PMLA coverage extends to virtual digital asset exchanges, transfers, custody or administration, and related financial services, with virtual digital asset entities treated as reporting entities. Enhanced record-maintenance and due-diligence obligations require beneficial ownership identification, client-structure information, trustee and senior-management details, and registered-office information. Trusts and companies are subject to a ten per cent controlling-interest threshold for beneficial interest, while non-profit organisation clients require registration on the NITI Aayog DARPAN portal. Politically exposed persons are defined by reference to prominent foreign public functions.

Personal hearing under Section 75(4) of the CGST Act is mandatory where an adverse decision is contemplated, regardless of a "No" selection in FORM GST DRC-06. Where FORM GST DRC-01 does not contain hearing particulars, the proper officer must separately communicate the date, time, and venue; reminders showing "N.A." do not provide an effective hearing. Section 75(6) additionally requires a reasoned order addressing relevant facts, the taxpayer's reply, and supporting material. For ITC eligibility, the recipient must establish actual movement of goods and transaction genuineness beyond invoices and banking payments.

Wrong-head GST payments must be reconciled against the correct tax liability where IGST was mistakenly paid under CGST and SGST because of a clerical return-entry error. Established and available excess amounts may be adjusted to prevent duplicate recovery, but the adjustment extends only to that extent. A residual IGST shortfall remains recoverable in cash with applicable interest. Demand confirmation must remain within the grounds stated in the show-cause notice and must address the taxpayer's reconciliation through a reasoned adjudication.

Transitional input tax credit omitted because the portal did not permit correction of an earlier return should be tested through verification rather than defeated solely by procedural lapse. Proper officers must examine relevant records and issue a reasoned determination. First appellate authorities must independently assess facts, identify issues, address defence grounds and give speaking orders. Clerical tax-head mismatches may permit CGST/SGST credit set-off against an IGST shortfall through the electronic credit ledger, with any remaining dues payable in cash with applicable interest.

Police investigation is not excluded merely because allegations arise from GST registration, invoicing, input tax credit claims, or tax compliance. Where an FIR contains distinct cheating and forgery offences, tax authorities and police may examine connected aspects under their respective legal powers. GST officers may scrutinise registrations, invoices, returns, credits and tax consequences, while police may investigate separate criminal ingredients. A disputed return, accounting error, or input tax credit claim does not itself establish penal offences; statutory ingredients and supporting evidence remain necessary.

Section 9 of the Arbitration and Conciliation Act permits interim measures securing an amount in dispute where circumstances show that enforcing a future arbitral award may become difficult. A registered cancellation deed, issuance of a cheque for the identified principal amount, and its dishonour for insufficient funds may prima facie support a refund claim. Financial and contractual disputes, negligible disclosed bank balances, pending enforcement proceedings, and assignment of redevelopment rights may establish a genuine risk to recoverability. Deposit of the disputed principal amount can preserve the claim pending arbitration without determining underlying rights or liabilities, where the balance of convenience supports such protection.

Sales-tax demand notice dated 15 July 1997 for assessment year 1991-92 fell within the five-year limitation under Section 12 of the Rajasthan Sales Tax Act, 1994. An earlier notice concerning the same assessment year and sales-tax demand had been issued within the prescribed period. The later notice was treated as a continuation of the earlier timely notice, rather than as an independent and time-barred demand, and was therefore valid.

Registered security interests recorded before a State tax charge receive statutory priority over government taxes, cesses and other dues under section 26E of the SARFAESI Act. A State's statutory first charge for sales tax cannot displace that priority where the secured creditor registered its interest first. Tax-recovery notices and attachments cannot burden the secured asset in those circumstances, particularly where the prescribed public-proclamation procedure for attachment has not been established. The auction purchaser is consequently entitled to receive the secured asset free of the State tax encumbrance.

Under the compounded levy scheme, capacity-based duty must be determined from verified production-capacity parameters and charged at the prescribed rate applicable to the chosen payment option. A demand cannot be confirmed on an annual-capacity basis not proposed in the show cause notice. No duty accrues after permanent factory closure where no production occurs, and duty paid in excess of liability calculated on the correct capacity and rate is refundable. Interest and penalty under Rules 96ZO, 96ZP and 96ZQ cannot be sustained because those provisions had been declared ultra vires.

Amounts paid during investigation or adjudication that are not appropriated towards duty retain their character as revenue deposits rather than statutory refunds or pre-deposits. The refund provisions governing duty and delayed statutory refunds do not apply while that character remains. Interest at 12% per annum is payable from payment until refund. Where an amount is later treated as a statutory pre-deposit, interest remains payable at that rate for the intervening period before its conversion, because later treatment does not alter its original revenue-deposit character.

