The factual basis for sustaining the demand was therefore absent.

Conclusion: The demand for reversal of excess input tax credit and consequential interest and penalty cannot be sustained; the taxpayer is not liable for any further interest or penalty.

Issues: (i) Whether the appeal against refusal of provisional release was maintainable despite the objection that it was filed through the power-of-attorney holder; (ii) Whether the seized dry dates were entitled to provisional release pending adjudication.

Issue (i): Whether the appeal against refusal of provisional release was maintainable despite the objection that it was filed through the power-of-attorney holder.

Analysis: Section 2(26) of the Customs Act, 1962 gives an inclusive meaning to "importer", covering an owner, beneficial owner, or a person holding himself out as importer. Section 129A of the Customs Act, 1962 permits an appeal by any person aggrieved by an order of the Commissioner acting as adjudicating authority. These provisions supported hearing the appeal irrespective of the objection concerning the capacity in which it was instituted.

Conclusion: The appeal was maintainable. This issue was decided in favour of the assessee.

Issue (ii): Whether the seized dry dates were entitled to provisional release pending adjudication.

Analysis: Section 110A of the Customs Act, 1962 confers discretion to provisionally release goods seized under Section 110 upon bond, security, and conditions pending adjudication. The goods were alleged to have originated in Pakistan but declared as of UAE origin, attracting the import prohibition under Notification No. 06/2025-26 dated 02.05.2025 and potential confiscation under Section 111(d) and Section 111(m) of the Customs Act, 1962. The statutory process had progressed through extension for issuance of show-cause notice and issuance of the notice; the competent authority had validly declined release in view of the alleged prohibited import, fraud, and national-security implications.

Conclusion: Provisional release was rightly refused. This issue was decided against the assessee.

Final Conclusion: No basis existed for appellate intervention against the refusal to provisionally release the seized goods, which remain subject to statutory adjudication.

Ratio Decidendi: Provisional release under Section 110A is discretionary and may be refused where seized goods are prima facie prohibited imports involving alleged misdeclaration of origin and national-security concerns, particularly after commencement of adjudicatory proceedings.

Issues: (i) Availability of Special Additional Duty exemption under Notification No. 45/2005-Customs dated 16.05.2005 for goods transferred from a FTWZ to the assessee's domestic tariff area unit on a stock-transfer basis; (ii) Validity of invoking the extended period of limitation for recovery of Special Additional Duty.

Issue (i): Availability of Special Additional Duty exemption under Notification No. 45/2005-Customs dated 16.05.2005 for goods transferred from a FTWZ to the assessee's domestic tariff area unit on a stock-transfer basis.

Analysis: The notification exempts goods cleared from a special economic zone and brought to another place in India, subject to its proviso where the goods, when sold in the domestic tariff area, are exempt from sales tax or VAT. Stock transfer is not a sale, and deferral of VAT liability until a subsequent sale does not amount to exemption from VAT. The identical question stood settled by coordinate-bench decisions extending the exemption benefit; a departmental circular could not curtail the notification's scope.

Conclusion: The Special Additional Duty exemption is available for the stock-transfer clearances. The issue is decided in favour of the assessee.

Issue (ii): Validity of invoking the extended period of limitation for recovery of Special Additional Duty.

Analysis: The clearances were undertaken through the prescribed departmental procedure and under supervision of customs officers. The prevailing practice had support in communications and directions of SEZ authorities, including acceptance of chartered-accountant certification regarding payment of VAT on subsequent sale. These circumstances negated mala fide intent, wilful misstatement, and suppression of facts. The demand covering April 2012 to July 2013, raised by notice dated 28.05.2015, was beyond the normal one-year period.

Conclusion: The extended period of limitation could not be invoked, and the entire duty demand is time-barred. The issue is decided in favour of the assessee.

Final Conclusion: The duty demand and consequential confiscation and penalties, being founded on an unsustainable extended-period allegation, cannot survive.

Ratio Decidendi: The extended period for customs duty recovery is unavailable where departmental knowledge and an officially accepted clearance practice negate suppression or wilful misstatement with intent to evade duty.

Issues: Whether penalties upon the customs broker and its director for knowingly advising misclassification and facilitating improper importation were sustainable.

Analysis: A statement recorded under Section 108 of the Customs Act, 1962 is substantive evidence when voluntary, since Customs officers are not police officers. The unretracted statement of the director admitted that the importers had been advised to classify areca nuts under an incorrect tariff entry to obtain exemption benefits. This admission was corroborated by the test reports and the unretracted statements of the importers. The material established knowing and intentional advice for misclassification and undervaluation, satisfying the knowledge and intent required for penal liability.

