Issues: Whether the proposed imports for use in manufacturing lithium-ion battery packs qualify for the 2.5% concessional rate of basic customs duty.

Analysis: Serial No. 295 of Notification No. 45/2025-Customs covers specified parts, components and accessories for manufacturing lithium-ion batteries and battery packs, and sub-parts for manufacturing those items, regardless of their tariff chapter. Lithium-ion cells and printed circuit board assemblies are excluded. Eligibility depends on each item's actual characteristics and intended use, as well as compliance with Condition No. 3 and the applicable concessional-import and end-use rules. A declared tariff heading or general technical description alone is insufficient; the proper officer may verify the supporting documents and end-use evidence.

Conclusion: Yes. Qualifying individual imports are eligible for the 2.5% rate, subject to the prescribed exclusions and conditions. No blanket determination of classification or eligibility is made for every proposed import.

Ratio Decidendi: A concessional duty for battery-manufacturing inputs applies only to individually qualifying goods that satisfy the prescribed exclusions, end-use and procedural conditions; a declared tariff heading or general description alone does not establish eligibility.

Issues: Whether an ad-interim stay of the direction to change the petitioner's corporate name was warranted pending adjudication of the writ petition.

Analysis: For the interim assessment, proceedings under Section 16 of the Companies Act concern whether a corporate name is identical with or too nearly resembles an existing registered trade mark; they do not require a determination of likelihood of confusion. The registration was effective before incorporation, and no final order cancelling it had been passed. The challenged order addressed the relevant contentions, while the petitioner's reply before the Regional Director was not on record. No prima facie illegality, perversity, arbitrariness or jurisdictional error warranting judicial review was established at this stage.

Outcome: Ad-interim stay was not granted at this stage. The writ petition and stay application remain pending, with replies directed.

Issues: Whether documents first produced on appeal to establish the nature of the receipts should be considered and verified.

Analysis: The ex parte adjudication relied on income-tax data without examining the subsequently produced work orders, certificates and reconciliation statements. The claimed exemption under Notification No. 25/2012-S.T. covers specified road construction and repair services for public use. Verification and correlation of the documents with the income-tax records are necessary to identify the works and corresponding receipts, with a reasonable hearing in accordance with natural justice.

Conclusion: The documents could not be rejected solely because they were not produced at the original stage. They require verification and a fresh decision; taxability and all other issues remain open.

Ratio Decidendi: Evidence material to the nature of transactions cannot be rejected solely because it was not produced during the original adjudication; it requires verification before liability is determined.

Issues: Whether the plaintiff was entitled to exemption from pre-institution mediation on the ground that urgent injunctive relief was contemplated.

Analysis: Section 12A of the Commercial Courts Act, 2015 requires consideration of whether urgent interim relief is genuinely contemplated. From the plaintiff's standpoint, the relief sought was plausibly urgent. Comparison of the publications with the claimed original literary works disclosed prima facie copying of headnotes; irreparable harm and the balance of convenience also supported temporary protection. An ex parte restraint operates until the next hearing; the injunction application and the suit remain pending.

Conclusion: The plaintiff was exempted from pre-institution mediation.

Issues: (i) Whether the reassessment notice was sustainable within the asserted extended limitation period; (ii) Whether reopening the assessment on the same ground was permissible.

Issue (i): Whether the reassessment notice was sustainable within the asserted extended limitation period.

Analysis: The Revenue had conceded in Supreme Court proceedings that notices issued on or after 1 April 2021 for assessment year 2015-16 would have to be dropped because they did not fall within the period prescribed by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The same disclosure-related ground had already formed the basis of the original assessment.

Conclusion: The notice was not sustainable under the asserted extended limitation period.

Issue (ii): Whether reopening the assessment on the same ground was permissible.

Analysis: The exemption claim had been examined during the original assessment, and the proposed addition relied on the same asserted lack of particulars.

Conclusion: Reopening on that ground was an impermissible change of opinion.

Final Conclusion: The impugned reassessment proceedings cannot affect the completed assessment.

Ratio Decidendi: Reassessment cannot be used to review an assessment on a ground already examined by the assessing officer.

Issues: Whether penalties could be imposed on a customs broker for overvaluation of export goods.

Analysis: The penalty provisions of the Customs Act, 1962 were invoked in relation to the exporter's overvaluation. Revenue produced no evidence that the broker knew of the overvaluation. No proceedings had been initiated against the broker under the Customs Brokers Licensing Regulations, 2018.

