Goods Transport Agency classification requires both provision of transportation-related service and issuance of a consignment note. Receipts from hiring lorries owned or operated by the service provider, without consignment notes, do not meet that definition. Such receipts also cannot support service-tax liability under clearing and forwarding service where that taxable category is not established by the nature of the activity. The service-tax demand and consequential liabilities are therefore unsustainable.

Limitation for an appeal under Section 85(3A) of the Finance Act, 1994 runs from receipt of the Order-in-Original rather than its date. Dispatch is treated as the filing date. Where an appeal was dispatched six days after the two-month period but within the further one-month condonable period, resetting an old service-tax password and obtaining prior records constituted bona fide sufficient cause. The delay was therefore condonable, making dismissal solely on limitation unsustainable.

Service-tax valuation for renting of immovable property is confined to the gross consideration charged by the service provider for the taxable service. Renovation and upgradation costs independently incurred and capitalised by the service recipient, paid directly to third parties, and neither controlled by the provider nor shown to be consideration or a condition of renting, fall outside the taxable value. Rule 3(b) of the Service Tax (Determination of Value) Rules, 2006 cannot expand the statutory valuation base under the Finance Act, 1994. Tax liability therefore remains limited to the lease consideration actually received, and penalties linked solely to an enhanced valuation demand do not survive.

Service tax on ocean freight under the reverse charge mechanism cannot be demanded from an Indian importer where goods are supplied on CIF terms. The overseas seller is the recipient of the sea-transportation service, while the Indian importer is neither the service provider nor the service recipient. Binding rulings on this position require application in the absence of a stay, and subsequent decisions, including rejection of a similar Revenue challenge, support the same result. The reverse-charge demand is therefore unsustainable against the importer.

Limitation for an appeal from an adjudication order runs from receipt of the order, not its dispatch. Valid service requires proof that the order was served in the prescribed manner; dispatch alone does not establish communication. In the absence of evidence of earlier service, the appeal filed after receipt of the certified copy was within time. Ex parte adjudication without proof that the assessee knew of the proceedings denies an effective opportunity of representation and breaches principles of natural justice. The limitation rejection could not stand, and the merits required adjudication after a reasonable opportunity to respond.

Target-based and other manufacturer incentives received by an authorised vehicle dealer operating on a principal-to-principal basis are trade discounts or price adjustments, rather than consideration for a taxable service, where the dealer resells vehicles and parts for its own profit. Increased manufacturer sales are incidental, and meeting sales targets is only a condition for a discount unless the dealer assumes an enforceable, identified obligation in return. Section 66E(e) requires an agreement expressly obliging a person to do, refrain from doing, or tolerate an act, with consideration specifically linked to that obligation. Without that contractual nexus, incentives, support and reimbursements do not attract service tax or consequential penalties.

Verification of discrepancies between Form 26AS receipts and ST-3 returns should cover corrected challans, tax payments, and reconciliation evidence. Where differential receipts represent customer advances invoiced later, the timing of service-tax discharge in the succeeding period requires examination. Production of supporting documents and a hearing are necessary before fresh adjudication; the matter was remanded to the original adjudicating authority for that verification.

Trading or sales involving transfer of title in goods fall outside the statutory definition of service, while renting a residential dwelling for hostel accommodation is excluded from service tax as residential use. Extended limitation requires evidence of deliberate suppression, fraud, or wilful misstatement intended to evade tax; disclosures and a reasonable view of non-taxability defeat its use. Form 26AS and income-tax return data alone cannot establish a taxable service, the parties to it, or consideration paid for it. Accordingly, these receipt categories do not support a service-tax demand or consequential liabilities.

Section 126 of the Finance (No. 2) Act, 2019, read with Rule 6 of the Sabka Vishwas (Legacy Dispute Resolution Scheme) Rules, 2019, requires the Designated Committee to verify departmental records, the declarant's disclosure, and supporting material before determining the amount payable. The Scheme provides specified relief on tax dues, subject to its conditions, and does not permit refunds. Materially inconsistent Forms SVLDRS-3 issued on the same date, without verification of disclosed payments and documentary evidence, cannot support a valid determination. A fresh determination requires complete verification of the declaration and supporting records.

Rectification proceedings concern correction of a clerical mistake said to have inadvertently appeared in a prior judgment. The Directorate of Enforcement filed the application, but no representative appeared to argue it. The public prosecutor was directed to notify the Directorate's office, and the matter was listed for a later date. No determination on the requested correction is recorded.

At the discharge stage, material must be assessed only for a prima facie case or strong suspicion; a roving inquiry or trial-like weighing of evidence is impermissible. Bank transfers, statements recorded under the Prevention of Money Laundering Act, and corroborative accounts of cash arrangements and delivery indicated that the transfers were not supported as ordinary business transactions. Knowingly assisting or participating in a process connected with proceeds of crime constitutes money laundering. The material therefore raised strong suspicion of knowing involvement in facilitating the transfer of proceeds of crime, and discharge was unwarranted.

