Valuation of consideration for a limited patent-use licence turned on materially divergent expert reports applying an internationally accepted cost approach and a substantially higher departmental valuation. Neither valuation position was accepted in full. A lump-sum estimate was adopted in the interest of justice, expressly without precedential effect, fixing the amount attributable to the limited patent-use right at USD 900,000. Consequential computation was directed in accordance with law, and the appeal was partly allowed to that extent.

TDS credit omitted from an original return may be claimed through rectification where Form 26AS reflects the deduction and the corresponding income has been offered to tax. Mere failure to claim the credit in the original return should not result in its denial in those circumstances. The Assessing Officer must verify the TDS claim and inclusion of the related income before granting the credit.

Enhanced leave-encashment exemption for non-government employees is treated as a beneficial, curative fiscal measure addressing hardship from the previously unrevised limit. Such beneficial provisions receive liberal construction and apply to pending proceedings unless retrospective operation is expressly barred. On that basis, the enhanced ceiling under section 10(10AA) applies to Assessment Year 2021-22, allowing exemption of the full leave-encashment receipt within that ceiling and removing the related addition.

Jurisdictional defect in an assessment may be raised in collateral penalty proceedings where the assessment was made without a valid notice under section 143(2) from the jurisdictional Assessing Officer. An order made without jurisdiction is a nullity and may be challenged whenever enforcement or reliance is attempted, notwithstanding that the assessment has attained finality. Because the assessment was invalid and non est, the consequential penalty order was quashed.

Timely pronouncement of reserved judgments required release of an indirect-tax writ petition after the Bench could not adhere to stipulated timelines. Applying the principle concerning prompt delivery of reserved decisions, the matter was placed before the regular Bench hearing indirect-tax writ petitions. Interim status quo was directed to continue for four weeks, preserving the parties' existing position pending further hearing.

Customs Broker licence revocation requires a serious breach of primary regulatory obligations; address-change and Customs Station intimation failures, and signature-related irregularities, are procedural contraventions warranting penalty rather than revocation or security forfeiture. Electronic processing through ICEGATE means same-day clearances at multiple ports do not, without supporting evidence, prove licence subletting. Client due diligence does not require physical verification of premises, and undisclosed DRI notices cannot be inferred without proof of receipt. A Customs Broker's compliance-advice duty is limited to documents handled at entry or departure and does not extend to exporters' downstream excess RoSL claims. Licence revocation and security forfeiture were set aside, while procedural penalties were maintained or reduced.

Voluntary statements made by an importer, its proprietor and its agents during a Customs Act inquiry may be relied on as substantive admissions where they acknowledge under-invoicing and retail sale price misdeclaration. Denial of cross-examination does not breach natural justice where those persons cannot be compelled to depose against themselves. Original supplier invoices recovered from the importer's laptop and forensically examined in its presence constitute primary electronic evidence, without requiring a certificate applicable to secondary electronic records. Evidence of misdeclaration justified rejection of the declared transaction value and sequential redetermination under the Customs Valuation Rules. The consequential duty demand, confiscation and penalties were sustained.

Subsisting judicial orders require immediate compliance by the Ministry and affected parties unless stayed or modified. An intention to file a review petition does not justify withholding implementation of a restoration direction. The Registrar of Companies must restore the company's name to its register and reflect the company as active on the Ministry's website. Implementation remains subject to any subsequent order in a review application, preserving the respondent's position while ensuring prompt compliance with the existing restoration judgment.

Service of notice in insolvency proceedings is satisfied where repeated attempts through speed post and email, corrected address particulars, and further opportunities to respond provide reasonable opportunity before ex parte action. A corporate debtor that keeps its registered office non-functional cannot rely on resulting non-receipt to establish a breach of natural justice, absent a challenge to email service or evidence of incorrect particulars or mala fides. For a corporate guarantor, a demand guarantee may contractually treat the principal borrower's acknowledgment or balance confirmation as the guarantor's acknowledgment. Written settlement proposals acknowledging liability can therefore extend limitation, while the section 7 inquiry remains confined to financial debt and default.

Substitution of attached proceeds of crime with a bank guarantee does not justify release of identifiable immovable property under the PMLA. The statutory scheme aims to prevent enjoyment of assets derived from illegal activity and preserve them for confiscation or restitution. Releasing such property for use or transfer may enable its depletion, generate further funds, and legitimise income derived from it, undermining those objectives. The request for de-attachment and substitution with an equivalent bank guarantee was rejected, and the writ petition was dismissed.

Good corporate governance is central to development and depends on responsible governance, ethical practices, transparency, institutional accountability and professional excellence. Company Secretaries have an expanding role in strengthening governance practices through professional expertise. Professional institutions should promote governance standards, support institutional excellence, and evolve their practices in response to changing requirements. Their wider contribution lies in fostering a culture of ethical entrepreneurship, responsibility, transparency and sound governance.

