Verification of discrepancies between Form 26AS receipts and ST-3 returns should cover corrected challans, tax payments, and reconciliation evidence. Where differential receipts represent customer advances invoiced later, the timing of service-tax discharge in the succeeding period requires examination. Production of supporting documents and a hearing are necessary before fresh adjudication; the matter was remanded to the original adjudicating authority for that verification.

Trading or sales involving transfer of title in goods fall outside the statutory definition of service, while renting a residential dwelling for hostel accommodation is excluded from service tax as residential use. Extended limitation requires evidence of deliberate suppression, fraud, or wilful misstatement intended to evade tax; disclosures and a reasonable view of non-taxability defeat its use. Form 26AS and income-tax return data alone cannot establish a taxable service, the parties to it, or consideration paid for it. Accordingly, these receipt categories do not support a service-tax demand or consequential liabilities.

Section 126 of the Finance (No. 2) Act, 2019, read with Rule 6 of the Sabka Vishwas (Legacy Dispute Resolution Scheme) Rules, 2019, requires the Designated Committee to verify departmental records, the declarant's disclosure, and supporting material before determining the amount payable. The Scheme provides specified relief on tax dues, subject to its conditions, and does not permit refunds. Materially inconsistent Forms SVLDRS-3 issued on the same date, without verification of disclosed payments and documentary evidence, cannot support a valid determination. A fresh determination requires complete verification of the declaration and supporting records.

Rectification proceedings concern correction of a clerical mistake said to have inadvertently appeared in a prior judgment. The Directorate of Enforcement filed the application, but no representative appeared to argue it. The public prosecutor was directed to notify the Directorate's office, and the matter was listed for a later date. No determination on the requested correction is recorded.

At the discharge stage, material must be assessed only for a prima facie case or strong suspicion; a roving inquiry or trial-like weighing of evidence is impermissible. Bank transfers, statements recorded under the Prevention of Money Laundering Act, and corroborative accounts of cash arrangements and delivery indicated that the transfers were not supported as ordinary business transactions. Knowingly assisting or participating in a process connected with proceeds of crime constitutes money laundering. The material therefore raised strong suspicion of knowing involvement in facilitating the transfer of proceeds of crime, and discharge was unwarranted.

Money-laundering proceedings under the PMLA raise issues concerning discharge and framing of charges, the statutory meaning of "proceeds of crime", and the character of money-laundering as an independent offence. Key questions include the admissibility of statements recorded under the PMLA, the need for prior sanction to prosecute a public servant, and whether evidence establishes a link between the accused and alleged criminal proceeds. The existence of a traceable money trail is also material to assessing the evidentiary basis for the charge.

Section 61(2) of the Insolvency and Bankruptcy Code requires an appeal within 30 days, with condonation for sufficient cause limited to a further 15 days. Time spent obtaining a certified copy cannot be excluded where the order was pronounced, uploaded on the same date, and publicly announced, particularly when administrative impediments and diligent pursuit of the copy remain unsubstantiated. Knowledge of the order does not extend limitation. Appeals filed beyond the non-extendable outer limit are not maintainable.

Section 96 of the Insolvency and Bankruptcy Code imposes an interim moratorium on legal actions concerning debt during the moratorium period, but its scope is confined to civil debt-recovery actions. Criminal prosecution for cheque dishonour under Section 138 of the Negotiable Instruments Act remains outside that protection because it safeguards the credibility of negotiable instruments and enforces personal accountability. Accordingly, an interim moratorium does not bar or stay cheque-dishonour proceedings.

Retrospective renewal of an expired Way Leave Permission cannot revive rights that lapsed before corporate insolvency resolution proceedings or impair intervening authorised works. Fresh permission remains within the Railway authorities' competence and requires compliance with applicable engineering standards. A comprehensive safety audit and an opportunity of hearing are necessary where a proposed structure may affect existing underpasses, adjoining property or public safety. Persons facing potential adverse civil consequences have standing to challenge such administrative permission. Fraud or collusion requires proof beyond reasonable doubt; invalidity of the permission alone does not establish either allegation.

Article 141 makes the Supreme Court's declared law and unambiguous directions binding on all courts. A trial court must implement an express direction for immediate vacant possession where an undertaking binds all accused; it cannot use inherent jurisdiction under the Bharatiya Nagarik Suraksha Sanhita, 2023 to reinterpret, dilute, or sit in appeal over that direction. A pending review petition does not suspend the operative force of the judgment unless the Supreme Court grants a stay, modification, or suspension. The direction requiring the accused to vacate the residential quarters therefore remains enforceable.