CENVAT credit is admissible for service tax paid on commissions to overseas agents that procure export orders. Rule 2(l) of the CENVAT Credit Rules, 2004 treats sales-promotion services as input services. Commission-agent activities that procure orders and facilitate sales contain a sales-promotion element, bringing them within that definition. The subsequent explanation confirms the legislative intent that credit extends to commission-agent services used for such sales-related functions.

Amounts deposited under protest during an investigation, rather than as statutory pre-deposits under section 35F of the Central Excise Act, fall outside section 35FF's refund-interest regime. Delayed refund of such deposits attracts interest at 12% per annum from the payment date until realisation under applicable jurisdictional High Court precedent. The distinction between an investigation deposit and a section 35F pre-deposit determines both the governing refund provision and the applicable interest rate.

Actual diesel-cost reimbursements, where diesel is supplied at market cost and paid against petrol-pump bills, constitute pure-agent expense reimbursements rather than consideration for a taxable service. Such reimbursements are therefore not liable to service tax. Service-tax demands cannot rest solely on unverified third-party income-tax data or assumed taxable values. Without independent inquiry establishing the services supplied, their recipients, and the taxable value, the demand lacks an evidentiary and taxable foundation and is unsustainable.

Token amounts collected from designated roadside establishments under a passenger-facility scheme did not constitute consideration for a taxable declared service. Taxability under the Finance Act, 1994 requires an activity undertaken by one person for another for consideration. The prescribed provision of passenger amenities and regulated bus halts served safety, hygiene and administrative purposes, without an identifiable service-provider and service-recipient relationship or quid pro quo. Permitting buses to stop at approved locations was integral to passenger transportation and did not grant an exclusive right, amount to promotion or marketing, or constitute renting of property. The service-tax demand was therefore unsustainable.

Entry No. 13 of Notification No. 25/2012-ST exempts construction, repair, maintenance, renovation or alteration of roads used by the general public from service tax. Work orders and Form 26AS records linking receipts to repair and renewal of public roads undertaken for the Public Works Department support the exemption. Reliance on a work order from a different financial year does not negate the qualifying nature of the relevant services; the resulting tax demand cannot be sustained.

Swachh Bharat Cess and Krishi Kalyan Cess paid on eligible taxable input services used for export of goods fall within the refund mechanism under Notification No. 41/2012-ST. The Finance Acts of 2015 and 2016 deem these cesses to be service tax and extend applicable service-tax refund provisions to them. Applying the notification consistently with that statutory deeming treatment preserves export neutrality and prevents exclusion of the cesses from refunds available for services used in exporting goods.

Service-tax liability in joint development arrangements depends on contractual rights, consideration, period-wise taxability, correct classification as construction service or works contract, and valuation without duplicating values already taxed. Land or development rights may constitute non-monetary consideration only after taxable character is established. Reverse-charge liability requires proof of each statutory prerequisite, including qualifying GTA documentation, provider status for security and legal services, and supply by an independent manpower provider; ledger entries alone are insufficient. Extended limitation requires fraud, wilful misstatement, or deliberate suppression intended to evade tax, assessed separately for distinct transactions. Penalties depend on the ultimate findings on liability and limitation.

Unauthorised foreign-exchange contraventions require proof that seized currency represents proceeds of prohibited transactions. A documented cash withdrawal and cash-book entries may explain possession of currency, while failure to prove seizure undermines reliance on recovered cash. Presumptions for seized documents apply only after independent admissibility is established; loose sheets that are not books of account cannot be validated by statutory presumption. A retracted statement requires proof of voluntariness and corroborative material. Burden shifting applies only once the Department proves the foundational act requiring permission. These evidentiary requirements prevent proof of contravention through unproved seizures, inadmissible records, or uncorroborated statements.

Suspended directors who are personal guarantors and unsuccessful resolution applicants may challenge resolution-plan approval under the Insolvency and Bankruptcy Code. E-bidding terms may prevent unilateral post-closure bid revisions, while the Committee of Creditors may seek clarifications and permit compliance-related modifications without reopening financial bidding. Approved plans are not displaced unless statutory non-compliance or material irregularity is established; commercial decisions on negotiations, viability and compliant valuations ordinarily remain within the Committee's domain. Valuations conducted through the prescribed process, continuation of a retained resolution professional, and optional special-purpose-company structures do not by themselves invalidate a plan. A consortium must retain majority shareholding during implementation, and acceptance of a declined one-time settlement cannot be compelled after plan approval.

Fixed-deposit withdrawal entitlement under the interim direction belonged to the appellant in the civil appeal, who was expressly permitted to apply before the Appellate Tribunal in accordance with entitlement. The direction distinguished that appellant from the corporate debtor's representative, identified as the depositor. The suspended director could not claim withdrawal, and the deposited amount with accrued interest was to be remitted to the civil-appeal appellant accordingly.