Rule 26 of the Central Excise Rules, 2002 permits penalties where a person deals with excisable goods known or believed to be liable to confiscation, or issues documents enabling another person to obtain an ineligible benefit. Penalty could not be sustained because the seized goods were not held liable to confiscation and no material showed that the appellant issued invoices or other documents enabling an ineligible benefit. The statutory requirements for imposing the penalty were therefore not met, and the penalty was set aside.

Extended-period limitation cannot support a duty demand where the taxpayer repeatedly disclosed its clearances and duty-payment structure, and Revenue acknowledged the position through correspondence and periodic audits. Revenue knowledge of the material facts prevents reliance on the extended period when the show-cause notice is beyond the normal limitation period. The demand is time-barred, and no penalty is imposable.

Composite construction contracts requiring procurement and supply of materials on which VAT or sales tax is paid, together with execution of construction work, fall exclusively within Works Contract Service. Following its introduction into the service-tax levy from 1 June 2007, such arrangements cannot be classified as Construction Service merely because the underlying activities resemble construction. The service-tax demand classified under Construction Service for the disputed composite contracts was therefore unsustainable.

Service tax under the reverse charge mechanism was not payable on mining royalty where the relevant mining lease deeds were executed before 1 April 2016 during the negative-list regime. The subsequent accrual or payment of royalty did not independently create liability for a later period. Applying the established treatment of mining royalty, the service-tax demand and consequential penalty relating to those pre-existing leases were unsustainable.

Receipts attributable to newspaper sales constitute sale transactions rather than taxable service receipts and must be excluded when determining service-tax liability. Once those amounts are excluded, the remaining receipts for each relevant period fall below the applicable threshold exemption of Rs. 10 lakhs. Consequently, no service tax is payable on the remaining receipts, and no penalty arises.

The extended limitation period for denying CENVAT credit under the proviso to Section 73(1) requires evidence of suppression, wilful misstatement, fraud, or comparable deliberate conduct intended to evade tax. Regular self-assessment, ST-3 filings disclosing credit, and audit detection of irregular credit do not by themselves establish that intent. Where a registered assessee supplies records during audit and no mala fide intent is proved, including where it is a State instrumentality, the extended period is unavailable and the resulting demand is unsustainable.

Affiliation and recognition fees collected by a statutory nursing council for granting or renewing permission, recognition and affiliation to nursing colleges and institutions are not chargeable to service tax. The applicable principle treats comparable fees received by universities and statutory educational authorities as outside service-tax liability. Consequently, service-tax demands, related interest and penalties founded on those fees cannot be sustained.

Extended limitation for a service-tax demand was unavailable where tax had been self-assessed, declared and paid, though belatedly, and an application under the Sabka Vishwas Scheme concerning interest and penalty had been accepted. These circumstances placed the material particulars within the Department's knowledge and negated reliance on the extended period. As the show-cause notice was issued outside the normal limitation period, the demand was time-barred and consequential penalties were not imposable.

Extended limitation cannot rest solely on audited accounts and records available to the department: accounting treatment or non-declaration, without wilful suppression or intent to evade, is insufficient. Labour charges paid to local workers for renovation, where the recipient procures materials and no contractor supplies goods and services, do not establish a taxable works contract under reverse charge. Shared advertising-cost recovery between associates is reimbursement, not consideration for Business Promotion Service, absent a provider-recipient relationship. Employee secondment for the recipient's work constitutes manpower supply, but a demand dependent on an invalid extended period is time-barred.

Service tax paid on invoices for a period in which no service was rendered may be taken as credit under Rule 6(3) of the Service Tax Rules without a prescribed time limit. Following repeal of the service-tax regime, the corresponding amount is refundable in cash under the CGST transitional provision where credit would otherwise have been available. Section 11B limitation does not bar that transitional cash refund. No credit note is required where no contract, service, or payment from the recipient existed.

Composite maintenance-and-repair contracts involving both services and materials constitute works contracts and were not chargeable under pre-existing taxable-service categories before 1 June 2007. For the later period, where no composition-scheme option was established and the value of transferred goods was indeterminable, maintenance and repair work is valued at 70% of the gross amount charged under the prescribed valuation method. Free supplies from the service recipient are excluded, but subcontractor payments cannot reduce taxable value. Cum-tax treatment and adjustment of tax already paid apply. Non-disclosure of full gross receipts may constitute suppression, supporting extended limitation and penalties, while an unrebutted verification report does not by itself breach natural justice.

