Section 74 GST notices alleging fraud, suppression or wrongful input tax credit must set out case-specific facts, the basis for invoking the provision, relied-upon material and the proposed liability. Mere reproduction of statutory language does not provide a meaningful opportunity to respond. Natural justice requires disclosure of relevant documents where the department relies on supplier information, digital data, statements or transport records. Recovery and bank attachment must rest on a legally sustainable notice, and taxpayers should request particulars and documents in writing while preserving records relevant to the allegations.

Patent injunctions are equitable remedies assessed through a prima facie case, balance of convenience and irreparable injury, rather than as automatic consequences of alleged infringement. Patent validity, infringement evidence, market effects, alternatives, delay, public interest and adequacy of damages guide the assessment. Protection of innovation and research investment must be reconciled with competition, consumer welfare and access to essential products, particularly medicines. Standard Essential Patent disputes also require consideration of Fair, Reasonable and Non-Discriminatory licensing, interoperability and market access.

Patent injunctions are equitable remedies assessed through a prima facie case, balance of convenience and irreparable injury. Courts consider patent validity, evidence of infringement, comparative hardship, alternatives, delay, market effects and whether damages adequately compensate the patentee. Relief is not automatic upon infringement: public interest, consumer welfare, affordable access to essential medicines and competition may weigh against restraint. Standard essential patent disputes also require consideration of FRAND licensing and interoperability. Expedited trials and technical evidence can reduce the market effects of prolonged interim orders.

Interim protection under Section 9 may secure a lender's outstanding loan where agreed project mortgage security remains uncreated and the borrower has not maintained the Debt Service Reserve. Although mortgage creation under the amended agreement depended on a no-objection certificate, the borrower's separate obligation to establish and maintain the reserve continued. The absence of a constituted arbitral tribunal and pending insolvency proceedings did not prevent interim relief. The uncreated mortgage supported a prima facie case, with balance of convenience and prejudice favouring protective measures, including creation of the Debt Service Reserve on the lender's requirement.

Dismissal of a tax appeal solely for non-appearance, without examining the assessee's written objections, statement of facts, and grounds of appeal, violates principles of natural justice. An appellate authority making a prejudicial decision must consider the affected person's contentions; failure to do so reflects non-application of mind. The dismissal therefore constituted a substantial breach of natural justice and operated in favour of the assessee.

Rule 20 of the Customs, Excise and Service Tax Appellate Tribunal (Procedure) Rules, 1982 permits dismissal of an appeal for the appellant's non-appearance, while requiring the Tribunal to set aside that dismissal and restore the appeal if sufficient cause for the absence is established. A restoration application must therefore be considered on whether sufficient cause exists; it cannot be rejected solely as an impermissible review of the dismissal order. The rule confers jurisdiction on the Tribunal and imposes an obligation to restore an appeal dismissed for default once the prescribed condition is satisfied.

Denial of effective cross-examination and failure to consider material submissions breached principles of natural justice in the excise adjudication. The Tribunal noted that witness statements were relied on without testing them under Section 9D, cross-examination was wrongly refused because statements were unretracted, and permitted cross-examination was not substantially conducted. It also found that the explanation concerning packing material procured by other franchisees manufacturing the same branded goods was not addressed. A full remand for fresh adjudication was therefore considered unobjectionable, with no substantial question of law arising.

Services comprising rental receipts from electricity supply companies, supervision charges for transmission infrastructure works, and reimbursements connected with electricity transmission and distribution were treated as having a clear nexus with transmission and distribution of electricity. They fell within services in relation to electricity transmission and qualified for the exemption under Notification No. 45/2010-S.T. Consequently, no service tax was payable on those activities, and the associated tax, interest and penalty demands were unsustainable.

Service-tax recovery from legal representatives of a deceased sole proprietor is impermissible where the governing framework contains no machinery provisions for assessment or recovery against the deceased person's estate or heirs. A proprietorship has no legal identity separate from its proprietor, and a demand determined during the proprietor's lifetime does not by itself render legal heirs liable. Applying the principle governing recovery provisions comparable to Central Excise Act recovery rules, the garnishee notice seeking recovery from the legal representatives was quashed.

Cancellation of regular bail may be justified without post-release misconduct where the original bail order is inherently perverse or ignores mandatory statutory restrictions. Documentary material recovered in search, including cash ledgers, digital transaction records and slips, was relevant at the bail stage, and the presumption regarding proceeds of crime could not be displaced merely because depositors did not directly implicate the accused. An external broker may fall within conduct connected directly or indirectly with proceeds of crime. Delay or closure of a predicate FIR does not prevent independent assessment of the money-laundering allegation, and custody duration cannot override the mandatory twin bail conditions.

