Intermixing superior kerosene oil (SKO) with high-speed diesel or motor spirit during pipeline transfer does not constitute manufacture under Section 2(f) of the Central Excise Act, 1944, where the goods are not listed in the Third Schedule to the Central Excise Tariff Act, 1985. A departmental circular cannot, without statutory support, require duty on SKO at the higher HSD/MS rate. Nor can manufacture be sustained on a ground absent from the show-cause notice. Consequently, the higher differential central excise duty demand on interface-SKO clearances was unsustainable.

Cenvat credit is admissible on group mediclaim and group personal accident insurance policies obtained for employees where they are connected with employment and employer liability. The exclusion in Rule 2(l)(C) applies to specified services, including life and health insurance and vacation travel benefits, when used primarily for employees' personal use or consumption. Policies not obtained for vacation purposes and distinguishable from life-insurance policies specifically covered by the exclusion do not fall within that bar. Accordingly, employer-provided group medical and personal accident cover qualifies for Cenvat credit.

Composite irrigation-canal contracts involving labour and transfer of property in goods, with VAT paid on the goods component, fall outside Management, Maintenance or Repair Service, which applies to service contracts simpliciter. The resulting service-tax demand is unsustainable. Extended limitation requires deliberate suppression or intent to evade tax; payment of VAT and the absence of such intent do not support its invocation. A one-time manpower supply activity may be taxable in nature, but no demand survives where its taxable value, after excluding exempt values, remains below the applicable threshold exemption.

Activities of an organisation formed by women workers to provide training, employment security and direct client engagement did not amount to manpower recruitment or supply agency service, because it was comprised of the workforce rather than supplying manpower as a service. The service-tax demand was therefore unsustainable. Reimbursed wages paid to members performing the work could not be included in taxable value unless established as consideration for a taxable service. As the remaining registration fee was negligible and below the taxable limit, adopting gross collections without excluding wage reimbursements was unsustainable.

Composite construction contracts involving both material supply and civil construction activity were not liable to service tax before works contract service became taxable on 1 June 2007. The applicable framework did not permit taxing such indivisible works contracts during the earlier period. Service tax and applicable interest voluntarily paid for the period from 1 June 2007 to March 2008 were subject to appropriation. Consequently, the pre-1 June 2007 demand and related penalties were set aside, while appropriation of tax and interest for the subsequent period was sustained.

Indirect-tax refund requires the claimant to establish independently that the tax incidence was not passed to the service recipient. A non-levy or non-recovery notification concerning electricity transmission and distribution services protects against recovery of tax not levied, but does not itself create an unconditional right to recover tax already collected and deposited. A non-taxability clarification likewise does not remove refund requirements. Where contractual consideration is inclusive of Service Tax, the statutory presumption of passing on applies unless rebutted by primary records, such as invoices, ledgers, credit notes, reduced consideration, or proof of repayment to the recipient.

Mere sub-letting of hoarding sites to advertising agencies before 1 May 2006, without supplying services within the taxable category, did not attract service tax as Advertising Agency Service. For the period after 1 May 2006, extended limitation was unavailable where advertising agencies discharged tax on client consideration, including hoarding-space charges, making the arrangement revenue-neutral. Demand particulars derived from statutory records, regular returns were filed, and no positive concealment was identified. A bare allegation of suppression could not displace the bona fide interpretational dispute arising amid conflicting views; the related tax demand, interest and penalties were unsustainable.

Clinical-trial testing and analysis performed by a clinical research organisation for sponsors holding trial approvals falls within the service-tax exemption where separate approval for the organisation is not issued under the regulatory framework. Strict construction does not justify imposing an impossible approval condition. Employee bond-forfeiture recoveries following premature resignation are compensatory for breach of a service commitment, not consideration for commercial training, coaching, or tolerating an act. Extended limitation requires fraud, suppression, or contravention with intent to evade tax; prior disclosure and a tenable exemption belief do not meet that standard. Consequently, no interest or penalties arise where the underlying tax demands fail.

Under the Prevention of Money Laundering Act, 2002, a panchnama does not replace disclosure of documents relied upon to authorise retention of seized material. Affected persons must receive those documents to make an effective response; non-supply denies a fair opportunity, although fresh proceedings or remand may be inequitable after substantial delay and filing of a prosecution complaint. Retention is justified only where seized material is relied upon in a prosecution or supplementary complaint and is necessary to prove allegations at trial. Material not so relied upon must be released within a reasonable time, while authenticated photocopies may be retained and evidentiary documents kept until trial concludes.

Equivalent-value attachment under the Prevention of Money Laundering Act requires a demonstrable nexus between the targeted property and proceeds of crime, including evidence that tainted funds were passed on or layered and are unavailable for direct attachment. A subsidiary relationship or an unrelated gift to a holding company does not, by itself, establish that nexus or justify disregarding separate corporate identity. Provisional attachment also requires a substantiated likelihood that property will be concealed, transferred, or otherwise dealt with to frustrate confiscation. Existing mortgages, arbitration measures, and insolvency proceedings subjecting property dealings to the NCLT process do not establish that risk. Dealings with the properties remain governed by the insolvency process.

