The special leave petition challenging a High Court judgment in a VAT and sales-tax dispute was dismissed after the Supreme Court declined to interfere. Delay in filing was condoned. The High Court judgment therefore remained undisturbed, and all pending applications were disposed of.

Threshing, cleaning, sieving and sizing dried broken raw tobacco leaves, followed by bulk packing, do not constitute manufacture because the processes neither produce a commodity with a distinct name, character or use nor alter the tobacco's essential identity. Deemed manufacture for tobacco covers labelling, relabelling, repacking from bulk to retail packs, or treatment that renders tobacco marketable to consumers. As the tobacco was already marketable, received no chemical treatment, flavouring, blending, branding or retail packing, and was packed only bulk-to-bulk, the activities do not fall within deemed manufacture. Central Excise duty is therefore not payable merely for these operations.

CENVAT credit is admissible on commission paid to a sole selling agent where the agent promotes sales and provides installation, commissioning and warranty-related after-sales services contractually connected with dutiable final goods. These services qualify as input services when they enhance the value of the goods, particularly where invoices identify commission for sales and the service tax treatment corresponds with the services supplied. Extended limitation cannot apply merely from ordinary business records; it requires evidence of suppression. A bona fide credit claim on an interpretative issue does not support invocation of the extended period. Consequently, denial of the disputed credit and the related demand are unsustainable on both merits and limitation.

Full recovery or payment of the amount required for pre-deposit satisfies the pre-deposit condition under Section 35F, even where compliance occurs after dismissal of the appeal. Dismissal for initial non-compliance should not permanently extinguish the statutory right of appeal once complete compliance is established and Revenue suffers no prejudice. Rule 41 permits restoration where required to secure the ends of justice. Appeals dismissed solely for failure to meet the pre-deposit condition must therefore be restored for adjudication on merits after the entire service-tax liability has been recovered or paid.

Rule 5 of the CENVAT Credit Rules, 2004 permits refund of accumulated CENVAT credit attributable to exported output services. Eligible exporters of software services remain entitled to refund of unutilised credit even where the exported software service is not taxable. Non-taxability of the exported service does not defeat the refund claim under Rule 5, including in relation to the taxable-service definition and Notification No. 18/2008-ST.

Penalty imposed in the assessee's capacity as partner of one entity had attained finality. A distinct penalty arising from the assessee's position as majority shareholder of the holding company of another entity was not covered by the existing remand direction, although that entity's matters had been sent for fresh consideration. The separate shareholder-related penalty is remitted to the adjudicating authority for de novo consideration together with the remanded matters of the relevant entity and connected entities.

Reverse-charge service tax on royalty under mining leases depends on when the Government's grant of mining rights was provided or agreed to be provided. Before 1 April 2016, Government services, including grants of rights in natural resources, were generally outside the taxable net under the negative-list regime; Government services supplied to business entities became taxable after that amendment. As the relevant mining lease agreements were not produced before the lower authorities, their terms require examination under applicable Tribunal decisions. The impugned order was set aside and the matter remanded for fresh adjudication.

Amounts written off as unclaimed vendor balances or other outstanding credits do not constitute consideration for tolerating an act under Section 66E(e) of the Finance Act, 1994 unless an independent express or implied contractual obligation requires one person to tolerate, refrain from, or perform an act for another and consideration flows for that obligation. Mere accounting write-back of lapsed balances as income does not establish a taxable service. The extended limitation period also requires evidence of a positive act to evade tax; absent such evidence or suppression of taxable activity, it cannot be invoked. Consequently, the service-tax demand, interest and penalty founded on such write-backs cannot be sustained.

Provisional attachment of properties acquired through layered diverted loan funds remained valid despite claims of prior sale or mortgage. Receipt of funds from the accused entity, without invoices, GST returns, income-tax returns, or evidence of genuine business activity or an independent acquisition source, supported treatment of the entities as shell companies used to layer proceeds of crime and acquire assets. A seller retaining no interest after an asserted sale could not challenge attachment; purchasers may pursue independent claims. Mortgages did not displace attachment, while mortgagees' claims remained open. Confirmation of the attachment, including for mortgaged and partly sold properties, was sustained.

Forfeiture of a successful auction bidder's part sale consideration before expiry of an extended payment period was inconsistent with liquidation-sale terms permitting delayed payment with interest. Regulation 33 and Schedule I contemplated payment beyond the original due date where an extension had been granted; cancellation and forfeiture during that period were therefore premature. Retaining the deposit after a subsequent higher-value sale would result in unjust enrichment. Section 74 of the Indian Contract Act did not support forfeiture before the modified payment period ended. The deposited sale consideration was refundable without interest.

Homebuyers' associations cannot independently intervene in an ongoing corporate liquidation as creditors to challenge a liquidator's proposed asset sale. Amended Section 21(11), applicable where no dissolution application has been filed, permits the committee of creditors to supervise the liquidator's conduct. Individual association members who qualify as stakeholders may independently seek intervention before the adjudicating authority under that framework. Consequently, intervention by the association is not maintainable, but member-stakeholders may file a fresh application before the NCLT.

