CENVAT credit supported by valid invoices, statutory records, receipt and freight documentation, banking payments, and undisputed use in manufacture cannot be denied solely on untested third-party statements. Statements of suppliers or transporters require compliance with the statutory procedure for admission, including examination of the statement-makers, and must be supported by positive evidence of non-receipt or fraudulent availment. In the absence of factory discrepancies, cash reimbursement evidence, or an alternative source of inputs, credit denial, consequential interest, and penalties are unsustainable. Extended limitation also requires proof of fraud, collusion, wilful misstatement, or deliberate suppression with intent to evade duty.

CENVAT credit supported by statutory receipt records, valid invoices, banking payments and undisputed consumption in manufacturing dutiable final products cannot be denied merely on untested supplier or transporter statements and uncorroborated presumptions. Investigation statements require compliance with the prescribed evidentiary procedure before reliance, and the Revenue must establish alleged non-receipt through tangible corroborative evidence. Extended limitation for a credit demand requires fraud, collusion, wilful misstatement or suppression with intent to evade duty; absent specific sustainable allegations and proof, the extended period is unavailable. Consequently, the credit demand, related interest and penalties lack legal basis.

Capacity-based levy under Section 3A depends on the maximum speed at which a packing machine can operate, not actual production. Rules 4 and 5 link deemed production and duty to that speed, while Rule 6 allows approval and revised declarations after parameter changes. Following conversion from twin-pack to single-pack, the original speed rating did not govern. Without reliable technical evidence supporting the lower band, duty applies under the category for machines operating at 751 pouches per minute and above.

Rule 21 of the Central Excise Rules, 2002 permits excise-duty remission for goods that become unfit for consumption or marketing before removal. Where a trademark injunction prevents use of the relevant brand and renders existing stock unsaleable, remission cannot be denied on unverified assumptions that the goods could be repacked under another brand or exported. A show-cause notice founded solely on a remission-rejection order cannot survive once that foundational order has been set aside.

AED (GSI) credit under the MODVAT regime was unavailable for unprocessed nylon tyre cord fabric where the intermediate TCWS was exempt from AED (GSI) and finished tyres were not chargeable to that duty. Rule 57C barred credit for inputs used in exempt or nil-rated final products, while Notification No. 5/94-C.E. (N.T.) confined AED (GSI) credit to payment of the same additional duty on final products; it could not offset basic excise duty. Refund for exported tyres likewise required valid underlying credit and therefore did not arise. Later CENVAT changes did not apply to 1998-99, and the retrospective amendment applied only from 1 April 2000.

Royalty arising from mining leases executed before 1 April 2016 falls within the negative-list treatment under the Finance Act, 1994 and is not subject to service tax under the reverse charge mechanism. The execution date of each mining lease requires factual verification where the agreements were not produced before lower authorities. Once pre-1 April 2016 execution is established, no penalty is imposable in relation to the royalty liability.

Supply of tangible goods service applies only where tangible goods are provided for use without transferring possession and effective control. Vehicles fitted with hydrogen cylinder skids, charged on a per-trip basis, were characterised as transportation activity rather than vehicle renting. The activity was therefore not classifiable as supply of tangible goods service. It also did not satisfy the requirements for classification as goods transport agency service. Consequently, the service-tax demand raised under the supply of tangible goods service category was set aside.

Extended limitation for service-tax recovery requires positive, deliberate and wilful suppression; mere failure or omission to declare receipts does not suffice, particularly where the department already possesses Form 26AS, income-tax return and receipt data. Recovery cannot rest on the extended period without independent evidence of intent to evade tax. The public-road construction exemption for works contract services covers widening and strengthening works and integral footpaths within a composite Government road-development project. On that basis, the service-tax demand and consequential interest and penalties are unsustainable.

Commission-based order procurement for an overseas principal qualifies as export of Business Auxiliary Service where the recipient is outside India and consideration is received in foreign exchange; under later rules, the place of provision follows the recipient's location. Equipment hire transferring possession, custody and effective control to the customer is a deemed sale rather than Supply of Tangible Goods service. Reverse-charge demands based solely on disclosed accounts, particularly where tax would be available as Cenvat credit, lack suppression and are time-barred. Rule 10 permits Cenvat-credit transfer on demerger; disclosed credit supported by invoices, registers and reconciliations cannot be denied. Audit-based demands founded on returns and departmental disclosures do not justify extended limitation absent intent to evade tax.

Licence fees and additional licence fees paid for a State-granted exclusive liquor privilege are statutory imposts, not consideration for a taxable service, where the State assumes no reciprocal service obligation. Before 1 April 2016, the grant did not constitute support services and fell within the Negative List; later expansion of taxable Government services retained the requirement of an activity for consideration. Retrospective relief also neutralised service tax on relevant liquor-licence and application fees after that date. Extended limitation does not apply absent suppression of facts with intent to evade tax; consequently, the related tax, interest and penalties do not subsist.

