Extended limitation is an exceptional jurisdiction, not an additional period available after normal limitation expires. A tax discrepancy or possible taxability does not establish fraud, wilful misstatement, suppression of facts, or intent to evade tax. The show cause notice must set out the factual and legal basis for both classification and extended limitation, including the specific statutory limb invoked and material supporting culpable conduct. Audit observations, return mismatches, or protective proceedings cannot replace these foundational facts.

Occupation pursuant to a secured creditor's statutory auction is traceable to the sale certificate and does not constitute unauthorised occupation merely because leasehold-transfer formalities remain incomplete or prior dues are disputed. Unauthorised occupation requires possession without authority, or continued possession after the underlying authority has expired or been duly determined. Summary eviction under the M.P. Lok Parisar (Bedakhali) Adhiniyam, 1974 cannot rest solely on unresolved lease-transfer formalities or disputed liabilities of the former lessee. Recoverable arrears must be pursued against the person legally liable rather than by treating the auction purchaser as a trespasser.

Delayed deposit of Foreign Travel Tax before issuance of a show-cause notice constitutes delayed payment, not failure to pay under Section 38(3) of the Finance Act, 1979. Delays in deposit and return filing fall under Section 38(4) and the Foreign Travel Tax Rules, which permit condonation on sufficient cause. Notice-and-hearing requirements preserve discretion to decline penalty despite mandatory wording or a prescribed minimum. Penalty was therefore unwarranted for explained delays. The prohibition against reformatio in peius also prevents an appellant from facing an enhanced penalty solely for pursuing an appellate remedy. The penalties and consequential demands were invalid, requiring refund and discharge of the bank guarantee.

Export refund claims under Rule 5 of the CENVAT Credit Rules, 2004 should not fail where export clearances, accumulated unutilised credit, and the nexus with exported goods are undisputed. Supporting documents sought during verification are evidentiary for quantification and may be furnished later without affecting substantive eligibility. A refund application filed within the statutory period retains its original filing date; later document submission does not re-date the claim. Limitation cannot be introduced through adjudication where it was absent from the show cause notice, and a limited remand for document verification does not permit reopening settled issues. Only verification and computation of the eligible refund remain.

Excise assessment and PDS exemption eligibility are determined by the character, intended use and applicable conditions when SKO leaves the refinery. Subsequent intermixing of SKO with MS/HSD in a common pipeline outside the factory does not retrospectively reclassify the cleared goods or create differential duty liability. A departmental circular cannot impose a duty unsupported by statute. Extended limitation and penalties require evidence of suppression or wilful misstatement with intent to evade duty; where the Department could have made timely enquiries and a bona fide belief is supported by prevailing decisions, those consequences do not apply.

Sugar syrup containing more than 65% sugar by weight is stable, capable of being bought and sold, and therefore marketable and excisable under the Central Excise Act, even when captively consumed in exempt biscuit manufacture; actual sale is unnecessary. Extended limitation, interest and penalty apply where production and captive consumption of the syrup without duty payment were not disclosed in communications or ER-1 returns. Where duty is payable on the intermediate syrup, Cenvat credit for sugar used in its manufacture is available upon production and verification of duty-paying invoices; the credit requires verification and quantification.

Cenvat credit cannot be denied merely on an unsubstantiated allegation that invoiced copper ingots were not physically received. Transporter-issued goods receipts and supplier invoices supporting transportation and delivery remain material evidence where the department neither investigates the transporter nor disproves the records. Reliance on uncorroborated statements and third-party material requires compliance with the statutory conditions governing such evidence under Section 9D. The burden lies on the department to produce cogent evidence of non-receipt, particularly where no enquiry, statement, or premises search supports the allegation and duty-paid clearance of manufactured goods is undisputed.

Statutory appellate remedy against an order-in-original may remain available where the order is issued while related writ proceedings are pending, especially where constitutional challenges have already been resolved through final earlier orders. In those circumstances, the appellant may pursue the prescribed appeal and raise all grounds available under law. Limitation protection can be provided where the appeal is filed within the stipulated period, while merits issues remain open for consideration in the appellate process.

Perpetual assignment of copyright in independently produced television programmes constitutes a sale of goods, not taxable TV or Radio Programme Producer Service, where the programmes were not produced for or on behalf of broadcasters. Copyright is capable of transfer and commercial exploitation and therefore has attributes of goods. Exclusive, perpetual transfer of all rights in dubbed serials, leaving no rights with the producer, supports treatment as a sale; payment of VAT further confirms that the transaction falls outside service tax. Consequently, service tax, interest and penalties are not sustainable.

Construction services supplied to statutory bodies qualify for exemption under Entry 12 where the recipients fall within the definition of Governmental Authority. Comparable statutory authorities cannot be denied that status without reasoned grounds distinguishing them from authorities granted exemption; the resulting service-tax demand requires reconsideration. Entry 12A separately conditions exemption on a contract having been entered into and applicable stamp duty having been paid before 1 March 2015. Entitlement under that conditional exemption depends on verification of newly produced supporting documents and the relevant work contracts.

