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  • Himachal Pradesh High Court: Pending CBI or Vigilance Inquiry Cannot Justify Interference with Arbitral Award Under Section 37

    Himachal Pradesh High Court: Pending CBI or Vigilance Inquiry Cannot Justify Interference with Arbitral Award Under Section 37

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 02.11.2026

    Himachal Pradesh High Court: Pending CBI or Vigilance Inquiry Cannot Justify Interference with Arbitral Award Under Section 37

    This Short Article has been prepared & written by Arbitrator Shobhit Malik. The views expressed are based on his interpretation of the law. He can be reached at his mob no- +91 9712924188 and email id shobhit.Ica23@gmail.com.

    The Himachal Pradesh High Court has dismissed the Union of India’s appeal against an arbitral award in favour of contractor Pramod Sood, reaffirming that courts have only a narrowly limited role in reviewing arbitration decisions under the Arbitration and Conciliation Act, 1996.

    Background of the dispute

    The dispute arose from work relating to the trenching and laying of optical fibre cable (OFC). Pramod Sood, the claimant, pursued arbitration following directions of the High Court. The sole arbitrator, V.K. Khurana, issued an award on 21 July 2006.

    The Union of India and another party challenged that award before the District Judge, Shimla, under Section 34 of the Arbitration and Conciliation Act, 1996. Their objections were dismissed on 1 September 2011. They then appealed to the High Court under Section 37(1)(b) of the Act.

    Grounds raised by the Union of India

    The appellants argued that the award was founded on surmises and conjectures. They also relied on the fact that records connected with the work had been seized by the Central Bureau of Investigation in 1997 and that a vigilance inquiry had earlier been underway.

    According to the Union of India, requiring payment while those inquiries remained pending could undermine the purpose of examining alleged irregularities. It further challenged the award of interest at 14% per annum from 1 November 1996, contending that Clause 16.2 of the contract barred interest on earnest money, security deposits, or sums payable to the contractor.

    High Court’s reasoning: Section 37 review is highly restricted

    Justice Virender Singh held that an appeal under Section 37 is not a routine appeal on facts or contractual interpretation. Where an arbitral award has already survived a challenge under Section 34, the appellate court’s scope is even narrower.

    The Court relied on Supreme Court guidance in Konkan Railway Corporation Ltd. v. Chenab Bridge Project Undertaking and Bombay Slum Redevelopment Corporation Pvt. Ltd. v. Samir Barain Bhojwani. These decisions establish that courts should not set aside an award merely because another interpretation of the evidence or contract is possible.

    Interference is justified only where the award is perverse, manifestly arbitrary, or otherwise falls within the limited statutory grounds under Section 34. Under Section 37, the court primarily examines whether the Section 34 court exercised that limited jurisdiction correctly.

    CBI seizure and vigilance inquiry did not invalidate the award

    The High Court found that the CBI seizure of records and the vigilance inquiry did not affect the merits of the arbitral determination. The arbitrator had decided the dispute after providing both sides an opportunity to present their case.

    The District Judge had also considered this issue. The High Court noted that the appropriate stage to raise such objections was when the application under Section 18 of the Act was being considered. Crucially, the appellants did not show how the award violated public policy.

    Decision

    The High Court found no basis to interfere with the District Judge’s well-reasoned order dismissing the Section 34 objections. The appeal under Section 37 was therefore dismissed, along with any pending applications.

    Key legal takeaway

    The decision reinforces the finality of arbitration in India. A party challenging an arbitral award cannot succeed under Section 37 simply by offering a different reading of the facts or contract. It must demonstrate a serious legal defect, such as perversity or manifest arbitrariness, within the narrow limits set by the Arbitration and Conciliation Act, 1996.

    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: Himachal Pradesh High Court

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  • Bombay High Court Upholds Compassionate Appointments After Years of Service

    Bombay High Court Upholds Compassionate Appointments After Years of Service

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 02.11.2026

    Bombay High Court Upholds Compassionate Appointments After Years of Service

    This Short Article has been prepared & written by Advocate Madhumita Jha. The views expressed are based on her interpretation of the law. She can be reached at her mob no- +91 8726929060 and email id jhamadhumita27@gmail.com .

    The Bombay High Court has set aside attempts to cancel the compassionate appointments of two Maharashtra government employees after finding that the State had wrongly treated their deceased fathers’ posts as Group B solely because of the pay scale attached to them.

    Background of the dispute

    The case combined petitions filed by Avinash Kondiram Wagh and Abhay Chandrakant Khond against the State of Maharashtra and officials in the Vocational Education and Training Department.

    Both petitioners had received government employment on compassionate grounds after their fathers died while in service:

    • Avinash Wagh was appointed as a Group Instructor in 2004 after his father, a junior clerk, died in service.
    • Abhay Khond was appointed as a Junior Clerk-cum-Typist in 2008 after his father, a Training Officer, died in service.

    They completed probation, were confirmed in service, and continued working for years. In 2010, however, departmental authorities issued show-cause notices proposing to cancel their appointments. The authorities argued that the posts held by the deceased employees carried the pay scale of Rs. 6,500–10,500 and therefore fell within Group B, whose dependants were allegedly not eligible for compassionate appointment under the policy then relied upon by the State.

    The Maharashtra Administrative Tribunal dismissed the petitioners’ challenges in 2014. The High Court had meanwhile protected their employment during the litigation.

    Court’s key finding: Pay scale alone does not determine classification

    The central issue was whether the State could classify the relevant posts as Group B merely because of their pay scale.