Provisional attachment under the Prevention of Money-Laundering Act may extend to proceeds of crime held by any person, including a person not named as an accused in the FIR or ECIR. Sections 5 and 8 focus on tracing and freezing tainted property rather than the holder's accused status. Where the property holder fails to establish disclosed, ancestral, or other legitimate sources capable of explaining acquisition, the statutory burden remains undischarged and attachment may be sustained. A prior Supreme Court order warrants release only where it demonstrably concerns the attached properties and directs such relief.

Anticipatory bail in Prevention of Money Laundering Act proceedings remains an extraordinary discretionary remedy, granted sparingly in economic-offence investigations. Section 45 imposes twin conditions for bail, alongside safeguards governing arrest and bail. The necessity of arrest under Section 19(1) is an additional consideration, but prima facie material indicating the petitioner's involvement in the alleged offence weighed against relief. Anticipatory bail was therefore denied.

Going-concern sales in liquidation may receive consequential directions needed to implement the sale effectively, including recognition of revised shareholding and listing arrangements, release of charges, updating credit records, unfreezing accounts, continuity of litigation under new management, continuation of subsisting licences and entitlements, and change of corporate status from liquidation to active. These measures operate subject to applicable filings, fees, ownership-change compliance and independent statutory powers. The clean slate doctrine prevents pre-transfer unpaid claims from being imposed on the purchaser after distribution of sale proceeds. Relief cannot, however, preserve all receivables, create a fresh limitation period, waive stamp duty, taxes or registration charges accepted under sale terms, or grant concessions beyond the transaction documents.

Company-affairs investigations require the Tribunal to satisfy the statutory conditions for investigation, record rational reasons demonstrating necessity, apply its mind to the prescribed circumstances, and give the affected company or persons a reasonable opportunity of hearing. These safeguards apply before investigative steps are initiated or external agencies are asked to provide tracking information, because such directions may have civil, economic and reputational consequences. Directions to the Enforcement Directorate and Central Bureau of Investigation for tracking information issued without recorded satisfaction, reasons or prior hearing are unsustainable. Any reconsideration of their necessity must follow a hearing and an order made in accordance with law.

Restricted import of second-hand goods, other than capital goods, requires authorisation under the Foreign Trade Policy. Their restricted status may make them liable to confiscation, but does not by itself justify absolute confiscation. Denial of redemption on payment of fine requires specific, reasoned exercise of discretion under the Customs Act; absent recorded reasons, redemption should remain available. Penalties for improper importation and penalties for false or incorrect declarations rest on distinct statutory bases. A penalty imposed under one provision cannot be enhanced or substituted under the other without the requisite legal basis. The original redemption option and penalty framework were restored.

Extended limitation for customs duty requires deliberate non-disclosure of material facts with intent to evade duty; prior departmental knowledge and acceptance of the declared classification therefore precluded extended-period liability. Specific classification of woven warp cut-pile fabrics under CTH 5801, rather than headings based on constituent textile material, applied because the pile-fabric heading governed their essential character; the live consignments remained so classified. Alternative CVD and SAD exemption claims may be raised after clearance absent fraud but require fact-based determination of notification conditions, requiring remand for merits review. Prior acceptance also negated blameworthy conduct, so confiscation and penalties did not survive.

Directorate of Revenue Intelligence officers appointed as customs officers and assigned proper-officer functions may issue recovery notices under the Customs Act. Assignment of functions relating to assessment and recovery distinguishes the statutory roles under the relevant provisions and defeats a jurisdictional objection to such notices. Personal penalties for smuggling prohibited goods are sustainable where an admitted arrangement with de facto importers enabled clearance of concealed goods for cash consideration, demonstrating an active and serious role in the operation. The recovery notice and penalties consequently remain valid on these grounds.

Excess export duty first quantified through departmental reassessment is governed by the reassessment date for refund limitation and statutory interest. Refunds based on an alleged legal error must follow the self-contained mechanism under Section 27 of the Customs Act; the Limitation Act and Article 265 cannot independently override that regime. Where the excess payment was not reflected in the original assessment records, reassessment ascertains the refund entitlement, rendering a pending correction request and refund claim maintainable. Interest under Section 27A runs after three months from reassessment until actual payment, at the notified rate.

Section 110A permits bond, security and conditions for provisional release pending adjudication, but requires a case-specific and proportionate exercise of discretion. For non-prohibited goods involving tariff classification and differential-duty disputes, security should correspond to the disputed duty and be assessed on relevant material, including classification test reports. Compliance with interim security to maintain business operations does not end the importer's grievance or appellate entitlement. A tribunal cannot treat revenue protection as sufficient and dispose of the challenge without deciding the validity and extent of the security demand on merits.

Statutory revision under the Customs Act is the appropriate forum for examining confiscation of baggage goods where the alleged waiver of notice and hearing, oral show-cause notice, and their voluntariness and legal effect are disputed. Although an alternative remedy does not absolutely bar writ jurisdiction under Article 226, its exercise is discretionary and is unsuitable where contested factual questions require examination of the record. The legality of confiscation, penalty, and compliance with the notice requirement remains open for determination by the revisional authority in accordance with law.