The first proviso to Section 129A(1) excludes Tribunal appellate jurisdiction over orders relating to goods imported as baggage. Gold chains brought into India by an arriving international passenger retain their character as baggage regardless of the method of carriage or issues concerning the merits of confiscation. Challenges to confiscation orders involving such baggage must therefore be pursued through the statutory revisionary remedy under Section 129DD, rather than by appeal before the Tribunal. Appeal papers filed before the Tribunal are to be returned for pursuing revision.

Article 227 supervisory intervention in ongoing arbitration is confined to a manifest and patent lack of inherent jurisdiction. Where the arbitration agreement, its invocation for a joint venture, and commencement of the reference are undisputed, a dispute over a liquidator's authority to represent the joint venture and continue proceedings falls within the arbitral tribunal's competence. A joint venture constituent that remains silent after notice of the liquidator's asserted authority may be treated as having acquiesced. Equitable supervisory relief is unavailable where intervention seeks to terminate a pre-existing claim rather than protect the joint venture's interests, particularly where the conduct is in bad faith.

Section 32A(1) of the Insolvency and Bankruptcy Code ends a corporate debtor's liability for offences committed before commencement of CIRP once an approved resolution plan results in a qualifying change in management or control. The immunity can protect a successor company that takes over and amalgamates with the former corporate debtor, preventing civil or criminal liability for the predecessor's pre-CIRP acts, including alleged Air Act offences. Its application is company-specific: proceedings may be quashed against the protected successor without affecting prosecution of the remaining accused.

Tribunal leave is mandatory for continuation of a pending suit by or against a company in liquidation. Where joint reliefs are sought against the company and a co-defendant, the claimant cannot maintain the suit or appeal by deleting the company from the parties. The liquidator must be served and represented in proceedings involving the company in liquidation. The commercial judgment was set aside, and the suit was remitted for fresh consideration only if leave is obtained from the Tribunal to continue proceedings against the company.

Non-party former management, including a shareholder and personal guarantor, cannot seek recall of an order concerning resolution-plan implementation merely because counsel appeared in the proceedings. Participation rights are subordinate to timely insolvency resolution; without creditor status, impleadment, permitted intervention, or legal injury, no locus standi arises. Where a successful resolution applicant has paid the upfront amount but possession of the corporate debtor's property remains withheld through unauthorised occupation, excluding time for payment obligations facilitates implementation without modifying the approved resolution plan. The Adjudicating Authority may grant that extension without express committee of creditors concurrence.

Individual shareholders do not, merely by virtue of shareholding, qualify as aggrieved persons entitled to appeal approval of a corporate debtor's resolution plan. Allegations that post-approval modifications were fraudulent cannot expand standing unless supported by specific material. Homebuyers who have not independently challenged the resolution plan cannot contest it indirectly by supporting a shareholder's appeal. The shareholder's challenge to the approved resolution plan was therefore treated as not maintainable, and the related interlocutory applications were rejected.

Separately billed room-service food and beverages supplied in hotel rooms were treated as sales rather than restaurant services because hotel rooms were not restaurant premises and no evidence linked the charges to room-service value; the related service-tax demand was set aside. Exclusive liquor-brand listing, displays and branded accessories constituted taxable promotional or sponsorship service, leaving that demand sustainable only within the normal limitation period. Actual electricity charges recovered from tenants on sub-meter readings and remitted to suppliers were not consideration for renting, so the demand was set aside. Extended limitation required deliberate evasion, not mere non-declaration; the surviving demand was restricted to the normal period.

Parallel criminal acquittal for failure to prove penal ingredients does not by itself negate an independently acknowledged financial liability supporting cheque dishonour proceedings. A notarized agreement and written declaration may establish a legally enforceable debt. Once foundational facts are proved, presumptions of consideration and discharge arise and require a probable, material-supported defence; an uncorroborated snatched-cheque assertion without a contemporaneous police complaint or bank intimation is insufficient. Registered dispatch to the drawer's correct address supports due service of the statutory demand notice, while revisional review remains limited to perversity, lack of evidence, or material legal or procedural error.

Availability of an efficacious statutory GST appeal generally weighs against writ adjudication of challenges to a consolidated show-cause notice. Objections that the notice is barred by limitation, issued without jurisdiction, or impermissibly combines separate financial years may involve disputed questions of fact and law suitable for appellate examination. The statutory appeal under Section 107 of the CGST Act preserves those objections for determination. The writ petition was relegated to that remedy, subject to an adjusted pre-deposit, with no coercive action until the appeal attains finality.

