Issues: Whether the alleged personal land transactions of the company's directors could prima facie be attributed to the company for proceedings concerning money-laundering.

Analysis: The order noted that liability of a company requires material connecting the company itself with the alleged activity under Section 3 of the Prevention of Money-laundering Act, 2002. Personal acts of directors are not automatically attributable to the company merely by reason of their office. Further consideration was found necessary on whether the requisite evidentiary connection existed on the stated facts.

Outcome: Notice was issued and the impugned order and consequential proceedings were stayed, insofar as they concern the petitioner, until the next hearing. No final adjudication has taken place.

Issues: (i) Whether the extended-period service-tax demand was sustainable where the assessee failed to pay tax after amendment of the exemption notification due to claimed ignorance of that amendment; (ii) Whether an equal penalty under section 78 was sustainable for the post-2015 period despite the claimed absence of intent to evade tax.

Issue (i): Whether the extended-period service-tax demand was sustainable where the assessee failed to pay tax after amendment of the exemption notification due to claimed ignorance of that amendment.

Analysis: The services were exempt only up to the relevant pre-amendment period, and the lower authorities had already granted the available exemption and abatement while confining the demand to taxable services. Under the proviso to section 73(1) of the Finance Act, 1994, ignorance of a change in an exemption notification could not excuse non-payment. A registered service provider claiming an exemption was required to keep track of amendments affecting its availability.

Conclusion: The extended-period service-tax demand was sustainable; against the assessee.

Issue (ii): Whether an equal penalty under section 78 was sustainable for the post-2015 period despite the claimed absence of intent to evade tax.

Analysis: The reasonable-cause protection under section 80 of the Finance Act, 1994 was unavailable for the disputed post-2015 period. The claimed ignorance of the amended exemption could not displace the statutory consequence under section 78.

Conclusion: The equal penalty under section 78 was mandatory and sustainable; against the assessee.

Final Conclusion: The surviving service-tax liability, interest and equal penalty, after giving effect to available exemption and abatement, remain enforceable.

Ratio Decidendi: Ignorance of an amendment to an exemption notification does not excuse non-payment of service tax or preclude the extended period and statutory penalty where the reasonable-cause protection is unavailable.

Issues: Whether additional documentary evidence may be brought on record after closure of the complainant's evidence under Section 311 of the Code of Criminal Procedure, 1973.

Analysis: Section 311 of the Code of Criminal Procedure, 1973 confers broad power to permit evidence at any stage where it is essential to a just decision. The controlling consideration is the materiality and necessity of the evidence, rather than the stage of the proceedings. The proposed invoice and related payment records bore a direct nexus to the payment relied upon in the defence and were relevant to explain whether that payment related to the liability in issue. Producing such material to explain a fact arising from defence evidence is distinct from impermissibly filling a lacuna in the original case. Closure of evidence does not by itself bar material evidence, particularly where the opposing party is afforded an opportunity to contest it.

Conclusion: The additional documents were permitted to be placed on record, with full opportunity to the respondent to contest their admissibility, authenticity and evidentiary value.

Outcome: Applications for condonation of delay and the special leave petition were dismissed.

Issues: Whether the landowner's unilateral revocation of the joint development agreement and power of attorney warranted exclusion of the subject land from the corporate insolvency resolution process, and whether interim preservation of the land was warranted pending disposal of the appeal.

Analysis: The joint development agreement and power of attorney prima facie created irrevocable and non-determinable development rights in favour of the corporate debtor. The contractual period for construction was reckoned from the approvals and the subsequent agreement, and had not expired when termination was asserted. The purported termination was not accepted; the alleged no-objection communication was conditional upon repayment of the proportionate project loan and amounted to a counter-offer. Existing mortgage rights and possible third-party rights could not be conclusively ruled out at this stage.

Outcome: The landowner was permitted to intervene, exclusion of the subject land from the corporate insolvency resolution process was not granted at this stage, and the parties were directed to maintain status quo pending hearing of the appeals.

Outcome: The special leave petition was disposed of as premature, with liberty to seek adjournment before the Adjudicating Authority.

