CENVAT credit is available for services used to maintain a fly ash pond and to load, unload and transport fly ash from a power plant to a cement manufacturer's factory. Fly ash constitutes an input or raw material for cement manufacture, and the services facilitate its extraction, handling, procurement and inward movement. The definition of input service covers services used directly or indirectly in or in relation to manufacture, including procurement and inward transportation of inputs, without requiring that services be physically received within factory premises. Denial of credit solely because the services were performed outside the factory is therefore not sustainable.

Dilution of duty-paid styrene butadiene latex with water, addition of preservative, branding and repacking do not constitute manufacture unless the process creates a new article with a distinct name, character or use. Where the input and processed products retain the same chemical characteristics and comparable uses, no fresh central excise duty arises. The Department also cannot adopt a contrary position for later periods where unchallenged Tribunal decisions on the identical process and facts have attained finality, absent any material distinction or new evidence. Accordingly, the excise-duty proceedings were dropped and the prior settled position was maintained.

The Supreme Court found no grounds to interfere with the CESTAT, Chandigarh orders in the central excise dispute and dismissed the civil appeals. Pending applications were also disposed of.

Service-tax exemptions for original works supplied to government bodies depend on the prescribed non-commercial-use, recipient and temporal conditions. Construction of market infrastructure under a government scheme requires evidence that its use is predominantly non-commercial; fee-based use without proof of statutory public-function status or treasury remittance does not establish that condition. Government-approved residential housing projects may qualify where work orders show supply to the relevant government housing authority. Entry 14A applies only to original-work contracts entered into before the specified cut-off date, making contract date determinative for school-construction exemption.

Service tax on the Government's grant of natural-resource rights is determined by the date the mining right was assigned, rather than by the date periodic royalty or related payments are made. Where a mining lease was executed before 1 April 2016, when grants of natural resources became taxable, the later levy does not apply to royalty, District Mineral Foundation and National Mineral Exploration Trust contributions, or user fees paid from 1 April 2016 to 30 June 2017 under that lease. On this analysis, the related tax demand, interest and penalties are unsustainable.

Service-tax liability under the positive-list regime required identification of the particular taxable service, its recipient and the consideration attributable to that service. A demand based only on discrepancies between income-tax returns, ST-3 returns and unbilled revenue, without specifying the allegedly rendered service or explaining why the amounts were taxable, lacked the necessary factual foundation. Registration under multiple service categories did not remove the requirement to identify the specific service forming the basis of liability. The show cause notice was therefore vague and incapable of sustaining the service-tax demand.

Construction of residential complex service was treated as taxable only from 1 July 2010; therefore, a service-tax demand for the earlier period was unsustainable. For the taxable period, documentary evidence showed that tax had been discharged on the relevant consideration. Extended limitation could not be invoked because the assessee was registered, filed ST-3 returns and paid tax on its receipts, circumstances that negated suppression. The demand, interest and penalty were consequently unsustainable, although voluntary payments made without protest were not refundable.

Indivisible turnkey ATM supply, installation and commissioning contracts executed before 1 June 2007 could not be split to levy service tax on a notional commissioning or installation component. Where the contract provided a single composite consideration and installation and commissioning were integral to delivering functional ATMs, the then-applicable charging and valuation provisions did not permit segregation of an embedded service element. A valuation exercise could not create a taxable event or support attribution of part of the consideration to taxable services. The subsequent works-contract entry and valuation mechanism confirmed the earlier framework did not cover such indivisible composite contracts.

Article 226 judicial review, read with Section 482 CrPC, may be invoked to examine the legality of an Enforcement Case Information Report (ECIR) and consequential proceedings under the Prevention of Money Laundering Act. An ECIR's character as an internal administrative record does not restrict constitutional review where it triggers coercive measures such as search, seizure, attachment, arrest or prosecution. The ECIR and resulting action form a single cause of action. Where the predicate offence has ceased following acceptance of a closure report, the continued legality of money-laundering action founded on that offence is open to judicial scrutiny. The preliminary objection to writ maintainability is rejected.

Provisional attachment orders are described as raising questions about the Enforcement Directorate's authority and jurisdiction to attach property, the requirement of a "reason to believe" that property constitutes proceeds of crime involved in money laundering, the effect of withdrawing concessions made by counsel, and the meaning of "proceeds of crime." The text further records that delay was condoned and the special leave petitions were dismissed without interference with the impugned judgments and orders.

Replacement of an interim resolution professional or resolution professional is governed by the Committee of Creditors' statutory voting process under the Insolvency and Bankruptcy Code. Admission of homebuyers' claims affecting other creditors' voting shares, or admission of a claim below the amount asserted, does not alone demonstrate lack of integrity or justify removal. Where the professional entity's appointment and fees have Committee approval, and the relevant contract resolution remains unimplemented, creditor-group conflict does not displace majority class support for the professional. Tribunal intervention in replacement decisions is confined to exceptional circumstances, which were not established; challenges to a later appointment may be pursued before the appropriate forum.

