Supply of Tangible Goods Service applies where an aircraft lessor retains legal possession and effective control, including operational responsibility, use rights when the lessee is not using the aircraft, trip-wise redelivery, and termination rights. Taxable value cannot include unrelated "other collections" absent an alleged and established nexus with the aircraft lease. Receipts already subjected to a demand against a related concern cannot be taxed again on the same transaction. The extended limitation period requires a fresh positive act of suppression or intent to evade tax; absent these elements, only the normal period applies. Penalties for fraud, collusion, wilful misstatement, or suppression are not sustainable where those elements are unproved and reasonable cause exists.

SEZ service-tax exemption under Notification No. 9/2009 applies to approved taxable services supplied for authorised operations of an SEZ unit, including services rendered by a subcontractor through a main contractor. A certificate issued in the main contractor's name may establish that the services were provided to an authorised person where the services were approved for the unit's authorised operations. Non-submission of Form A-1 does not defeat the exemption for periods before its introduction, and the requirement is procedural rather than a condition overriding substantive eligibility.

Towers and pre-fabricated buildings used in mobile telecommunication services qualify as goods and as inputs under Rule 2(k) of the CENVAT Credit Rules, 2004. Although they do not directly transmit signals, they are indispensable for the functioning and positioning of antennas and have a close, inseparable nexus with the provision of output telecommunication services. The phrase "used for providing any output service" extends beyond equipment that directly transmits signals. CENVAT credit is therefore admissible on these items.

Limited interim access to frozen funds may be permitted pending appeal to meet verified employee salary arrears and statutory liabilities of a holding company. Where the applicant has no employees or independent operations but received substantial funds from its holding company and prima facie owes it amounts, the balance of convenience can support essential payments. Requiring defaults in TDS and GST remittances is not justified when the Central Government benefits from those payments and safeguards can preserve the freezing action. Relief operates only after verification of salary details and statutory dues, followed by bank authorisation for legitimately payable amounts; appeal merits remain open.

Provisional attachment of property held by a company not accused of money laundering requires material showing that proceeds of crime were transferred to the company and used for acquisition, or that the asset is validly identifiable as equivalent-value property of a person involved in money laundering. Property acquired through a bank auction using documented loan funds and the company's own savings cannot be treated as proceeds of crime without a demonstrated money trail. Alleged control by the principal accused, based mainly on unsupported witness statements, does not establish the accused's title, use of layered proceeds, or an equivalent-value basis for attachment. The attachment was therefore unsustainable.

Production before an available Magistrate after court hours, followed by production before the Special Court within twenty-four hours, does not invalidate arrest or detention without resulting prejudice. Communication of arrest grounds is not prima facie deficient where the arrestee received them and surrounding circumstances indicate relatives knew of the arrest and grounds. Bail under the Prevention of Money-laundering Act requires satisfaction of the statutory threshold; prolonged custody alone does not justify release where prima facie material links the accused to proceeds of crime and risks of witness influence, evidence tampering, or flight persist.

An unsuccessful scheme proponent may withdraw after its proposed scheme is not accepted and the matter is remitted for fresh consideration. An earnest money deposit guarantee secures submission of the proponent's scheme; it does not, without a valid legal basis, oblige the proponent to continue formulating or pursuing a revised scheme acceptable to the committee of creditors or the Adjudicating Authority. Recovery of the guarantee for the liquidation estate is unsustainable where the proponent lawfully exercises its commercial choice to withdraw and no enforceable basis for forfeiture is established.

Committee of Creditors may reconsider and reject a resolution plan remitted for reconsideration where statutory and stakeholder claims must be addressed and the resolution applicant declines to revise the plan or accommodate additional claims. Unchallenged directions requiring such reconsideration attain finality. The Committee's commercial decision on plan acceptance, rejection or liquidation is non-justiciable before the Adjudicating Authority approves a resolution plan. The Insolvency and Bankruptcy Code permits the Committee to resolve for liquidation before that approval. Rejection of the proposed plan and non-interference with the Committee's decision were treated as valid.

Section 100(4) gives requisitioning members an additional, alternative right to call and hold an extraordinary general meeting if the Board fails to act on a valid requisition; it need not be exhausted before seeking relief under Section 98. Section 98 independently permits the Tribunal to direct a meeting only where convening or conducting it through ordinary mechanisms is reasonably impracticable. This exceptional jurisdiction must be exercised sparingly and requires concrete factual proof, not merely director disagreement or rejection of a requisition by a Board majority. In the absence of foundational evidence that shareholders could not convene the meeting, intervention under Section 98 is unavailable.

Customs valuation must ordinarily be based on the declared transaction value under Section 14(1). If the declared value is doubted, Rule 12 requires reasonable and cogent grounds, further inquiry where necessary, recorded reasons for rejection, communication of those grounds on request, and a reasonable hearing before value is determined under the applicable valuation rules. Reassessment under Section 17 must comply with this framework. An importer's written acceptance of an enhanced value, including to secure prompt clearance, neither waives the right to contest assessment nor removes the requirement to follow statutory valuation safeguards and natural justice. Enhancement based solely on consent is therefore legally unsustainable.