Conclusion: The penalties under Sections 114 and 114AA were unsustainable.

Ratio Decidendi: Penalties for export overvaluation cannot be sustained against a customs broker where Revenue produces no evidence of the broker's knowledge of the overvaluation.

Issues: (i) Whether the exception for adverse comments against an officer applied; (ii) whether jurisdictional annulment of the reassessment rendered the tax effect unquantifiable; (iii) whether interest and penalty formed part of the tax effect for the monetary limit.

Issue (i): Whether the exception for adverse comments against an officer applied.

Analysis: The passage concerning failure to follow reassessment procedures recorded the assessee's submissions; the finding followed a coordinate bench without independent reasoning. The circular addresses strictures or adverse comments directed at an officer, as distinct from identification of procedural error in an assessment.

Conclusion: The exception did not apply, in favour of the assessee.

Issue (ii): Whether jurisdictional annulment of the reassessment rendered the tax effect unquantifiable.

Analysis: The reassessment was annulled on jurisdictional grounds without examination of its merits. The record contained a net tax liability of Rs. 1,23,07,705.

Conclusion: The jurisdictional annulment did not make the tax effect unquantifiable in this case, in favour of the assessee.

Issue (iii): Whether interest and penalty formed part of the tax effect for the monetary limit.

Analysis: The applicable litigation policy prescribed a monetary limit of Rs. 2 crore. The net tax liability was Rs. 1,23,07,705, while the amount including interest was Rs. 2,09,62,403.

Conclusion: Interest and penalty were excluded from the tax effect, which fell below the monetary limit, in favour of the assessee.

Final Conclusion: The jurisdictional annulment of the reassessment remains undisturbed, with the merits unexamined.

Ratio Decidendi: For the monetary limit under the revenue litigation policy, a quantifiable tax effect excludes interest and penalty.

Issues: (i) Whether the imported coal was classifiable as steam coal or bituminous coal. (ii) Whether the imports qualified for the basic customs duty exemption for steam coal.

Issue (i): Whether the imported coal was classifiable as steam coal or bituminous coal.

Analysis: The tariff definition of bituminous coal requires both the prescribed calorific-value and volatile-matter limits to be met on their respective measurement bases. The department used air-dried values in applying the Parr formula, rather than the as-received values required by the applicable methodology. Recalculation placed seven consignments below the calorific-value threshold. For the remaining consignment, the calculated values met both limits, but the departmental discharge-port report identified the sample as having the characteristics of steam coal; no retesting was undertaken.

Conclusion: All eight consignments were classifiable as steam coal under tariff item 2701 1920, in favour of the assessee.

Issue (ii): Whether the imports qualified for the basic customs duty exemption for steam coal.

Analysis: The exemption entry specifies both steam coal and tariff item 2701 1920. Bituminous coal under the separate tariff item is not covered by that entry merely because it is used to generate steam.

Conclusion: The imported coal qualified for the basic customs duty exemption, in favour of the assessee.

Final Conclusion: The declared tariff treatment and exemption apply, and the differential duty demands and penalties do not survive.

Ratio Decidendi: Classification as bituminous coal requires both statutory limits to be established using the prescribed measurement bases and a properly applied testing methodology.

Issues: (i) Whether the duty demand could be sustained on the valuation basis adopted in adjudication; (ii) whether the finding that the buyer relationship influenced prices for two years was sustainable; (iii) whether accounting shortages justified a duty demand for clandestine removal.

Issue (i): Whether the duty demand could be sustained on the valuation basis adopted in adjudication.

Analysis: For domestic tariff area clearances by a 100% export-oriented unit, Section 3 of the Central Excise Act, 1944 requires valuation under the customs framework. The show-cause notice based its demand on the Central Excise Valuation Rules, whereas adjudication adopted deductive valuation under Rule 7 of the Customs Valuation Rules, 2007. The show-cause notice is the foundation for levy and recovery, and a valuation rule not invoked as the basis of the notice cannot subsequently be applied to sustain the demand.

Conclusion: The demand based on the substituted valuation rule was unsustainable, in favour of the assessee.

Issue (ii): Whether the finding that the buyer relationship influenced prices for two years was sustainable.

Analysis: The adjudicating authority found no price influence for one product throughout the disputed period and for the other product during three of five financial years. Against those findings, the attribution of price influence to the same relationship for the latter product in only two years was inconsistent.

