De novo adjudication must independently reconcile relevant facts, figures and evidence, verify sales-tax material, and consider the assessee's explanation as required by remand directions. Mechanical adoption of findings from an earlier order that was set aside, without addressing evidence, submissions or cited authorities, fails to show application of mind. Quasi-judicial determinations affecting rights must provide cogent reasons and comply with natural justice and the remand mandate. The de novo order was therefore unsustainable and required fresh adjudication in accordance with the earlier directions.

Works-contract services supplied to a Government authority for road construction and river-ghat protection qualified for service-tax exemption. Repair services supplied to a subsidiary company did not qualify because it was not established as a governmental authority; reverse-charge payment by the recipient covered only its share, leaving the provider liable for the balance. Failure to register, file returns and timely pay tax attracts civil penalties without proof of mens rea. Interest follows the surviving tax liability; the tax-linked penalty was correspondingly reduced, while registration and return-default penalties remained operative.

Service-tax demand based solely on PAN-level 26AS receipts cannot be sustained against one registration where the same receipts have been wholly attributed to multiple registrations under the same PAN. Independent processing of identical differential receipts against three registrations, coupled with prior dropping of equivalent demands in two matters, undermines the proposed demand. Absent correlation between the receipts and activities from the registered premises, or verification that they represented undeclared taxable services, the tax demand, consequential interest and penalties are unsustainable.

Pre-1 July 2012 service-tax liability required identification of the applicable specified taxable service; demands without an established taxable category do not survive. From 1 July 2012, consideration for activities performed by one person for another is taxable, subject to the normal limitation period. Revenue neutrality arising from available reverse-charge credit negates mala fide intent and prevents use of the extended limitation period. Payments to foreign service providers constitute consideration rather than reimbursable expenses where received services are established. Cum-tax valuation is unavailable where service tax is payable by the recipient under reverse charge. Penalties for suppression and return-related contraventions do not survive where mala fide intent is absent and returns were filed.

Separately priced ocean freight, port charges and handling services retain their distinct tax classifications and cannot be aggregated as Cargo Handling Service merely because they support coal movement. Port-area services fall within the separate port-service classification, while pre-01.09.2009 coastal ocean carriage under principal-to-principal charter arrangements was not Business Auxiliary Service; the specific waterways levy applied only from that date. Extended limitation for waterways tax is unavailable where transactions were disclosed, earlier notices covered substantially the same activities, the dispute concerns classification, and reverse-charge credit created revenue neutrality. Consequently, the associated tax demands, interest and penalties fail.

Notification-based service-tax exemption requires the claimant to establish eligibility with supporting contractual evidence. Where work orders, agreements and tender documents are not produced to correlate receipts with allegedly exempt handling and transportation services, the exemption claim remains unsubstantiated. Unanswered assertions concerning contractual rates and taxes further weaken the challenge to the demand. Extraordinary writ jurisdiction does not ordinarily warrant interference in those circumstances, particularly where a statutory appellate remedy is available; the taxpayer may pursue that remedy in accordance with law.

Section 73(4B)(b) of the Finance Act, 1994 requires expeditious adjudication in extended-period matters. Its qualification, "where it is possible to do so", permits only a reasonable and legally justifiable departure from the prescribed timeframe; it does not allow indefinite delay. An unexplained, inordinate delay in issuing an adjudication order is arbitrary and violates this requirement. Although an appellate remedy ordinarily limits writ intervention, writ jurisdiction remains available where delayed adjudication raises a foundational legal issue and offends Article 14.

Service-tax treatment of construction services for Traffic and Transit Management Centers concerns whether a transport-terminal exclusion applies under the taxable-service definition. Relevant considerations include whether construction of bus terminals is recognised as a separate activity and whether the extended period of limitation may be invoked. Transport-terminal classification, recognition of the relevant construction activity, and limitation requirements govern the service-tax analysis.

Provisional attachment under the Prevention of Money Laundering Act, 2002 requires the authorised officer to record written reasons to believe, based on material in possession, that proceeds of crime exist and require protection from dealings that could frustrate confiscation. Charge-sheet and investigation material alleging fraudulent recognition-related conduct, record manipulation, unlawful student collections and grant-fund misappropriation established the required nexus. Buildings and infrastructure constructed using Government grants, capitation fees, admission fees and unrefunded caution deposits derived from scheduled offences may be attached as the value of proceeds of crime. Commercial failure of the institution does not negate money laundering where criminally derived property is projected as untainted.

Proceeds-of-crime classification requires a demonstrated nexus between property or funds and the alleged scheduled offence. A coal-block allocation letter, without revenue from mining or evidence connecting share application money to criminal activity, cannot establish that nexus. Investment statements attributing funding to business prospects did not show inducement through the allocation, while the alternative allegation that investors were entities controlled by the directors undermined the theory of deceptive investment. In the absence of a predicate offence or fraud evidence concerning the investment flow, the share application money and attached properties were not shown to be proceeds of crime; attachment confirmation was unsustainable.

