Production-linked power assistance that enables an industrial unit to operate more profitably after commencement of production, without an identified contribution towards a new asset or capital outlay, is a revenue receipt. Subsidy designed to set up a new unit or substantially expand an existing unit is a capital receipt. A power subsidy calculated from electricity charges and payable during production is revenue in character.

GST search-and-seizure powers require a separate statutory basis for the property seized and the purpose of retention. Section 67(2) permits seizure of confiscable goods and documents, books, or things useful as evidence; money cannot be treated as confiscable goods merely because it is alleged to be untaxed sale proceeds. "Things" must be read with documents and books, covering articles with an evidentiary purpose rather than unexplained wealth or security for a future tax demand. Reasons to believe require identifiable material linking cash to the statutory conditions for seizure.

Challenges to adjudication orders were required to be pursued through statutory appeals. The validity of service through the Common Portal remained unadjudicated because the operation and effect of earlier precedent on that issue had been stayed by the Supreme Court. Petitioners could file appeals within the stipulated period, and appellate authorities could not object on limitation if the required statutory deposit was made.

Removal of PPCP and SAN inputs to moulders after CENVAT credit reversal and payment of VAT/CST does not constitute trading or an exempted service. Consequently, the payment obligation applicable to exempted services does not arise merely because inputs are cleared as such for conversion into battery components. Extended limitation based on suppression is unavailable where departmental Range and Divisional officials knew of the credit availment, removals and reversals, as that knowledge negates suppression with intent to evade duty. The resulting demand, interest and penalty lack legal basis.

Authorised job work through a Domestic Tariff Area unit does not override the specific exemption conditions governing electricity generated from duty-free furnace oil and supplied in the Domestic Tariff Area. Subcontracting and movement permissions permit authorised production processes but do not exempt every utility supplied to a job worker. Where the recipient has ceased to be an Export Oriented Unit, electricity used for job work remains subject to the applicable duty consequence. Failure expressly to consider cited job-work provisions permits only limited rectification to address that contention, not a review of concluded merits.

Steel materials used to fabricate spares, parts and accessories of eligible sugar-manufacturing machinery qualify for CENVAT credit because components, spares and accessories fall within capital goods. Materials used for necessary supporting structures that enable machinery to function smoothly are likewise covered. A MODVAT-credit precedent does not govern CENVAT entitlement for accessories. Denial of credit and consequential interest and penalty is unsustainable.

Transitional refund claims for unutilised Krishi Kalyan Cess credit are treated as timely where the original application precedes the stipulated cut-off, even if later returned for non-use of a prescribed form lacking stated legal basis. The transitional provision requires such claims to be processed under existing law while allowing cash payment, limiting reliance on the ordinary one-year refund bar. Refund eligibility cannot be rejected on grounds outside the show-cause notice where it alleged limitation alone. The asserted exclusion under an unnotified Explanation 3 to the transitional credit provision does not independently bar KKC refund when linked Explanations 1 and 2 were not operational. Cash refund with applicable interest follows.

The mutually exclusive appellate scheme for indirect tax matters places disputes concerning the rate of duty or value for assessment outside High Court jurisdiction. Classification and taxability questions, including whether services supplied to an overseas entity are intermediary services and qualify as exports, are treated as issues concerning taxability and valuation. Such appeals must therefore proceed through the statutory appellate route to the Supreme Court rather than the High Court.

Extended limitation for recovery of Additional Excise Duty requires proof of fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade duty. Disclosed manufacturing activity, filed declarations, departmental awareness, a claimed small-scale exemption, and genuine uncertainty over duty liability may negate deliberate concealment. Mere registration deficiencies, non-payment, procedural omissions, or subsequent discovery of clearance levels do not independently establish wilful suppression or intent to evade. Without those statutory conditions, recovery beyond normal limitation and an equivalent penalty founded on the same allegations cannot be sustained. The substantive liability to Additional Excise Duty and marketability remain undecided.

Technical testing, inspection and certification services supplied to an overseas recipient qualify as export of services where reports are delivered to that recipient and payment is received in convertible foreign exchange. Subsequent use of the certification by the recipient's Indian clients does not change that character. CENVAT credit should not be denied solely because an invoice contains an incorrect service-provider registration number where the registration certificate and supporting material verify the correct number. Verifiable documentary compliance preserves credit despite a clerical typing error.

Encashment of bank guarantees for a shortfall in minimum guaranteed cargo tonnage does not constitute consideration for agreeing to tolerate an act or situation. The declared-service provision applies only where an agreement expressly or impliedly provides for tolerance in return for specified consideration. Amounts recovered for failure to meet committed cargo tonnage are penal charges designed to secure contractual performance and deter default, not consideration for any taxable service. Consequently, such bank-guarantee encashment is not taxable as a declared service, and related service-tax demand, interest and penalty are unsustainable.