Conclusion: The finding of price influence for the two years was unsustainable, in favour of the assessee.

Issue (iii): Whether accounting shortages justified a duty demand for clandestine removal.

Analysis: The applicable product standard recognised heating loss, and one reported annual shortage was less than 0.05% of production. The shortages were taken from income-tax audit declarations without independent verification or evidence connecting them to clandestine clearances.

Conclusion: The demand on the reported shortages was unsustainable, in favour of the assessee.

Final Conclusion: The confirmed duty demands and associated penalties lack a sustainable legal basis.

Ratio Decidendi: A duty demand cannot be sustained on a valuation rule not invoked as the basis of the show-cause notice.

Issues: Whether the proceedings and recovery notice were sustainable where the notice and original order were communicated through the portal and the petitioner was not heard.

Analysis: The show-cause notice and original order were uploaded on the portal, and the petitioner had no opportunity to be heard. The decision relied on the distinction between sufficient and effective service under Section 169 of the GST Act and the use of alternative statutory modes when portal-based service is ineffective.

Conclusion: The show-cause notice, original and appellate orders, and recovery notice were quashed.

Ratio Decidendi: Where portal-based service is ineffective and a person is denied an opportunity to respond, failure to use an alternative statutory mode of service violates natural justice and vitiates the proceedings.

Issues: Whether a writ challenge to cancellation of GST registration is maintainable after the statutory appeal period and the permitted extension have expired without an appeal being filed.

Analysis: Section 107 of the Central Goods and Services Tax Act, 2017 provides a three-month appeal period and permits a further month on sufficient cause; it confers no power on the appellate authority to condone delay beyond that extension. The right of appeal is statutory. The petitioner did not use that remedy and attributed the omission to lack of familiarity with the GST portal. Allowing a writ challenge solely because the remedy had consequently been lost would undermine the statutory limitation.

Conclusion: The writ challenge to cancellation was not maintainable in these circumstances.

Ratio Decidendi: Writ jurisdiction cannot be used to circumvent the statutory appeal limitation merely because a party's own omission has resulted in loss of the appellate remedy.

Issues: (i) Whether payment of the entire first-appeal pre-deposit through the electronic credit ledger rendered the appeal time-barred or required a further cash deposit. (ii) Whether input tax credit of integrated tax paid on imports could be denied for return mismatches, supplier reporting or misclassification of the credit.

Issue (i): Whether payment of the entire first-appeal pre-deposit through the electronic credit ledger rendered the appeal time-barred or required a further cash deposit.

Analysis: The special appeal notification prescribed a filing window and a pre-deposit of 12.5% of disputed tax, at least 20% of which was to be paid through the electronic cash ledger. The appeal was filed within that window and the full deposit was paid through the credit ledger. The notification's filing deadline was distinct from its payment-mode condition, and a payment defect could be cured without treating a timely appeal as time-barred. A further cash payment over the full deposit already made would increase the total deposit beyond 12.5%; an additional cash deposit had also been made at the Tribunal stage.

Conclusion: The appeal was timely, the deposit was sufficient in the circumstances, and no further cash deposit was required. The issue was decided in favour of the assessee.

Issue (ii): Whether input tax credit of integrated tax paid on imports could be denied for return mismatches, supplier reporting or misclassification of the credit.

Analysis: Bills of entry are recognised documents for claiming import credit. The bills and corresponding return entries matched the credit claimed, and the customs assessment and clearance records supported actual payment of integrated tax. Import credit is reported separately from domestic-supplier credit, and no domestic supplier's return exists in the import chain. The supplier-reporting provision invoked in the demand was not in force during the relevant financial year. Reporting import credit under another return category affected its classification rather than its underlying eligibility.

Conclusion: The import credit was eligible, and the related tax, interest and penalty demands could not survive. The issue was decided in favour of the assessee.

Final Conclusion: The first-appeal deposit was accepted for maintainability, and the assessee's import credit was restored without the related tax, interest and penalty liability.

Ratio Decidendi: Import credit supported by bills of entry and payment of integrated tax cannot be denied solely on domestic-supplier reporting grounds or because it was entered under the wrong return category.

Issues: Whether the earlier order rejecting condonation of delay could be recalled on the asserted ground of e-filing failure and a subsequent judicial decision.

