Review of the Supreme Court's earlier dismissal of the special leave petitions was refused because no ground for review was established from the order or record. The Court permitted filing of the review petitions with additional grounds and condoned the filing delay, but declined the request for an open-court hearing. The review petitions were consequently dismissed. The underlying subject concerns refund of an unlawfully collected amount, constitutional invalidity of a levy or premium, unjust enrichment, restitution for payment made under a mistake of law, and the effect of higher courts leaving legal questions open.

Refund of accumulated unutilized Cenvat credit cannot be denied for lack of nexus between input services and exported output services where that nexus has already been settled in the assessee's favour for the relevant services. The earlier appellate basis for rejecting refund had been overturned, and the identical ground could not be used to deny refund for the later period. Consequential relief was available in accordance with law.

Turnover and transaction charges received by a stockbroker are includible in taxable value for service-tax purposes from 16 May 2008 where they constitute the provider's expense. Exclusion applies only when the service recipient is legally liable and the provider pays the amount solely as a pure agent; this condition was not met. Service tax was therefore payable on the charges. Extended limitation applies where the provider consciously fails to disclose liability despite clarification that gross amounts received by stockbrokers are taxable and denial of reimbursement treatment. Non-filing of service-tax returns and deliberate non-disclosure establish wilful suppression, defeating a claim of bona fide belief.

Section 85(3A) of the Finance Act, 1994 requires a service-tax appeal to be filed within two months of receiving the adjudication order and permits condonation for sufficient cause only up to a further one month. The appellate authority lacks jurisdiction to condone delay beyond this statutory outer limit, and the merits of the underlying dispute do not affect the limitation determination. An appeal filed more than seven years after receipt of the original order is therefore barred by limitation and cannot be entertained.

Labour contracts constitute taxable manpower recruitment or supply service where the agreement, read as a whole, appoints a labour contractor, requires labour billing and worker PF and ESIC compliance, and lacks independent output-quality standards or production obligations. Output-based payment does not by itself convert labour supply into job work or a manufacturing contract. An unretracted statement confirming labour-contractor status may be relied on where hearing opportunities were not used. Non-disclosure and non-payment of tax on known taxable labour-supply activity justify extended limitation and penalty. Form 16A receipts may support demand where the taxpayer does not prove they relate to non-taxable activity.

Composite subcontracts involving machinery, labour, fuel, lubricants, spares and other materials may constitute works contract services where property in goods passes in any form by accretion and is leviable as a deemed sale. Separate supply or billing of goods, actual VAT payment, or VAT exemption does not negate that character. Such subcontract services supplied for exempt Government dam and canal works fall within the exemption for sub-contracted works contracts. The extended limitation period cannot apply to a bona fide interpretative dispute without positive evidence of deliberate suppression or intent to evade tax; consequential penalties cannot survive.

Composite construction and sale agreements for residential flats substantially undertaken before 1 July 2010 could not be subjected to service tax on composite consideration where no statutory mechanism existed to segregate goods and service components. Construction for individual purchasers' personal use was also described as falling outside the meaning of a residential complex under the applicable exclusion and departmental clarification. The extended limitation period was not available where the assessee was registered, filed returns, and the dispute involved an unsettled interpretational issue without deliberate suppression or wilful misstatement. Consequently, the service-tax demand, interest and penalties were stated to be unsustainable, subject to verification and adjustment of any late fee paid.

Attached assets covered by an approved resolution plan may be restored to successful resolution applicants under the second proviso to Section 8(8) of the Prevention of Money Laundering Act where they are bona fide claimants with a legitimate interest. The consensual restitution arrangement released the covered bank balances and residential units, and excluded any enforcement lien over assets forming part of the plan. Section 32A of the Insolvency and Bankruptcy Code protected the corporate debtor after resolution, provided the successful applicants lacked links to former management and were not beneficiaries of proceeds of crime. The corporate debtor was removed from the prosecution complaint, while proceedings against former management and other liable persons continued. Questions of law remained open and the order was non-precedential.

Medical circumstances did not warrant interim bail because the medical board found the petitioner clinically stable, while advising continued management and angiography for further evaluation. The pending regular bail petition was already listed before the High Court, and an undertaking ensured appropriate treatment, including angiography if required. The Supreme Court dismissed the special leave petition seeking bail on medical grounds without expressing any view on the merits of the regular bail petition.

Anticipatory bail in a money-laundering investigation was refused after the High Court found the petitioner ineligible for pre-arrest bail on both merits and medical grounds. The Supreme Court dismissed the special leave petition seeking anticipatory bail and disposed of pending applications. The text identifies the twin conditions for bail as part of the subject matter but provides no further reasoning on their application.

