Electronic data and computer printouts qualify as documentary evidence for excise purposes only when statutory conditions, including the required certificate, are met. Material failing that threshold cannot quantify alleged clandestine manufacture or clearance; the limited third-party certificate exception requires proof that all possible steps to secure it were taken. Investigative statements remain distinct evidence. Refusal of cross-examination invalidates reliance on them only where demonstrated, witness-specific prejudice exists. Unretracted statements, read with invoices, transport, weighment and statutory records, may establish transactions or quantities independently, but quantities appearing only in inadmissible electronic records cannot be adopted. Duty, interest and penalties must rest solely on independently admissible evidence after hearing.

Admissibility of evidence governs denial of CENVAT credit for alleged non-receipt of inputs. Third-party investigative statements require examination and formal admission unless a statutory exception applies, while third-party electronic records require prescribed safeguards and certification. Uncorroborated transport discrepancies or portal data do not, without transaction-specific proof, displace invoices, payment records, production records and duty-paid clearances. Personal penalty requires proof of knowledge, active participation and conscious dealing with goods liable to confiscation. A deposit during investigation, including a payment asserted to be coerced, does not alone establish liability or fraudulent availment of credit.

Job-work services involving goods produced from client-supplied materials qualify for exemption where the processed goods are returned for use in manufacturing final products cleared on payment of appropriate excise duty. In those circumstances, inputs and input services used for the job work remain eligible for CENVAT credit under Rule 3 of the CENVAT Credit Rules, 2004. The services are not treated as exempted services for Rule 6 purposes, so the Rule 6 credit-reversal restriction does not apply.

Royalty paid under mining lease agreements executed before 1 April 2016 is not liable to service tax under the reverse charge mechanism under the negative-list regime, and no penalty is imposable. The execution date of each mining lease agreement is material to determining the exclusion. Where agreements were not produced before the lower authorities, factual verification of their execution dates is necessary before service tax liability and penalty can be determined.

Earmarked government grants-in-aid do not constitute taxable consideration for Business Exhibition Service where they fund specified activities, are subject to utilisation certification, are fully recorded as expenditure, and lack a service-provider-client relationship, invoices, or payment for services. The grants operate as reimbursement-like funds rather than consideration. Extended limitation is unavailable where grant transactions and expenditure appear in audited accounts and a bona fide belief negates suppression or intent to evade tax. It is likewise unavailable for reverse-charge liability where recorded transactions are revenue neutral because any tax paid would be available as CENVAT credit.

Expatriate deputation by an overseas employer for a fixed, short duration fell within taxable Manpower Recruitment and Supply Service; salary payment, tax deduction and Form 16 issued by the recipient did not alter that character. However, extended limitation required deliberate withholding of material facts. Audit or investigation-based detection, without a reasoned finding of deliberate suppression, was insufficient. The demand was therefore time-barred despite taxable service on merits.

Composite service classification follows the essential character test: work orders predominantly involving transportation of coal, slurry and related material fall under goods transport agency service, while incidental activities do not convert the service into mining. Consignment-note transactions may attract reverse-charge liability for specified corporate recipients; transport without consignment notes falls within the negative list. Small-service-provider exemption applies to management, maintenance and repair and supply of tangible goods services except for limited non-exempt turnover. In the absence of suppression with intent to evade, no penalty for non-payment applies, although delayed return filing remains penalised. A separate unsupported demand for the later period is unsustainable.

Service-tax exemption under Notification No. 18/2009-S.T. required the exporter to submit the certified half-yearly return and supporting documents within 15 days after the relevant period. The Service Tax Rules allowing belated returns on payment of a fine did not displace that separate exemption condition, so late filing defeated the claim. Penalty for service-tax default had to remain within the statutory daily or monthly calculation and maximum ceiling; a penalty calculated above those limits could not be sustained.

Duplicate service-tax demands arising from two show-cause notices issued on the same date for the same tax period required verification because separate orders may have confirmed identical liability. As the related demand order was already under statutory appeal, the matter was remitted for fresh adjudication to determine whether the demands overlapped, after providing an opportunity to submit a reply and be heard.

Sponsorship for service-tax purposes requires a stipulated reciprocal promotional benefit, such as mandatory display of the payer's logo; payments made without any obligation on the recipient to provide a benefit remain non-taxable donations or gifts. Unilateral acknowledgement or a sponsorship label in records does not establish the payment's true character, and Revenue bears the burden of proving taxable sponsorship. The extended limitation period requires credible material of fraud, collusion, wilful misstatement, or suppression of facts. Without such material, the extended period is unavailable; consequently, otherwise taxable logo-display payments are time-barred and no service-tax demand survives.