Section 6(5)(b) of the Prevention of Money Laundering Act permits a one- or two-member Adjudicating Authority bench, including a single Finance Member, to determine attachment proceedings under Section 8. Statutory appeals on facts and law provide the applicable adjudicatory safeguard. A provisional attachment requires recorded reasons to believe that non-attachment may frustrate proceedings; challenges to the factual basis of that satisfaction are generally to be pursued through the statutory appellate process rather than writ review. The Adjudicating Authority must independently assess whether property represents proceeds of crime. Property acquired before registration of the predicate offence may be attached if directly or indirectly linked to proceeds of crime.

Bail in alleged money-laundering proceedings was considered appropriate where the accused had remained in custody for more than one and a half years and the nature of the charge did not require continued incarceration. Release was made subject to terms and conditions fixed by the Trial Court.

An arbitration clause does not displace the statutory insolvency remedy where the requirements of debt and default are met. A settlement claim arising from disputes over the supply of raw cotton remains operational debt, and the creditor need not have directly supplied goods or services to qualify as an operational creditor. An alleged contractual damages claim bars a Section 9 application only if it constitutes a genuine, pre-existing dispute supported by material. A belated and unpursued damages assertion raised in response to a demand notice does not meet that standard. Insolvency resolution therefore remains available for settled operational debt connected with the supply of goods.

Financial debt under the Insolvency and Bankruptcy Code requires reliable material showing an independent, legally enforceable liability of the corporate debtor. Where payment was made to another entity, no banking trail linked funds to the corporate debtor, and ledger and balance-sheet entries reflected reversible internal adjustments among commonly managed entities, the claim does not establish such debt. A memorandum contemplating further payment and a definitive agreement does not by itself create a concluded commercial arrangement. The resolution professional must verify and update claims, and may revisit provisional admission during verification without adjudicating disputed rights. Rejection of the claim is justified where no independent financial debt is proved.

Correction of the record was confined to entering counsel's appearance for Respondent No. 2. Reliance on a cited decision concerning photocopies was not material because the earlier dismissal rested on an undisputed default and the default record filed with the Information Utility under the Insolvency and Bankruptcy Code. The appearance entry was directed to be corrected, while the request for further speaking-to-the-minutes changes was disposed of without costs.

Insolvency moratorium under the IBC bars recovery-oriented provident fund inquiries against a corporate debtor during CIRP, even where statutory dues may otherwise be assessed. Once a provident fund claim has been dealt with under an approved and unchallenged resolution plan, pre-approval liabilities not preserved by that plan are extinguished and cannot be reassessed or recovered. Following a resolution plan involving a change in management or control, statutory immunity protects the restructured corporate debtor and its assets from recovery, damages, interest and prosecution relating to pre-CIRP defaults attributable to the former management. Consequently, assessed provident fund liabilities and coercive measures for such defaults cannot be enforced against the restructured entity.

Under the applicable F&O regulatory framework, a professional clearing member's constituent was the trading member, and client-margin restrictions did not require the clearing member to verify each trading member client's debit or credit position before collateral liquidation. Real-time client-level reporting and segregation were introduced only later. Stock exchange, clearing corporation and committee powers did not extend to monetary restitution through restoration or value-blocking of lawfully liquidated securities; disgorgement authority lay separately with SEBI. Clients whose losses arose from a trading member's default or unauthorised assured-return arrangements could not recover from the clearing member absent privity or breach of a regulatory duty. Remedies remained against the relevant trading member, subject to lawful exceptions.

Forensic audit in foreign-award enforcement may be necessary where substantial reductions in promoter shareholding, inconsistent explanations of pledges and share sales, regulatory disclosures, and interconnected corporate transactions indicate possible dissipation of assets. Separate corporate personality does not preclude inquiry where judgment debtors control the promoter-holding structure and listed company and a prima facie nexus exists with frustration of execution. The audit scope includes tracing shares and sale proceeds, reviewing bank security and fund flows, and testing compliance with securities-law requirements and judicial directions. Investigative expert evidence does not itself determine civil, contempt, or restitutionary liability.

Contempt jurisdiction arises only from a clear, solemn, unambiguous and firm undertaking intended to be acted upon by the court; a statement that an entity had then decided not to proceed with an acquisition is merely clarificatory and does not support contempt. A foreign money decree from a superior court in a reciprocating territory is prima facie executable, and protective security may be required where corporate restructuring and related transactions create a genuine apprehension of asset dissipation. Such interim protection preserves effective execution without determining whether the corporate veil may be lifted or assets of related entities reached, which remains for the executing commercial courts.

Penalty under Section 114(i) of the Customs Act was not imposable on an authorised courier where prohibited Red Sander Logs were concealed in an export consignment declared as piano parts. The courier had obtained and processed the consignor's identity and accompanying documents, submitted the shipment for Customs examination, and met the due-diligence requirement under Regulation 12 of the Courier Imports and Exports Regulations, 2010. As Regulation 6 barred opening export packages in the Customs area without the proper officer's permission, failure to physically inspect the contents could not establish liability. In the absence of evidence of knowledge or abetment, the penalty was set aside.