Outcome: Special Leave Petitions dismissed and pending applications disposed of.

Issues: Whether the applicant should be granted regular bail pending trial for alleged fraudulent availment and utilisation of input tax credit.

Analysis: The charge-sheet had been filed, the applicant had remained in custody since 20.07.2026, and the sole criminal antecedent was from 2018. The alleged offences under Sections 132(1)(b) and 132(1)(c) of the Central Goods and Services Tax Act, 2017 were noted to be non-bailable but compoundable. No opinion on the merits of the prosecution case was expressed.

Outcome: Regular bail was granted on execution of the prescribed bond and compliance with the stipulated conditions.

Issues: (i) Whether a shareholder and personal guarantor, who was not a party to the proceedings relating to implementation of the approved resolution plan, had standing to seek recall; and (ii) Whether excluding the delay in handing over possession from the implementation period and extending the time for balance payment constituted an impermissible modification of the approved resolution plan warranting recall.

Issue (i): Whether a shareholder and personal guarantor, who was not a party to the proceedings relating to implementation of the approved resolution plan, had standing to seek recall.

Analysis: Rule 11 of the National Company Law Appellate Tribunal Rules, 2016 was invoked for recall. The applicant was neither a financial creditor nor an operational creditor, was not impleaded in the underlying implementation proceedings, and had not been permitted to intervene. The procedural rights of the suspended management remain subservient to the objectives of the insolvency process after the Committee of Creditors has exercised its commercial wisdom. No legal injury from the extension was established.

Conclusion: The applicant lacked standing to seek recall of the order concerning implementation of the resolution plan.

Issue (ii): Whether excluding the delay in handing over possession from the implementation period and extending the time for balance payment constituted an impermissible modification of the approved resolution plan warranting recall.

Analysis: The successful resolution applicant had made the entire upfront payment, but possession of the subject asset had not been handed over because of continued unauthorised occupation. Handing over possession upon receipt of the upfront amount was an obligation arising under the approved plan. An exclusion of time caused by failure to hand over possession was consistent with implementation of the plan. Extension or exclusion of time for performance of financial obligations in these circumstances does not alter the substantive terms of an approved resolution plan.

Conclusion: The exclusion of delay and consequential extension did not amount to modification of the approved resolution plan and did not warrant recall.

Final Conclusion: The approved resolution plan remains enforceable with appropriate exclusion of time for delay in handing over possession not attributable to the successful resolution applicant.

Ratio Decidendi: Extension or exclusion of time for performance under an approved resolution plan, where implementation is impeded by failure to hand over possession despite timely upfront payment by the successful resolution applicant, does not constitute modification of the plan.

Issues: (i) Whether service tax was chargeable on the termination amount claimed upon premature cancellation of the lease; (ii) Whether service tax on lease rent for April 2013 to August 2014 was to exclude August 2014 and account for the small-service-provider exemption and tax already paid; (iii) Whether the service tax demand based on monthly rent of Rs. 2.90 lakhs received from the subsequent tenant was sustainable.

Issue (i): Whether service tax was chargeable on the termination amount claimed upon premature cancellation of the lease.

Analysis: The termination claim was not received under the eventual compromise. The amount stipulated upon premature vacation was compensatory for reneging on the lease and could not retain the character of rent after the premises had been vacated.

Conclusion: The service tax demand on the termination claim was set aside, in favour of the assessee.

Issue (ii): Whether service tax on lease rent for April 2013 to August 2014 was to exclude August 2014 and account for the small-service-provider exemption and tax already paid.

Analysis: There was no evidence of rent having been paid for August 2014 after vacation of the premises. The small-service-provider exemption, if available, could not be denied, and the tax liability required recomputation after giving credit for tax already deposited.

Conclusion: The demand was partly sustained only after excluding rent for August 2014, allowing the applicable exemption, and appropriating tax already paid, in favour of the assessee.

Issue (iii): Whether the service tax demand based on monthly rent of Rs. 2.90 lakhs received from the subsequent tenant was sustainable.

