Sections 35G and 35L of the Central Excise Act, 1944 allocate appellate jurisdiction by excluding High Court appeals involving questions related to the rate of duty or value for assessment. Taxability and excisability fall within that excluded category. Determinations of whether services constitute intermediary services or qualify as exports of services may involve service classification, excisability and valuation for assessment. Appeals raising those issues must therefore be pursued before the Supreme Court under Section 35L rather than before the High Court.

Appeals under Section 35G of the Central Excise Act exclude disputes concerning the rate of duty or value for assessment, which fall within the Supreme Court's jurisdiction under Section 35L. Taxability and excisability form part of this excluded category. Characterising services supplied to an overseas entity as intermediary services, and determining whether they qualify as export services, concerns classification, excisability and assessable value. Challenges to such determinations are therefore not maintainable under Section 35G and must be pursued under Section 35L.

Restoration of property attached under the PMLA during trial is confined to claimants with a legitimate interest and quantifiable loss, subject to framing of charge and a hearing for the owner under the Restoration of Property Rules. An association that is not itself a homebuyer and has no quantifiable loss cannot qualify; the restoration order obtained on its application was set aside. Assets of former promoters or other entities remain outside the corporate debtor's insolvency estate, and an insolvency professional's undertaking cannot alter that position. An independent monitoring committee will verify genuine homebuyers and maintain asset data, while liquidation or restoration remains deferred pending attachment challenges and available remedies.

Forensic audit directions concerning commercial transactions and relationships between the judgment debtors, FHL, FHHPL and the banks are confined to those transactions. Relevant clauses do not authorise a general examination of the banks' affairs beyond that scope. The audit therefore cannot become a fishing and roving inquiry into the banks' entire affairs.

Reasoned appellate orders must address material factual and legal grounds, evidence and authorities relied upon; conclusory confirmation of original orders does not provide an effective appellate determination and undermines natural justice. Where first appellate review omits those grounds, deciding the dispute only at the second appellate level may deprive the party of a statutory appellate level. Fresh original adjudication should ensure identification and access to relied-upon documents, reasonable opportunity to respond, effective personal hearing, and a reasoned determination.

Requested personal hearings and reasoned orders are required where an adverse GST determination turns on disputed factual evidence. Denial of a post-reply hearing and failure to address explanations concerning duplicate e-way bills, a single supply, and alleged additional taxable transactions breach the requirements of Sections 75(4) and 75(6). Later appellate hearings do not automatically rectify that original-stage defect. Rule 138(9) does not create a new charge; failure to cancel an e-way bill is relevant but not conclusive of an additional supply. The dispute requires fresh adjudication confined to the existing notice, with primary records, a meaningful hearing, and a speaking order.

Supreme Court directions permitted aggrieved registered assessees to file or revise Form GST TRAN-1 and Form GST TRAN-2 for availing transitional input-tax credit. The relief allowing Form GST TRAN-1 filing for transitional credit corresponded with that concession, leaving no basis to disturb it and preserving the assessee's ability to seek the credit. Transitional credit may therefore be pursued through the filing or revision mechanism specified in those directions.

Cross-examination must be afforded where an assessing authority treats third-party statements as credible and relies on them directly to deny an input tax credit claim. Although cross-examination is not an absolute right in every assessment, natural justice and fair-hearing requirements require an effective opportunity to rebut materially relied-upon statements. Denial of that opportunity vitiates the assessment and requires fresh adjudication after the assessee receives a reasonable opportunity to cross-examine the relevant individuals.

Inverted-duty GST refund eligibility for cotton-yarn manufacturing requires fresh factual verification of the inputs purchased, manufacturing activity, output-tax payment and accumulated input tax credit. Rejection based on Circular No. 135/05/2020-GST is unsustainable where that circular has already been quashed in relation to the same refund issue. The Department should also maintain consistency where comparable refund claims have been sanctioned. Refund must be granted once the factual requirements for eligibility under the inverted duty structure are established.

Refund eligibility under an alleged inverted duty structure required verification of whether outward supplies comprised cotton yarn manufactured using cotton fibre, packing material and consumables, or cotton yarn traded without manufacturing. Supporting records had to establish the actual nature of the claimant's activities before refund entitlement could be determined. The impugned orders were quashed, and the refund claims were remitted for fresh determination on that factual verification.