Substantively eligible CENVAT credit remains available where receipt of input services, service-tax payment and supporting documents are undisputed; non-reflection in ST-3 returns and delayed utilisation are procedural lapses that do not defeat entitlement. A service-tax demand based solely on information from the Income Tax Department cannot invoke the extended limitation period without material establishing suppression, misstatement, fraud, collusion or intent to evade tax. The original adjudication was restored, preserving eligible credit and preventing demand confirmation through extended limitation.

Rule 6(4A) permits excess service tax paid in an earlier period to be adjusted against service-tax liability in a succeeding month or quarter. The rule does not require adjustment exclusively in the immediately following period. Limiting adjustment to that period would undermine the provision where no liability arises then or where the excess payment exceeds that liability. Since the amount is already with the Revenue, adjustment against a later liability causes no revenue loss. Consequently, excess service tax may be adjusted against liabilities arising in later subsequent months or quarters, and a contrary demand is unsustainable.

Integrated excavation, loading, transportation and unloading of limestone within a mining lease area constitute a composite mining activity rather than Cargo Handling Service where handling is incidental to extraction and movement of mineral. Subsequent coverage of unchanged activities under the specific Mining Service entry supports that classification. A demand proposed solely under Cargo Handling Service cannot be sustained under a different taxable category because adjudication must remain within the show-cause notice allegations. Extended limitation does not apply where the classification issue permits more than one interpretation and no suppression or intent to evade is established. The tax liability, consequential interest and penalties therefore lack legal basis.

PMLA permits provisional attachment of property linked to proceeds of a scheduled offence. Recorded statements, charge-sheet allegations and the roles of senior company functionaries may support a finding of active participation in inducing investments through unlawfully issued preference shares, diverting collected funds and acquiring property from those funds. A claim that attached assets were acquired solely from salary and incentives does not displace the attachment where sums traced to the individuals substantially exceed the value of the assets. Confirmation of attachment remains contingent on the final outcome of the related criminal proceedings.

PMLA attachment may extend to property of equivalent value where directly derived proceeds of crime are unavailable, siphoned off or untraceable, including assets acquired before the alleged criminal activity. An insurance policy remained attachable because later premiums were paid from funds intermingled with and layered through alleged proceeds of crime; money laundering was treated as a continuing offence. Attachment is not limited to property previously quantified as proceeds of crime or to persons accused in the predicate offence, where another person holds or is involved with such proceeds. An inadvertent reference to an unrelated company did not undermine reasons to believe where other material supported the funds' nexus. Discharge of a co-accused based on personal lack of knowledge did not determine another person's position.

Rule 5(5) permits acceptance of a fixed deposit in place of jointly owned immovable property only up to the concerned person's estimated share, and its discretionary wording creates no general enforceable right to substitute attached property with equivalent security. Financial hardship and the preservatory purpose of attachment do not independently establish substitution rights. Where a statutory appeal against an Appellate Tribunal order is available, writ jurisdiction should not ordinarily be invoked unless jurisdictional error, perversity, breach of natural justice, manifest illegality, or another exceptional circumstance is established. Challenges to attachment remain for the statutory appellate process.

Anticipatory bail after proclamation proceedings, pre-arrest protection in a money-laundering prosecution involving a person not arraigned in the scheduled offence, and the Prevention of Money-laundering Act's twin bail conditions were raised before the Supreme Court. The Supreme Court declined to interfere with the High Court's judgment and dismissed the special leave petition. The supplied material does not provide the High Court's reasoning or specify the substantive legal effect of the dismissal beyond that outcome.

Section 31 of the Insolvency and Bankruptcy Code binds governmental and local authorities to an approved corporate insolvency resolution plan. Statutory claims for electricity duty, cess and royalty that were not lodged during the resolution process, despite public notice, do not form part of the plan and stand extinguished once the plan attains finality. Pre-approval recovery proceedings for such dues cannot be initiated or continued. As the authorities neither submitted claims before the NCLT nor challenged plan approval, the statutory demands were quashed.

IBC moratorium under Section 14 restricts proceedings against the corporate debtor but does not shield directors or authorised signatories from statutory cheque-dishonour liability under the Negotiable Instruments Act. Suspension of board powers during insolvency does not retrospectively extinguish personal penal liability for pre-moratorium acts. Where complaints specifically plead the signatory's role and cheque issuance, defences concerning knowledge, due diligence or inability to operate accounts require trial and cannot be conclusively determined in proceedings under the Bharatiya Nagarik Suraksha Sanhita. Criminal complaints may therefore proceed, while liability and statutory defences remain subject to evidence.

Competing open-offer timelines require a competing acquirer to make its public announcement within fifteen working days of the first acquirer's detailed public statement. A subsequent letter of offer or its advertisement is a distinct procedural stage and cannot reset the period, ensuring identical timelines and equal treatment of competing bidders. The exemption power applies only to the obligation to make an open offer; it does not permit relaxation of requirements governing an ongoing competing offer. Once the prescribed period has expired and the existing open-offer process has closed, a competing offer cannot be revived, although a fresh takeover process may be initiated in accordance with the Regulations.