Section 60(5) of the Insolvency and Bankruptcy Code confers broad jurisdiction over questions connected with an insolvency resolution process. Recovery of electric vehicles owned by one corporate debtor and leased to another directly concerned preservation and control of the owner's assets. Suspended directors of the lessee corporate debtor had acknowledged responsibility to provide available information and assistance regarding those vehicles. A direction requiring their cooperation to identify and recover the leased assets was therefore stated to fall within the Adjudicating Authority's jurisdiction.

An unpaid security-service claim may be submitted in the company's ongoing Corporate Insolvency Resolution Process before the NCLT. The service provider may join the insolvency proceedings and place its claim for unpaid security-service charges before that forum for consideration.

Pelargonium sidoides root extract with Maltodextrin is classifiable as an other vegetable extract under Customs Tariff Item 1302 19 19 where processing consists of hydro-ethanolic extraction, filtration and solvent removal without purification or high-refinement processes. Maltodextrin functions as an inert carrier and does not create a medicinal mixture, while bulk import and intended downstream pharmaceutical use do not determine classification. The product consequently falls within the relevant exemption entry under Serial No. 37 of Notification No. 45/2025-Customs, subject to fulfilment of notification conditions and assessment-stage verification. The earlier classification premise of concentration was corrected as unsupported by the factual record.

Unauthenticated foreign customs intelligence and electronic printouts, without verification of origin certificates or independent corroboration, cannot establish misdeclaration of imported goods' country of origin; origin-based confiscation and related demands were therefore set aside. Goods already examined and cleared for home consumption could not later be confiscated for alleged phytosanitary non-compliance, while seized consignments lacking mandatory phytosanitary certificates remained confiscable, subject to a redemption option and production of the required certificate. Penalties under Section 112 of the Customs Act could not be imposed because the show cause notices had not proposed them, and those penalties were set aside.

Duty demand against an importer using transferable DFIA licences cannot rest solely on alleged fraudulent procurement by the exporter where those allegations remain unestablished and the licences have not been cancelled. A bona fide purchaser of transferable licences cannot be treated as involved in a fraudulent import method merely because of alleged irregularities in the exporter's licence procurement. As no sustainable charge existed on the merits, invoking the extended limitation period was also unjustified. The demand was therefore unsustainable on both merits and limitation.

Plant-related items, including parts, spares and accessories used for manufacturing-facility modernisation and expansion, fall within the broad definition of capital goods under Notification No. 104/2009-Cus. where they have the required manufacturing nexus. The notification covers plant, machinery, equipment and accessories required directly or indirectly for manufacture, including replacement, modernisation, technological upgradation and expansion. The restriction on components, spares and parts applies only where they relate to capital goods imported earlier; it does not limit imports of capital goods, including accessories, not previously imported. Accordingly, the described imports qualify for the exemption and the duty demand, interest and penalty are unsustainable.

Declared customs transaction values cannot be rejected on third-party investigation material, indicative market data or suspicion without cogent importer-specific evidence of undervaluation. The Revenue must establish a business nexus, parallel invoices, extra consideration, clandestine remittance or comparable incriminating circumstances; similarities with other importers' prices are insufficient. Transaction value remains the primary basis, and enhanced valuation requires a reliable foundation and proper sequential consideration of valuation methods before using the residual method. Contemporaneous imports and the reliability and comparability of price-publication data must be addressed. Operative comparable Tribunal rulings and final appellate assessments concerning the same imports reinforce the requirement of judicial discipline and support rejection of unsustainable valuation enhancements and consequential liabilities.

Export duty exemption for iron ore fines depended on Fe content being below the applicable threshold. Contemporaneous CRCL, Visakhapatnam testing of Customs-drawn representative samples showed Fe content below 58%, corroborated by load-port and discharge-port reports, contractual quality adjustments, and realised export proceeds. A re-test requires objective and legally sustainable grounds and cannot arbitrarily displace reliable contemporaneous evidence. The later CRCL, New Delhi re-test, reported over a year after export, was unreliable because prolonged storage and moisture loss could affect dry-basis Fe determination, and no scientific or procedural defect in the earlier evidence was established. The belated re-test could not support denial of exemption or levy of export duty and cess.

Declared transaction value cannot be rejected on suspicion, unverified third-party import data, uncorroborated statements, or electronic records lacking the required statutory certification and proof of integrity. Uniform loading is unsustainable where the alleged comparable imports are not shown to match the goods in grade, quality, quantity, commercial level, or time. Extended limitation for customs duty recovery requires evidence of fraud, collusion, wilful misstatement, or deliberate suppression with intent to evade duty; prior disclosure and assessment of import details defeat that basis. Where the duty demand fails and no link to a customs offence is established, seized currency and investigation deposits must be released or refunded with applicable interest.