Refund limitation for duty paid on stolen goods runs from the judicial release order returning the recovered goods, rather than from the date of duty payment. Where stolen goods could not be used in manufacture and were subsequently recovered, the release order created the cause of action for seeking a refund. A claim filed within one year from that order falls within the statutory limitation period and is allowable.

Rule 8(3A) had been declared ultra vires, so a manufacturer could not be compelled to pay excise duty exclusively in cash or be prevented from using CENVAT credit during a default period. Where defaulted duty was subsequently paid with interest, denial of CENVAT-credit utilisation and a demand based on that restriction were impermissible. CENVAT credit therefore remained available for duty payments despite the payment default.

Transportation of potato qualified for the service-tax exemption available to agricultural produce. Vehicle-hire services supplied to other goods transport agencies also fell within the relevant exemption. For goods transport agency services provided to specified recipients, including body corporates, reverse charge placed the tax liability on the recipient rather than the service provider. Residual transport receipts remained eligible for the small-service-provider threshold exemption and the applicable GTA abatement. Tax liability was therefore confined to the taxable residual receipts, subject to verification, and service-tax penalties were set aside.

On-site catering at premises supplied by the service recipient falls within Outdoor Catering Service; continuous use does not make those premises the caterer's own place of business. Gross receipts under a composite catering contract may be taxed as service receipts rather than treated exclusively as food sales. The RBI-specific exemption applies only where tax liability shifts to RBI under the prescribed reverse-charge framework. A bona fide interpretative dispute, absent proven suppression or intent to evade tax, prevents extended limitation and penalties. Tax remains confined to the normal period, with statutory interest and cum-tax valuation requiring recalculation.

Specified construction and installation services for pollution control, water treatment or sewage treatment plants are exempt from service tax under Sl. Nos. 12 and 13 of Notification No. 25/2012-Service Tax when supplied to the Government, local authorities or governmental authorities and the plants do not form part of a factory. Composite turnkey works for water and effluent treatment plants supplied to municipal corporations and a public health engineering department fall within this exemption where the nature of the works and recipient status are undisputed. Service-tax demands on such exempt works cannot be sustained.

Extended limitation cannot be invoked merely because differential tax liability was identified through audit scrutiny of books and invoices or because payment was delayed. Invocation requires material establishing deliberate suppression of facts and intent to evade tax. Where prior departmental communication had quantified the liability and no such evidence existed, the extended period was unavailable. A show-cause notice issued beyond the normal limitation period was therefore time-barred and could not sustain the consequential demand.

Attachment under the Prevention of Money Laundering Act, 2002 may extend to property connected with proceeds of crime even where its holder is not accused of the predicate offence. Financial statements, banking records, cash deposits, seized assets and unexplained currency may establish the required nexus and support reason to believe. Claimed lawful sources, including sale proceeds, inheritance, disclosed income and housing loans, must substantiate acquisition; loans cannot validate tainted funds merely by giving them an apparent legitimate form. Property representing equivalent value may be attached where tainted property is unavailable or unidentifiable.

Territorial jurisdiction under Article 226(2) may arise where material elements of the cause of action, including property attachment, bank-account attachment, residence, or custody, have a sufficient territorial nexus with the court. Under the Prevention of Money Laundering Act, where cognizance of the scheduled offence and money-laundering complaint is taken by different courts, the statutory committal mechanism enables the scheduled-offence matter to be placed before the Special Court. The resulting proceedings remain separate trials. The authorised authority's discretion to invoke committal must conform to the statutory scheme and cannot be exercised arbitrarily, particularly without a cogent change in facts or law after earlier recognising the connection between proceedings.

Resolution-plan approval requires the plan to identify the cause of default and set out how it will address that cause; recording losses, lack of turnover and liabilities, or offering an undefined future business proposal, is insufficient. Committee of Creditors approval cannot cure this mandatory compliance failure. A plan valued below liquidation value does not alone prejudice a dissenting financial creditor if its minimum liquidation entitlement is paid in cash and in priority. Investigation by a liquidator, including potential avoidance proceedings, may be warranted by the debtor's circumstances. An assignee's distributable share cannot be capped before that investigation. Rectification or restoration of CIRP before liquidation remains discretionary, not mandatory. Material non-compliance and circumstances requiring investigation can support plan rejection and liquidation.

Interim protection for a proposed acquisition depends on fulfilled contractual conditions, performance of independently due obligations, and a present risk to the subject matter before preservative or mandatory relief is granted. A binding term sheet may create enforceable obligations while leaving completion conditional on due diligence, approvals, escrow, pre-conditions and definitive agreements. Loan advances do not become share-purchase consideration merely because transaction documents are read together; their character depends on the governing loan terms and contemporaneous records. An unpaid staged instalment may undermine readiness and willingness to perform. Control-oriented restraints over management or assets exceed limited preservative protection where immediate risk is not established.

