Monetary limits for departmental appeals under the Central Excise and service-tax framework apply to pending legacy matters, including disputes involving recurring issues. Appeals before the High Court below the prescribed threshold cannot be pursued merely on alleged cascading consequences or a common question of law. The only retained exceptions concern challenges to the constitutional validity of an Act or Rule and findings that a notification, instruction, order, or circular is illegal or ultra vires. The former classification-and-refund exception was withdrawn, and income-tax circulars do not expand the available exceptions. Below-threshold appeals outside those exceptions are precluded, while proposed substantial questions of law remain open.

Finality of assessments in Bills of Entry bars a subsequent differential customs-duty demand based on reclassification when Revenue did not challenge the original assessments. Goods were assessed under the importer's declared classification and cleared after out-of-charge; those assessments consequently became final. The confirmed demand was set aside, and Revenue's challenge to the dropped demand was not maintainable.

Penalty for alleged evasion of anti-dumping duty through routing Chinese-origin goods via Malaysia requires legally admissible proof that certificates of origin were false, unauthorised or discrepant, and that the person penalised knew of or aided the contravention. The alleged procurement of false certificates must be supported by reliable evidence and prescribed verification of the certificates. Electronic material lacking evidentiary admissibility, retracted statements, and statements relied upon without cross-examination despite statutory safeguards cannot establish the requisite knowledge, involvement or abetment for penalty under Section 112(a)(ii) of the Customs Act, 1962.

Penalty under Section 112(b) of the Customs Act requires reliable material establishing that a person dealt with goods liable to confiscation with knowledge or reason to believe that liability. A promptly retracted statement, unsupported by verification of alleged owners, the landlord, or other corroborative evidence, does not satisfy that requirement. An invoice supporting the claim that certain cartons were Indian-made further weakens attribution of foreign-origin cigarettes. Where confiscation, release, and valuation of seized electric rice cookers and ceramic stoves remain inadequately established, release on a reduced redemption fine may be appropriate.

Unflavoured supari classification under CTI 2106 90 30 is governed by Rule 1 of the General Rules for Interpretation, tariff descriptions and Supplementary Note 2 to Chapter 21, which covers supari without requiring added ingredients. Revenue must produce cogent evidence to displace that specific entry; inconclusive laboratory testing of physical features does not establish classification as split areca nuts, while food-safety material supports product identity without conclusively determining classification. An unchallenged Certificate of Origin supports preferential basic customs duty. With classification as supari and no lawful basis to reject declared value, valuation proceeds under Section 14(1), leaving no basis for confiscation or consequential customs liabilities.

Misdeclaration of restricted goods as refractory bed material in an attempted export supports confiscation, redemption fine and penalties where no mala fides, statutory violation or extreme arbitrariness affects the discretionary sanctions. The re-export principle applicable to imported goods does not govern such attempted exports. Seized goods may be disposed of through e-auction where provisional release is not obtained within the prescribed period, but Customs must issue proper prior notice, allow at least 30 days for objections, and comply with applicable statutory requirements and instructions.

Investigative clearance enabled the petitioner to obtain duplicate SIM cards for mobile numbers whose SIM cards had been seized. The request for release arose while the petitioner was detained and was made through the petitioner's wife. Availability of duplicate SIM cards addressed the practical grievance concerning continued access to the mobile numbers. Allegations in the writ petition remained denied and unadmitted because no affidavit in opposition was called for.

Contractual deductions from mining-transport bills for failure to meet agreed performance quantities constitute allowable business expenditure where they arise solely under contractual terms and are not connected with an offence or a purpose prohibited by law. Such recoveries therefore fall outside the exclusion in Explanation 1 to Section 37(1). Cash payments do not attract disallowance under Section 40A(3) where no individual payment to a payee exceeds Rs. 20,000 on a single day. The contractual recovery remains deductible and no cash-payment disallowance arises when the prescribed daily threshold is not crossed.

Additions for alleged on-money receipts founded on WhatsApp chats, third-party statements and seized material require meaningful confrontation and cross-examination of material witnesses. Untested material containing no specific admission or complete enforceable agreement remains a suspicious circumstance and cannot sustain an addition. Proceedings under Section 153C require year-specific satisfaction establishing a nexus between seized material and income determination for each assessment year. A consolidated satisfaction note spanning years for which no incriminating material is alleged lacks that nexus, invalidating initiation of proceedings and undermining consequential assessment and penalty.

Set-off of brought-forward business losses under Section 72 requires verification from departmental records that relevant returns were filed and that losses remain eligible and available for carry forward; this verification cannot recompute the quantum or character of losses determined in the year incurred. Section 50 deems capital gains on transfer of depreciable assets to be short-term only for computation. It does not change a qualifying depreciable immovable asset's long-term character for the Section 112 tax rate, subject to verification of the prescribed holding period.