Regular bail in the money-laundering proceedings was considered appropriate because the alleged transactions dated to 2013-2014, the petitioners had already undergone substantial incarceration in connected predicate-offence proceedings, and they had remained in custody in the present proceedings for over sixteen months. Although a prosecution complaint had been filed, charges had not been framed and early completion of trial was unlikely. On these circumstances, the petitioners were entitled to release on bail.

Fraud classification under the 2024 Fraud Master Circular requires a reasoned order addressing the noticee's response, the relevant facts and circumstances, and reasons for rejecting the defence. An order that merely reproduces forensic-audit observations and the show-cause notice, without engaging with the defences, is unsustainable. Fraud proceedings could not be recommenced for the relevant review period where the forensic audit identified no fraudulent transactions during the individual's directorship, the individual had ceased to be a director before the account became an NPA, and no personal guarantee was established. The fraud classification lacked a sustainable basis and could not be revived on that audit material.

Prior approval under the proviso to Section 33(5) of the Insolvency and Bankruptcy Code is required before a liquidator invokes arbitration for a corporate debtor. An arbitration request commences upon receipt by the respondent, so approval must precede invocation. Where approval is absent, the invocation is ineffective rather than void because Section 33(5) does not prescribe voidness. Post facto approval makes the invocation effective from the approval date, with subsequent arbitral procedure running from that date. This approach preserves potential estate recoveries while avoiding a fresh invocation and related limitation consequences.

A show-cause notice proposing fraud classification cannot rest on an inconclusive forensic-audit report prepared without the borrower's complete books and supporting records. The report was based only on limited lender-provided material and expressly remained subject to further findings once full records were produced. Where the company is in liquidation, available records must be obtained through the Liquidator or investigating authority for a proper forensic examination. Reliance on complete and relevant material is required for a definite finding in a fair adjudicatory process. The notice was invalid, though fresh action may be taken after necessary records are obtained and a definite forensic finding is made.

Imported mobile phones proposed for re-export could not be confiscated where the departmental communication neither specified nor established the contravention said to attract confiscation and denied statutory notice and opportunity of defence. Its jurisdictional basis and manner of issuance were also deficient. A re-export request prompted by a GST-related pricing change did not, on the recorded facts, demonstrate improper importation, misconduct, or mala fide intent. Accordingly, confiscation lacked a legal basis, redemption fine and penalty were not imposable, and re-export was permissible without those exactions.

Penalties for alleged gold smuggling were examined against the limits of the show cause notice and the evidentiary basis for imputing involvement. The notice concerned only the seized gold under a specified airway bill and recorded that verification of the other consignments was pending. Reliance on earlier cleared consignments was unsupported by adequate investigation into the supplier, account, transactions, commercial documents, remittances, or any collusive arrangement. Medical material and an affidavit also undermined the voluntariness and admissibility of the attributed statements. On these grounds, penalties under the Customs Act for the alleged smuggling were set aside.

A fresh Customs Broker Licence application cannot be rejected solely on an earlier revocation order where a final appellate finding on the same export transaction found no evidence that the applicant knowingly facilitated illegal export. Although licensing proceedings under the Customs Broker Licensing Regulations are distinct from penalty proceedings under the Customs Act, the appellate exoneration is a relevant circumstance when both matters rest on identical foundational allegations. The licensing authority must independently reconsider the application on its merits after taking that finding into account.

A sanction order implementing an earlier judicial direction for payment of the tariff value of perished seized goods, without deciding any dispute or the pending interest claim, does not constitute an appealable adjudication order under the customs appellate mechanism. Acceptance of the sanctioned tariff value does not extinguish an expressly raised claim for interest on delayed payment. Where that claim remains unadjudicated and available remedies have been preserved, the competent customs authority must issue a reasoned determination on the representation in accordance with law within the stipulated period.

Customs house agent licence revocation proceedings under Regulation 22 were required to be completed, including the Commissioner's order, by the stipulated deadline. The inquiry report, disagreement memorandum and revocation order were completed within that period. The Tribunal treated the proceedings as delayed without considering the binding time direction or compliance with it, and set aside revocation without examining the merits. The High Court therefore found no delay, set aside the Tribunal's order, and remanded the agent's appeal for a merits-based decision in accordance with law.

Substantial questions arise on the availability and interpretation of customs and integrated tax exemptions for orthopaedic implants, including the meaning of goods for disabled persons and the consequences of an interpretative dispute over exemption notifications. The questions also concern the consequential demand, limitation, confiscation and penalty. The appeal was admitted on three substantial questions of law.