Tariff classification requires separately imported components to be assessed under their specific headings and the Section XVI notes. The Motherboard falls under Tariff Item 8473 30 20, while the model-specific Chassis, being solely or principally suitable for an automatic data processing machine and lacking independent coverage, falls under Tariff Item 8473 30 99. The Power Supply Unit, as a static converter independently described under Heading 8504, falls under Tariff Item 8504 40 29 rather than as a machine part. Its classification brings it within applicable BIS certification requirements at import. It may also qualify for basic customs duty exemption as a static converter for an automatic data processing machine, subject to prescribed conditions and import-time verification.

Sl. No. 2 of Notification No. 45/2017-Customs exempts aircraft parts re-imported after overseas repairs from IGST, while customs duty is confined to the repair value, freight and insurance. The later amendment extending the entry to tax and cess, together with the corresponding circular, was ultra vires to that extent. The IGST exemption therefore applies to qualifying re-imports made after the amendment as well.

Exemption for parts consumed within the factory of production requires strict compliance and does not cover imported aluminium profiles sent outside for job-work fabrication where usable mounting frames emerge only after that process. The exemption claim therefore fails on merits. Extended recovery cannot be invoked merely because an exemption or classification claim was made in a Bill of Entry; wilful misstatement or suppression of material facts must be established. Where material movement and disposal were recorded in statutory records and earlier audit raised no objection, recovery beyond normal limitation, interest and related penalties do not survive.

Duplicate customs-duty payment caused by an ICEGATE portal error constitutes an unauthorised excess collection where duty for the same consignment had already been paid. Section 27 of the Customs Act governs refunds of duty legally payable under the Act; it does not govern recovery of a second payment compelled by an incorrect portal reflection that duty remained unpaid. The one-year limitation prescribed under Section 27 therefore does not apply, and the duplicate payment is refundable.

Customs penalties for acts rendering imported goods liable to confiscation require reliable evidence of knowledge, abetment, or intentional involvement. Statements of co-accused relied on in adjudication must undergo the process prescribed by Section 138B; uncorroborated statements without cross-examination are not reliable evidence. Printed WhatsApp-chat data recovered from a seized mobile phone likewise requires cogent evidentiary support. In the absence of independent proof that a person knew the container contents, abetted the prohibited or misdeclared import, or knowingly used a false declaration or document, the essential requirements for penalties under Sections 112(a)(i), 112(a)(ii), and 114AA are not met.

Properly raised alternative classification and connected exemption claims must be decided on merits in differential-duty proceedings to determine the legally correct duty assessment; any resulting duty liability is confined to the normal period. Redemption fine is unsustainable where goods have already been cleared for home consumption and are unavailable for confiscation. Penalty for customs evasion is also unsustainable where a classification or exemption dispute is interpretational and lacks misdeclaration, suppression, wilful intent, or other deliberate conduct to evade duty. Unresolved classification and exemption entitlement require fresh merits determination.

Electric steering-lock assemblies that immobilise a vehicle after operation for anti-theft purposes are accessories, rather than integral steering-system parts, where they neither transmit steering force nor control vehicle direction. They fall under the residual motor-vehicle parts and accessories entry, rather than the specific entry for steering wheels, steering columns or steering boxes. Revenue must support reclassification with cogent technical evidence. Where the declared description is complete and the classification dispute is bona fide, denial of preferential duty, differential duty, confiscation, redemption fine, extended limitation and penalties do not arise from the rejected reclassification.

Personal penalties for improper import require proof that a noticee was an importer or owner, or committed or abetted the act rendering goods liable to confiscation with the requisite knowledge. A consignee merely named in a bill of lading, who filed no bill of entry and did not claim ownership, does not incur such liability without reliable corroborative evidence. Electronic correspondence must satisfy statutory safeguards governing electronic records, and an untested shipping manager's statement without cross-examination cannot establish knowing participation. In rem confiscation of offending goods remains distinct from personal penal liability.

Timely payment of duty, interest and the prescribed penalty under the statutory settlement mechanism deems all matters stated in the customs notice concluded, except proceedings expressly preserved by law. Because confiscation proceedings are not preserved among the specified exceptions, confiscation cannot continue after such payment. Redemption fine, being dependent on valid confiscation, is likewise unavailable; provisional release of goods and the proviso governing redemption fine do not revive concluded proceedings. Penalty proceedings forming part of the notice also terminate, as no discretion remains to selectively continue them after deemed conclusion.

Concessional customs-duty exemption for imported components used to manufacture electric buses remains available where the prescribed end-use is substantially met through job work at shared manufacturing premises. The IGCR provisions on re-export or domestic clearance of unutilised or defective goods do not apply when the components are actually used in the specified manufacture. Timely intimations, continuity bonds and returns support compliance. Invoices showing supply to a job worker do not, by themselves, establish diversion or breach of the end-use condition. As job-work manufacture is not prohibited, procedural documentation lapses do not defeat the exemption where substantive end-use compliance is established.