Central-excise allegations of clandestine manufacture, removal, under-invoicing, or undervaluation require admissible, cogent evidence independently linking the assessee to unaccounted production, clearance, or additional consideration. Third-party records require corroboration through material such as raw-material procurement, production, electricity use, transport movement, or receipt of unaccounted funds. Computer-generated printouts require statutory compliance, certification, and established custody; unidentified handwritten ledgers lack reliability without proven authorship and provenance. Witness statements require examination and an opportunity for cross-examination under the applicable procedure. Transaction value cannot be displaced solely by uncorroborated third-party rates, and penalties require a sustainable duty basis and proof of knowing involvement.

Road transportation without issuance of a consignment note does not qualify as Goods Transport Agency service because issuing that note is required for that classification. Such transportation falls within the negative-list exclusion for road transport provided otherwise than by a Goods Transport Agency or courier agency and is therefore not liable to service tax. Transportation of food-grains is also not liable to service tax as Goods Transport Agency service. Consequently, the related service-tax demand, interest, penalties and late fee are unsustainable, and tax already paid is refundable.

Form 26AS and income-tax-return data, maintained on a receipt basis for tax-deduction purposes, cannot alone establish the taxable value or actual rendition of taxable services. Service-tax liability requires independent verification of the nature of receipts and corroborative evidence, particularly where billing-based tax liability differs from figures reported in Form 26AS. An extended-period service-tax demand based solely on CBDT data was therefore set aside. Service-tax liability, if any, for the normal period, together with interest, remained payable.

Overseas local area representatives that only arrange third-party filming locations, equipment, personnel and production support qualify as intermediaries where the producer retains creative, budgetary and business control and the representatives' fixed fee is separately identifiable from third-party costs. The specific place-of-provision rule for intermediary services, or alternatively the later equally applicable rule, locates the service at the representatives' overseas location. Because that location is outside the taxable territory, reverse-charge service tax does not apply. Governmental production incentives routed through representatives do not establish independent provision of film-production services; the related tax demand and penalties are unsustainable.

Service-tax liability requires evidence establishing both the rendition and value of taxable services; Form 26AS and income-tax-return data alone do not establish taxable turnover. Where a registered taxpayer regularly filed service-tax returns, an extended-period demand based only on an income-tax mismatch, without independent verification or corroboration, was set aside, while properly quantified normal-period tax and interest could remain payable. A demand for part of 2017-18 calculated by proportionately allocating annual income was also set aside because supporting period-specific data was absent and that method was not proposed in the show-cause notice.

Reverse-charge service-tax liability arises independently of a recipient's entitlement to Cenvat credit. Under the Cenvat Credit Rules, credit becomes available only after actual tax payment, which is a condition precedent for credit; prospective credit eligibility therefore cannot avoid payment. Where tax paid under reverse charge would be available as Cenvat credit to the same recipient, the transaction is revenue neutral. Extended-period recovery is consequently unavailable, and the Section 78 penalty cannot be sustained, although recovery for the normal period, if any, and Section 77 penalty may remain.

Hiring transit mixture machines to transport ready-mix concrete falls within supply of tangible goods service where possession and effective control remain with the supplier. Retention of the driver, maintenance and diesel by the supplier indicates that the customer did not obtain such control. In the absence of consignment notes or evidence of goods transport agency services, the hiring receipts are taxable as supply of tangible goods service rather than goods transport agency service.

Money-laundering proceedings under the PMLA may continue independently, but pronouncement of judgment should await judgment in the scheduled-offence prosecution. Proceeds of crime arise from criminal activity connected with a scheduled offence; consequently, the predicate trial's result directly bears on the existence of proceeds of crime and money-laundering culpability. Deferring the money-laundering judgment avoids inconsistent or paradoxical outcomes while the predicate offence remains undecided. A person not party to earlier proceedings fixing a trial timeline may raise this objection where no earlier opportunity existed.

Redevelopment of a co-operative housing society may proceed despite a confirmed money-laundering attachment over a flat, provided the enforcement interest remains fully protected. Safeguards include identifying a replacement flat, continuing the attachment and possession in favour of the Enforcement Directorate, disclosing the attachment in redevelopment documents, and prohibiting transfer or encumbrance. All redevelopment-related accruals must be deposited directly into an account designated by the Enforcement Directorate. A bank guarantee is unnecessary where it would financially burden the society before the developer and redevelopment terms are finalised. Relevant development documents require enforcement vetting, and the Special Court must be informed of the arrangement.

Anticipatory bail in money-laundering matters is governed by the twin conditions in Section 45 of the Prevention of Money Laundering Act. Money laundering is a standalone offence involving processes connected with proceeds of crime. Investigators may rely on material indicating a person's involvement with proceeds of crime even where that person is not named or charge-sheeted in the scheduled offence, and are not confined to amounts quantified in predicate-offence chargesheets. Financial transactions, digital records, witness statements, non-compliance with summons, and the need for custodial interrogation are relevant to assessing bail eligibility.

