HDFC Bank computer resources relating to Core Banking Solution, Real Time Gross Settlement and National Electronic Fund Transfer, comprising the Structured Financial Messaging Server, are declared protected systems and treated as Critical Information Infrastructure. The designation extends to associated dependency computer resources. Access is authorised for designated employees, authorised contractual managed service provider or third-party vendor team members requiring need-based access, and specified consultants, regulators, government officials, auditors and stakeholders on a case-by-case basis.

Section 67(7) establishes a six-month return rule where no notice in respect of seized goods is issued. Any further period requires sufficient cause, action by the proper officer, and a maximum further period of six months; ongoing investigation cannot replace an actual extension order. Although Section 67(7) uses "goods" while Section 67(2) also covers documents, books and things, its application to seized mobile phones and bank debit cards indicates that classification cannot be used to avoid the temporal restriction where articles are held under statutory seizure.

Section 70 of the Information Technology Act, 2000 declares the computer resources of CCTNS, NAFIS and I-MoT, including associated dependencies, to be protected systems forming part of Critical Information Infrastructure. Access is limited to authorised employees, need-based authorised managed service provider personnel and vendors, and consultants, regulators, Government officials, auditors and stakeholders authorised in writing on a case-to-case basis.

Section 151A and the e-Assessment of Income Escaping Assessment Scheme, 2022 require randomised automated allocation for reassessment functions, including the section 148A process and issuance of section 148 notices. General concurrent-jurisdiction directions cannot permit a jurisdictional Assessing Officer to bypass the prescribed faceless allocation, because allocation determines the officer's statutory competence. Risk-based selection of a matter is distinct from algorithmic allocation of the officer. Section 147A's retrospective deeming rule was held unconstitutional because it did not amend the continuing statutory and scheme-based requirements for automated allocation, and therefore did not remove the legal foundation of prior jurisdictional rulings. Administrative instructions cannot override the Act or a valid notified scheme.

Doctrine of merger under Article 136 depends on whether the Supreme Court granted leave and exercised appellate jurisdiction, not merely on disposal of a special leave petition. A non-speaking refusal of leave neither merges the challenged order nor confirms its reasoning, creates automatic res judicata, or independently bars review or writ proceedings. A speaking refusal likewise does not cause merger, although legal propositions expressly declared may bind under Article 141. Merger follows when leave is granted and the appeal is decided. In remanded GST proceedings, an earlier dismissal of special leave therefore does not prevent consideration of residual grounds or reliance on a later binding ruling, subject to applicable review, limitation, and procedural requirements.

Section 37 of the NDPS Act imposes cumulative conditions for bail in commercial-quantity offences: after the Public Prosecutor has an opportunity to oppose, the court must record reasonable grounds that the accused is not guilty and is unlikely to commit an offence while on bail. General bail considerations and Article 21 concerns, including prolonged custody and trial delay, remain relevant but do not replace this statutory inquiry. Non-recovery, procedural objections, or exclusion of inadmissible statements cannot alone satisfy either condition; the available record requires broad assessment. For foreign nationals in commercial-quantity matters, verified sureties, passport deposit and other enforceable safeguards may be required, while technological tracking must remain proportionate.

Customs-duty liability for pilfered imported goods arises under Section 45(3) only where the goods were unloaded in a customs area and pilfered while in the custody of a person approved under Section 45(1). Approval is a necessary precondition, so liability does not extend to pilferage before the approval became operative. A statutory port authority may be an approved custodian, and its civil responsibilities as bailee do not displace its separate revenue liability. The importer's duty exemption for pilferage operates alongside the custodian's statutory obligation. Pilferage, rather than an unexplained cargo discrepancy or non-pilferage loss, must be established through contemporaneous custody and security records.

STA micro-cuvettes containing an enclosed steel ball are assessed as complete functional components of a blood-coagulation analyser, rather than merely as plastic laboratory articles. Classification turns on their objective design, analytical role, exclusive or principal suitability and absence of practical general use. Chapter 90 Note 2 requires consideration of an independent specific heading first and then classification of other dedicated parts or accessories with the relevant instrument. Disposable or single-use status and plastic composition do not by themselves establish classification as residual plastic articles.

The substituted wording removes the earlier limitation to contraventions relating to Chapter IX of the Information Technology Act, 2000. It extends the scope to contravention of any provision of the Act and of any rule, regulation, direction or order made under it. Adjudicating officers may therefore conduct enquiries concerning contraventions across the Act and its subordinate regulatory instruments.

Section 5 of the Limitation Act, 1963 may apply to special-law appeals through Section 29(2) unless the governing enactment excludes it expressly or by necessary implication. A special limitation period alone is insufficient; exclusion may arise from phrases such as "but not thereafter" or "not exceeding", a defined condonable ceiling, or a self-contained scheme that selectively confers condonation. For appeals under Section 9 of the Chhattisgarh Rajya Suraksha Adhiniyam, the 30-day period and certified-copy exclusion do not bar Section 5 because no outer limit or equivalent restrictive language exists. Delay remains condonable only upon sufficient cause, while applicability before non-court statutory forums depends on the forum and enactment.