Article 226 permits writ review despite an available statutory appeal where undisputed facts and legal questions, including prolonged pendency, make the alternate remedy inappropriate. Judicial discipline requires subordinate quasi-judicial revenue authorities to follow an operative, unstayed appellate order notwithstanding a pending departmental challenge. Construction-service exemption under Clause 12A(a) applies where a state-established entity has at least 90% governmental equity or control and performs municipal functions under Article 243W, including public-distribution activities linked to poverty alleviation and social and economic development. Clause 14(d) covers original works forming post-harvest storage infrastructure where godowns principally store paddy and rice procured from farmers.

Amalgamation extinguishes the transferor company's legal existence, rendering proceedings and a show-cause notice issued solely in its name a nullity. An adjudication order founded on such notice was set aside. Service-tax liability, amalgamation documentation and surrender of registration were left for fresh determination on the petitioner's representation rather than resolved in the quashed adjudication.

Release of property mortgaged to a bank but attached under the Prevention of Money Laundering Act requires the mortgagee to establish non-involvement in the offence and adequate due diligence in both loan sanction and recovery. RBI guidance for advances against a depositor's own fixed deposits does not extend to loans secured by third-party deposits. Delayed recovery action and unresolved concerns over fund flows or prior associations may prevent enforcement of the security interest. Relief concerning auction and outstanding dues may be pursued before the Special Court under the Act's prescribed provisions.

Interference with an order granting regular bail in a money-laundering matter is distinct from cancellation based on post-release misconduct or supervening circumstances. Appellate interference is justified only where the bail order is illegal, arbitrary, perverse, based on irrelevant material, or omits relevant considerations; detailed evaluation of evidence remains impermissible at the bail stage. Consideration of the absence of material linking the accused to proceeds of crime, completion of investigation, delayed trial prospects, and protective bail conditions can demonstrate application of the statutory twin conditions and general bail principles. Mere disagreement with that assessment does not justify setting aside bail.

Further investigation into money laundering may continue after filing of a complaint and before charges are framed, without prior leave of the Special Court. Explanation (ii) to Section 44(1) permits additional oral or documentary evidence after a complaint. The permission requirement under the proviso to Section 193 of the Bharatiya Nagarik Suraksha Sanhita, 2023 applies only during trial, which begins upon charge framing. Further investigation continues the original investigation rather than constituting impermissible reinvestigation; the Enforcement Directorate may therefore issue summons at that pre-trial stage.

Recall of an ex parte order should not be rejected as delayed where the applicant filed after the Adjudicating Authority expressly granted liberty to seek recall following identification of an earlier procedural mistake. Treating such an application as time-barred is hypertechnical where the underlying proceeding remains pending. The delay-based rejection was set aside, the ex parte order was recalled for the appellant, and its reply was taken on record with permission to participate in further proceedings.

Expiry of the CIRP period without receipt of a resolution plan or a valid extension requires mandatory liquidation. This consequence operates independently of liquidation initiated through a Committee of Creditors resolution; failure to obtain the voting threshold for such a separate resolution does not prevent liquidation following CIRP expiry. The Committee of Creditors' commercial wisdom cannot override statutory timelines or prescribed consequences. Post-expiry resolutions seeking directions, later expressions of interest, or eligibility-related claims cannot revive an expired CIRP.

Liberty to revive appeals dismissed as infructuous following a one-time settlement applies where the settlement fails because of the bank's default, not where the principal borrower and personal guarantors fail to perform their obligations. The settlement required payment of outstanding stipulated amounts and guarantors' cooperation; no further payment was made after the upfront amount. As the borrower's and guarantors' liabilities were co-extensive, personal guarantors could not invoke revival liberty to benefit from their own non-compliance. Revival of the appeals was therefore unavailable to them.

Landowners entering a Joint Development Agreement are co-promoters under the Real Estate (Regulation and Development) Act, 2016 where the developer and seller are different persons, and share statutory functions and liabilities. A pending Corporate Insolvency Resolution Process does not automatically bar enforcement under another law; questions on the moratorium, insolvency estate, and protection of the resolution process fall within the National Company Law Tribunal's jurisdiction. A public auction issued to execute an unchallenged Recovery Certificate may proceed because the certificate remains valid and enforceable unless stayed, modified, or set aside by a competent forum.

An approved resolution plan under the Insolvency and Bankruptcy Code binds the corporate debtor, creditors, governmental authorities and other stakeholders. Where the plan expressly waives pre-effective-date arrears, transfer charges, interest, penalties and lease-related liabilities, those claims cannot be revived through a later demand. The clean-slate principle prevents recovery of extinguished liabilities and supports unconditional mutation and transfer of leasehold rights where the plan requires change-in-control approval.