Freezing of property under the Prevention of Money Laundering Act was examined for compliance with the statutory requirements governing reasons to believe, retention, and confirmation by the Adjudicating Authority. The material records that the mandatory requirements for freezing and retention under the relevant provisions were complied with before the Adjudicating Authority passed its confirmation order. The Supreme Court declined to interfere with the High Court's orders and dismissed the special leave petitions, leaving the freezing orders and their confirmation undisturbed.

Company-liability provisions under FEMA attach responsibility to a person in charge of business conduct or whose neglect contributes to the company's contravention. Authority to execute export-related banking and transaction documents established responsibility for non-realisation and repatriation of export proceeds; neglect was attributable despite no proven consent, connivance or mens rea. Liability was therefore retained. The monetary penalty was limited to the amount already deposited, modifying the adjudication order while preserving the finding of contravention.

Liquidator appointment under the Insolvency and Bankruptcy Code must give due effect to a unanimous Committee of Creditors recommendation, subject to the statutory grounds for replacement and verification of the proposed professional's subsisting Authorisation for Assignment. A general IBBI communication cannot be used to exclude a recommended insolvency professional where it falls outside Section 34(4) or does not factually apply. An unresolved eligibility objection cannot independently support appointment of another liquidator, but the Adjudicating Authority must verify regulatory authorisation before charge is assumed. Routine liquidation steps already taken may be preserved, with appropriate costs and fees for work genuinely performed.

Unadjudicated interest and damages under provident fund law that remain undetermined and non-final when the corporate insolvency resolution process begins are contingent, uncrystallized liabilities. Although provident fund dues may be excluded from the liquidation estate, a resolution plan need not include such uncrystallized interest and damages. The Committee of Creditors may make a lump-sum provision in its commercial wisdom, but omission does not itself breach the Insolvency and Bankruptcy Code. Resolution applicants are entitled to certainty over assumed liabilities, and a Committee-approved plan may be rejected only on the limited statutory grounds governing plan approval.

An unadjudicated assertion in pleadings before the Supreme Court establishes only that the assertion was made; it neither declares law under Article 141 nor determines an entity's applicable statutory regime. That regime must be assessed under the governing framework based on the entity's objects, activities, operational area and relevant circumstances. Mandamus ordinarily requires a distinct prior demand for performance of a mandatory duty and a subsequent refusal or neglect within a reasonable time. Without evidence of such demand and refusal, and where jurisdiction over the entity is disputed, mandamus is not warranted.

India-UAE CEPA preferential customs duty treatment may not be denied merely because original Certificates of Origin used a tentative or non-prescribed format, named a third-party consignee, or contained an endorsement that did not alter origin, value, or goods description. Certificates issued before notification of the Origin Rules cannot be rejected for failing to meet a later-prescribed format, and the applicable duty rate is determined when Bills of Entry are presented. The Origin Rules permit replacement of erroneous certificates and retrospective issuance within the stipulated period. Where a valid revised certificate is produced in time and origin authenticity is undisputed, procedural discrepancies do not defeat preferential treatment.

Cross-objections under the Customs Act may challenge any adverse part of an order once an appeal is filed, not merely the appellant's grounds. Declared import values cannot be rejected without evidence of a statutory related-party relationship, price influence, additional consideration, or excess remittance; proforma invoices, relationships among persons behind separate entities, and consultancy or investment payments are insufficient. Post-import redetermination of retail sale price lacked statutory machinery for the relevant period, and undisclosed invoices prejudiced the importer's defence. A transdermal foot patch intended for therapeutic relief and improved circulation is classifiable as a medicament, not a skin-care preparation. Consequential undervaluation, confiscation and penalty findings lack foundation.

Amounts paid when filing a bill of entry may remain refundable deposits where imported goods are neither cleared for home consumption nor finally assessed, demanded, or appropriated as customs duty. Where goods are destroyed for failure to meet quarantine requirements before clearance, the taxable event for import duty does not arise. Redemption fine and penalties for the underlying statutory contravention do not change the character of the pre-clearance payment. The analysis therefore treats the payment as a refundable deposit rather than customs duty.

Differential export duty on iron ore fines must be determined by reference to the iron content, condition and weight of the goods at the time of export, including moisture. Departmental test reports obtained months after sampling and tested on a dry basis cannot reliably establish the iron content of exported goods at the relevant time. Where the exporter's reports showed iron content below the concessional-duty threshold, the delayed reports could not support a differential-duty demand. A prior decision on the identical issue was treated as governing the matter, rendering the demand unsustainable.

Punitive action against an authorised courier for concealed contraband requires evidence of knowledge, wilful contravention, or failure to exercise due diligence. The inquiry found no evidence linking the courier to the concealed gold or showing knowledge of it; the concealment was detectable only through Customs X-ray examination, facilities unavailable to the courier when receiving the cargo. As the courier acted bona fide and exercised due diligence, and the proposed Customs Act penalties were dropped, punitive measures under Regulation 14 were not justified.