Conclusion: Penalties imposed upon the customs broker and its director under the Customs Act, 1962 were valid; the issue was decided against the assessee.

Issues: (i) Whether leave to appeal against the acquittal should be granted; (ii) Whether the leave petition was filed within the limitation period under Section 419(5) of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Issue (i): Whether leave to appeal against the acquittal should be granted.

Analysis: At the leave stage, the applicable standard is whether a prima facie case or arguable points requiring scrutiny of the material and reappreciation of evidence arise. The appellate forum is not to undertake a minute evaluation of the evidence or determine at that stage whether the acquittal must ultimately be overturned. The double presumption of innocence does not by itself warrant refusal of leave where deeper scrutiny is required.

Conclusion: Leave to appeal against the acquittal was granted, in favour of the petitioner.

Issue (ii): Whether the leave petition was filed within the limitation period under Section 419(5) of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Analysis: The period spent in preparation and delivery of the certified copy was excluded from the elapsed period. After excluding 54 days consumed in obtaining the copy, the effective period was 178 days, which was within the prescribed 180-day period.

Conclusion: The leave petition was within limitation and required no condonation of delay, in favour of the petitioner.

Final Conclusion: The challenge to the acquittal raises matters requiring appellate scrutiny, and the criminal appeal is to proceed for adjudication on merits.

Ratio Decidendi: Leave against an acquittal should be granted where arguable points warrant deeper scrutiny or reappreciation of evidence; the appellate forum should not conduct a minute merits review at the leave stage.

Issues: Whether operation of tube wells for supply of water to municipal water authorities qualifies for Service Tax exemption under Serial No. 25 of Notification No. 25/2012-ST dated 20.06.2012.

Analysis: Serial No. 25 exempts services provided to Government, a local authority or governmental authority in relation to functions ordinarily entrusted to a municipality, including water supply. The prescribed consideration was calculated per tube well, shift and day, establishing that the services were for operation of tube wells and supply of water. The same nature of water-supply service was rendered to all the concerned municipal authorities.

Conclusion: The services qualify for the exemption under Serial No. 25 of Notification No. 25/2012-ST dated 20.06.2012, and the consideration received is not liable to Service Tax.

Issues: (i) Whether secondment of employees by an overseas group company to its Indian group entity constitutes taxable manpower recruitment or supply agency service under the reverse-charge mechanism; (ii) Whether the extended period of limitation could be invoked for recovery of service tax on the secondment arrangement.

Issue (i): Whether secondment of employees by an overseas group company to its Indian group entity constitutes taxable manpower recruitment or supply agency service under the reverse-charge mechanism.

Analysis: Section 66A(1) of the Finance Act, 1994 fastens reverse-charge liability on the recipient of taxable services received from abroad. Despite the Indian entity exercising operational control over the secondees and bearing the reimbursed employment costs without markup, the overseas entity remained their employer, paid their salaries, maintained their employment terms, and received them back after secondment. The arrangement therefore amounted to supply of manpower by the overseas entity.

Conclusion: The secondment arrangement constituted taxable manpower recruitment or supply agency service received by the assessee from the overseas group company; this issue is against the assessee.

Issue (ii): Whether the extended period of limitation could be invoked for recovery of service tax on the secondment arrangement.

Analysis: Under Section 73 of the Finance Act, 1994, invocation of the extended limitation period requires fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade tax. The secondment expenses were recorded in the books, remitted through banking channels, and arose amid conflicting views on taxability. Mere non-payment of tax did not establish wilful suppression or an intent to evade service tax. As the entire notice-period demand fell outside the normal limitation period, no part of the confirmed demand survived.

Conclusion: Invocation of the extended period was unsustainable; the service-tax demand, interest, and penalties were not recoverable. This issue is in favour of the assessee.

Final Conclusion: Although the arrangement attracted service-tax liability in principle, no enforceable liability remained because the whole demand was time-barred.

Ratio Decidendi: In employee-secondment arrangements, retention of the employment relationship by the overseas entity can establish taxable manpower supply, but extended limitation cannot be invoked without proof of wilful suppression or intent to evade tax.

Issues: Whether a bank governed by the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 can invoke that Act to recover a secured loan acquired from a non-banking financial company which was not a notified financial institution when the loan was originated.

Analysis: The statutory scheme enables banks and financial institutions to enforce security interests for recovery of live and owing debts. The definitions of borrower, security arrangement, security interest and secured creditor, construed purposively, apply to existing loan agreements irrespective of whether the original lender was a notified financial institution when the loan was advanced. The principles applicable where an originally non-covered lender subsequently becomes covered by the Act, or where its debt passes to a covered successor-in-interest, equally apply where a bank already covered by the Act acquires the secured debt. Assignment to such bank immediately gives the acquired loan the attributes of a secured debt for purposes of enforcement under the Act.