Analysis: The agreement recording monthly rent of Rs. 2.90 lakhs was corroborated by the tenant's confirmation and was found more credible than the later agreement recording substantially lower rent.

Conclusion: The service tax demand computed on monthly rent of Rs. 2.90 lakhs was upheld, against the assessee.

Final Conclusion: Unreceived compensatory termination amounts were excluded from the taxable value, while the liability on actual lease rent was confined to a recomputed amount and the higher evidenced rent from the subsequent tenancy remained taxable.

Ratio Decidendi: A compensatory amount stipulated for breach of a lease, which is not received and is not rent for continued occupation, is not liable to service tax as consideration for renting.

Issues: (i) Whether taxability and classification are determined by the physical form of goods at the time of sale or by their later end product or end use; (ii) Whether GRD Powder and GRD Mix are classifiable as non-alcoholic drinks and beverages or under the residuary entry.

Issue (i): Whether taxability and classification are determined by the physical form of goods at the time of sale or by their later end product or end use.

Analysis: Taxing statutes require strict construction, and the taxable event is the sale or supply of goods in the form in which they are supplied. A consumer's subsequent choice to mix a powder with milk or water, or to use it in a solid preparation, does not alter the taxable identity of the goods. Common-parlance, functional-character, or basic-nature tests cannot be used to import an end-use criterion where the statutory entry classifies goods by their physical form.

Conclusion: Tax liability and classification are determined by the form in which the goods are sold, not by their possible later end use.

Issue (ii): Whether GRD Powder and GRD Mix are classifiable as non-alcoholic drinks and beverages or under the residuary entry.

Analysis: Entry 20(ii) associates beverages with syrups, cordials, distilled juices, ark and essences, which constitute a class of liquid goods. Applying ejusdem generis, the expression "beverages" takes its meaning from those associated liquid preparations. The expression "including" does not extend the entry to goods of a materially different physical form, and the entry contains no deeming inclusion of powders, concentrates or biscuits used to prepare drinks.

Conclusion: GRD Powder and GRD Mix, being sold as powder and biscuit, are not non-alcoholic drinks or beverages and fall under the residuary entry.

Final Conclusion: Products sold in powder or biscuit form remain subject to the residuary classification notwithstanding their possible subsequent preparation as drinks.

Ratio Decidendi: For fiscal classification, the taxable identity of goods is determined by their physical form at the time of sale, and a later consumer end use cannot convert a powder or solid product into a beverage where the specific entry contextually covers liquid goods.

Issues: (i) Whether acquittal in a separate prosecution for criminal breach of trust and cheating extinguishes the independently acknowledged legally enforceable debt supporting the cheque-dishonour prosecution; (ii) Whether the drawer rebutted the statutory presumptions by a probable defence based on an uncorroborated claim that the cheque leaf was snatched; (iii) Whether the statutory demand-notice requirements were met despite the drawer's plea of non-service; and (iv) Whether the concurrent findings warranted interference in revisional jurisdiction.

Issue (i): Whether acquittal in a separate prosecution for criminal breach of trust and cheating extinguishes the independently acknowledged legally enforceable debt supporting the cheque-dishonour prosecution.

Analysis: A prosecution for cheque dishonour is founded upon the independently enforceable monetary liability underlying the cheque. The written declaration and notarized agreement acknowledging liability supplied an independent basis for the debt. An acquittal in the separate criminal prosecution because of deficiencies in proof of its distinct penal ingredients did not negate that written acknowledgment or the monetary liability.

Conclusion: The separate acquittal did not extinguish the legally enforceable debt underlying the cheque. The issue is decided against the petitioner.

Issue (ii): Whether the drawer rebutted the statutory presumptions by a probable defence based on an uncorroborated claim that the cheque leaf was snatched.

Analysis: Upon proof of drawing, presentation and dishonour of the cheque, the statutory presumption of consideration and liability arose. Although the reverse onus could be discharged on a preponderance of probabilities, a bare statement under Section 313, unsupported by defence evidence, a contemporaneous police report or intimation to the bank, did not amount to a probable defence.

