Self-borne TDS paid by a service recipient from its own funds, without deduction from consideration payable to a foreign service provider, is not consideration for taxable service and is excluded from taxable value under reverse charge. Although the Commissioner (Appeals) has remand jurisdiction, remand is inappropriate where the relevant facts are conclusively established. For reverse-charge service tax, the applicable rate is determined by the date of receipt of service, not by a later invoice or payment date; a subsequent rate reduction does not alter liability for earlier services. Interest applies only to the surviving rate-differential liability, while penalties do not apply to the excluded TDS component or an interpretational rate dispute.

Pre-amendment service-tax valuation under Section 67 is confined to consideration for the taxable service. Insurance premiums collected from borrowers solely for full remittance to an insurer, without mark-up or retention, lack the necessary nexus and are excluded from taxable value; separately charged administrative fees remain taxable. Extended limitation requires fraud, collusion, wilful misstatement, suppression, or contravention intended to evade tax; an interpretative valuation dispute and voluntary payment of tax and interest on administrative charges do not establish those elements. Penalty requires the same culpable conduct and is not sustainable absent those elements.

Regular bail under the Prevention of Money Laundering Act requires reasonable grounds to believe that the accused is not guilty. Prima facie material indicating a central role in an alleged investment scheme, including mobilisation of investments, management of connected entities, and use or movement of alleged proceeds of crime, could not be discarded at the bail stage. Financial and documentary material, investigation statements, and the alleged mismatch in cloud-storage capacity remained matters for trial, particularly while key witnesses awaited examination. The custody period and parity claim did not displace the statutory bail threshold, as the co-accused's bail arose where those conditions did not apply.

The first proviso to Section 45(1) of the Prevention of Money Laundering Act provides a discretionary exemption from the twin bail conditions where the laundering amount attributable to an individual accused is below the monetary threshold. Attribution must be assessed separately for each accused and not mechanically equated with total proceeds of crime alleged against a wider group. Section 3 addresses knowing assistance in processes involving proceeds of crime, and Section 23 creates a presumption for interconnected transactions. Bail cancellation requires a perverse, fallacious, or investigation-prejudicial exercise of discretion; custody need not continue where bail conditions adequately secure investigation and trial attendance.

Concluded liquidation e-auctions, letters of intent and sale certificates cannot be reopened at the request of a prospective bidder that neither participated nor demonstrated genuine interest in the auction. A speculative assertion that later-disclosed conditions concerning dismantling, export facilitation or costs might have prompted a bid does not provide a substantive ground for interference. Deterrent costs may be imposed on a stranger to the liquidation process, but must remain proportionate where the challenge has not delayed the process.

Clause 24 of the deed of guarantee addresses the security arrangement and does not limit the personal guarantors' joint and several liability, created under Clauses 1, 6 and 9, for principal, interest, costs and charges. A final unchallenged debt-recovery determination of that liability cannot be reopened through collateral repayment-plan proceedings under Section 114. Repayment plans under Sections 111 and 114 require affirmative creditor votes representing 66% of the voting share; without that approval, the Adjudicating Authority cannot override creditors' commercial decision or independently approve the plan.

Bulk drugs and active pharmaceutical ingredients (APIs) classified under Chapters 28 or 29 qualify as "all drugs and medicines" under Serial No. 226 of Schedule I to Notification No. 9/2025-Integrated Tax (Rate), including where imported for manufacture, testing, clinical trials, bioavailability, or bioequivalence studies. The term "drugs" includes substances intended as drug components, and the entry's reference to goods under Chapter 30 "or any Chapter" extends to APIs outside Chapter 30. The specific drugs-and-medicines entry prevails over general chemical entries. Such imports attract 5% IGST, unless the particular API is covered by the nil-rate exclusion under Serial No. 113 of Notification No. 10/2025-Integrated Tax (Rate).

Bulk drugs and active pharmaceutical ingredients imported under Chapters 28 or 29 may fall within the 5% IGST entry for all drugs and medicines where they qualify as drugs under the Drugs and Cosmetics Act, including substances intended as drug components. Their use in formulation manufacture, testing, clinical research, or bioavailability and bioequivalence studies does not change that character. The phrase covering goods under any Chapter extends the entry beyond finished formulations, and the specific drugs-and-medicines description prevails over general chemical classifications. Eligibility remains subject to the relevant nil-rate exclusion for particular goods.

Woven man-made fibre textile rolls designed exclusively for garment labels, supplied in strips and suitable for durable printing, fall under CTI 5807 10 20 as woven labels or similar articles of man-made fibre. Their unprinted condition and cutting after import do not alter their character as labels; the specific man-made fibre entry prevails over the residual entry, subject to verification of the declared description, construction and composition at import. As articles under Heading 5807, the rolls fall within Entry 370 of Schedule I to Notification No. 09/2025-Integrated Tax (Rate) and attract IGST at 5 per cent.

End-use concessional duty for imported lithium-ion cells under the IGCR Rules requires their use in manufacturing the specified battery or battery pack. Manufacture requires emergence of a new product with a distinct nature, character, use or name; cells damaged or rejected and sold as scrap do not meet that condition. Where no prescribed process-loss or wastage tolerance applies, scrapped cells are treated as unutilised or defective goods. Differential duty, being the difference between normal import duty and concessional duty, is recoverable on the imported goods' assessed quantity and value with applicable interest, rather than proportionately to scrap sale proceeds.

