Furnace Oil and Light Diesel Oil are distinct commodities where their commercial identity, technical characteristics and functional use materially differ. A tariff rate prescribed for the specific entry of Light Diesel Oil cannot be extended to Furnace Oil merely because both products are used as fuel. Relevant distinctions include composition, viscosity, distillation range, sulphur content, sedimentation, ash and water content, and end-use. Classification of Furnace Oil as Light Diesel Oil is therefore unsustainable without a specific entry covering Furnace Oil, requiring fresh classification on that basis. Constitutional objections to statutory pre-deposit requirements were left for the appellate mechanism, which could determine the classification dispute on merits.

Section 9D of the Central Excise Act requires investigation statements to be admitted through the prescribed procedure, including examination of the maker, a reasoned finding on admissibility, and cross-examination. Under Rule 14 of the CENVAT Credit Rules, recovery is confined to credit wrongly taken or utilised. Allegations that goods were not received cannot rest on untested third-party statements or general findings unconnected to the assessee. Where supplier-side manipulation is not linked to the assessee and stock verification or other corroborative evidence is absent, denial of CENVAT credit, interest and penalty is unsustainable.

Cable-laying under or alongside roads does not constitute erection, commissioning and installation service where it does not result in erection, installation or commissioning of specified plant, machinery, equipment or structures. Service-tax demands require a clear basis, taxable value, and year-wise and category-wise break-up; demands lacking these particulars are vague and unsustainable. The extended limitation period does not apply where transactions were recorded in regular books, routed through banking channels, disclosed in financial statements, and non-payment arose from a bona fide, interpretational understanding of taxability. In the absence of suppression, fraud, concealment, mala fides, or misstatement, fiscal liabilities based on such demands cannot be sustained.

Suppression of taxable receipts, understatement in ST-3 returns, non-reporting of a second unregistered firm's receipts, and unsupported threshold-exemption claims permit invocation of the extended limitation period under the service-tax regime. Service-tax liability may consequently be determined on actual taxable receipts. Cum-tax adjustment requires reliable evidence that tax was not separately collected; incomplete sample invoices covering only a negligible portion of receipts do not establish entitlement. Unutilised Cenvat credit must be timely availed through prescribed returns and supported by evidence; a claim raised at the appellate stage without fresh supporting material is not allowable. Interest and penalties remain consequentially sustainable.

Rule 3A(2) requires a claimant receiving restored property to execute a bond undertaking to produce that property before the Special Court when required. It does not require a surety to furnish a solvency certificate. Because the State Government had discontinued issuance of solvency certificates, imposing that condition was incapable of compliance and unduly onerous. The solvency-certificate condition was set aside; the claimant and surety must execute the bond fixed by the Special Court, and the claimant must undertake to refund the amount if required.

Section 17 of the Prevention of Money Laundering Act, 2002 permits search and seizure where an authorised officer possesses material and records reasons to believe that money-laundering, proceeds of crime, or relevant property or records are involved. Acquisition of land already vested in a local body, void cancellation of its gift deed, same-day conveyances, valuation disparity, and receipt of acquisition compensation supported that statutory threshold. Section 19 permits arrest on recorded reasons based on material indicating guilt and requires communication of arrest grounds. Recorded material concerning the cancellation, conveyance, compensation, partial refund, retained amount, and alleged concealment, together with same-day supply of arrest grounds, satisfied these safeguards.

Special leave proceedings under the Prevention of Money Laundering Act challenging a High Court judgment were dismissed without interference. The High Court judgment consequently remains undisturbed at this stage. The trial court was encouraged to complete the pending trial as early as possible in accordance with law, and pending applications were disposed of.

Limitation for prosecuting failure to transfer unpaid or unclaimed dividends to the Investor Education and Protection Fund begins when the seven-year transfer obligation expires. Where the alleged offence is punishable only with a fine, the six-month period under Section 468 applied, rendering a complaint instituted in 2006 time-barred. Criminal proceedings that had remained pending since 2006 without substantial progress were also unwarranted, as their continuation would not serve the ends of justice. The dividend-transfer prosecution could therefore not be sustained.

Bail pending investigation into alleged customs and anti-dumping duty evasion is considered where the inquiry primarily rests on documentary evidence, including country-of-origin certificates, correspondence, bills of lading and records requiring cross-border verification. Questions concerning the genuineness and legal effect of original and revised certificates may be pursued through the accused's attendance and production of records. Continued custody is not necessary where the risk of evidence tampering can be adequately addressed through appropriate bail safeguards after prior investigative remands and substantial detention.

Battery-integrated rear or back cover assemblies for tablet PCs fall under the lithium-ion accumulator classification rather than the residual heading for parts of automatic data processing machines. Heading 8473 excludes covers and similar articles, while Section XVI Note 2(a) requires goods specifically covered by a Chapter 84 or 85 heading to be classified there before a general parts heading is considered. Chapter 85 Note 3 includes accumulators presented with ancillary operational or protective components, including protective housing. Thermal-management, securing, waterproofing and housing elements have the required functional nexus with the battery.

