Declarations under the Sabka Vishwas Legacy Dispute Resolution Scheme, 2019, rejected solely because the disclosed amount differs from departmental records should be reconsidered where the declarant accepts the liability quantified in the show-cause notice as final and undertakes not to contest it. The Scheme is intended to settle eligible legacy tax disputes. For recalculation under the Scheme, the show-cause notice amount is to be treated as the final liability after the declarant receives an opportunity to present its case. This permits settlement despite a mismatch between the declared amount and departmental records.

Service-taxability and valuation of interest arising from bill-discounting facilities raise a jurisdictional question under the appellate framework. Section 35L of the Central Excise Act, 1944, applied to service-tax matters through Section 83 of the Finance Act, 1994, covers determinations on taxability and valuation for assessment. Such disputes were considered prima facie capable of falling within the Supreme Court's direct appellate jurisdiction rather than High Court review. Further submissions on jurisdiction remained open, and the matters were listed for orders.

Ex parte ad-interim relief against online reports requires a prima facie case, balance of convenience and irreparable injury. Reports portraying a person as an accused despite no summons, process or complaint, and referring to attachment of shares, were treated as prima facie unfair, sensational and capable of causing continuing reputational harm. Recent and continuing publications did not establish acquiescence. Protection of reputation and dignity must be balanced against freedom of speech, requiring reporting to remain accurate and non-sensational within constitutional limits. Restraint, takedown, de-indexing and preservation measures covered identified material and substantially similar later-identified content pending suit.

Property acquired during the established period of criminal activity may constitute proceeds of crime where it is directly or indirectly derived from a scheduled offence. Acquisition in 2020 fell within the relevant crime period, and the absence of documentary support for lawful business income, unexplained account credits and cash deposits supported continued attachment of the immovable property. Statements recorded under summons were treated as reliable where written by their makers and corroborated by investigation material and unexplained financial transactions; allegations of coercion alone did not justify their exclusion. The provisional attachment remained legally sustainable.

Provisional attachment of properties may be substituted with a joint escrow arrangement where it secures the quantified proceeds of crime and permits asset sales. After accounting for earlier realised sale proceeds, the remaining quantified amount was supplemented by an additional 50% security requirement to protect investors' interests and preserve funds for the pending trial. Sale proceeds must remain in escrow until the stipulated aggregate amount is secured. Attachment is to be lifted proportionately as properties are sold and fully lifted once the entire secured amount is placed in a fixed deposit pending trial.

Section 19 of the Prevention of Money Laundering Act requires an authorised officer to possess material, record reasons to believe a person is guilty of money-laundering, communicate arrest grounds promptly, and forward material to the adjudicating authority within a reasonable time. Judicial scrutiny is limited to compliance with these safeguards rather than the adequacy of the underlying material. Section 45's twin bail conditions and Section 24's statutory burden apply to money-laundering allegations, but prolonged pre-trial detention may engage Article 21. Completed investigation, no need for custodial interrogation, documentary evidence held by investigators, and an unlikely early trial support personal liberty and speedy-trial protections over continued detention.

Quashing a predicate FIR through compromise does not, by itself, eliminate alleged proceeds of crime for bail consideration under the Prevention of Money Laundering Act, 2002. Given serious laundering allegations, their substantial scale and the need for further investigation, the statutory bail rigour applied; bail previously granted to one accused was set aside. For the other accused, the incomplete investigation and seriousness of the allegations required application of the same threshold, and bail was refused.

Section 19(2) of the Prevention of Money Laundering Act requires immediate forwarding of the arrest order and supporting material, but imposes no fixed time limit. Expeditious, substantially contemporaneous compliance may accommodate time needed to compile voluminous records and complete administrative requirements; a five-day delay therefore did not invalidate the arrest or custody. The bail restrictions under Section 45 cannot displace Article 21 protection of personal liberty where investigation is complete, pre-trial custody is prolonged, and trial completion is not reasonably foreseeable. Continued detention in those circumstances becomes punitive, warranting bail despite the twin conditions.

Seized documents recovered under a signed panchnama may be relied on without forensic verification or panch-witness examination where authenticity, forgery and recovery are not genuinely disputed. A retracted statement requires corroboration; seized transactional records and statements of connected persons can establish a foreign-exchange contravention even without recovery of foreign currency. Medical records and later loss of departmental files do not displace otherwise reliable contemporaneous evidence. Where the contravention amount is unquantified, monetary sanction must remain proportionate to the proved circumstances and health condition; liability remained sustained while the penalty was reduced.

Late-filed homebuyer claims in a corporate insolvency resolution process need not be collated or incorporated into the information memorandum or resolution plan where no corresponding liability appears in the corporate debtor's records. Regulation 12 operates within a time-bound process; transfers through a holding company and settlements not binding on the corporate debtor do not establish a recorded liability. Admission of delayed claims requires genuine and sufficient cause. Prior legal assistance, creditor-committee participation, and a claimed misunderstanding about separate filings did not justify a prolonged delay after creditors approved the resolution plan. Such claims remain outside the insolvency resolution process.