Interim amounts deposited under judicial directions during a pending patent dispute do not constitute royalty or consideration for intellectual property rights services where they merely secure interests and balance equities pending adjudication. No vested entitlement to the deposits accrues to the patent holder, and use of the relevant patents or technology remains undetermined. On settlement and withdrawal of the suit, vacating the interim directions and releasing the deposits confirms their non-taxable character for reverse-charge service-tax purposes. A separate settlement payment made as royalty remains subject to IGST under the applicable tax regime.

Provisional attachment under the Prevention of Money Laundering Act was sustained because the Trust failed to establish that grant-funded aids and appliances had been distributed to disabled beneficiaries. Claimed distribution camps were not held in the stated districts, official signatures in supporting records were forged, and beneficiaries denied receiving the items. Purchase invoices and bank records did not prove distribution or explain transfers to the Trust's representative. The attached movable and immovable assets and bank balances fell within the value of the misused grant and were treated as proceeds of crime or property representing their value.

PMLA attachment of property identified as proceeds of crime prevails over a prior mortgage and enforcement action under the SARFAESI framework. The two regimes operate in distinct fields, with the PMLA overriding in matters involving money-laundering and tainted property. A secured creditor must establish bona fide acquisition of its interest, adequate consideration and appropriate due diligence to obtain protection. Where land was acquired through tainted funds and the mortgagee could not show sufficient due diligence when creating the security, the attachment continues despite the creditor's lack of criminal culpability. Recourse remains available before the Special Court under the PMLA.

Criminal process cannot be used to recover contractual dues where allegations do not disclose essential criminal ingredients; the civil-works payment proceedings were quashed. An Enforcement Case Information Report under the Prevention of Money Laundering Act is not automatically invalidated by technical quashing of predicate FIRs when the underlying scheduled-offence complaint survives without merits exoneration; the 2022 ECIR and summons continued. Homebuyer allegations of non-delivery, double sale, multiple financing and fund diversion prima facie warranted investigation, and buyer payments may constitute deposits under the Karnataka deposit-protection law. The 2025 ECIR and provisional attachment remained subject to statutory adjudication and review.

PMLA proceedings may continue alongside proceedings for the predicate offence, but the judgment in the PMLA matter must be pronounced simultaneously with the judgment in the predicate-offence matter. Earlier directions were clarified and modified to permit continuation while preserving synchronised delivery of both judgments. The miscellaneous application was disposed of accordingly.

No ground was found to interfere with the High Court order in proceedings concerning money laundering. The petitioner received six weeks to surrender before the Trial Court and may then seek regular bail. The Trial Court must consider any regular-bail application expeditiously after surrender. The special leave petition was dismissed with that liberty, while pending applications stood disposed of.

Suspended directors may attend creditors' committee meetings on a non-voting basis and obtain resolution-plan material, subject to advance written authority for any representative and a confidentiality undertaking. These safeguards protect confidential plan information and do not restrict personal attendance or access once the undertaking is furnished. Non-compliance will not invalidate committee proceedings without demonstrated actual prejudice or a denial of substantive opportunity. Where the process was not materially defective and an approved plan has been implemented, reopening it conflicts with the time-bound, value-preserving insolvency framework. Costs should remain proportionate to the nature of the challenge.

Regulation 21A of the Liquidation Process Regulations treats secured assets as part of the liquidation estate where a secured creditor does not communicate its decision to realise the security within thirty days of liquidation commencement. A customs creditor's failure to exercise non-relinquishment within that period resulted in deemed relinquishment. Expired EPCG obligations, uninvoked and unrenewed bank guarantees, and automatic-renewal clauses did not alter that statutory consequence. Principles concerning subsisting guarantees or margin money held in trust were inapplicable. The funds underlying the bank guarantees formed part of the liquidation estate, requiring return of original bonds and remittance of FDR amounts to the liquidation account.

Restoration applications dismissed for non-prosecution may be considered beyond the 30-day period under Rule 48(2) where sufficient cause exists. Section 238A of the Insolvency and Bankruptcy Code applies the Limitation Act to interlocutory restoration proceedings, permitting condonation under Section 5. Continuing authority under an existing vakalatnama, together with professional and procedural rules governing counsel's discharge, can prevent a party from appointing replacement counsel without consent or leave. Deliberate non-appearance by counsel and refusal to enable substitution may constitute a genuine impediment, so delay alone should not bar restoration and the underlying claim should be examined on merits.

Interim status quo and stay protection pending appeal were declined because a Civil Court restraint order remained in force, competing property interests were asserted, and applications for intervention and impleadment were pending. Objections and rejoinder were directed, and the application was listed with the appeal. No additional interim protection was granted at that stage.