Rule 2(a) classifies incomplete goods as complete articles only when they have the essential character of the finished article. Electric ride-on toy consignments lacking functional components such as batteries and motors remain toy parts under CTH 95030091 rather than complete CKD/SKD toys. Adding locally procured essential components, job-worked components, assembly and testing produces a distinct finished toy and constitutes manufacture for concessional import-duty treatment under Notification No. 50/2017-Cus. The Toys (Quality Control) Order, 2020 applies to toys, or parts independently capable of being regarded as toys; non-functional individual imported parts fall outside its scope.

The one-year filing limit for refund of Special Additional Duty, introduced by Notification No. 93/2008-Customs amending Notification No. 102/2007-Customs, cannot bar a refund claim where binding jurisdictional precedent has read down that condition. A substantive limitation that restricts refund rights cannot be imposed through subordinate legislation without statutory authority. A contrary High Court view does not displace the applicable binding precedent. Consequently, the notification-based one-year limitation cannot defeat entitlement to Special Additional Duty refund.

Export valuation must ordinarily reflect the price actually paid or payable under the final transaction value. Where unrelated parties contractually adjust iron ore prices for quality parameters and the final invoice value is supported by banking-channel realisation, laboratory findings on iron content alone do not justify substituting a notional value. Enhancement requires a legally sustainable basis to reject the declared transaction value, including evidence of additional consideration, side payments, flowback, or other unrecorded remittance. An undisclosed test report and selective reliance on different reports for separate parameters do not support adverse valuation. Provisional assessments should be finalised on the genuine final value realised after verification of export documents.

Interest on delayed customs-duty refunds commences immediately after expiry of three months from receipt of the initial valid refund application, even where reassessment of bills of entry remains pending. Delayed reassessment or refund processing attributable to Revenue cannot defer the statutory interest commencement date. For prolonged withholding of the refund, jurisdictional precedent supports interest at 12% per annum rather than 6%, with adjustment for interest already paid. The stated position preserves the interest period beginning after the statutory three-month window and requires payment of the differential interest on the delayed refund.

Post-export amendment of shipping bills under Section 149 is available where contemporaneous documentary evidence existed at export. A circular-prescribed limitation cannot curtail the statutory amendment power if it is ultra vires Section 149, and a later notification imposing a limitation applies only prospectively to shipping bills filed after its publication. Conversion of free shipping bills to EPCG shipping bills may be processed on the basis of shipping bills, duty-payment records, invoices and bank realisation certificates; absence of physical examination at export does not displace this documentary standard. A clerical omission of EPCG authorisation details should not defeat substantive export benefits where eligibility is supported by contemporaneous evidence.

Fire-damaged automobiles that have lost their commercial identity and utility as vehicles, and are restricted to scrap or demolition use, are to be classified by their resultant character as scrap rather than restricted second-hand motor vehicles. Import-licensing restrictions and confiscation for prohibited import therefore do not apply. Unloading under customs requirements requires physical removal of cargo from a vessel; entry into, or berthing at, a notified customs port or ship-breaking area does not itself constitute unloading. Where damaged cargo remains on board until seizure and ship-breaking, confiscation of the cargo, vessel and consequential penalties for unauthorised unloading is unwarranted.

Refund of Special Additional Duty under the exemption mechanism in Notification No. 102/2007-Cus is available on fulfilment of conditions including subsequent sale and payment of applicable sales tax or VAT. Section 27 of the Customs Act prescribes limitation for refund claims but does not cover Special Additional Duty. A one-year limitation, introduced by Notification No. 93/2008-Cus and calculated from payment of that duty, extends the statutory limitation framework to a duty outside Section 27 and restricts a substantive refund right without statutory amendment. Consequently, that one-year limitation is inapplicable to Special Additional Duty refund claims.

Condonation of delay in customs appeals requires sufficient cause, assessed through bona fides, diligence and a satisfactory explanation for the entire period of delay. A High Court appeal under the Customs Act is confined to substantial questions of law and cannot revisit factual findings unless they are perverse, unsupported by evidence or reached by ignoring material evidence. Participation through counsel, email service on counsel, attempted dispatch to the recorded address and notice-board display supported the finding that prolonged inaction remained unexplained. Refusal to condone the delay therefore disclosed neither perversity nor a substantial question of law.

For unabated assessments under section 153A, completed assessments may be disturbed only through additions based on incriminating material found during the search. Additions for cash payments, tax-deduction defaults, expenses, credits and negative cash balances cannot rest solely on disclosed books, special-audit observations or uncorroborated investigation statements where no seized document, record or electronic evidence directly supports them. The identified additions therefore lacked the required jurisdictional foundation and were deleted.

Statutory housing activities providing accommodation, particularly to lower-income and weaker sections, fall within advancement of an object of general public utility. Charging consideration for residential units, plots and allied activities does not by itself amount to trade, commerce or business under the proviso to section 2(15). The decisive inquiry is whether charges substantially exceed cost, administrative expenses and a nominal mark-up for reasonable growth, indicating a profit motive. Section 11(4A) applies consistently to incidental business activity. Exemption under section 11 depends on verification of the pricing structure and remains available where no profit element is established.