Section 62 of the Insolvency and Bankruptcy Code imposes a 45-day appeal period and permits condonation for no more than 15 additional days; its self-contained limitation regime prevails over Companies Act appellate provisions. "Date of receipt" does not allow a litigant to postpone limitation by delaying an application for, or collection of, a certified copy. Pronouncement in open court constitutes pronouncement of the order, and Section 12(2) of the Limitation Act excludes only the period from applying for the copy until it becomes available, not preceding inaction. Because the appeal exceeded the absolute 60-day ceiling even after permissible exclusion, it was time-barred and delay could not be condoned.

Finality of prior appellate directions affirmed by the Supreme Court prevents renewed appellate interference with consequential implementation orders. Where an impugned order merely reiterates binding directions and contains no independent factual or legal finding on the merits of the company petition, a challenge to that order would indirectly reopen matters already settled. Connected compliance directions remain governed by the finality of the affirmed appellate directions.

Rule 22 of the Customs, Excise and Service Tax Appellate Tribunal (Procedure) Rules, 1982 was applied after the appellant's death certificate was produced. The customs appeal consequently abated. The operative point is that the appellant's death, established through the submitted certificate, brought the pending appeal to an end under the Tribunal's procedural framework.

Section 123 of the Customs Act places the statutory burden of proof on the relevant party only for notified goods. As the seized betel nuts were neither prohibited nor notified goods, the Revenue bore the burden of establishing that they were smuggled. That burden was not discharged on materially identical facts arising from the same adjudication order. The penalty was therefore unsustainable because smuggling of the seized goods remained unproved.

Interest on customs duty may be waived where payment for a bill of entry was initiated on time but remained uncredited because of continuing ICEGATE technical failure. Although the Customs (Waiver of Interest) Third Order limited relief to bills of entry filed by a specified cut-off date, continuing system disruption acknowledged in a later advisory and bank evidence of timely payment initiation supported waiver and refund despite that cut-off. Technical failures causing delay in crediting payments may therefore protect importers from interest liability where timely payment initiation is established.

Customs duty recovery under Section 28 may proceed notwithstanding self-assessment, because recovery of unpaid duty is distinct from refund proceedings; differential duty was therefore recoverable. CKD e-bike components with pre-assembled essential parts may be classified under Rule 2(a) as complete electrically operated motorcycles despite absent batteries or chargers. Concessional exemption for a knocked-down kit requires all components necessary for assembly, and an alternative exemption not claimed in Bills of Entry cannot later be invoked; both benefits were unavailable. A pre-adjudication corrigendum correcting the answerable authority caused no prejudice, while pre-notice consultation had occurred, preserving notice validity. Confiscation and penalty remained sustainable even without redemption fine.

Provisional-release security should protect the assessable value through a bond without requiring security for fines or penalties that remain unascertained pending investigation and consequential proceedings. Security conditions may be recalibrated where prior clearance of goods from the same exporter on a certificate of origin is relevant. Regulation 6(1)(l) bars a Customs Cargo Service Provider from charging rent or demurrage on seized, detained or confiscated goods, subject to other applicable law. The detained consignment consequently received complete waiver of demurrage and related charges.

Sufficient cause under limitation law requires a credible, bona fide explanation, particularly where delay is inordinate; condonation cannot be granted mechanically despite negligence, inaction, or lack of diligence. Receipt of the order by counsel, a vague explanation for prolonged delay, and the litigant's failure to pursue the proceeding while continuing business activity showed insufficient vigilance. A litigant must monitor its litigation and cannot attribute the entire delay to counsel. On those facts, refusal to condone the customs appeal delay was justified, and no substantial question of law arose.

Classification disputes concerning imported goods fall outside High Court appellate jurisdiction where they require determination of the applicable customs duty rate. Section 130 excludes appeals involving questions on the rate of duty or value of goods for assessment, while Section 130E directs appeals from Appellate Tribunal orders determining those questions to the Supreme Court. Consequently, an appeal concerning classification and resulting duty liability must be pursued before the Supreme Court, not the High Court.

Royalty payments for trademark and marketing know-how must be benchmarked separately from branded-product purchases under the Resale Price Method, which tests gross margins and does not absorb royalty incurred below the gross-profit level. A Comparable Uncontrolled Price adjustment cannot rely on unsigned, unexecuted franchise-agreement templates rather than actual uncontrolled transactions; the royalty adjustment was deleted. Restricted stock-unit costs, shared IT support charges, and recurring tester, advertising, and sales-promotion expenditure qualified as business expenditure under Section 37(1), resulting in deletion of the related disallowances. Set-off of brought-forward business losses and unabsorbed depreciation requires verification and allowance in accordance with law.