Technical meaning governs the scope of the customs concession for Train Protection and Warning System (TPWS) equipment. Railway specifications distinguish track-side and on-board TPWS signalling equipment from interfaces with brake-control systems. Disc Brake Units and Pole Wheels, which form part of axle-mounted disc braking and wheel-slide protection systems, therefore do not qualify as TPWS parts or components and cannot receive the concessional duty rate. Strict construction requires the exemption claimant to establish square coverage. Where a notice invokes only the normal limitation provision for duty recovery, differential duty may be demanded only for Bills of Entry within that period; recovery beyond it requires invocation of the extended-period provision.

Under the Customs Act, the burden-shifting presumption for gold arises only where seizure rests on a seizing officer's reasonable belief, supported by definite and objective material, that the goods are smuggled. Without that foundation, the Department must independently establish illicit importation through cogent evidence before confiscation or penalties can follow. Domestic procurement records, payment trails, stock and tax records, and transport or melting documents require effective rebuttal; uncorroborated or retracted statements alone do not prove smuggling. Cross-examination is required when specifically sought for relied-upon witness statements; absent such a request, its non-grant does not itself breach natural justice.

Under Advance Authorisations, the physical-incorporation requirement for satisfying export obligation applies to imported inputs used in the resultant export product. Imported Vetted Malt Scotch physically incorporated in exported IMFL meets that condition; separately procured duty-free bottles, caps and labels used only for packing do not constitute inputs physically incorporated in IMFL. Their use therefore does not, by itself, breach the relevant exemption condition or invalidate export-obligation fulfilment. For customs-duty recovery, DRI officers may issue notices when appointed as customs officers and assigned the relevant recovery function, which is distinct from assessment.

Provisional release of seized betel nuts under the Customs Act was not warranted where testing did not establish unequivocal Indian origin. Initial sampling indicated resemblance to Indonesian areca nuts and mould infestation; re-sampling reported Indian origin but did not address mould. Food-laboratory findings that the nuts were mould- and insect-damaged beyond prescribed limits, sub-standard and unsafe supported non-release. The availability of an appellate statutory remedy meant that challenges concerning seizure and release could be pursued through that remedy.

Paragraph 1.05(b) of the Foreign Trade Policy, 2023 provides transitional protection for bona fide import commitments made before a restrictive import notification. Although the provision expressly refers to irrevocable commercial letters of credit, substantial advance payments may provide equivalent or greater payment security to overseas sellers where business records establish genuine pre-existing transactions. The restriction on gold imports remains a policy decision, but its transitional application requires a purposive construction. Delegated legislation ordinarily operates prospectively unless retrospective operation is statutorily authorised. Pre-notification gold import transactions supported by substantial advance payments qualify for the transitional benefit.

Section 110(5) of the Customs Act limits provisional bank-account attachment to six months, extendable once by a competent Commissioner in writing for up to a further six months, with communication before the original period expires. The maximum attachment period is therefore twelve months. A show cause notice under Section 124 or pending adjudication does not extend that limit. Once the maximum period expires, the attachment ceases by operation of law and cannot continue through administrative action.

Availability of an efficacious statutory appeal ordinarily calls for restraint under Article 226 but is not an absolute bar to writ jurisdiction. A challenge to treating goods as prohibited solely by description and asserted criminal-law application, without an identified statutory or notification-based prohibition, raised an arguable departure from objective legal standards affecting the right to trade. The preliminary alternative-remedy objection was rejected, the writ petition was maintainable, and the merits remained for hearing.

Prior approval for provisional attachment under Section 24 of the Prohibition of Benami Property Transactions Act, 1988 must follow issuance of a written notice to the alleged benamidar, founded on recorded reasons to believe, with a copy to the beneficial owner. Attachment may be ordered only after the prescribed opinion is formed and the Approving Authority grants approval on the relevant material and reasons. Approval obtained before the statutory notice is issued is invalid because it bypasses the mandated sequence, lacks the necessary evidentiary basis, and makes the attachment process mechanical. Consequently, a provisional attachment based on such prior approval, and its confirmation, cannot be sustained.

Section 115BBE's enhanced tax rate, introduced by the 2016 amendment with effect from 1 April 2017, applied to surrendered income for assessment year 2019-20. As the amendment was already operative for that year, taxation at the normal rate was a mistake apparent from the record and could be rectified. The surrendered income was therefore chargeable at the enhanced rate.

Section 56(2)(vii) did not support an addition where the difference between purchase consideration and DVO valuation fell within the applicable tolerance band. The Section 50C(2) valuation mechanism was treated as pari materia, extending its tolerance to that valuation difference; the stamp-duty-based addition was therefore deleted. Investment and stamp-duty payments traceable to the taxpayer's disclosed bank account and available balance constituted an explained source of funds. The unexplained-investment addition was consequently deleted, resulting in deletion of both property-acquisition additions.