Amended Section 16(4) of the GST enactments, effective from 27 September 2024, regularises belated availment of input tax credit. Credit eligibility remains subject to compliance with all other applicable statutory and rule-based conditions. Demands concerning delayed input tax credit availment require fresh adjudication under the amended provision. Fresh adjudication of demands unrelated to Section 16(4) is conditional on payment of 50% of the disputed tax in cash and submission of a reply supported by relevant material.

Cancelled GST registration may be restored where the registered person satisfies the applicable restoration requirements. A penalty proceeding for failure to furnish required information, where no reply to the show-cause notice was filed and hearing opportunities were not used, may undergo fresh adjudication after a 10% cash deposit of the disputed tax and submission of a reply supported by documents. The existing penalty order is to operate as an addendum to the show-cause notice, requiring a merits determination after the prescribed compliance.

CGST assessment orders that are appealable under the statutory appellate mechanism should be challenged through that remedy. Taxpayers may raise all objections to an assessment order in the statutory appeal, where the contentions are to be considered and decided in accordance with law within a reasonable period. The material addresses a challenge to an assessment order and identifies the statutory appeal route as the available legal remedy, with pending applications to be disposed of accordingly.

Prima facie breach of NDPS search-and-seizure safeguards arose because the appraisal letter inaccurately communicated the option of a search before a Magistrate or Gazetted Officer. Identification of alleged contraband without required testing, followed by mixing material from four separate pouches before weighing, further indicated a vitiated seizure process. These observations were limited to the bail stage and did not determine the prosecution's merits; regular bail was granted.

Section 50 personal-search safeguards require clear communication of the statutory choice to be taken before the nearest Magistrate or Gazetted Officer. Presenting only a qualified option to be searched before a Magistrate may amount to prima facie non-compliance. Sampling safeguards also require the prescribed sample quantity and certification in Form No. 5. Samples below the prescribed quantity and a non-prescribed certificate may weaken the prosecution seizure case at the bail stage, supporting regular bail without determining guilt on the merits.

Pre-sampling mixing of contraband recovered from separately seized packets conflicts with prescribed seizure and sampling safeguards. Separate packages or containers must be individually weighed and serially numbered, and samples must be drawn from each packet or container. Where contents are identical, representative quantities may be combined only through the prescribed inventory and sampling process in a Magistrate's presence. Immediate mixing at the seizure stage is prima facie impermissible and constitutes a substantive breach rather than a minor procedural irregularity. Non-compliance with mandatory seizure and sampling requirements may undermine the prosecution case and support entitlement to regular bail.

Separate memoranda of appeal are required where a common judgment both dismisses a suit and allows a counterclaim. Failure to file separate memoranda is curable if the composite appeal was timely and otherwise free of serious defects. Procedural rules allow dispensation with a duplicate judgment copy in specified circumstances. Courts should permit rectification before technical rejection, preserving determination on merits.

Cash gifts from the assessee's mother and brother were not unexplained cash credits where donor identities, PANs, income-tax returns, regular income sources, and evidence of advances under agricultural-land sale agreements established the nature and source of the gifts. For assessment year 2018-19, Section 68 did not require the assessee to establish the source of the donors' funds, because that requirement applied only from assessment year 2022-23. The gifts were therefore satisfactorily explained and could not be assessed under Section 68.

Section 69 applies only to unexplained investments made during the relevant year; deposits evidenced as pre-existing opening balances fall outside its scope. Financial extracts drawn from accounting records seized during search are not fresh additional evidence under Rule 46A where the underlying records were already available and the figures remain undisputed. Section 69C requires proof that expenditure was actually incurred, not merely that liabilities were recorded as payable. Interest on unrecoverable loan principal is hypothetical rather than real income, and income must be assessed in the hands of the person or entity to whom it belongs.

Additional evidence comprising shipping and banking records may be admitted where necessary for proper determination of unexplained Customs-duty expenditure and capital-credit additions; those additions require fresh factual adjudication after hearing. Interest on fixed deposits pledged as margin money for business credit facilities has a direct business nexus and is assessable as business income rather than income from other sources. Export sale proceeds and export incentives cannot be treated as bogus or unexplained solely on investigative show-cause material where export and banking evidence supports the transactions. Overseas customer advances received through banking channels are not unexplained credits once party particulars and receipt evidence discharge the taxpayer's burden, absent Revenue rebuttal or available verification.