Reverse-charge service tax on legal services received from advocates or law firms was revenue-neutral where the recipient could claim full CENVAT credit for use in providing taxable output services. Because payment of tax and corresponding credit availability created no net revenue loss, the service-tax demand was unsustainable. As the underlying tax liability could not survive, consequential interest and penalty were also unsustainable. The confirmed reverse-charge liability on the disputed legal services was annulled, with consequential relief available in accordance with law.

Examination-related services supplied to educational institutions for voluntary Olympiad and talent-search tests fall within the service-tax exemption for services relating to the conduct of examination. The exemption covers activities directly connected with examinations, including question-paper preparation, examination materials, evaluation, tabulation and result declaration, without requiring that examinations be compulsory or curriculum-based. Where schools identify participants, collect fees, conduct tests and forward answer sheets, they are the service recipients despite the students' ultimate benefit. Extended limitation requires evidence of deliberate concealment, wilful misstatement or intent to evade tax; an interpretational dispute supported by disclosed records does not establish suppression. Consequently, no consequential penalty arises where the exemption applies and bona fide belief is supported.

Adjustment or refund of service tax paid cannot be determined before the contract is classified as a works contract or a service contract. The applicable tax incidence and nature of tax liability depend on that classification. As the classification exercise remained pending after remand, any definitive denial of adjustment or refund was speculative and premature. The earlier finding was vacated, and the appropriate authority must consider the adjustment or refund question after completing contract classification.

Regular bail in money-laundering proceedings was considered in light of allegations that local area development funds were misused through 32 tenders for sports equipment and that public funds were diverted. The investigation material was considered insufficient to support release at that stage. Regular bail was therefore declined.

Regular bail under the Prevention of Money Laundering Act was declined because the scheduled offence continued to subsist and the applicant did not satisfy the statutory requirements for bail. The Supreme Court dismissed the special leave petition while granting liberty to renew the bail request before the Trial Court at an appropriate stage.

Foreign-exchange compliance governing non-resident share transfers, escrow arrangements, overseas-loan security and residential status is examined. Recording bank shares in the names of unapproved non-resident entities was treated as prohibited, with resulting corporate and role-based liability for responsible directors, officers and company secretaries. Escrow accounts and custody arrangements securing overseas loans required prior Reserve Bank permission and could constitute prohibited deposits or guarantees. The chairman's foreign-exchange charge did not stand because he was treated as resident outside India at the relevant time. Penalties were substantially reduced.

For non-physical software imports, the importer must establish actual receipt of software corresponding to foreign-exchange remittances through reliable certification; an intimation to Customs, a pre-import valuation report, and a later expert opinion based on company-supplied CDs were insufficient. The material therefore supported the company's contravention, although penalties were substantially reduced for financial hardship. A CEO, director, shareholder and joint authorised signatory who authorised outward remittances was personally liable where his statement indicated the software lacked value and he failed to prove due diligence to prevent the contravention.

Alleged fraudulent removal from directorship, share transfers, misuse of digital signatures and internal management disputes must be pursued through the specialised company-law mechanism under the Companies Act, 2013. Investigation into alleged fraud or misconduct in company affairs is available through the National Company Law Tribunal, while claimed industrial-policy and lease-condition breaches depend on resolution of the underlying corporate dispute. Disputed questions concerning consent, transfer documents and record authenticity require evidence and investigation unsuitable for writ jurisdiction. Alleged official inaction does not create a public law element in an essentially private corporate dispute, leaving the petitioner to seek relief before competent company-law authorities.

Independent Chartered Accountants who certify statutory e-Forms are not officers or officers in default merely because they act as external professional certifiers. Criminal liability for false filings requires specific material showing knowing falsity, intentional concealment, or active connivance; certification alone does not establish mens rea. Responsibility for accurate filings primarily rests with the company and its directors. Prosecution for offences carrying a maximum two-year sentence must be instituted within the applicable three-year limitation period, unless delay is validly condoned. Proceedings initiated after that period without a sufficient basis for condonation are barred by limitation.

Magnesium Bis-glycinate Chelate is classified as a single chemically defined coordination compound by reference to its organic ligand under Chapter Note 5(C)(3) of Chapter 29. As the ligand, glycine, falls under Heading 2922, the product is classifiable under Tariff Item 2922 49 90 as other amino-acids and their esters; salts thereof. Water and citric acid do not alter this result because permitted water and stabilisers required for preservation or transport are disregarded. Classification follows the goods' objective characteristics and composition at import, rather than their intended use in nutritional supplements; the product is not a food preparation or antibiotic.

Redemption fine and penalty for alleged import misdeclaration require proof that the importer misdeclared quantity or value and, for redemption fine, determination of market price and margin of profit. Supplier documents supported the declared quantity, with no evidence that the importer ordered excess goods or suppressed quantity. The value enhancement relied on assessment practice rather than specific contemporaneous import data or an identified valuation rule. As misdeclaration under the Customs Act was not established and the required basis for redemption fine was absent, the fine and penalty were unsustainable.