Conclusion: The statutory presumptions remained unrebutted, as the snatched-cheque defence was not probable. The issue is decided against the petitioner.

Issue (iii): Whether the statutory demand-notice requirements were met despite the drawer's plea of non-service.

Analysis: Dispatch of the notice by registered post to the drawer's admitted correct address attracted the presumption of due service. No reliable material established incarceration at the relevant delivery time. Further, receipt of court summons with the complaint afforded an opportunity to pay the cheque amount within fifteen days; failure to do so precluded reliance on an alleged defect in notice service.

Conclusion: The statutory notice requirements were satisfied. The issue is decided against the petitioner.

Issue (iv): Whether the concurrent findings warranted interference in revisional jurisdiction.

Analysis: Revisional jurisdiction is not a second appellate review and is exercisable only where concurrent findings are perverse, unsupported by evidence, or affected by gross illegality or procedural miscarriage. The findings rested on the cheque, dishonour memo, notice materials, written acknowledgment and the unrebutted statutory presumptions, without any demonstrated patent perversity or legal infirmity.

Conclusion: No ground for revisional interference was established. The issue is decided against the petitioner.

Final Conclusion: The independently acknowledged liability, unrebutted statutory presumptions and valid notice process sustain the conviction and sentence for dishonour of cheque.

Issues: (i) Whether dates appearing in Forms GST DRC-01 and GST DRC-07 govern limitation for issuance of show cause notices and adjudication orders under Sections 74(2) and 74(10) of the Central Goods and Services Tax Act, 2017; (ii) Whether challenges to the invocation of Section 74 and the evidentiary basis of the demand should be entertained in writ jurisdiction despite an available statutory appeal.

Issue (i): Whether dates appearing in Forms GST DRC-01 and GST DRC-07 govern limitation for issuance of show cause notices and adjudication orders under Sections 74(2) and 74(10) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 74(2) requires issuance of the substantive notice under Section 74(1), while Section 74(10) requires issuance of the substantive order under Section 74(9) within the stipulated periods. Rule 142(1)(a) treats Form GST DRC-01 as an electronic summary accompanying the notice, and Rule 142(5) treats Form GST DRC-07 as an electronic summary of the order. The substantive notices and orders bore dates preceding the asserted limitation cut-off dates; the later dates on the electronic summaries could not replace or alter the dates of the substantive instruments.

Conclusion: Forms GST DRC-01 and GST DRC-07 do not determine limitation under Sections 74(2) and 74(10), and their later dates do not render the substantive notices or orders time-barred.

Issue (ii): Whether challenges to the invocation of Section 74 and the evidentiary basis of the demand should be entertained in writ jurisdiction despite an available statutory appeal.

Analysis: The objections concerning fraud, wilful misstatement, suppression, knowledge or collusion, admissibility of input tax credit, computation, penalty, and sufficiency of departmental material require factual examination and appreciation of evidence. Section 107 provides an efficacious appellate remedy competent to address those questions of law and fact. No denial of hearing or patent jurisdictional defect was established, and the limitation objection did not justify bypassing that remedy.

Conclusion: The merits challenges are not to be entertained in writ jurisdiction and may be urged before the statutory Appellate Authority under Section 107.

Final Conclusion: Timely substantive notices and adjudication orders are not invalidated by subsequent electronic summaries, and factual challenges to the demand must be pursued through the statutory appellate mechanism.

Ratio Decidendi: For limitation under Section 74 of the Central Goods and Services Tax Act, 2017, the relevant dates are those of the substantive show cause notice and adjudication order; Forms GST DRC-01 and GST DRC-07 are consequential electronic summaries and do not substitute those instruments.

Issues: (i) Whether the computer printouts and private or third-party records were admissible and sufficiently linked to the assessee to establish clandestine manufacture and under-invoicing; (ii) Whether abnormal electricity consumption and alleged theft of electricity established unaccounted manufacture and clearance; (iii) Whether the alleged clandestine production was sustainable in view of the installed furnace capacity; (iv) Whether statements relied upon for the demand could be admitted without compliance with the prescribed procedure.

