Indivisible turnkey ATM supply, installation and commissioning contracts executed before 1 June 2007 could not be split to levy service tax on a notional commissioning or installation component. Where the contract provided a single composite consideration and installation and commissioning were integral to delivering functional ATMs, the then-applicable charging and valuation provisions did not permit segregation of an embedded service element. A valuation exercise could not create a taxable event or support attribution of part of the consideration to taxable services. The subsequent works-contract entry and valuation mechanism confirmed the earlier framework did not cover such indivisible composite contracts.

Article 226 judicial review, read with Section 482 CrPC, may be invoked to examine the legality of an Enforcement Case Information Report (ECIR) and consequential proceedings under the Prevention of Money Laundering Act. An ECIR's character as an internal administrative record does not restrict constitutional review where it triggers coercive measures such as search, seizure, attachment, arrest or prosecution. The ECIR and resulting action form a single cause of action. Where the predicate offence has ceased following acceptance of a closure report, the continued legality of money-laundering action founded on that offence is open to judicial scrutiny. The preliminary objection to writ maintainability is rejected.

Provisional attachment orders are described as raising questions about the Enforcement Directorate's authority and jurisdiction to attach property, the requirement of a "reason to believe" that property constitutes proceeds of crime involved in money laundering, the effect of withdrawing concessions made by counsel, and the meaning of "proceeds of crime." The text further records that delay was condoned and the special leave petitions were dismissed without interference with the impugned judgments and orders.

Replacement of an interim resolution professional or resolution professional is governed by the Committee of Creditors' statutory voting process under the Insolvency and Bankruptcy Code. Admission of homebuyers' claims affecting other creditors' voting shares, or admission of a claim below the amount asserted, does not alone demonstrate lack of integrity or justify removal. Where the professional entity's appointment and fees have Committee approval, and the relevant contract resolution remains unimplemented, creditor-group conflict does not displace majority class support for the professional. Tribunal intervention in replacement decisions is confined to exceptional circumstances, which were not established; challenges to a later appointment may be pursued before the appropriate forum.

Section 60(5) of the Insolvency and Bankruptcy Code confers broad jurisdiction over questions connected with an insolvency resolution process. Recovery of electric vehicles owned by one corporate debtor and leased to another directly concerned preservation and control of the owner's assets. Suspended directors of the lessee corporate debtor had acknowledged responsibility to provide available information and assistance regarding those vehicles. A direction requiring their cooperation to identify and recover the leased assets was therefore stated to fall within the Adjudicating Authority's jurisdiction.

An unpaid security-service claim may be submitted in the company's ongoing Corporate Insolvency Resolution Process before the NCLT. The service provider may join the insolvency proceedings and place its claim for unpaid security-service charges before that forum for consideration.

Pelargonium sidoides root extract with Maltodextrin is classifiable as an other vegetable extract under Customs Tariff Item 1302 19 19 where processing consists of hydro-ethanolic extraction, filtration and solvent removal without purification or high-refinement processes. Maltodextrin functions as an inert carrier and does not create a medicinal mixture, while bulk import and intended downstream pharmaceutical use do not determine classification. The product consequently falls within the relevant exemption entry under Serial No. 37 of Notification No. 45/2025-Customs, subject to fulfilment of notification conditions and assessment-stage verification. The earlier classification premise of concentration was corrected as unsupported by the factual record.

Unauthenticated foreign customs intelligence and electronic printouts, without verification of origin certificates or independent corroboration, cannot establish misdeclaration of imported goods' country of origin; origin-based confiscation and related demands were therefore set aside. Goods already examined and cleared for home consumption could not later be confiscated for alleged phytosanitary non-compliance, while seized consignments lacking mandatory phytosanitary certificates remained confiscable, subject to a redemption option and production of the required certificate. Penalties under Section 112 of the Customs Act could not be imposed because the show cause notices had not proposed them, and those penalties were set aside.

Duty demand against an importer using transferable DFIA licences cannot rest solely on alleged fraudulent procurement by the exporter where those allegations remain unestablished and the licences have not been cancelled. A bona fide purchaser of transferable licences cannot be treated as involved in a fraudulent import method merely because of alleged irregularities in the exporter's licence procurement. As no sustainable charge existed on the merits, invoking the extended limitation period was also unjustified. The demand was therefore unsustainable on both merits and limitation.

Plant-related items, including parts, spares and accessories used for manufacturing-facility modernisation and expansion, fall within the broad definition of capital goods under Notification No. 104/2009-Cus. where they have the required manufacturing nexus. The notification covers plant, machinery, equipment and accessories required directly or indirectly for manufacture, including replacement, modernisation, technological upgradation and expansion. The restriction on components, spares and parts applies only where they relate to capital goods imported earlier; it does not limit imports of capital goods, including accessories, not previously imported. Accordingly, the described imports qualify for the exemption and the duty demand, interest and penalty are unsustainable.