Customs Broker licensing proceedings were not invalidated because the show-cause notice was issued within the prescribed period and subsequent inquiry and hearing provided adequate opportunity despite no separate post-suspension hearing. Regulation 10(d) was not breached where declarations relied on importer-supplied, importer-approved invoices, bills of lading and checklists, without proof that the broker knew of, colluded in, or facilitated misdeclaration. Regulation 10(e) was also not breached because no evidence showed that the broker imparted incorrect information to the importer. Revocation of licence, security-deposit forfeiture and penalty therefore lacked a sustainable basis.

Recommendatory anti-dumping final findings do not create a statutory obligation to consider representations against them before a Central Government notification is issued. A writ direction cannot create a remedy unavailable under law or compel a decision on representations where no statutory duty exists. As the findings had not yet resulted in notification and a statutory appeal to CESTAT would be available after notification, the requested writ intervention was premature. The High Court therefore declined to direct consideration of the representations or exercise writ jurisdiction.

Section 130 of the Customs Act excludes High Court appellate jurisdiction over Tribunal determinations relating to the rate of customs duty or the value of goods for assessment. Challenges involving anti-dumping duty and valuation must therefore follow the appellate route under Section 130E, requiring pursuit before the Supreme Court rather than the High Court.

RTGS credits purportedly received from gold sales were treated as a benami transaction where demonetised cash was deposited with the alleged benamidar, followed by transfers from entities under his control, supported by his sworn statement regarding RTGS-entry arrangements. Invoices, ledgers and stock records did not independently substantiate genuine sales, and the absence of prior business dealings, timing, rates and unusual weights weakened the explanation. Cross-examination was not required where no intermediary statement existed, the benamidar was summoned but did not appear, and no actual prejudice was shown. The provisional attachment was therefore sustained.

Consistent earlier-year treatment applies where the functional profile and material facts remain unchanged, supporting deletion of the back-office transfer-pricing adjustment and limiting the Letter of Comfort adjustment to a 0.04% commission. Derivative mark-to-market losses, leased-asset depreciation, amortised bond-discount expenditure, club fees, broken-period interest and accrued year-end provisions are treated as deductible business expenditure under the stated facts. Goodwill and acquired business or commercial rights arising on amalgamation qualify for depreciation, while employee stock-option discount is employee compensation deductible despite being raised without a revised return. Sufficient interest-free funds preclude interest disallowance under Section 14A; administrative expenditure and foreign-tax, relief and tax-deducted-at-source claims require Assessing Officer verification.

Transfer-pricing comparability in the software development segment requires fresh examination of Ishir Infotech, Sasken Communication Technologies, Tata Elxsi and Akshay Software. Verification is required for Ishir's employee-cost computation and information obtained under section 133(6), Sasken's merger and acquisition events, Tata Elxsi's functional profile including embedded product-design activities, and Akshay Software's onsite and offshore margin data. The comparability exercise is remitted to the Transfer Pricing Officer after providing the assessee a reasonable opportunity. Penalty under section 271(1)(c), being founded on the related transfer-pricing additions, requires fresh determination by the Assessing Officer because the underlying quantum issues were remitted.

Consistency in tax assessment required acceptance of the school as part of the registered educational society where the Revenue had accepted that status in an earlier year and established no contrary evidence, material factual distinction, or changed circumstances. Although each assessment year is separate and res judicata does not strictly apply to taxation, the authorities had not verified whether the school's income was already included in the society's accounts. The separate assessment of the school and the related addition could therefore not be sustained.

Failure to furnish separate segmental profitability for associated-enterprise and non-associated-enterprise transactions did not attract penalty where preparing the details was impracticable in the diamond trade due to mixed lots and varying diamond characteristics. The assessee provided Form 3CEB, audit reports and other transfer-pricing documentation, and no arm's length price adjustment was made. These facts established substantial compliance with transfer-pricing documentation requirements and reasonable cause for incomplete segmental information. Penalty under Section 271G was therefore not leviable, and its deletion was sustained.

Reassessment notices issued beyond three years require cumulative compliance with Section 148 and the extended-limitation conditions under Section 149(1)(b). Material available to the Assessing Officer must reveal income escaping assessment above the prescribed threshold and link that income to an asset, expenditure, or book entry. Recorded reasons must identify seized material relevant to the assessee and document the required satisfaction and prior approval under Explanation 2(iv) to Section 148. Ledger entries of alleged entry providers, without disclosed contents or verification against the assessee's books and tax treatment, do not independently establish escapement of income. Non-compliance renders the notice time-barred and invalidates consequential reassessment proceedings.