Issue (i): Whether the computer printouts and private or third-party records were admissible and sufficiently linked to the assessee to establish clandestine manufacture and under-invoicing.

Analysis: Electronic records require compliance with the safeguards under Section 36B, including the prescribed certification concerning their production and device. The separately captioned computer folder, records not bearing the assessee's name, and documents recovered from dealer premises lacked independent verification linking the transactions to the assessee. There was also no tangible corroboration through raw-material consumption, transport, buyers, financial flow-back, or actual excess production.

Conclusion: The computer printouts and private or third-party records were inadmissible or insufficient to establish clandestine manufacture or under-invoicing, in favour of the assessee.

Issue (ii): Whether abnormal electricity consumption and alleged theft of electricity established unaccounted manufacture and clearance.

Analysis: Electricity consumption may vary because of operational and technical factors. Without a scientifically established plant-specific consumption norm and independent evidence linking consumption to quantified unaccounted production and clearance, electricity data and an allegation of electricity theft could not substantiate excise evasion.

Conclusion: Abnormal electricity consumption and alleged theft of electricity did not establish unaccounted manufacture or clearance, in favour of the assessee.

Issue (iii): Whether the alleged clandestine production was sustainable in view of the installed furnace capacity.

Analysis: A charge of clandestine manufacture must be tested against the physical capacity of the plant. The alleged production was not shown to be achievable even with both operational furnaces, and no undisclosed manufacturing facility was established.

Conclusion: The alleged clandestine production was not sustainable in view of the unaddressed capacity constraint, in favour of the assessee.

Issue (iv): Whether statements relied upon for the demand could be admitted without compliance with the prescribed procedure.

Analysis: Statements recorded during investigation cannot prove the truth of their contents unless the mandatory procedure under Section 9D is followed. The required statutory exercise was not undertaken, and the statements had not been tested in the prescribed manner.

Conclusion: The untested statements could not be read in evidence against the assessee, in favour of the assessee.

Final Conclusion: The cumulative absence of admissible electronic evidence, independently corroborated material, capacity-based proof, and legally usable statements left no sustainable evidentiary basis for excise liability, interest, or penalty.

Ratio Decidendi: A charge of clandestine manufacture, clearance, or under-invoicing cannot rest on uncertified electronic records, unverified private or third-party documents, untested statements, or electricity consumption alone; it requires legally admissible and independently corroborated evidence.

Issues: Whether the demand notice dated 15.07.1997 for sales tax assessment year 1991-92 was barred by the five-year limitation prescribed under Section 12 of the Rajasthan Sales Tax Act, 1994.

Analysis: The earlier demand notice dated 06.03.1997 concerning the same assessment year had been issued within the prescribed five-year period. The subsequent notice dated 15.07.1997 was in continuity of that earlier notice and related to the same sales-tax demand.

Conclusion: The demand notice dated 15.07.1997 was not barred by limitation and was valid. The issue was decided against the assessee.

Issues: Whether the contractual claim for refund of the GST element under Clause 2.14.A was covered by the arbitration clause, thereby justifying dismissal of the writ petition on the ground of an alternative arbitral remedy.

Analysis: The refund claim was founded on the specific tax-reimbursement stipulation in Clause 2.14.A. The arbitration clause did not extend to this dispute. The existence of an arbitration agreement therefore could not justify declining writ jurisdiction on that basis. The merits of the competing interpretations of Clause 2.14.A and the GST-refund claim were left for determination by the High Court within the scope of judicial review.

Conclusion: The GST-refund dispute under Clause 2.14.A does not fall within the contractual arbitration clause, and dismissal of the writ petition on the ground of an available arbitral remedy was unjustified.

Issues: Whether the Tribunal could restore the matters to the first appellate authority without adjudicating the revenue appeals and the assessee's cross-objections on merits, despite the reasoned first-appellate order available for one of the assessment years.

Analysis: The Tribunal treated both assessment years alike by relying on the absence of reasons in the first-appellate order for one year, while overlooking that a detailed and reasoned order on the same issues existed for the subsequent year. The relevant factual material and grounds were available before the Tribunal, which was required to undertake adjudication on merits rather than mechanically restoring both matters. The approach disclosed non-application of mind.

