Section 85(3A) of the Finance Act, 1994 requires an appeal before the Commissioner (Appeals) to be filed within two months and permits condonation for sufficient cause only up to a further one month. This outer limitation restricts the appellate authority's jurisdiction, and the merits of the underlying demand cannot support condonation beyond it. Consequently, delay exceeding the maximum condonable period cannot be condoned, leaving the appeal outside the Commissioner (Appeals)' jurisdiction.

Extended limitation for service-tax demands requires deliberate suppression with intent to evade tax; discrepancies apparent from statutory financial records or Form 26AS, without corroborative evidence, do not meet that standard. Taxable turnover must be based on reconciled figures, and a demand alternating between balance-sheet and Form 26AS turnover without reconciliation lacks a sustainable basis. Directors' remuneration recorded, taxed and disclosed as salary falls within the negative-list exclusion from taxable service. Consequently, the tax demand, interest and penalties were legally unsustainable.

Reverse-charge service-tax liability may be determined from expense heads, accounting records, ST-3 returns, balance sheets and Form 26AS where returns do not reconcile and the taxpayer fails to furnish adequate particulars despite requisitions. The resulting demand remains confined to the normal limitation period, with applicable interest and recomputation of liability. Revenue neutrality arises where reverse-charge tax is fully available as Cenvat credit to the same taxable person, reducing forward-charge cash liability. That position negates the intent to evade required for extended limitation and the corresponding suppression penalty; however, any remaining penalty is retained.

GST appellate remedy before the Tribunal was available within the prescribed filing window, subject to the statutory pre-deposit. The challenge to invocation of Section 74 was left for determination by the Tribunal rather than addressed in writ proceedings. The writ petition was disposed of with the petitioner directed to pursue the appellate remedy.

Subsequent service-tax adjudication and garnishee recovery for a period already covered by an appellate determination could not stand. Works performed exclusively for Government Departments were treated as exempt under Notification No. 25/2012-S.T., and the services also fell within the small-scale service-provider exemption under Notification No. 33/2012-S.T. The earlier appellate determination found no taxable service, return-filing liability, sustainable demand, or late fee, and resulted in refund of the deposited amount. Reliance on income-tax returns and Form 26AS could not support a later demand for the same period. The subsequent order-in-original and recovery notice were set aside.

Appeals involving determination of service-tax liability or classification of taxable services must be filed before the Supreme Court under section 35L of the Central Excise Act, 1944, as applied to service tax through section 83 of the Finance Act, 1994. Where the dispute concerns taxability of royalty under intellectual property rights and service classification, the High Court lacks appellate jurisdiction. The statutory remedy lies exclusively before the Supreme Court, rendering an appeal before the High Court not maintainable.

Pre-deposit compliance was addressed where appeals had been dismissed for failure to meet the prescribed requirement. The writ petitions were disposed of with liberty to make the required pre-deposit through the prescribed portal and seek restoration of the appeals. No final determination was made on the validity of the earlier payment. A separate application may be made for refund of the amount deposited through DRC-03.

Under the Prevention of Money Laundering Act, 2002, a compromise decree entered after attachment does not create an enforceable interest in attached property where title has not transferred and the attachment was known. Single-member adjudication by a Finance Member is permissible because the Adjudicating Authority conducts statutory scrutiny and remains subject to appellate review. Property acquired before registration of a scheduled offence may still be attached if directly or indirectly derived from criminal activity relating to that offence. Provisional and confirmation attachments require recorded, independent reasons to believe that the property constitutes proceeds of crime and that non-attachment may frustrate proceedings. Challenges to the factual basis of such satisfaction fall within the statutory appellate process.

Under the Prevention of Money Laundering Act, the Adjudicating Authority must be constituted in accordance with the statutory requirement of a Chairperson and two qualified Members; a sole-Chairperson Bench without proof of lawful constitution lacks jurisdiction. Continued freezing or retention requires a reasoned, property-specific finding that identified assets are involved in money-laundering, supported by a nexus to criminal activity. General satisfaction that restraint is needed for adjudication is insufficient, and an appellate body cannot retrospectively supply the omitted original finding. Gross turnover, foreign remittances, or bank-account ownership alone do not establish proceeds of crime without a predicate offence and asset-specific justification.

Article 21 protects undertrials from pre-trial detention becoming punitive because of prolonged delay. The restrictive bail conditions under section 45 of the Prevention of Money Laundering Act may be relaxed where continued custody unjustifiably impairs personal liberty. Conditional bail was considered appropriate where incarceration had exceeded a year, bail had been granted in the scheduled offences, proceedings remained at the pre-cognizance stage, documentary material was already held by the Enforcement Directorate, and early trial completion was unlikely. This relief does not determine the merits of the money-laundering allegations.