Pre-movement e-way bill compliance requires issuance of an invoice at or before removal, generation of the e-way bill before road movement, and carriage of both records during transit. Where goods are intercepted without either record, the contravention arises upon commencement of undocumented movement; documents generated only after interception cannot retrospectively establish compliance. Such documents may still be considered with other contemporaneous evidence when assessing bona fides or alleged intent to evade tax. Section 129 detention proceedings remain subject to notice, hearing, electronic-summary and statutory-timeline requirements.

Section 107(12) requires a written appellate order identifying material points for determination, deciding them, and giving reasons. Formulaic confirmation of original assessment does not establish independent appellate consideration, particularly where jurisdiction, notice, evidence, quantification, taxability, section 74 conditions, interest, or penalty are contested. Sections 74 and 75 require a defined notice, disclosure of relied-upon material, effective hearing, and reasoned determination within the notice's scope. Where procedural defects arise at the original stage as well as on appeal, reconsideration must occur at the level capable of curing the foundational defect without expanding the show-cause case.

Project-import contract finalisation requires importers to submit a complete statement of imported goods with a Chartered Engineer Certificate, installation certificate, reconciliation statement and other required records within three months of clearance of the last consignment, subject to permitted extension. Non-compliance may result in enforcement of bonds, cash security or bank guarantees, duty-demand proceedings and penalties. Provisionally assessed bills of entry covered by the amended framework must be finalised before 29 March 2027.

Natural justice in GST adjudication requires the Proper Officer to consider a taxpayer's representation under section 74(9) read with rule 142(4). Form GST DRC-06 need not be furnished exclusively through the electronic portal; a manually filed reply acknowledged at personal hearing cannot be disregarded solely because it was unavailable online. Issuing a demand order before expiry of time allowed for supporting documents, without addressing the reply or jurisdictional objection, denies a meaningful hearing. Such procedural defects support writ intervention despite an alternative statutory remedy. The demand order was set aside and remitted for fresh adjudication, with jurisdictional and merits objections left open.

Recipient input tax credit did not require reversal solely because a supplier issued credit notes during the relevant period: neither the Act nor the Rules imposed that obligation, the statutory matching mechanism was inoperative, and Rule 37 concerned non-payment to suppliers. Accordingly, the premise for reversal failed. Excess IGST adjusted against CGST and SGST liabilities was procedurally irregular because the prescribed refund, re-credit or subsequent IGST-adjustment route was not used. However, as a bona fide first-year GST correction causing no revenue loss, it did not justify a fresh tax demand, interest or penalty; the departmental appeal was dismissed.

Assignment of leasehold rights in an industrial plot to a third party is treated as a transfer of benefits arising from immovable property rather than a GST-taxable supply. A binding High Court ruling on that characterisation remains operative absent a stay or recall, notwithstanding an intended review. GST is therefore not leviable on such assignment, and the appellate order rejecting the departmental challenge stands sustained.

Retrospective contractual price escalation fixes the true value of pre-GST clearances from their original clearance date. Section 142(2)(a) permits GST-compliant debit notes and post-transition reporting of differential tax, but does not create a new taxable event or defer accrual of the enhanced value. Differential tax on the increased value is therefore due from inception, making statutory interest mandatory despite the absence of formal provisional assessment. Penalty under section 122 is not warranted where the differential tax is voluntarily paid after price finalisation under a bona fide understanding of complex transitional provisions, without suppression, fraud, wilful misstatement or deliberate evasion.

Credit notes validly issued for returned or rejected supplies reduce taxable turnover and are deductible from adjusted total turnover under the zero-rated supply refund formula. Credit notes issued during the refund period against invoices for Financial Year 2019-20 after expiry of the statutory time limit cannot be excluded from adjusted total turnover and must be included on recomputation. As the recomputed refund remained within the maximum permissible amount, the refund already sanctioned remained admissible and the Revenue challenge failed.

For inverted duty structure refunds, credit notes issued for returned or rejected supplies generally reduce taxable turnover and adjusted total turnover. Credit notes relating to invoices from an earlier financial year but issued after the statutory period for issuing and declaring them cannot be excluded from adjusted total turnover. Their value must therefore be included when recomputing accumulated input tax credit refund under Rule 89(5), reducing the refund to the permissible amount and requiring recovery of any excess refund.

Departmental GST appeals challenging only a penalty must assess the disputed penalty against the applicable monetary threshold under the departmental litigation policy. An exception to that policy must be specifically identified and supported by the relevant facts and basis; it cannot be presumed. Commissioner authorisation to file an appeal under section 112(3) does not independently establish an exception or dispense with compliance with the monetary-limit policy. Absence of material showing a recorded case-specific opinion under a residual exception makes the appeal non-maintainable, without determination of the underlying tax merits.