Declared customs transaction values cannot be rejected on third-party investigation material, indicative market data or suspicion without cogent importer-specific evidence of undervaluation. The Revenue must establish a business nexus, parallel invoices, extra consideration, clandestine remittance or comparable incriminating circumstances; similarities with other importers' prices are insufficient. Transaction value remains the primary basis, and enhanced valuation requires a reliable foundation and proper sequential consideration of valuation methods before using the residual method. Contemporaneous imports and the reliability and comparability of price-publication data must be addressed. Operative comparable Tribunal rulings and final appellate assessments concerning the same imports reinforce the requirement of judicial discipline and support rejection of unsustainable valuation enhancements and consequential liabilities.

Export duty exemption for iron ore fines depended on Fe content being below the applicable threshold. Contemporaneous CRCL, Visakhapatnam testing of Customs-drawn representative samples showed Fe content below 58%, corroborated by load-port and discharge-port reports, contractual quality adjustments, and realised export proceeds. A re-test requires objective and legally sustainable grounds and cannot arbitrarily displace reliable contemporaneous evidence. The later CRCL, New Delhi re-test, reported over a year after export, was unreliable because prolonged storage and moisture loss could affect dry-basis Fe determination, and no scientific or procedural defect in the earlier evidence was established. The belated re-test could not support denial of exemption or levy of export duty and cess.

Declared transaction value cannot be rejected on suspicion, unverified third-party import data, uncorroborated statements, or electronic records lacking the required statutory certification and proof of integrity. Uniform loading is unsustainable where the alleged comparable imports are not shown to match the goods in grade, quality, quantity, commercial level, or time. Extended limitation for customs duty recovery requires evidence of fraud, collusion, wilful misstatement, or deliberate suppression with intent to evade duty; prior disclosure and assessment of import details defeat that basis. Where the duty demand fails and no link to a customs offence is established, seized currency and investigation deposits must be released or refunded with applicable interest.

Challenges to seizure of gold and pending customs show-cause proceedings were left for statutory adjudication rather than determined in writ jurisdiction. The Additional Commissioner of Customs was identified as the available forum to determine the parties' competing claims. No view was expressed on the legality of the seizure, the show-cause notice, or the merits. Petitioners were directed to place further material before the customs authority and participate in proceedings, which must conclude by a reasoned order after a fair hearing. The writ petitions were kept pending and adjourned sine die until adjudication is completed.

Pending representations for provisional release of seized imported goods and currency must be considered by the proper customs officer in accordance with law. The claimant may supplement the representations and is entitled to prior notice and an opportunity of hearing. The officer must issue a reasoned decision within three weeks. The merits of the seizure, the provisional release claim, and the challenge to the subsequent seizure memorandum remain open.

Interim stay of an order declaring an earlier advance ruling void ab initio was refused because a stay would revive that ruling despite the impugned finding of misrepresentation of material facts. The scope of the power to invalidate an advance ruling, the alleged misrepresentation, and procedural fairness were identified as issues requiring detailed examination at final hearing. The appeal was admitted for final adjudication, but interim relief was denied.

Provisional attachment under the Prohibition of Benami Property Transactions Act requires the Initiating Officer to form an opinion, supported by a factual basis, that the person in possession may alienate the property during the notice period. Cash and gold already seized and attached by the Income Tax Department remained outside the appellants' control, with no established risk of alienation. The possibility of a future tax adjustment or release did not satisfy this statutory condition. Provisional attachment and its confirmation were therefore unsustainable, without preventing fresh action if a risk of alienation arose after release.

Benami ownership requires affirmative proof that another person provided consideration and that the property is held for that person's benefit; corporate ownership and recorded funds are not conclusive, and the burden remains on the Initiating Officer. Acceptance of an investment as explained in income-tax assessment does not bar benami proceedings, but findings accepting the banking trail, loans and advances must be considered. A benami finding founded on a retracted third-party statement requires meaningful cross-examination and entity-specific examination of documented funding sources. Without these safeguards and independent evidence, the finding is vitiated and requires fresh fact-finding.

A section 148 notice issued on 23 July 2022 for assessment year 2015-16 was described as invalid because notices issued on or after 1 April 2021 for that year fell outside the period permitted by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The reassessment had originated under the earlier regime, followed by proceedings under section 148A and a fresh notice. The text notes that the Revenue conceded the point and that cited decisions supported dropping such notices. Consequently, the notice was quashed and the reassessment could not survive.

Faceless reassessment schemes issued under section 151A require initiation of proceedings, including orders under section 148A(d) and notices under section 148, through automated allocation and the mandatory faceless mechanism under section 144B. A Jurisdictional Assessing Officer cannot initiate such proceedings outside that prescribed mode after the schemes commenced. Departure from the mandatory statutory procedure invalidates the initiation and deprives the consequential reassessment of valid jurisdiction. Accordingly, an order under section 148A(d) and notice under section 148 issued by a Jurisdictional Assessing Officer are illegal, and the resulting reassessment is liable to be quashed.