Regular bail in allegations of fraudulent input tax credit availment and GST evasion requires assessment of the accusation, punishment, risks of evidence or witness tampering and abscondence, and public interest. Where the statutory period has expired, no recovery or discovery remains, the offence carries a limited maximum sentence and is triable by a Magistrate, continuing investigation alone need not justify custody. Stringent conditions can address concerns regarding electronic evidence and attendance. Personal liberty, bail as the norm, and avoidance of pre-trial punishment support release where trial is likely to take time, while conditions protect the investigation and trial.

Redetermination of GST tax, interest and penalty after rejection of proceedings under Section 74 requires independent, non-mechanical adjudication. Input Tax Credit cannot be denied solely because suppliers failed to deposit tax where invoices, transport and transaction records, banking-channel payments, and the absence of established purchaser fraud or collusion are material. The proper officer must consider the applicable statutory framework and purchaser evidence, hear the parties, and issue a reasoned speaking order. Appellate findings favourable to the purchaser remain undisturbed, and the adjudication is to be completed within four months.

Delay in filing a statutory GST appeal was condoned because the sole proprietor's cancer illness was supported by medical certificates. The medical evidence provided a sufficient basis for condonation, and adjudication on merits was preferred over barring the appeal on limitation. The appeal was restored for a merits decision, subject to deposit of costs.

Composition permission under the Gujarat Value Added Tax framework is conditional on compliance with prescribed scheme requirements. Rule 28C(6) bars a composition dealer from purchasing eatables or raw materials through inter-State trade or commerce, and Rule 28C(7) permits cancellation for breach. Cancellation was unsustainable where ledger entries showed funds received from an adjoining hotel business and paid to its supplier, no sugar purchase was debited to the dealer, and no evidence established that the dealer made the inter-State purchases.

Mere selection, grouping, branding and packing of bought-out LPG/CNG conversion components as a vehicle-specific kit does not constitute manufacture where the components retain their individual identity and undergo no processing or transformation. Manufacture requires both transformation into a distinct article with a new name, character or use and marketability; commercial identity or marketability of the kit alone is insufficient. Consequently, no excise duty arises from such non-transformative packing activity. Where the company incurs no excise-duty liability, a related employee penalty under Rule 26 of the Central Excise Rules, 2002 is unsustainable and must be set aside.

Waste and scrap arising from manufacture of goods under headings 8601 to 8606 cleared at a concessional duty rate falls within the exemption for such scrap, because the relevant entry does not limit relief to wholly exempt or nil-rated finished goods. An incorrect claim under a different notification does not displace an independently available exemption. The extended limitation period requires particularised fraud, wilful suppression, or intent to evade duty; departmental knowledge of the material facts and a bona fide notification-interpretation dispute defeat its invocation. Consequently, the duty paid is refundable, and no duty demand, consequential interest, or penalty survives.

Rule 6(3) permits a manufacturer that does not maintain separate accounts to choose the prescribed payment method or proportionate CENVAT-credit reversal. Rule 6(3A) requires written intimation of the date from which the proportionate-reversal option is exercised. Neither the Rules deem an election on the first day of a financial year nor treat continued payments under an earlier regime as an election of the payment option. Withdrawal restrictions apply only after actual exercise of an option; therefore, the proportionate-reversal option may be exercised during the financial year where no prior act of election occurred.

Foreign CRS/GDS services used to disseminate real-time flight availability and facilitate travel-agent ticket bookings did not fall within online information and database access or retrieval services. That classification required the foreign provider to supply data or information to the recipient, whereas the arrangements principally promoted and increased bookings and consideration depended on successful bookings. Booking information already existed in the airline's records and was automatically updated; it was not provider-owned data supplied to the airline. Incidental data flow could not alter the service's essential character. Receipt of the services therefore did not trigger reverse-charge service-tax liability.

Landowner receipts under a joint development arrangement were attributable to the sale of residential flats rather than consideration for a taxable transfer of development rights. Transactions concerning land and benefits arising from land fall outside the definition of service under the Finance Act, 1994. Where development rights are inseparable from the land and the parties jointly develop and sell flats, the arrangement does not create a distinct taxable supply of development rights to the developer. Consequently, the landowner's agreed share of sale proceeds was treated as proceeds from immovable property, with no service tax or penalty payable.

Road carriers qualify as goods transport agencies only when they both provide transport of goods by road and issue consignment notes. Road transport is otherwise within the negative list, except for services rendered by a goods transport agency or courier agency. Carriers that do not issue consignment notes therefore fall outside the definition of goods transport agency and are not liable to service tax on those road-transport services.