Customs tariff classification of the Excalibur Hybrid X archery crossbow turns on the General Rules for Interpretation, Chapter Notes and HSN Explanatory Notes. Chapter 93 excludes bows and arrows, while Heading 9506 expressly covers archery equipment, including bows, arrows and targets. Because the crossbow propels bolts or arrows through stored mechanical energy in its limbs and string, rather than explosive charge, compressed air, gas or a firearm mechanism, it falls within the residual sub-heading for other sports or outdoor-game equipment. Classification therefore lies under Customs Tariff Item 9506 99 90, not Item 9304 00 00.

Imported automotive components must be classified under the specific tariff entry determined by their material composition and sole or principal vehicular use. A protector tube made entirely of PVC falls under the PVC heading and cannot receive a preference claimed under a rubber heading. A brake-hose bracket and a brake-fluid-flow connector designed specifically for automobile brake systems fall within vehicle-parts classification rather than general metal articles or Chapter 39 plastic fittings. Incorrect self-assessment causing duty short payment, supported by changed declarations, discrepancies and voluntary differential-duty payments, permits extended limitation and penalties for intentional misdeclaration.

Section 123 of the Customs Act shifts the burden of proving that notified goods are not smuggled only where seizure rests on reasonable belief supported by tangible material and cumulative circumstances. Inland seizure or absence of foreign markings is not independently decisive; carriage, concealment, admissions, markings, provenance, accounting records and other incriminating material require collective assessment. Domestic acquisition may be established on a preponderance of probabilities through reliable documentary and circumstantial evidence, without invariably proving uninterrupted physical identity of fungible gold. Tax invoices for domestic purchases could not be rejected without findings that they were false or unrelated to business stock, rendering confiscation and penalty unsustainable.

Goods sold through duty-free shops beyond the customs barrier, including warehoused or re-exported goods, remain imported goods from their entry into Indian territorial waters. Fiscal principles limiting customs duty and sales tax do not create immunity from domestic non-fiscal regulation. Restrictions or prohibitions under other domestic laws render such goods prohibited goods for customs purposes. Import licensing and other regulatory requirements therefore continue to apply despite warehousing, non-clearance for home consumption, or an intended re-export.

Estimated disallowances of alleged inflated purchases, where the extent of inflation is unproved, do not by themselves establish concealment for penalty under section 271(1)(c); penalty deletions were sustained. Documentary support for purchase claims, including invoices, vehicle details and ledgers, prevents their characterisation as wholly unsubstantiated expenditure for misreporting under section 270A(9)(c), although the taxpayer's explanation did not qualify for the section 270A(6) exception; penalty deletions were sustained. A separate section 271AAC penalty on cash received back from suppliers does not preclude a section 270A penalty absent a one-to-one correlation with the estimated purchase-inflation addition.

Assessment validity under Sections 143(3) and 153A depends on verifying whether it was founded on the original notice or a later notice issued after the initial proceedings were dropped. Where the search authorisation did not cover the assessee, the effect of the fresh Section 153A notice, subsequent Section 142(1) notices, and any return filed in response requires factual examination. The appellate authority may exercise powers under Section 250(4) to conduct or direct further inquiry, including obtaining a remand report, before deciding jurisdictional objections and remaining grounds.

Closing stock damaged while factory premises were under bank possession may be valued at cost or net realisable value, whichever is lower, where that accords with the consistently disclosed accounting method. Internet-price revaluation does not justify an addition unless it disproves the reduced recoverable value; the closing-stock addition was deleted. Cash deposits during demonetisation recorded as cash sales in audited books, supported by sale bills, delivery challans, sales registers and stock registers, were not unexplained money absent contrary material. The deposits were explained by the non-performing bank account and takeover of the business and residential premises, so the addition under Section 69A was deleted.

Substantiation of tax claims is required for deductions, exemptions, and explanations of entries in seized records. A section 80C deduction is available only to the extent qualifying payments are evidenced; unsupported amounts are disallowed. HRA exemption requires documentary proof of rent payment and entitlement, with the taxpayer bearing the onus. Entries in seized Excel sheets recording loans advanced may be treated as unexplained investment where no material establishes a different classification or underlying business nature. Unsupported claims and explanations therefore fail.

Long-term capital gains from listed-share sales supported by contract notes, demat statements and bank records cannot be characterised as non-genuine accommodation entries solely because of general investigation material or abnormal price appreciation. Purchases through a recognised broker, banking-channel payments, demat credits, exchange sales and banking-channel sale proceeds constitute direct documentary evidence unless disproved as false or fabricated. Such treatment requires evidence linking the taxpayer to operators or price-rigging, such as a cash trail, commission payment, pre-arranged transactions, or participation in manipulation. Suspicion and the human-probabilities test cannot replace proof.

Unexplained cash-credit treatment of share-sale proceeds and consequential share investment requires evidence directly connecting the taxpayer with accommodation-entry transactions. Third-party statements and general investigation material may trigger enquiry but, without corroboration, cannot displace unrebutted purchase bills, contract notes, bank records, and banking-channel fund movements; suspicion cannot substitute proof. Finality of appellate deletion concerning the original share purchase removes the factual basis for treating subsequent sale proceeds and related investment as unexplained, requiring deletion of the additions.