Bail under Section 45 of the Prevention of Money-Laundering Act requires a broad-probability assessment of whether property is proceeds of crime, not a trial-stage determination of innocence. Property must be derived or obtained, directly or indirectly, from criminal activity relating to a scheduled offence. Later refinancing, disposal, or electronic evidence of subsequent dealings cannot alone establish the required nexus for assets acquired before the alleged offending period. Although money laundering may cover dealings by persons uninvolved in the original offence, the property must still qualify as proceeds of crime. Prolonged pre-trial detention, secured evidence, and an unlikely early trial must be assessed consistently with Article 21, with risks addressed through bail safeguards.

Commencement of CIRP vests management of the corporate debtor in the interim resolution professional, rendering an appeal filed in the debtor's name by a suspended director incompetent from inception. Substitution of that director individually after the statutory appellate period cannot relate back to cure the lack of authority. For operational-creditor insolvency proceedings, a Section 9 enquiry requires a real and plausible pre-existing dispute rather than unsupported objections. Rectified measurement issues, available material certificates, absence of objections from the principal employer, and unauthorised later laboratory reports limited to sampled goods did not establish a genuine quality or contractual dispute; operational debt and default remained established.

Customs penalties for acts rendering goods liable to confiscation require evidence that the person committed, participated in, or abetted the relevant act. Penalties for false documents similarly require proof of knowing or intentional involvement in making, signing, using, or causing their use. Mere introduction of persons or forwarding of documents to a licensed Customs Broker, without knowledge of concealment or misdeclaration, beneficiary status, or participation in the prohibited conduct, does not satisfy these statutory prerequisites. On those facts, penalties under both provisions were unsustainable.

Customs reassessment departing from an importer's declared classification or transaction value requires written acceptance or a timely speaking order under the Customs Act. Payment of differential duty under protest, or to secure clearance and avoid demurrage, does not constitute written acceptance. Classification of identical imported machinery should be applied consistently; absent cogent reasons, classification uncertainty favours the assessee. Rejection or enhancement of declared transaction value requires stated reasons and evidentiary support, including comparable-import material where relied on. Without a speaking order and lawful factual basis, revised classification and enhanced valuation cannot govern assessment.

Principles of natural justice require adequate opportunity of hearing before an appellate authority confirms an addition through an ex parte order. Where the taxpayer challenges the addition, seeks to produce supporting evidence, and the reasons for non-appearance cannot be ruled out, fresh appellate adjudication is required. The matter should be remitted so that relevant information may be presented and considered after providing a meaningful hearing opportunity.

Compliance with interim judicial directions prohibiting tax deduction at source on leave travel concession reimbursements involving a foreign travel leg prevented bank branches from being treated as assessees in default. Although the Section 10(5) exemption was unavailable for foreign travel, the directions operating during the relevant period displaced the Section 192 deduction obligation. Section 201(1) applies only where tax was required to be deducted and was not deducted; a subsequent merits determination could not retrospectively create a default. Consequently, interest under Section 201(1A) was not chargeable for that period.

Payments to non-resident service providers directly and inextricably connected with mineral-oil prospecting, extraction or production fall within the presumptive regime under Section 44BB. The mining-project exclusion from fees for technical services applies where the pith and substance of the agreement establishes that connection. Section 44BB consequently prevails over the general fees-for-technical-services computation mechanism under Section 44DA for qualifying contractual services. Tax deducted at the rate applicable to Section 44BB payments is therefore correct, and the payer is not an assessee in default on that basis.

Post-transfer receipts reflected in Form 26AS are not conclusively taxable to the PAN holder where substantive material shows that the underlying business and revenue transferred to a successor entity. Verification is required to confirm that the successor accounted for and was taxed on the receipts, and that the original entity did not claim the related TDS credit; verified duplicate taxation requires deletion of the addition and appropriate regulation of TDS credit. Advertising expenditure is deductible when invoices, publication evidence, payment records and TDS establish actual promotional services and business nexus. Related-party status, absent separate agreements, and no immediate revenue increase do not alone justify disallowance without proof of excessiveness.

For computing long-term capital gains under Section 48, the cost of acquisition of a constructed residential flat should include independently substantiated acquisition and construction expenditure, even where the registered conveyance records a lower amount. Contemporaneous housing-finance records, including loan disbursement, repayment and closure material, corroborate the additional cost and support applicable indexation; the recorded sale-deed consideration is not conclusive where the loan is not shown to be unrelated to the property. Reassessment based on property-sale information and non-filing of a return remains valid where an opportunity under Section 148A(b), an order under Section 148A(d), and notice under Section 148 were issued.

Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue; it is not triggered merely because an assessing officer could have undertaken a more detailed enquiry after specifically examining and verifying a Section 80G claim. CSR expenditure disallowed in computing business income under Explanation 2 to Section 37(1) may nevertheless be considered separately for a Section 80G deduction from gross total income. Adding back the expenditure prevents double deduction, while eligibility for the charitable-contribution deduction remains subject to the statutory conditions, including any specific exclusion for designated funds.