Under the PMLA, a provisional attachment cannot be confirmed by relying on a subsequent FIR absent from the recorded reasons to believe, attachment order, and original complaint. Such an FIR may create a separate basis for fresh attachment but cannot retrospectively validate an earlier attachment. Attachment of alleged proceeds of crime also cannot continue once the underlying scheduled offences are not established or no longer survive. Quashing of the foundational FIRs or filing of closure reports extinguishes the basis for PMLA proceedings and consequential attachment. On these grounds, the provisional attachment and its confirmation were set aside.

Reverse-charge liability on foreign or intermediary bank charges deducted while transmitting export proceeds requires a taxable service provider-recipient relationship. Where the exporter neither engaged the banks nor owed them consideration, deductions from export proceeds do not establish that relationship and do not attract service tax under Banking and Other Financial Services. Regulatory dossier preparation and compilation for overseas pharmaceutical approvals must be classified by the activity actually performed, not the provider's technical qualifications. Preparing documentation from available information or published literature, without advice or scientific or technical assistance, is not Scientific or Technical Consultancy Service. The related service-tax demands, interest and penalties were unsustainable.

Exemption for construction of civil structures or other original works does not extend to a work order limited to transporting boulders, even where transportation, fixing and levelling support a Government or governmental-authority project. The activity remains outside the original-works exemption because it does not itself constitute construction or execution of original works. A subcontractor performing transportation for a railway-track project remains liable for service tax; use of that service by the main contractor as an input service does not alter its taxability. Service-tax liability on the subcontracted transportation work was therefore sustained.

Annual Production Capacity determination under the applicable rules is an administrative exercise rather than an appealable order; failure to challenge it therefore does not bar a refund claim. Duty imposed on stenter galleries, being unconstitutional, must be excluded when capacity is redetermined. The unjust-enrichment bar and refund provisions governing duty recovery do not apply where the levy itself was unconstitutional. Annual Production Capacity must be recalculated excluding galleries, consequential duty determined, and the refund claim processed. No interest is payable until the refund claim is determined. Questions concerning rectification applications remain unanswered.

Recovery of irregular or excess suo motu credit under Notification No. 39/2001-CE is treated as recovery of excise duty erroneously refunded where the credit is not reversed. The limitation applicable to erroneous refunds therefore governs such recovery. A recovery notice issued more than five years after credit was taken was time-barred, rendering the related demand, interest and penalty unsustainable. Annual differential-duty credit taken after submission of the prescribed statement and prolonged inaction by the jurisdictional officer was treated as compliant with the notification. Revenue authorities' cited decisions on different forms of suo motu adjustment or refund did not apply. The impugned order was consequently set aside.

Vicarious liability of a company director for cheque dishonour requires a complaint to specifically aver that the director was both in charge of, and responsible to, the company for conducting its business when the offence occurred. Mere directorship or a general allegation that all directors managed day-to-day affairs is insufficient. The complaint must also disclose the identity of the person who drew or signed the cheque. As no individual role was attributed to the director and no cheque signatory was identified, continuation of the prosecution was treated as an abuse of process and the cheque-dishonour proceeding was quashed against that director.

Section 74 of the CGST Act permits extended limitation only where the show cause notice states specific facts and material establishing fraud, wilful misstatement, or suppression of facts with intent to evade tax. Figures and boilerplate statutory language alone do not disclose the charge. The extended period is jurisdictional, and the Revenue must plead the relevant statutory limb and factual basis in the notice itself. A counter-affidavit, later submissions, personal hearing, or adjudication order cannot cure deficiencies in the notice.

Section 73 limitation for issuing a show-cause notice must exclude only the portion of the pandemic period from 15 March 2020 to 28 February 2022 that overlaps with the applicable statutory limitation period. The deadline is extended only by that overlapping duration, not by the entire excluded period in every case. For financial year 2020-21, this produces a two-month extension, while financial year 2021-22 remains unaffected because limitation commenced after the excluded period. Section 74 requires identification of fraud, wilful misstatement, or suppression rather than mechanical recital of all alternatives.

GST adjudication may use AI for research, drafting assistance and organisation of material, but AI cannot replace the statutory authority's independent application of mind. AI-generated authorities, statutory propositions and summaries must be verified against authentic primary sources for accuracy, relevance, factual context and continuing legal validity. Adjudicating authorities must consider the taxpayer's cited precedents and record reasons when rejecting them. Human oversight is indispensable: the issuing officer remains responsible for the legality and reasoning of every notice or order, and AI output cannot be mechanically adopted.