Conclusion: A bank may invoke the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 to enforce security interests securing a debt acquired from a non-notified non-banking financial company. The unadjudicated objections in the concerned securitisation application remain open for determination on their merits.

Issues: Whether verified escalation in construction-input costs could offset the benefit of additional input tax credit and negate profiteering under the anti-profiteering framework.

Analysis: Section 171 of the Central Goods and Services Tax Act, 2017 requires the benefit of additional input tax credit to be passed on through a commensurate price reduction. Genuine commercial factors, including proven cost escalation, may nevertheless be considered where they demonstrably offset the benefit. The verified additional expenditure on major construction inputs exceeded the total saving from additional input tax credit, resulting in negative net savings. The revised computation deducting the accepted cost escalation from the additional input tax credit saving was legally appropriate.

Conclusion: No profiteering arose, as the additional input tax credit benefit was fully offset by genuine and verified construction-cost escalation; consequently, there was no contravention of Section 171 of the Central Goods and Services Tax Act, 2017.

Issues: (i) Whether unconditional, non-expiring and unrestricted Electronic Gift Voucher credits constitute a valid mode of passing on the benefit under Section 171 of the Central Goods and Services Tax Act, 2017; (ii) Whether the system-generated nomenclature "Offers and cashback" negates the passing on of the GST benefit; (iii) Whether the Respondent had complied with Section 171 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether unconditional, non-expiring and unrestricted Electronic Gift Voucher credits constitute a valid mode of passing on the benefit under Section 171 of the Central Goods and Services Tax Act, 2017.

Analysis: Section 171 requires that the benefit of a tax-rate reduction reach recipients and prevents the supplier from retaining that benefit; it does not prescribe an exclusive mode of transfer. The EGV credits were credited to identified customers' e-wallets, carried monetary value, had no expiry, were unrestricted as to products, and were traceable to the relevant invoices and recipients. Such credits were distinguished from promotional discounts, cross-subsidisation, or additional quantity, because they transferred the quantified monetary benefit directly to the customers.

Conclusion: Unconditional, non-expiring and unrestricted EGV credits are a valid and effective mode of passing on the benefit under Section 171, in favour of the assessee.

Issue (ii): Whether the system-generated nomenclature "Offers and cashback" negates the passing on of the GST benefit.

Analysis: The EGV credits were supported by transaction-specific records containing the order identification, invoice particulars, price charged, and excess amount attributable to the GST-rate change. The documentary trail established that the credits corresponded to eligible supplies. Substance, rather than the automated label assigned by the system, governed whether the tax benefit had been passed on.

Conclusion: The nomenclature "Offers and cashback" does not negate the passing on of the GST benefit where the credits are traceable to identified transactions and customers, in favour of the assessee.

Issue (iii): Whether the Respondent had complied with Section 171 of the Central Goods and Services Tax Act, 2017.

Analysis: Credit notes issued for cancelled or returned transactions were accepted and excluded from the profiteering computation. EGVs totalling Rs. 5,48,650 were established as valid credits to recipients. However, of the revised profiteered amount of Rs. 5,58,891, the balance of Rs. 10,241 could not be reconciled to an identifiable customer or invoice and was therefore not shown to have been passed on. The amount was directed to be deposited in the Central Consumer Welfare Fund with interest at 18%.

Conclusion: The Respondent substantially complied with Section 171, but failed to pass on Rs. 10,241; compliance is therefore only partly in favour of the assessee.

Final Conclusion: EGVs and the accepted credit notes discharged the anti-profiteering obligation to the extent proved, while the unreconciled residual amount remained payable to the Central Consumer Welfare Fund with applicable interest; no penalty was attracted for the pre-penal-provision period.

Ratio Decidendi: A traceable credit of the quantified tax benefit to a recipient's e-wallet satisfies Section 171 where it is unconditional, unrestricted, non-expiring, and available as monetary value to that recipient.

Issues: Whether discretionary writ jurisdiction under Article 226 should be exercised against an appellate order of absolute confiscation when a statutory revision under Section 129DD of the Customs Act, 1962 is available.

Analysis: The statutory revisional remedy was efficacious and could address the disputed factual and legal questions concerning the alleged oral show-cause notice, the statement recorded under Section 108, compliance with Sections 110(2) and 124, personal hearing, and absolute confiscation. The asserted breach of principles of natural justice required examination of the complete record and did not justify bypassing the alternative remedy. No challenge to vires or lack of jurisdiction was established.

Conclusion: Discretionary writ jurisdiction was declined; the petitioner must pursue the statutory revisional remedy, with all merits questions left open.