Depreciation on newly acquired assets is restricted to 50% of the prescribed rate where the asset is acquired during the tax year and put to use for less than 180 days. The 2025 wording omits the expression "for a period" used in the corresponding 1961 provision. While the earlier expression is understood to refer to the elapsed period of use rather than actual working days, the revised wording may support an interpretation based on actual operational days, potentially causing disputes over full-year depreciation eligibility.

Rule 26(3) makes authentication of GST notices and adjudication orders mandatory through the prescribed signature or verification method. Portal upload, reference numbers, electronic generation, and an officer's authenticated login may evidence system access or transmission, but cannot replace authentication of the statutory document. Complete absence of authentication is a foundational defect: the notice or order is non est, cannot be cured as a minor procedural error, and cannot sustain recovery founded on it.

Currency seized as evidence of hawala transactions, illegal gratification, or fraudulent licence closures may be a thing under Section 110(3) rather than goods under Section 110(1). The six-month show-cause notice safeguard applies to goods seized for confiscation, not to documents or things useful or relevant to Customs proceedings. Retention of currency as evidentiary material has no prescribed outer time limit, but requires a bona fide seizure and demonstrable nexus to the investigation.

A zero-tolerance approach is identified under which fabricated or non-existent AI-generated precedents cannot be treated as valid legal authority, even where the false material did not directly influence reasoning. Rigorous verification of case law is an essential responsibility of adjudicating officers. AI-assisted tools may support legal research but cannot replace human diligence in confirming the authenticity of authorities relied upon.

GST electronic authentication requires use of the prescribed verification mode and identification of the authorised signatory. Digital signatures, e-signatures, and Electronic Verification Codes are distinct mechanisms, while scanned signatures, typed names, portal access, and service do not by themselves establish document authentication. Departmental notices and orders must be attributable to the issuing officer through the applicable statutory method. An unsigned annexure may nevertheless form part of a digitally authenticated order when expressly incorporated. Electronic record admissibility remains distinct from authentication, proof, and substantive correctness.

Section 9 insolvency proceedings concerning a claimed operational debt for GST-related professional services require a debt that has crystallised and is undisputed. A disputed result-linked fee, where contractual success, finality of the underlying GST proceedings, and professional permissibility are contested through contemporaneous correspondence and invoice rejection, may constitute a genuine pre-existing dispute beyond the limited Section 9 jurisdiction. Pending or remanded GST proceedings may prevent a demand reduction from creating an unconditional fee entitlement.

Post-conviction settlement cannot support compounding of a cheque-dishonour offence once a merits-based revision has finally affirmed the conviction and sentence. Inherent jurisdiction under Section 482 CrPC and Section 528 BNSS does not permit review, alteration, or nullification of a final judgment of a co-ordinate Bench. After final disposal, the Court is functus officio except to correct clerical or arithmetical errors. A later settlement therefore does not revive the concluded proceeding, leaving the final conviction and sentence unaffected.

Compensatory tax on the entry of goods into a local area is examined through the direct and immediate effect test and the principle of equivalence. The State bears the burden of establishing a quantifiable and measurable benefit corresponding to the levy. Key constitutional questions include the validity of retrospective validating legislation under Entry 52 of List II and whether entry tax satisfies Article 304 requirements of non-discrimination, reasonableness and public interest.

CENVAT credit cannot be denied when supporting invoices have been furnished in response to an audit objection and form part of the record. Failure to consider those invoices undermines the basis for disallowing credit. Where the invoices substantiate that credit was correctly availed, the credit remains allowable and no penalty is imposable.

CENVAT credit under Rule 2(l) covers brokerage, commission, membership fees, detention charges and insurance where they serve sales promotion or have a manufacturing nexus. Commission-based sales of dutiable goods fall within sales promotion, while storage-related detention costs and insurance for plant, stock and goods in transit remain eligible. Canteen and employee transportation services are excluded despite statutory welfare obligations. Where wrongful credit lacks fraud or wilful misstatement, penalty is limited to 10% and confined to irregular credit relating to rent-a-cab and staff-welfare services.