Analysis: Recall is distinct from review and is available on recognised grounds including patent lack of jurisdiction, fraud or collusion, court mistake prejudicing a party, or failure to serve or represent a necessary party. A reasoned order deciding the delay application had remained unchallenged and attained finality. The subsequent decision did not alter the limits of recall jurisdiction. E-filing remained available on holidays, which did not explain the additional delay. The Tribunal declined to reassess the technical report in recall proceedings.

Conclusion: No recognised ground for recall was established; the application was an impermissible attempt to review the earlier order.

Ratio Decidendi: Recall cannot be used as a substitute for review or an unexercised appeal to reopen a final order when no recognised ground for recall is established.

Issues: Whether the corporate debtor can compel the financial creditor to produce the requested documents before the admission hearing of an insolvency application.

Analysis: Admission proceedings under Section 7 of the Insolvency and Bankruptcy Code are summary in nature, and the financial creditor bears the burden of establishing financial debt and default. An unrestricted inquiry before admission would resemble a civil suit. Under Rules 43 and 131 of the National Company Law Tribunal Rules, the adjudicating authority retains power to require documents necessary for effective adjudication and to draw an adverse inference concerning documents legally required to be produced.

Conclusion: The corporate debtor cannot as of right compel production of the requested documents before the admission hearing.

Ratio Decidendi: In summary insolvency admission proceedings, document production is subject to the adjudicating authority's assessment of necessity and is not an automatic right of the corporate debtor.

Issues: (i) Whether service tax on the identified goods transport agency services was payable by the recipients under reverse charge; (ii) whether the identified transport services qualified for exemption; (iii) whether the extended limitation period was invocable; and (iv) whether the demand could be sustained solely on income-tax data without independent verification.

Issue (i): Whether service tax on the identified goods transport agency services was payable by the recipients under reverse charge.

Analysis: Notification No. 30/2012-ST and Rule 2 of the Service Tax Rules, 1994 place the full liability on the recipient where the consignor or consignee falls within the specified categories. The consignment-wise and party-wise documents identified the relevant recipients; the lower authorities had declined relief for want of recipient-wise payment proof.

Conclusion: The identified services were subject to reverse charge, and the demand against the assessee was unsustainable. The issue was decided in favour of the assessee.

Issue (ii): Whether the identified transport services qualified for exemption.

Analysis: The exemption under entry 21(e) of Notification No. 25/2012-ST applies to the identified transport of fertiliser, organic manure and oil cakes. The claimant bears the burden of proving entitlement; the consignee-wise chart and sample transport documents substantially discharged that burden.

Conclusion: The identified transport services were exempt, and the related demand was unsustainable. The issue was decided in favour of the assessee.

Issue (iii): Whether the extended limitation period was invocable.

Analysis: The demand was based on differences between income-tax data and service-tax returns. The income-tax data was available to the department through the CBDT, and the Tribunal found no basis to allege suppression from that data.

Conclusion: The extended limitation period was not invocable. The issue was decided in favour of the assessee.

Issue (iv): Whether the demand could be sustained solely on income-tax data without independent verification.

Analysis: Form 26AS and income-tax returns reflect data maintained for income-tax purposes. The demand was raised from that third-party data without independent verification of the nature of the services or corroborative evidence establishing taxable services.

Conclusion: The demand based solely on the income-tax data was unsustainable. The issue was decided in favour of the assessee.

Final Conclusion: The service-tax demand had no legal basis, and no consequential interest or penalty was payable.

Ratio Decidendi: Income-tax data alone, without independent verification of taxable services, cannot establish service-tax liability or justify invoking the extended limitation period on grounds of suppression.

Issues: (i) Whether book printing was excluded from service tax as manufacture or production of goods; (ii) Whether a service tax demand could be sustained solely on a difference between Form 26AS and ST-3 returns; (iii) Whether the extended period of limitation could be invoked.

Issue (i): Whether book printing was excluded from service tax as manufacture or production of goods.

Analysis: Book printing was a manufacturing or production process under the excise law, and printed books attracted a nil tariff rate. The Finance Act defined a process amounting to manufacture or production by reference to excise duties and placed such processes in the negative list of services.

Conclusion: Book printing was excluded from service tax as manufacture or production of goods, in favour of the assessee.

Issue (ii): Whether a service tax demand could be sustained solely on a difference between Form 26AS and ST-3 returns.

Analysis: The burden of establishing taxability lay on the department. The notices identified a difference in reported values but did not identify an untaxed service transaction or establish the statutory ingredients of a service.

Conclusion: The demand could not be sustained solely on the difference in returns, in favour of the assessee.