Conclusion: The Tribunal's restoration order was unsustainable. Both substantial questions were answered in favour of the assessee and against the Revenue, and the Tribunal was required to decide the matters on merits after hearing both sides.

Issues: (i) Whether assessment for 1993-94 completed on 31 March 2001 was time-barred following the amendment to Section 42; (ii) Whether purchases from dealers whose registrations were retrospectively cancelled could be treated as purchases from unregistered dealers where the transactions themselves were not genuine.

Issue (i): Whether assessment for 1993-94 completed on 31 March 2001 was time-barred following the amendment to Section 42.

Analysis: Section 42, as substituted with effect from 31 March 1994 by the Gujarat Sales Tax (Amendment) Act, 1994, confined the three-year limitation to fresh assessments made pursuant to orders under the specified appellate or judicial provisions. The substituted provision applied to the relevant assessment period and did not prescribe a limitation for completion of an original assessment between 1993 and 31 July 1998.

Conclusion: The assessment was not time-barred; the issue is decided in favour of the Revenue and against the assessee.

Issue (ii): Whether purchases from dealers whose registrations were retrospectively cancelled could be treated as purchases from unregistered dealers where the transactions themselves were not genuine.

Analysis: Concurrent factual findings established material discrepancies in the purchase and transport documents, including absence of vehicle particulars, inconsistency regarding the destination of goods, and lack of reliable evidence of payment and actual movement of goods. Tax benefits based on purchases require proof of genuine transactions and physical movement of the goods; a retrospective cancellation of the suppliers' registrations does not assist a purchasing dealer whose transactions are not proved genuine.

Conclusion: The purchases were rightly treated as purchases from unregistered dealers; the issue is decided in favour of the Revenue and against the assessee.

Final Conclusion: The assessment and the treatment of the impugned purchases as purchases from unregistered dealers are sustained.

Issues: (i) Whether petroleum products listed in Schedule II(d) as "kept outside VAT" remain taxable at the first point of sale under the Tripura Value Added Tax Act, 2004; (ii) Whether road development cess is leviable on the turnover of sales of petrol, diesel and natural gas.

Issue (i): Whether petroleum products listed in Schedule II(d) as "kept outside VAT" remain taxable at the first point of sale under the Tripura Value Added Tax Act, 2004.

Analysis: The proviso to Section 3(1)(b) permits specified Schedule II(d) goods to be kept outside the multi-stage VAT mechanism while being taxed at the first point of sale without input tax credit at notified rates. Petrol and diesel are listed in that Schedule. The expression "kept outside VAT" denotes exclusion from the ordinary multi-stage value-added-tax regime, not exclusion from the operation of the Tripura Value Added Tax Act, 2004. The statutory scheme therefore preserves a single-point levy on such goods.

Conclusion: The issue is decided against the assessee: petrol and diesel remain liable to the notified first-point tax, and no refund of the tax so collected is due.

Issue (ii): Whether road development cess is leviable on the turnover of sales of petrol, diesel and natural gas.

Analysis: Section 3(1) of the Tripura Road Development Cess Act, 2015 levies cess on the turnover of sales, subject to deduction for turnover on which cess was paid earlier and a prohibition against more than one-stage levy. "Turnover of sales" includes the sales price and tax levied under the Tripura Value Added Tax Act, 2004. Since petroleum products are outside the ordinary VAT mechanism but continue within the Tripura Value Added Tax Act, 2004 under the first-point tax regime, their turnover remains a valid basis for cess.

Conclusion: The issue is decided against the assessee: levy of road development cess on the relevant turnover is valid.

Final Conclusion: The statutory scheme lawfully subjects Schedule II(d) petroleum products to special first-point taxation and permits cess to be computed on their turnover of sales.

Ratio Decidendi: Goods excluded from the multi-stage VAT mechanism but expressly subjected to first-point tax under the governing tax statute remain within that statute and may form the tax-inclusive turnover base for a cess levy.