Money-laundering proceedings under the PMLA raise issues concerning discharge and framing of charges, the statutory meaning of "proceeds of crime", and the character of money-laundering as an independent offence. Key questions include the admissibility of statements recorded under the PMLA, the need for prior sanction to prosecute a public servant, and whether evidence establishes a link between the accused and alleged criminal proceeds. The existence of a traceable money trail is also material to assessing the evidentiary basis for the charge.

Section 61(2) of the Insolvency and Bankruptcy Code requires an appeal within 30 days, with condonation for sufficient cause limited to a further 15 days. Time spent obtaining a certified copy cannot be excluded where the order was pronounced, uploaded on the same date, and publicly announced, particularly when administrative impediments and diligent pursuit of the copy remain unsubstantiated. Knowledge of the order does not extend limitation. Appeals filed beyond the non-extendable outer limit are not maintainable.

Section 96 of the Insolvency and Bankruptcy Code imposes an interim moratorium on legal actions concerning debt during the moratorium period, but its scope is confined to civil debt-recovery actions. Criminal prosecution for cheque dishonour under Section 138 of the Negotiable Instruments Act remains outside that protection because it safeguards the credibility of negotiable instruments and enforces personal accountability. Accordingly, an interim moratorium does not bar or stay cheque-dishonour proceedings.

Retrospective renewal of an expired Way Leave Permission cannot revive rights that lapsed before corporate insolvency resolution proceedings or impair intervening authorised works. Fresh permission remains within the Railway authorities' competence and requires compliance with applicable engineering standards. A comprehensive safety audit and an opportunity of hearing are necessary where a proposed structure may affect existing underpasses, adjoining property or public safety. Persons facing potential adverse civil consequences have standing to challenge such administrative permission. Fraud or collusion requires proof beyond reasonable doubt; invalidity of the permission alone does not establish either allegation.

Article 141 makes the Supreme Court's declared law and unambiguous directions binding on all courts. A trial court must implement an express direction for immediate vacant possession where an undertaking binds all accused; it cannot use inherent jurisdiction under the Bharatiya Nagarik Suraksha Sanhita, 2023 to reinterpret, dilute, or sit in appeal over that direction. A pending review petition does not suspend the operative force of the judgment unless the Supreme Court grants a stay, modification, or suspension. The direction requiring the accused to vacate the residential quarters therefore remains enforceable.

Technical meaning governs the scope of the customs concession for Train Protection and Warning System (TPWS) equipment. Railway specifications distinguish track-side and on-board TPWS signalling equipment from interfaces with brake-control systems. Disc Brake Units and Pole Wheels, which form part of axle-mounted disc braking and wheel-slide protection systems, therefore do not qualify as TPWS parts or components and cannot receive the concessional duty rate. Strict construction requires the exemption claimant to establish square coverage. Where a notice invokes only the normal limitation provision for duty recovery, differential duty may be demanded only for Bills of Entry within that period; recovery beyond it requires invocation of the extended-period provision.

Under the Customs Act, the burden-shifting presumption for gold arises only where seizure rests on a seizing officer's reasonable belief, supported by definite and objective material, that the goods are smuggled. Without that foundation, the Department must independently establish illicit importation through cogent evidence before confiscation or penalties can follow. Domestic procurement records, payment trails, stock and tax records, and transport or melting documents require effective rebuttal; uncorroborated or retracted statements alone do not prove smuggling. Cross-examination is required when specifically sought for relied-upon witness statements; absent such a request, its non-grant does not itself breach natural justice.

Under Advance Authorisations, the physical-incorporation requirement for satisfying export obligation applies to imported inputs used in the resultant export product. Imported Vetted Malt Scotch physically incorporated in exported IMFL meets that condition; separately procured duty-free bottles, caps and labels used only for packing do not constitute inputs physically incorporated in IMFL. Their use therefore does not, by itself, breach the relevant exemption condition or invalidate export-obligation fulfilment. For customs-duty recovery, DRI officers may issue notices when appointed as customs officers and assigned the relevant recovery function, which is distinct from assessment.

Provisional release of seized betel nuts under the Customs Act was not warranted where testing did not establish unequivocal Indian origin. Initial sampling indicated resemblance to Indonesian areca nuts and mould infestation; re-sampling reported Indian origin but did not address mould. Food-laboratory findings that the nuts were mould- and insect-damaged beyond prescribed limits, sub-standard and unsafe supported non-release. The availability of an appellate statutory remedy meant that challenges concerning seizure and release could be pursued through that remedy.