Rule 5 of the Cenvat Credit Rules permits refund of unutilised export-related credit without item-wise or one-to-one matching of duty-paid inputs to exported goods, where inputs were used in manufacture and exports made the credit unusable. Verified purchase, input and export records support refund, subject to exclusions for short shipments. Full repayment of drawback removes the refund bar; an unchallenged determination of that issue attains finality and cannot be reopened by a remand limited to verification and quantification. Final determinations denying disallowance require consequential implementation. Although an unstayed appeal does not halt recovery proceedings, recovery of an allegedly erroneous refund and related interest fail when the refund is sustainable.

Rule 3(1) of the CENVAT Credit Rules establishes substantive entitlement to credit of eligible duties, while Rule 9 governs the supporting documentation. The proviso to Rule 3(1) should be read harmoniously with the objective of preventing cascading duties and should not be treated as an exclusive restriction confining credit to central excise duty on capital goods. Following debonding, inputs and capital goods on which assessed duty is paid become duty-paid goods for Domestic Tariff Area manufacture. Their earlier duty-free procurement under the EOU scheme does not bar credit of eligible duties actually paid on debonding.

Delayed payment of determined monthly duty is addressed by the second proviso to Rule 9, requiring payment of outstanding duty with interest. The seventh proviso applies only when non-payment continues during operation of packing machines and requires duty to be calculated on the higher of declared operating machines or machines available for production. Sealed or inoperative machines, including machines sealed by the Department, are not available for production absent reliable evidence of operation or misdeclaration. Accordingly, where only declared machines operated, delayed payment does not justify differential duty based on sealed machines.

Research and Development cess must be paid before payment for imported technology, while the service-tax exemption is available to the extent of cess paid. Where cess was paid after the service-tax due date but its payment was undisputed, the exemption remained available in full rather than being denied for delay. The delay resulted only in delayed payment of service tax corresponding to the claimed exemption, attracting interest on that delayed tax payment.

Extended limitation for service-tax demands relating to manpower supplied by an overseas holding company requires wilful suppression of facts or deliberate misstatement. A bona fide and legally tenable view on taxability does not establish those conditions. Where the arrangement is treated as receipt of manpower recruitment or supply service but no mala fide conduct is shown, service-tax demand remains sustainable only within the normal limitation period, with applicable interest. The extended-period demand and associated penalties cannot be sustained.

Installation of computer systems was outside Erection, Commissioning and Installation Services before the statutory inclusion of electrical and electronic devices on 16 June 2005. Recipient liability for maintenance or repair services received from abroad arose only when section 66A took effect on 18 April 2006; the Service Tax Rules could not independently create earlier reverse-charge liability. Cenvat credit could not be rejected on unnotified grounds, and a restrictive nexus test did not displace credit for services forming part of business and taxable-output activity. Financial records alone, without positive material of suppression or wilful misstatement, did not support extended limitation.

Dam-construction services at Aland and Jambaga fall within the service-tax exemption for dam works, eliminating the related demand. A rectified Form 26AS that reconciles with furnished service details leaves no differential taxable value for service tax. The Small-Scale Industry exemption applies to residual liabilities, eliminating one period's demand and reducing another. Where service receipts were disclosed in income-tax returns, non-registration alone does not establish suppression; without conscious misstatement or intent to suppress, the extended limitation period is unavailable and the remaining demand is time-barred.

Extended limitation for service tax demand was not invokable where the ST-3 return was filed on time and service tax payment was undisputed. An inadvertent reference to the registration number of another unit was treated as an error insufficient to justify the extended limitation period. The proceedings were quashed in favour of the assessee.

Service-tax demand against a goods transport agency cannot rest solely on Form 26AS data where tax liability for the services falls on recipients under the reverse charge mechanism. Verification with the identified recipients is necessary to determine whether they received the services and discharged the corresponding tax. Without such inquiry, Form 26AS entries do not substantiate liability against the service provider, rendering the demand unsustainable.

Service-tax refunds for ocean freight are subject to the one-year limitation under the statutory refund framework. Where the relevant date is the date of tax payment in other cases, a claim filed beyond one year is time-barred. Statutory authorities cannot waive or disregard that limitation because their jurisdiction is confined to the governing legislation. A challenge alleging that the levy itself is unconstitutional falls outside the statutory refund route and must instead be pursued through constitutional remedies under Articles 226 or 32. The ocean-freight refund claim was therefore barred by limitation.