A sub-contractor has an independent obligation to pay service tax on consideration received, and payment by the principal contractor does not extinguish that liability. However, the extended limitation period under the proviso to Section 73(1) of the Finance Act, 1994 cannot apply without substantive evidence of wilful suppression of facts with intent to evade tax. Where conflicting Tribunal decisions made sub-contractor liability an interpretational issue until settled by a Larger Bench, extended limitation is not justified. Accordingly, although the underlying service tax liability was affirmed, the demand was barred by limitation.

Coaching for CA-CPT, ICWA-Foundation and Intermediate (10+2) examinations falls within the service tax exemption for training leading to an educational qualification recognised by law. The exemption is not limited to final-stage qualifications: CA-CPT and ICWA-Foundation are compulsory statutory stages required for progression in their respective professional courses, while Intermediate coaching leads to a recognised educational qualification. The notification does not require a fee cap or separate affiliation, and identical treatment in subsequent periods supports consistent application. The coaching is therefore exempt under Notification No. 33/2011-S.T.

Procurement of privately owned railway wagons under the Liberalized Wagon Investment Scheme did not constitute a taxable supply of tangible goods for use to the Railways where the wagons were acquired at the assessee's cost, dedicated to its own traffic, and unavailable for the Railways' independent commercial exploitation. A taxable service requires an identifiable service rendered to another person for consideration. The Railways provided transportation to the assessee, while the concessional freight was a policy incentive linked to capital investment rather than consideration for wagon use. The arrangement could not be split into transportation and wagon-supply transactions; consequently, the service-tax demand, interest and penalties were unsustainable.

Provisional attachment orders under money-laundering law require the Enforcement Directorate or other competent authority to have reason to believe that the attached property represents proceeds of crime. The text records that the High Court directed release of the attached properties, modifying only the apportionment of interest accrued on deposited sums. It further records that the Supreme Court condoned delay and dismissed the special leave petitions without interfering with the High Court's judgment and orders.

Applications seeking condonation of delay in special leave petitions concerning bail in a money-laundering prosecution linked to an alleged police recruitment examination paper leak were rejected for failure to show sufficient cause. The special leave petitions were consequently dismissed as time-barred.

Recall of an ex parte order requires credible proof of non-service, fraud, misrepresentation, or sufficient cause for non-appearance. Notices and hearing communications sent to the appellants' admitted email address and by speed post were treated as served because the emails did not bounce and no material rebutted receipt. The record indicated wilful non-participation, while the recall request was made after about 400 days without a cogent explanation. In time-bound insolvency proceedings, the unexplained delay and absence of sufficient cause supported refusal to recall the ex parte order.

A moratorium under the Insolvency and Bankruptcy Code is confined to the corporate debtor and does not extend to directors, promoters, associated entities or other co-respondents unless expressly provided by statute. A consumer complaint may therefore continue against unprotected co-respondents, whose potential liability must be adjudicated on its merits. The Commission should not terminate proceedings against them at an interlocutory stage by treating the alleged deficiency as exclusively attributable to the corporate debtor while their liability remains unresolved.

Section 16(1)(a) permits the Central Government to direct a company to rectify its name when it independently forms the opinion that the name is identical with or too nearly resembles that of an existing company. An application from an existing company may provide the information that triggers consideration, but does not prevent exercise of this distinct statutory power. Section 16(1)(b), concerning applications by registered trademark proprietors, does not restrict the wider power under Section 16(1)(a). The names were almost identical and the companies operated in the same DNA-testing field; accordingly, the jurisdictional challenge to the name-change direction failed.

A fresh advance-ruling application on the same goods was maintainable because the statutory bar applies only where the question is pending before, or decided by, specified customs, appellate or judicial forums, not by an earlier Authority ruling; additional technical material also supported reconsideration. Off-road mining tyres were classifiable as tyres for construction, mining or industrial handling vehicles and machines because their objective engineering characteristics, including reinforced construction, specialised tread, puncture resistance, load capacity and low-speed design, established their principal intended use in severe off-road operations. Marketing descriptions, rim sizes and possible incidental road use did not alter that classification.

Appellate jurisdiction over baggage-related confiscation orders is statutorily excluded from the Tribunal's jurisdiction. Where gold brought into India as baggage is confiscated and the appeal challenges the Commissioner (Appeals)' order, the proper statutory remedy is a revision application before the Government of India's Revisionary Authority. Filing before the Tribunal may be treated as a bona fide error, but the Tribunal cannot entertain the baggage-related appeal.