The Finance Act 2010 deeming provisions treated specified construction intended for sale as taxable service only prospectively from 1 July 2010. Before the effective date, a builder's construction activity was treated as self-service and was not taxable either as construction of residential complex service or works contract service; related demands and penalties did not survive. Covered builder services supplied from 1 July 2010 fell within the service-tax net, leaving post-effective-date service-tax liability enforceable with applicable interest.

Service of an order-in-original by affixture at the registered premises, recorded through a panchnama, constitutes reliable evidence of service where postal communications are repeatedly returned and the address remains in use. Under section 85(3A) of the Finance Act, 1994, an appeal must be filed within two months, with condonation available for only one further month on sufficient cause. A first appeal filed after that maximum statutory period is time-barred and cannot be entertained.

RBI KYC Directions permit a bank to decline a transaction or account relationship before Customer Due Diligence is complete, but do not authorise a debit freeze after an account has been activated. Prescribed and suspicious transactions must be reported to the Financial Intelligence Unit, and filing a suspicious transaction report cannot itself restrict account operations. Internal transaction thresholds cannot override these directions. A freeze imposed without prior notice and a hearing breaches natural justice, and a later AML flag cannot retrospectively validate it. The debit restriction must be removed and account operations restored.

Information shared under Section 66(2) of the Prevention of Money Laundering Act that is supported by statements and documents and prima facie reveals cognizable corruption offences requires FIR registration by the competent vigilance agency. Such information substitutes for a preliminary inquiry; inquiry may only assess whether disclosures show an offence, not test their truth. A citizen and whistle-blower challenging refusal to act has standing under Article 226. Police leadership cannot create a special inquiry team where statutory power to establish special units rests with Government. Rejection of earlier private complaints founded on inadequate material does not prevent action on later independent statutory information.

Registration of an FIR for a cognizable corruption offence requires neither a pre-registration hearing for the suspected accused nor a preliminary inquiry where detailed, reasoned material prima facie discloses the offence, including material furnished under the Prevention of Money Laundering Act. A direction to register an FIR does not adjudicate guilt or individual legal rights. Persons challenging such a direction must show prima facie legal injury to establish locus standi for appellate leave; independent remedies to challenge the FIR or subsequent proceedings remain available.

Anticipatory bail under the Prevention of Money Laundering Act, including the statutory twin bail conditions and the necessity of custodial interrogation, was in issue. The Supreme Court did not determine those bail issues on their merits, finding no good reason to entertain the Special Leave Petition after an inordinate delay of 480 days. The petition was consequently dismissed solely on the ground of delay.

Non-impleaded persons may seek leave to appeal against writ directions requiring FIR registration, investigation and a final report where those directions themselves find that the material discloses cognizable offences. Because the FIRs arose from judicial directions rather than independent State action under the anti-money-laundering framework, denying appellate participation could prejudice a subsequent independent challenge to the FIRs. The criminal-procedure framework recognises broader participation by a potential accused in judicially directed FIR registration. Directions for investigation and a final report also require consideration of special-law conditions, including prior sanction for alleged offences involving public servants. Leave to appeal was available, and the merits appeals were restored.

Section 95 insolvency applications against personal guarantors are subject to the three-year limitation period under Article 137, running from expiry of the period stated in the demand invoking the guarantee. Any applicable COVID-19 exclusion must be deducted, but an application instituted after the resulting period expires is time-barred and not maintainable. Extension under Section 18 requires a conscious, unequivocal acknowledgment of subsisting liability by the debtor or an authorised person before limitation expires. A resolution professional's admission of a creditor's claim is an administrative act of collating and recording claims, not an admission of liability by the corporate debtor; it therefore neither acknowledges debt nor renews limitation.

Where allegations in complaints to the CBI and Enforcement Directorate substantially overlap with an FIR whose investigation has been stayed and remains pending before a High Court, directions for a parallel investigation or takeover cannot be pursued before another forum. Relief from the stay, or expedition of the pending proceedings, must be sought before the court already seized of the FIR or before the Supreme Court. The requested investigative directions were therefore unavailable.