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.

Limitation for an Official Liquidator's claim under Section 446(2) is governed by Article 137. The right to apply accrues on the winding-up order, provided the underlying claim was legally enforceable when winding-up proceedings commenced. Section 458A excludes the period between commencement of winding-up proceedings and the winding-up order, as well as one year immediately following that order. The Liquidator therefore receives the three-year Article 137 period together with the additional one-year exclusion. A claim filed within four years of the winding-up order falls within limitation, defeating a preliminary limitation objection.

Customs valuation must disclose the method and basis used to redetermine the value of imported goods, because valuation underpins duty, interest, fine and penalties. Where that basis is absent, the valuation and resulting liabilities require fresh determination after a reasonable opportunity of hearing and a speaking decision. Permission to re-export goods imported contrary to statutory prohibition does not remove their confiscability or preclude redemption fine. Confiscation and redemption operate separately: prohibited goods remain liable to confiscation, and re-export may be permitted after redemption within the statutory framework.

Customs duty refund claims filed within the prescribed period remain timely where later submissions merely cure perceived documentary deficiencies. A chartered accountant's certificate, importer's self-declaration, import documents and sales-invoice particulars may establish that the duty burden was not passed on, satisfying the unjust-enrichment requirement. Revised certification or document abstracts cannot be insisted upon unless required under the applicable refund framework, particularly where the requested material has subsequently been furnished. The claim must be processed from the date of its original timely filing, and rejection solely because deficiency-curing documents were submitted later is unsustainable.

Preferential tariff benefit under the AIFTA origin regime cannot be denied solely on delayed, partial or inadequately authenticated verification of Certificates of Origin. Rules 7(c) and 7(d) require timely return of the certificate, notice of grounds for non-acceptance, and detailed clarification from the issuing authority; alleged fraud does not displace those safeguards. Uncorroborated signature discrepancies, unavailable test reports, and unverifiable foreign material do not conclusively establish fraudulent origin declarations. Extended limitation for customs duty recovery requires credible proof of the importer's collusion, wilful misstatement or suppression. An importer is not liable for defects in a foreign-issued certificate without evidence of conscious knowledge, active involvement, or procurement of falsification.

Interest is payable on amounts voluntarily deposited during investigation when retained by Revenue and later refunded. The compensatory principle applies from the actual date of deposit until refund, even where the statutory refund-interest provision does not independently confer entitlement. Established precedent supports interest at 12% per annum for the period of Revenue's retention, ensuring compensation for deprivation of the depositor's funds.

National Litigation Policy exceptions for classification issues permit, but do not compel, the Revenue to pursue an appeal falling within an exception to the monetary-limit policy. Where the Tribunal sought confirmation of the policy's applicability, the Departmental Representative did not oppose it, and the later rejection of restoration remained unchallenged, the Revenue could not subsequently invoke those exceptions to require a decision on merits. The substantial question of law was resolved against the Revenue, leaving the appeal closed under the policy.

Section 138B of the Customs Act does not govern evidentiary procedure in Customs Broker licence-revocation inquiries, which are not prosecution proceedings. Regulation 17 of the Customs Brokers Licensing Regulations, 2018 requires relevant oral evidence to be taken during inquiry and gives the Customs Broker a right to cross-examine persons examined in support of the charges. Reliance on investigation-stage oral statements without producing the witnesses denies that statutory opportunity. Such denial is a curable procedural irregularity: fresh adjudication may proceed after affording cross-examination and does not amount to allowing the Department to fill a lacuna.

Four opportunities for personal hearing, including an advance-notified virtual hearing, satisfied the requirements of natural justice in revisional proceedings. A claim that counsel attended but the authority did not was unsupported and contradicted by the contemporaneous hearing sheet recording non-appearance. No further hearing was sought before the reserved order was pronounced. An incorrect hearing time recorded in the order was treated as an isolated clerical error, clarified by the hearing sheet, and did not establish procedural unfairness.