Section 28 proceedings against the importer were dropped because the High Court had already found the underlying show cause notice invalid; the adjudicating authority's action was therefore sustained. Penalty for alleged customs contraventions involving defective certificates of origin could not be imposed where neither the notice nor the adjudication established the individual's role or involvement in obtaining those certificates. The importer remained free from the proposed demand proceedings, and the individual's penal liability was set aside.

Concessional customs duty under Notification No. 82/2017-Customs cannot be denied by reclassifying imported synthetic bonded fabrics as bleached and dyed without supporting evidence. The importer's statement established only that the fabrics were synthetic and did not establish bleaching or dyeing. In the absence of a test report or other evidence proving those characteristics, the factual basis for reclassification was unsupported. The exemption benefit therefore remained available to the assessee.

Section 28D of the Customs Act creates a rebuttable presumption that duty incidence has been passed to another person, requiring an importer seeking refund of special additional duty to establish otherwise. Where no prescribed rebuttal method applies, relevant circulars permit reliance on a Chartered Accountant's certificate based on the importer's annual accounts. A certificate confirming that the duty burden was not passed on to buyers is sufficient evidence to rebut unjust enrichment and support the refund claim.

Assessments of persons other than the searched person under Section 153C require satisfaction notes that identify incriminating material for each relevant assessment year and explain its connection with determination of total income. General references to seized digital data, without specifying the material, proposed undisclosed income, or its bearing on the assessee's income, do not satisfy the jurisdictional requirements. On the stated analysis, omnibus satisfaction notes were invalid, and the Section 153C assessments were quashed.

For inherited property, fair market value as on 01.04.1981 may replace cost of acquisition under Section 55(2)(b) where no contrary material challenges the claimed value. Claimed improvement expenditure may be accepted when the Assessing Officer's estimate lacks a proper valuation exercise or reference under Section 55A and available valuation evidence supports substantial construction. Section 54 deduction covers capital gains actually invested in purchase or construction of a residential house by the extended return-filing date under Section 139(4); non-deposit in the Capital Gains Account Scheme by the Section 139(1) due date does not defeat the deduction. Capital-gains computation is accordingly revised using the substituted acquisition value, accepted improvement cost, and full residential-investment deduction.

Denial of an adequate hearing can vitiate assessment and appellate proceedings where assessment follows an incomplete response without awaiting the balance reply or granting a requested video-conference hearing. Additional evidence may be admitted under Rule 29 where it is relevant to effective adjudication and could not be produced earlier for reasons beyond the assessee's control. Deciding an appeal while remand verification remains pending, without a remand report, final hearing, or opportunity to address adverse findings, breaches natural justice. Surviving issues require fresh adjudication after adequate opportunity is provided.

Reassessment notices for assessment year 2015-16 issued on or after 1 April 2021 were required to be dropped under the applicable limitation regime, making a notice issued on 12 April 2022 time-barred and without jurisdiction. Reopening without verifying registered property documents and payment schedules also reflected non-application of mind where those records showed that the relevant payments had occurred earlier. Investment in immovable property must be assessed in the year in which payment is made; registration in a later assessment year does not shift the investment to that year. Accordingly, the reassessment and investment addition for assessment year 2015-16 were unsustainable.

Charitable registration requires a trust's exempt application of income to be confined to India. A trust deed permitting application of income for persons residing outside India is incompatible with that requirement, rendering the trust ineligible for regular charitable registration on its existing terms. Although a substantial filing delay was condoned on a reasonable and bona fide explanation arising from the absence of the person handling the trust's administrative and tax affairs, the registration rejection remained valid because the deed contemplated overseas application of income.

Employee stock-option settlement costs paid to a group entity upon allotment or conversion of stock units are treated as employee compensation incurred for business purposes and deductible as revenue expenditure under Section 37(1), where the corresponding vesting-period provision had been added back and no material factual change exists. For transfer pricing, an operating margin agreed in a Bilateral Advance Pricing Agreement for IT and IT-enabled support services may be applied to an otherwise uncovered Associated Enterprise transaction where the services, functional profile and circumstances are identical. The adjustment is consequently limited to aligning the uncovered transaction's margin with the agreed APA margin.

Actual write-off of pre-2006 NPA debts by a cooperative bank qualifies for deduction where no statutory provision for bad and doubtful debts existed under section 36(1)(viia); the provision-account limitation applies only to debts covered by that provision. Recovery of loans previously written off cannot be added again if it was already credited to profit and loss account and included in taxable income, as this would duplicate taxation. Disallowance of delayed employees' provident fund contributions requires verification of supporting details before applying the governing provisions and relevant Supreme Court ruling; the matter requires fresh determination.