Anticipatory bail following a CGST summons is not premature merely because no arrest order exists: summons alone neither establishes arrest nor makes a person an accused, but tangible circumstances may create a real and reasonable apprehension of arrest. Such apprehension only engages anticipatory-bail jurisdiction; it does not establish entitlement to pre-arrest protection. In an investigation concerning alleged clandestine manufacture and clearance, outstanding inquiries, a co-accused's arrest, and alleged non-cooperation supported the need for possible further interrogation. The application was therefore refused, as investigation requirements outweighed the requested extraordinary protection.

Service of the show-cause notice through the GST portal, registered post, or e-mail is essential before an ex parte GST demand may be sustained. Where the record contains no material establishing such service and the taxpayer received no opportunity to submit a defence or be heard, the adjudication breaches the required process. The adjudication and appellate orders were set aside, and the matter was remitted for fresh adjudication after furnishing the show-cause notice, permitting objections, and granting a hearing.

Natural justice in ex parte GST adjudication required fresh consideration where medical records substantiated the proprietor's pregnancy and consequent inability to participate. Expiry of the statutory appellate limitation left no appellate remedy. The ex parte GST demand was set aside subject to deposit of 10% of the tax demanded and remitted from the reply-and-document-production stage, with a reasonable opportunity of hearing. Non-appearance as directed would automatically revive the earlier order.

Compulsory acquisition of land and buildings under the State's eminent-domain power is an expropriation, not a supply of goods or services for GST purposes. Land and buildings attached to land are immovable property, and landowners do not sell goods or provide services merely by surrendering property pursuant to statutory acquisition. GST deducted from compensation for such acquisition therefore lacks statutory basis. The deduction was treated as exceeding legal authority, with the affected compensation notice quashed to that extent and refund of the deducted GST with interest directed.

Statutory outer limits on condonation of delay in GST registration-cancellation appeals confine the First Appellate Authority to the power expressly granted. Constitutional-court directions issued in extraordinary jurisdiction cannot enlarge that statutory power, and equity or substantial justice cannot displace the prescribed limit; appeals entertained after that limit are without jurisdiction. Where the Department has implemented appellate orders by restoring cancelled registrations, its own challenge becomes infructuous because the restored legal and commercial position cannot be unsettled without affecting intervening transactions. Such departmental appeals are not maintainable after implementation of the impugned orders.

Notional rental income under Section 23(1)(a) is not chargeable on unsold flats during a period in which they are legally unoccupiable because no occupancy certificate has been issued. A completion certificate alone does not establish legal occupiability for this purpose. Consequently, notional rental income cannot form the basis for revision of an assessment for that period, and the Revenue's appeal was dismissed.

Use of a company's disclosed income to purchase jewellery on its behalf does not, without more, constitute acceptance by its managing director of a cash loan or deposit. Storage of company jewellery at the managing director's residence or in his locker for safekeeping does not alter that character. Characterising the arrangement as a cash loan or deposit on assumptions, presumptions or surmise renders the related penalty unsustainable; the penalty was deleted.

Jurisdiction over an amalgamating company ends when it ceases to exist following amalgamation. A section 201 order issued and served in the former company's name, despite prior notification to the TDS authority, suffers a jurisdictional defect; referring to the successor company in the body of the order does not cure it. The order was void ab initio and quashed, while the issue of interest under section 201(1A) remained academic.

Interest under section 244A on a refund claimed through a return filed after the statutory deadline depends on the return's validity and prior condonation of delay. A return filed late without a preceding condonation application is treated as invalid for this purpose. Clause (ii) of paragraph 6 of the CBDT circular applies generally to belated refund claims, rather than only to supplementary refund claims, when read with the circular's preceding provisions. Statutory interest is therefore unavailable on refunds claimed through such belated returns.

Reassessment of a loan credit previously examined in scrutiny cannot rest on the same confirmation, bank statements and balance sheet without fresh information or tangible material; adopting a different view is an impermissible change of opinion. Separately, an electronic notice served on or after 1 April 2021 must follow section 148A: a show-cause notice, supply of material, consideration of the taxpayer's reply, and an order before issuing a notice under section 148. Failure to follow this sequence invalidates reassessment. On these independent grounds, the reassessment notice and consequential order were quashed, without deciding the loan-credit addition on merits.

Foreign tax credit for Australian employment income cannot be denied solely because a belated return and Form No. 67 were filed late where substantive entitlement and compliance with other required formalities are undisputed. Rule 128's timing requirement is treated as a directory procedural condition in subordinate legislation and cannot curtail substantive entitlement to foreign tax credit. The credit claim was consequently required to be accepted, and the denial was set aside.