Oven-roasted almonds and pistachios fall under CTI 2008 19 91 as other roasted nuts and seeds, because Heading 2008 covers nuts otherwise prepared or preserved and includes dry-roasted, oil-roasted and fat-roasted nuts. Oven-roasted cashew nuts fall under the specific CTI 2008 19 10 entry for roasted, salted, or roasted and salted cashews; the product-specific entry prevails over the general roasted-nuts entry. Preferential-duty treatment for these goods depends on satisfying origin requirements and prescribed documentary conditions, subject to verification by jurisdictional customs authorities at importation.

Cross-examination under the Customs Brokers Licensing Regulations, 2018 is required where penalty proceedings rely on witness statements. If a Customs Broker specifically requests cross-examination and it cannot be provided, those statements cannot be relied upon. Failure to examine the person alleged to have entrusted the clearance work, coupled with contradictory evidence from the proprietor and F-card holder, materially undermines the inquiry. Denial of the requested opportunity to test relied-upon evidence renders the penalty proceedings against the Customs Broker unsustainable.

Imported fish meal cannot be treated as finished goods where technical reports record coarse powder with scales and bone-like fibres, and BIS specifications do not conclusively establish finished or semi-finished status. An adverse inference for non-production of laboratory records is unsustainable where those records were seized and requested by the importer. Declared transaction value requires reliable evidence of consideration exceeding the invoice value before enhancement. Residual valuation cannot be used after bypassing the sequential valuation framework: available contemporaneous imports must be identified, assessed for comparability, and excluded only for recorded reasons. Without those elements, consequential duty, interest, confiscation, redemption fine and penalties lack a sustainable basis.

Penalty for attempted export of prohibited red sander logs under Section 114(i) of the Customs Act cannot rest solely on retracted statements or statements of co-accused. Although a statement recorded under Section 108 is admissible, involvement in a prohibited export requires independent, admissible and tangible corroborative evidence where the statement has been retracted. Failure to address a timely retraction, coupled with the setting aside of penalty against a person allegedly linked to the logistical arrangement, weakens the evidentiary basis for penalising the alleged facilitator. In the absence of corroboration, the penalty was unsustainable and set aside.

Fe content of iron ore fines exported in moist condition before 01.05.2022 is determined on a Wet Metric Ton basis, after accounting for moisture and other impurities, for tariff classification and export-duty assessment. The later supplementary note requiring Dry Metric Ton computation for Heading 2601 supports the position that this method did not apply to earlier exports. A legal challenge to classification or duty liability may be raised in appeal where it relies on existing test reports and concerns the correct legal assessment. Acceptance of the original assessment without protest does not validate an assessment contrary to the applicable tariff, binding precedent or Board circular, permitting consequential reclassification and reassessment.

Written acceptance of an enhanced assessable value under Section 17(5) waives only the requirement for a speaking order and does not extinguish the statutory appeal right under Section 128. Rejection of declared transaction value must comply with Section 14 and Rule 12(2), including written communication of grounds creating reasonable doubt. Acceptance letters that omit contemporaneous-import data or comparable particulars, particularly where enhanced-value clearance is under protest, do not establish unconditional waiver of a valuation challenge. Estoppel cannot defeat statutory rights in taxation matters. Appeals cannot be rejected solely because the importer accepted enhancement.

Customs exemptions for gold dore bars require strict proof of every licence-linked and notification-specific condition. Under the concessional-duty framework, prescribed weight and purity limits, together with the mining company's packing list and assay certificate, must be satisfied; supplier-issued documents and purity above the permitted limit do not establish eligibility. Failure of these conditions renders the exemption unavailable and may expose the goods to treatment as prohibited goods, confiscation, duty recovery and penalties. A simultaneous nil-duty claim based on country of origin also requires independent fulfilment of its conditions; certificates unsupported by authentic material are insufficient.

Advance Authorisation holders supplying goods to SEZ units may discharge export obligations through prescribed corroborative evidence when a Bill of Export is unavailable. Acceptable material may include an attested ARE-1 form, proof that the SEZ recipient received the supplies, or proof of payment by the SEZ unit, subject to stipulated conditions. The competent authority must assess whether the documents produced satisfy the applicable policy instructions. A Bill of Export is therefore not the sole acceptable proof of export-obligation fulfilment where subsequent circulars permit such alternative evidence.

Departmental exoneration does not automatically require termination of criminal proceedings because departmental and criminal processes are independent, rely on their respective evidence, and apply different standards of proof. At the discharge stage, the inquiry is whether prosecution material discloses the ingredients of the alleged offences or creates strong suspicion requiring trial. Prima facie material relating to conspiracy, illegal gratification, facilitation of gold smuggling, and the accused persons' alleged roles supports continuation of the prosecution. Proof of demand and the evidentiary weight of the material remain matters for trial.

Timely requests for duty quantification can preserve the right to redeem confiscated goods where Customs authorities quantify redemption fine and penalty but fail to quantify the applicable duty. Although unexercised redemption options ordinarily result in absolute confiscation after the prescribed period under the Customs Act, delay cannot be attributed solely to the person seeking redemption when the required duty figure was requested within time and remains unprovided. Redemption remains available on payment of the quantified duty, redemption fine, penalty, and applicable interest.