Disclosure of previously instituted public interest proceedings is mandatory under the Delhi High Court (Public Interest Litigation) Rules, 2010. A PIL concerning NSE shareholding and beneficial-ownership disclosures substantially overlapped with an earlier undisclosed writ petition, despite an averment that no similar proceeding existed. Suppression of that material fact and the contrary sworn assertion constitute lack of candour, unclean hands, forum shopping and abuse of PIL jurisdiction. These defects disentitle the litigant to equitable writ relief irrespective of the merits of the underlying allegations, and warrant exemplary costs.

Section 551 of the Companies Act, 1956 requires an Official Liquidator to file annual or final accounts. Audited half-yearly accounts covering each half of a financial year do not substitute for an annual account because consolidation is necessary to present the correct financial position of companies in liquidation. Accordingly, exemption from filing annual or final accounts for financial year 2024-25 was refused despite the filing of audited half-yearly accounts.

Unsubstantiated claims that auctioned land is assigned land cannot justify summary resumption or interference with a court-supervised sale. Registered transactions, revenue mutations, long uninterrupted possession and industrial use may support the need for formal adjudication where title is disputed. The State cannot determine its own title and dispossess persons in long possession through administrative resumption proceedings; whether land was assigned and transfers warranted resumption must be resolved in appropriate proceedings. On the stated facts, interference with the confirmed auction sale was unsustainable, the Company Court's confirmation was revived, the purchaser's possession was protected, and the connected writ matter required fresh consideration on merits.

Bulk drugs and active pharmaceutical ingredients qualify as drugs under the description-based entry for all drugs and medicines, including when imported for manufacture, testing, clinical trials, bioavailability studies or bioequivalence studies. Their classification follows the statutory treatment of drug components and APIs as pharmaceutical substances used directly or as formulation ingredients. The phrase "or any Chapter" extends the entry beyond Chapter 30 to APIs classifiable under Chapters 28 and 29. The specific drugs entry prevails over general chemical entries, resulting in IGST at 5%, unless the goods fall within the applicable nil-rated entry.

Bulk drugs and active pharmaceutical ingredients (APIs) classifiable under Chapters 28 or 29 qualify as "drugs" where intended for use as components of pharmaceutical formulations, including testing, clinical research, bioavailability or bioequivalence studies. Sl. No. 226 of Schedule I to Notification No. 9/2025-Integrated Tax (Rate) is a description-based entry covering drugs and medicines under Chapter 30 or any other chapter; its reference to formulations made from bulk drugs does not restrict relief to finished dosage forms. This specific entry prevails over general chemical entries. IGST at 5% applies to eligible APIs on import, subject to verification that the particular API is not covered by the nil-rate exclusion under Sl. No. 113 of Notification No. 10/2025-Integrated Tax (Rate).

Bulk drugs and active pharmaceutical ingredients used to manufacture pharmaceutical formulations, or for testing, clinical research, bioavailability or bioequivalence studies, fall within "all drugs and medicines" where they are pharmaceutical substances, components of drugs and satisfy applicable regulatory requirements. The description-based concessional entry applies regardless of classification in general chemical chapters; its separate reference to formulations manufactured from bulk drugs does not restrict the entry to finished dosage forms. The specific drugs-and-medicines entry takes precedence over general chemical entries, and ambiguity in a taxing rate notification is resolved in favour of the taxpayer. Qualifying APIs attract 5% IGST, subject to individual verification that no nil-rate exclusion applies.

Customs transaction value may be rejected only where objective reasons create reasonable doubt about its truth or accuracy; non-disclosure of an exporter's suggested list price, without evidence of abnormal or relationship-influenced pricing, is insufficient. Valuation must then follow the prescribed sequential methods, and the residual method cannot rely on the exporter's domestic-market price. Royalty and licence-related payments are includible only if they relate to imported goods and are a condition of sale. Payments for post-import manufacturing technology or know-how, where parts may be sourced independently, are excluded. Unpaid management fees cannot be added notionally without support.

Customs penalties may arise from admitted import undervaluation where declared values are materially below values redetermined from investigation material and the differential duty is accepted. Penalty for improper importation applies when an act or omission makes goods liable to confiscation. Knowingly or intentionally filing Bills of Entry supported by undervalued invoices may also attract penalty for false or incorrect declarations; that provision extends to import transactions and is not limited to exports. Both penalties may operate concurrently, although the penalty for false declarations may be mitigated after considering the existing improper-importation penalty and relevant transactional circumstances.

Condonation of delay in an appeal requires demonstrated sufficient cause, bona fides and due diligence. Pursuing remedies against a consequential assessment, while accepting revisionary adjustments and not challenging them within limitation, does not establish sufficient cause for a substantial delay. Maintainability also requires a genuine grievance against the order appealed from. Where appeal grounds challenge only the consequential assessment and expressly raise no objection to the revision order, an appeal against the revision order is not maintainable. The revisionary order consequently remains unassailed and cannot be used to contest the consequential assessment.