Section 115BAA allows a domestic company to elect the prescribed concessional tax rate by filing Form No. 10-IC within the specified time, subject to statutory conditions. Once validly exercised, the option is irrevocable and applies to subsequent assessment years; Form No. 10-IC is not required annually. Where the initial option was accepted and no breach of conditions or invalidity of the election arises, the concessional rate continues to govern later assessment years, requiring tax computation on that basis.

Brought-forward business losses may be verified at the set-off stage through departmental records of return filing and eligibility, but their quantum and character remain those determined in the year of loss and cannot be recomputed. Set-off follows where the losses are verified as available. Section 50's deeming fiction treats gains on depreciable assets as short-term only for capital-gains computation; it does not change the asset's long-term character when determining the applicable tax rate. Gains from depreciable immovable property satisfying the prescribed holding period are therefore taxable under section 112, subject to verification of that condition.

Cash payments for purchase of spares do not attract disallowance under section 40A(3) where no individual payment exceeds the prescribed daily threshold. Contractual deductions for failure to transport the agreed minimum quantity of coal constitute demurrage or damages under contractual terms, rather than penalties for infringement of law. Such expenditure therefore falls outside Explanation 1 to section 37(1) and remains deductible as business expenditure. The deletions of disallowances relating to both cash payments and contractual demurrage were sustained.

Redemption fine and penalties for attempted export of restricted natural garnet declared as refractory bed material may be sustained where the redetermined value, serious misdeclaration and export restriction through a canalising agency support their quantum. Appellate intervention in discretionary customs sanctions is confined to mala fides or extreme arbitrariness; the rule concerning non-imposition of redemption fine on re-export does not apply to attempted export of restricted goods. Confiscated goods remaining in Customs custody because provisional release was not availed may be e-auctioned under statutory disposal powers, but only after at least 30 days' notice inviting objections and compliance with applicable law and instructions.

Penalty under section 112(b) requires proof that a person dealt in goods liable to confiscation and knew or had reason to believe that the goods were confiscable. An unaddressed retraction and unverified allegations concerning other cigarette owners or the landlord could not establish those requirements, particularly where an invoice supported the claim that certain cigarettes were Indian-made; the penalty was set aside. Foreign-origin rice cookers and ceramic stoves were released on payment of redemption fine because neither confiscation nor release had been properly substantiated and their valuation rested on assumptions.

Penalty for alleged aiding and abetting anti-dumping duty evasion through Malaysian re-routing of Chinese-origin PVC Flex Banner Sheets requires proof of the statutory conditions for liability. The certificates of origin were not verified with Malaysian authorities, and no admissible evidence established that they were false. Retracted statements were relied on without cross-examination, while no specific material proved the appellant's knowledge of or participation in the alleged contravention. On substantially identical allegations, the Tribunal set aside the penalty because the statutory ingredients for its imposition were not established.

Finality of unchallenged Bills of Entry assessments barred a subsequent duty demand on imported networking products. The importer's declared classifications had been accepted and the goods cleared on out-of-charge, causing those assessments to attain finality. Without a challenge to the completed assessments, demand proceedings were unsustainable; the duty demand was set aside, the importer's appeal succeeded, and the Revenue appeal was dismissed as not maintainable.

Purchase and resale of air or train tickets by a tour operator, where no airline commission is received and no additional ticket-booking activity is performed, constitutes trading rather than taxable tour operator service. Accordingly, ticket sale proceeds and the margin earned on booking and resale do not form part of the taxable value of tour operator service. A prior final determination between the same parties on materially identical transactions supports consistent treatment where no factual distinction is established.

E-auction of confiscated goods should not proceed while a statutory appeal challenging the confiscation remains pending before CESTAT. The Tribunal is the appropriate forum to examine all issues concerning the proposed auction alongside the challenge to confiscation. The petitioner may seek consideration of the e-auction before CESTAT, and the auction is deferred until the Tribunal examines the issue. No final determination is made on the legality of either the confiscation or the proposed e-auction.

Customs classification is determined by the condition and identity of goods at importation, rather than by their intended post-clearance use or transformation. Communication modules imported independently fall under CTI 8517 70 90, not under tariff entries for meter parts merely because they may later be used in meters. Self-assessment requires the importer to assess goods as imported, without anticipating a later contrary departmental view. Prior departmental awareness and acceptance of the declared classification negate intentional misdeclaration or misclassification, making a differential-duty demand and consequential penalties founded on meter-parts classification unsustainable.