Issue (iii): Whether the extended period of limitation could be invoked.

Analysis: The proviso governing the extended period addresses evasion-related grounds. Neither the notices nor the adjudication order identified a positive act of evasion.

Conclusion: The extended period could not be invoked, in favour of the assessee.

Final Conclusion: The decision addresses the manufacturing exclusion and the evidentiary and limitation requirements for a service tax demand.

Ratio Decidendi: A service tax demand cannot rest solely on a discrepancy between tax-deduction and service-tax returns without identifying a taxable service and establishing the elements of the levy.

Issues: Whether removal of inputs as such after reversal of CENVAT credit constitutes trading attracting payment under Rule 6 of the CENVAT Credit Rules, 2004.

Analysis: The inputs were removed to sister units or independent buyers after reversal of the credit originally taken, as provided under Rule 3(5). Rule 6(3) governs specified payments in respect of exempted activities, and trading was declared an exempted service from 1 April 2011. The reasoning applied precedents distinguishing removal of inputs as such from trading.

Conclusion: Removal of inputs as such on reversal of credit is not trading and does not attract Rule 6(3). The post-1 April 2011 demands, interest and penalties were set aside; the pre-1 April 2011 demands remained dropped.

Ratio Decidendi: Removal of inputs as such after reversal of the credit taken is not trading and does not attract payment under Rule 6(3) of the CENVAT Credit Rules, 2004.

Issues: (i) Whether the challenges to the interim arbitral award were maintainable before the final award. (ii) Whether the loan agreements were governed by Maharashtra or Delhi stamp law. (iii) Whether the facility schedules could be disregarded when determining if the agreements specified monetary values.

Issue (i): Whether the challenges to the interim arbitral award were maintainable before the final award.

Analysis: Under the Arbitration and Conciliation Act, 1996, a rejected plea concerning the tribunal's jurisdiction is ordinarily challengeable after the final award, while an interim award conclusively deciding a preliminary issue may be challenged under Section 34. The arbitrator decided the preliminary stamping questions under the scope of the Supreme Court's directions, without deciding whether the earlier jurisdictional applications had been disposed of. Those determinations would not be revisited in the final award.

Conclusion: The challenges were maintainable before the final award.

Issue (ii): Whether the loan agreements were governed by Maharashtra or Delhi stamp law.

Analysis: The charging provisions of the stamp statutes must be strictly construed. For an instrument signed in different States, the applicable law depends on a real territorial nexus and the character of the instrument; the place of the first signature is not conclusively determinative. The agreements required the lender's signature as well as the borrowers' signatures. The lender signed in Delhi, completing the chargeable instruments there.

Conclusion: The agreements were executed in Delhi and are liable to be stamped under the Indian Stamp Act, 1899, as applicable in Delhi.

Issue (iii): Whether the facility schedules could be disregarded when determining if the agreements specified monetary values.

Analysis: The agreements required the relevant facility schedules to be read with the loan terms, and the schedules recorded facility amounts. Treating the executed schedules as separate merely because their format differed from the booklet ignored material contractual terms.

Conclusion: The facility schedules could not be disregarded; the finding that the agreements specified no monetary value could not stand.

Final Conclusion: Delhi stamp law governs the agreements, and the relevant facility schedules form part of the contractual documentation for assessing their monetary terms.

Ratio Decidendi: For a multi-party instrument requiring all parties' signatures, the applicable stamp law depends on the real territorial nexus and completed execution, not conclusively on the place of the first signature.

Issues: Whether the accused was entitled to bail in proceedings concerning an alleged GST offence.

Analysis: The bail application was made under the Bharatiya Nagarik Suraksha Sanhita, 2023, in relation to an alleged offence under the Central Goods and Services Tax Act, 2017. The accused had remained in judicial custody since arrest, his voluntary statement had been recorded, and the respondents accepted his release on conditions.

Conclusion: The accused is entitled to conditional bail on a personal bond with two sureties, attendance when called on notice, and abstention from similar offences.

Issues: Whether GST registration could be cancelled for non-deposit of input tax credit where returns were regularly filed.

Analysis: The alleged non-deposit concerned recovery of input tax credit, for which Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 provide a procedure. The petitioner had regularly filed returns.

Conclusion: The cancellation was unjustified, and its revocation was directed.

Ratio Decidendi: Non-deposit of input tax credit does not by itself justify cancellation of GST registration where returns are regularly filed; the applicable recovery procedure should be followed.