Reverse-charge service tax could not be levied on management consultancy services received from abroad where the service was rendered before 18 April 2006, when Section 66A became effective. The applicable legal position excluded reverse-charge liability for the pre-effective period. Consequently, no service tax was payable under reverse charge on the March 2006 service, and the confirmed demand was unsustainable.

Individually constructed residential dwellings provided for a buyer's personal use do not fall within taxable construction of a residential complex merely because they form part of a common housing layout. A perpetual lease of a plot and timber chalet or villa for individual residential use is therefore outside the service-tax levy. Service-tax refunds are governed by Section 11B through Section 83: for a purchaser other than the service provider, the relevant date is the service purchase date, evidenced by payment and the tax-bearing document. A claim filed within one year, where the purchaser bore and did not pass on the tax incidence, is eligible for consideration.

Extended limitation for service-tax recovery applies only where suppression of facts, collusion, or wilful misstatement with intent to evade tax is established. Prior departmental issuance of a show-cause notice concerning identical activities demonstrates awareness of the relevant facts and demand basis. Without the statutory grounds for the extended period, a subsequent notice issued beyond normal limitation for the disputed financial year is time-barred. The extended limitation period therefore cannot sustain recovery proceedings in those circumstances.

Extended limitation for service-tax recovery requires positive and deliberate suppression or misstatement with intent to evade tax; mere non-registration, non-payment, or non-filing of returns does not satisfy that standard, particularly where a bona fide interpretational dispute exists. Small service-provider threshold exemption applies where the preceding financial year's revenue remains below the prescribed limit. Service-tax liability also requires correct identification and classification of the taxable service; membership fees and commission receipts cannot be taxed merely on an unverified assumption that they constitute legal and administrative services. Consequently, an unclassified demand raised through invalid extended limitation lacks legal basis.

Extended limitation for service-tax recovery requires demonstrable deliberate suppression or wilful misstatement intended to evade tax. Mere non-payment, short-payment, discrepancies between returns and financial records, or a disputed exemption claim do not meet that threshold. Registered taxpayers who filed ST-3 returns, supplied agreements and financial records during investigation, and acted on a bona fide belief that services were exempt could not be treated as having deliberately concealed liability. A substantial reduction in the original demand further weakened any allegation of suppression. Recovery for part of the disputed period also exceeded the maximum five-year limitation period. The service-tax demand was therefore time-barred, with consequential interest and penalties unsustainable.

Transportation of goods by road without consignment notes falls outside taxable Goods Transport Agency services under the negative-list regime, because issuance of a consignment note is required for GTA status. Treating gross receipts alone as taxable consideration, without identifying another taxable service, cannot sustain Service Tax. Income Tax receipt data may prompt inquiry but does not by itself establish taxable activity, suppression, or intent to evade. Extended limitation therefore cannot apply absent independent evidence of deliberate concealment, and the tax demand, consequential interest, and penalties lack a sustainable basis.

Exhibit A, already part of the written submissions and record considered at the original hearing, may be incorporated into the final order where its omission is purely clerical and typographical. Such insertion records material already tendered, without changing the reasoning, findings, or operative directions; it therefore does not amount to a substantive review. Exhibit A is to be inserted, while all remaining findings and directions continue unchanged.

Hiring hot-mix plants, paver machines and accessories under agreements for consideration constitutes supply of tangible goods rather than construction, repair or road-maintenance services; the relevant construction and public-works exemptions therefore do not apply. Where service tax is not separately collected, taxable value is computed on a cum-tax basis. Threshold exemption is unavailable if preceding-year taxable turnover exceeds the prescribed limit. Failure to obtain registration or file returns despite taxable turnover above that limit, without a plausible explanation or bona fide belief, constitutes suppression with intent to evade tax. That conduct permits extended limitation and attracts the statutory equal penalty, while time-barred periods remain excluded.

Monetary limits for departmental appeals under the Central Excise and service-tax framework apply to pending legacy matters, including disputes involving recurring issues. Appeals before the High Court below the prescribed threshold cannot be pursued merely on alleged cascading consequences or a common question of law. The only retained exceptions concern challenges to the constitutional validity of an Act or Rule and findings that a notification, instruction, order, or circular is illegal or ultra vires. The former classification-and-refund exception was withdrawn, and income-tax circulars do not expand the available exceptions. Below-threshold appeals outside those exceptions are precluded, while proposed substantial questions of law remain open.

Finality of assessments in Bills of Entry bars a subsequent differential customs-duty demand based on reclassification when Revenue did not challenge the original assessments. Goods were assessed under the importer's declared classification and cleared after out-of-charge; those assessments consequently became final. The confirmed demand was set aside, and Revenue's challenge to the dropped demand was not maintainable.