Property derived or obtained, directly or indirectly, from criminal activity relating to a scheduled offence, including its value, falls within proceeds of crime under the Prevention of Money Laundering Act, 2002. Registration of a scheduled offence alone does not establish that every asset is tainted; a cumulative money trail can establish a prima facie nexus. Bank-account analysis and statements linked project escrow funds to the property's acquisition. Independent business income, accounting disclosure, and partial funding from the project account did not break that nexus. The attachment therefore satisfied the reason-to-believe requirement and warranted confirmation.

Temporary protection from coercive action was limited to permitting petitioners to appear and have their statements recorded in a money-laundering investigation. The protection operated only until recording was completed, based on their undertaking to cooperate and the position that no coercive steps were then contemplated. It neither determined the allegations on their merits nor granted immunity from subsequent investigative action.

Regulation 27(1)'s qualifying conditions in clauses (i), (ii) and (iii) of sub-regulation (c) apply uniformly to borrowers, subsidiaries and associates of a credit rating agency's promoter under sub-regulations (a) and (b). Although the provision was ambiguous on their reach, a harmonious construction supports a common conflict-of-interest safeguard across all such promoter-linked entities. The interpretation is reinforced by the provision's purpose, contemporaneous regulatory materials, parliamentary discussion and the analogous wording of Regulation 28V. This construction prevents borrowers and subsidiaries from being excluded from the qualifying conditions applicable to associated entities.

Recall jurisdiction cannot reopen a merits determination unless fraud affected the prior decision; a notarised affidavit complying with applicable requirements, with at most a curable formal defect and undisputed contents, does not establish fraud. Third-party participation in a disciplinary appeal against an insolvency professional requires a directly and substantially affected statutory interest. Representative participation is not a right, and a stakeholder outside the committee of creditors has no entitlement to seek replacement of the professional. Impleadment only in a stay application is impermissible where the applicant is not a party to the main appeal, consistent with dominus litis.

Separate corporate personality keeps a company's deposit obligations distinct from its directors' liabilities. A non-executive Chairman or Director does not become personally liable merely by holding office when deposits are accepted. Personal liability requires a personal guarantee, an independent contractual undertaking, statutory liability, or another recognised legal basis. As no such basis was established, the Chairman or Director bore no personal liability for repayment.

Advance rulings may cover ongoing imports where the goods are neither subject to a pending dispute nor already settled, with prospective operation. Pre-cut, non-rectangular, battery-specific die cut tape used principally for insulating and heat-protecting lithium-ion battery packs is classified as an other part of an electric accumulator under CTI 8507 90 90, rather than as a general-use plastic article. Continuous pressure-sensitive self-adhesive tape in rolls remains a general-use plastic article under heading 3919; rolls not exceeding 20 cm fall under CTI 3919 10 00, subject to dimensional verification. Both products are eligible for concessional basic customs duty when used in lithium-ion battery or battery-pack manufacture, subject to end-use and procedural requirements.

Storage-server classification under Heading 8471 turns on whether a model contains a central processing unit and system memory capable of automatic data-processing functions. CPU-less Crestone enclosures, being host-dependent devices that accept and deliver data, fall under tariff item 8471 70 90; CPU-integrated models are processing units combined with storage units under tariff item 8471 50 00, rather than units presented with input and output devices. Imported inputs used to manufacture all five servers qualify for the heading-level Basic Customs Duty end-use exemption if actually used in manufacture, excluding Chapter 74 goods and specified solar glass, and subject to concessional-duty procedures. The relief excludes integrated tax and other duties, taxes and cesses.

Car radio units designed for installation in motor vehicles, with AM/FM reception and integrated sound reproduction, fall within the specific tariff classification for motor-vehicle radio-broadcast receivers. Touchscreen, Bluetooth, Wi-Fi, USB, camera input, media playback and phone-mirroring functions remain integrated or ancillary features and do not alter that essential character. Where semi-knocked-down kits are imported together with the principal components and require only simple assembly, limited soldering, testing and configuration, they possess the essential character of the complete unit under Rule 2(a). Both completely built units and qualifying kits are classifiable under Customs Tariff Item 8527 21 00, subject to applicable BIS certification at import.

Refractories imported to re-line blast furnaces fall within the EPCG Scheme's capital-goods definition because they are accessories indirectly required to manufacture finished goods. The specific inclusion of refractories for initial furnace lining expands that definition and does not confine it to first installation or exclude replacement materials used in re-lining and maintenance. Such imports qualify for zero-duty treatment, leaving no basis for differential duty, interest, penalty, confiscation, or redemption fine.