Anticipatory bail under the Prevention of Money Laundering Act engages the statutory twin conditions governing bail in money-laundering offences. Money-laundering proceedings operate independently of predicate offences for this purpose. The legal focus is the interaction between anticipatory bail, the twin conditions, and the separate treatment of predicate and money-laundering proceedings under the Act.

The Insolvency and Bankruptcy Code, 2016 overrides inconsistent provisions of the Electricity Act, 2003 through its statutory overriding clause, notwithstanding the Electricity Act's non obstante provisions. Pre-CIRP parallel operation charge demands constitute liabilities arising before commencement of the corporate insolvency resolution process. Where an approved resolution plan expressly extinguishes pre-CIRP debts and related pending proceedings, those electricity-charge outstandings stand extinguished and cannot survive the plan.

Termination of the Corporate Insolvency Resolution Process granted the relief sought in relation to that process. As the termination itself resolved the relevant grievance, it did not provide a basis to challenge the NCLAT order before the Supreme Court. The NCLAT order terminating the CIRP was therefore not open to challenge on that stated ground.

Time-extension charges imposed under a lease and subsequent policy for delayed completion of housing projects were penal in nature, intended to deter the defaulting developer and ensure timely construction. Where the developer entered insolvency, homebuyers financed continued construction and the successful resolution applicant undertook implementation of the approved resolution plan. Treating charges arising from the corporate debtor's past default as Corporate Insolvency Resolution Process costs would penalise parties not responsible for the delay, undermine the lease's developmental purpose and obstruct project completion. In the stated circumstances, such penalty charges, including claims beyond three years, cannot be imposed on the resolution applicant or homebuyers.

Section 466 of the Companies Act, 1956 permits a permanent stay of winding-up where a revival proposal demonstrates public interest, commercial morality and bona fides. A scheme settling creditor and workmen dues, supported by secured creditors, shareholders and workmen, may satisfy those requirements even if it redevelops company land rather than resumes an unviable business. Objections concerning claim quantification, dividends, security and loans remain matters for claim adjudication and need not defeat revival. Changing the company's objects from textile operations to real-estate development is not prohibited where revival of the original business is commercially unviable. Negotiated workmen benefits materially support public-interest and commercial-morality assessment.

Writ jurisdiction should not be exercised against an order for provisional release of imported goods where an independent statutory appeal is available. The statutory appellate remedy remains effective unless exceptional circumstances justify bypassing it. Pendency and stay of an appeal concerning an earlier adjudication involving similar goods do not remove or displace the separate appeal available against the provisional-release order. Writ relief was therefore declined, requiring recourse to the prescribed appellate mechanism.

Release of seized goods under Section 110(2) is unavailable where a show-cause notice under Section 124(a) is issued within a validly extended statutory period. The six-month period may be extended under the proviso before its expiry; return is required only if no notice is issued within the original or validly extended period. As the extension preceded expiry of the initial period and the notice was issued before expiry of the extension, release of the detained gold was not warranted. Challenges concerning the extension, waiver and evidentiary status of statements remain for statutory adjudication.

Article 226 writ jurisdiction against a customs adjudication order remains exceptional where an effective statutory appeal under the Customs Act is available. Participation in adjudication, including acknowledgement of an oral show cause notice and waiver of written notice and personal hearing, may undermine claims that the process was invalid. Allegations of coercion, statement validity, procedural compliance and service of the order involve disputed facts ordinarily requiring determination by the appellate authority. Statutory deeming provisions concerning dispatch by speed post may also be relevant to service and limitation. Substantial delay, without exceptional circumstances, does not justify bypassing the statutory appellate remedy.

Customs seizure safeguards under Sections 110(2) and 124 operate on the applicable factual and procedural record; they do not justify unconditional return of detained jewellery where customs liability and baggage treatment remain disputed. Article 226 relief is discretionary and may be refused for unexplained delay, suppression of material facts, and factual disputes requiring statutory adjudication. A contemporaneous Section 108 statement recording non-declaration, acceptance of appraisement, and waiver of written notice and personal hearing materially affects the claim. Article 300A does not require release while lawful customs proceedings continue. Appraisement and consequential proceedings must therefore be completed under the Customs Act.

Reliance on unverified AI-generated material falsely presented as judicial precedent undermines the integrity of customs adjudication. AI may assist research but cannot replace an adjudicating officer's responsibility to independently verify any authority before relying on it. Customs penalty orders founded on non-existent, falsely cited, or hallucinated AI-generated precedents are unsustainable. Such matters require fresh adjudication by a different officer of equivalent rank.