    The Division Bench held that it could not. It found that the authorities had selectively relied on the Government Resolution of 2 July 2002 and an internal departmental letter dated 19 May 2010, without considering later government resolutions that specifically classified the posts in question.

    For Wagh’s case, the Court noted that multiple government resolutions treated the post of Group Instructor, carrying the disputed pay scale, as a Group C (Technical) post. These included resolutions dated:

    • 22 October 2008;
    • 31 March 2010;
    • 14 May 2010; and
    • 31 August 2010.

    The State did not establish that any of these resolutions had been withdrawn, superseded, or invalidated. The Court also observed that the departmental letter did not reconcile its position with these specific classifications.

    In Khond’s case, the respondents had admitted that his father was employed in a Class III post. The Court found no valid basis for subsequently treating that post as Group B. Khond himself had been appointed to a Group C post as Junior Clerk-cum-Typist.

    Long service and absence of wrongdoing mattered

    The High Court also relied on fairness and equity. Both petitioners had been appointed by competent authorities, completed probation, and served continuously for nearly two decades. Neither was accused of fraud, misrepresentation, suppression of facts, or misconduct.

    The Court held that it would be seriously prejudicial and disproportionate to unsettle their employment after such a long period, particularly because they had crossed the usual age limits for entering government service.

    Referring to the Supreme Court decision in Md. Zamil Ahmed v. State of Bihar, the Court reiterated that the State should not take advantage of its own alleged mistake after a long delay when the employee had not secured appointment through deception or concealment.

    Compassionate appointment is a beneficial measure

    The judgment restated that compassionate appointment is an exception to ordinary recruitment rules. Its purpose is to provide immediate financial support to a family facing hardship after the death of its earning member.

    The Court held that cancelling confirmed appointments decades later would undermine that objective. Once the petitioners had become confirmed employees, their service could not be taken away except in accordance with law and applicable service rules.

    The Court also noted that Maharashtra expanded its compassionate-appointment policy in September 2021 to cover dependants of employees in Groups A and B as well as Groups C and D. While this later policy did not retrospectively decide the petitioners’ entitlement, it showed that the earlier restriction had since been broadened.

    Outcome

    The High Court allowed both writ petitions and set aside the Tribunal’s 2014 order insofar as it had dismissed the petitioners’ original applications. The proposed cancellation of their compassionate appointments was held unsustainable.

    The ruling is expressly confined to the particular facts of these cases and is not to be treated as a precedent for other matters. Its core message is nevertheless clear: government authorities must consider all applicable classification rules and cannot undo long-standing compassionate appointments on a narrow or inconsistent reading of policy, especially where the employees acted in good faith and have served for many years.

    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: Bombay High Court

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  • Delhi High Court Ruled Deemed Occupancy Certificate Claim Cannot Override RERA

    Delhi High Court Ruled Deemed Occupancy Certificate Claim Cannot Override RERA

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 02.11.2026

    Delhi High Court Ruled Deemed Occupancy Certificate Claim Cannot Override RERA

    This Short Article has been prepared & written by Advocate Narendra Singh. The views expressed are based on his interpretation of the law. He can be reached at his mob no- +91 8800860662 and email id amitnaren@outlook.com .

    The Delhi High Court has dismissed two appeals by CJ Infrastructure Pvt. Ltd., holding that the developer could not avoid the Real Estate (Regulation and Development) Act, 2016 (RERA) on the basis of a claimed β€œdeemed” occupancy certificate and was required to comply with the statutory pre-deposit condition before its appeals could be heard.

    Background: Metroplex East commercial complex

    CJ Infrastructure developed Metroplex East, a commercial complex at 21, District Centre, Laxmi Nagar, Delhi. The project comprises 197 units along with common areas, including the entrance lobby, elevators and staircases. The developer stated that construction was completed on 14 February 2013 and that an architect had certified the building as fit for occupation.

    According to the company, it applied to the Delhi Development Authority (DDA) for an Occupancy-cum-Completion Certificate (OCC) in 2013 and early 2014. It argued that, because the DDA did not respond within the applicable period, the OCC should be treated as having been granted by operation of the building bye-laws.

    Between 2013 and 2015, the company sold or allotted 149 commercial units and executed registered conveyance deeds in favour of purchasers. Later, several purchasers initiated proceedings under RERA, principally alleging that the developer had not obtained a formal OCC for the building.

    The central dispute: Was the OCC deemed to have been granted?

    The developer’s principal argument was that the project had effectively been completed before RERA came into force and that a deemed OCC had arisen because of the DDA’s alleged inaction. On that basis, it contended that the RERA authorities lacked jurisdiction over the complaints.

    The Court did not accept this position. It examined the record placed by the DDA and highlighted key deficiencies:

    • The developer claimed that it had applied for completion on 14 February 2013, but the Fire Safety Certificate relied upon was dated 30 October 2013. The certificate was required for a completion application.
    • The OCC-fee receipt produced by the developer was dated 20 April 2017, approximately four years after the claimed OCC application.
    • The DDA reported deviations from the sanctioned plan.
    • The application was scrutinised under the Unified Building Bye-Laws, 2016, and the stated deficiencies were not rectified despite opportunities to do so.
    • The DDA rejected the OCC application on 8 September 2021.

    The Court held that a deemed OCC could not be claimed in these circumstances. It noted that deemed approval requires the applicant to have met the necessary requirements, including payment of applicable fees, and cannot authorise conduct contrary to lease conditions, the master plan, regulations or building bye-laws.

    Most importantly, the Court found that no OCC existed when the appeals were before the Real Estate Appellate Tribunal (REAT). Therefore, the project remained subject to RERA.

    Why the RERA pre-deposit requirement applied

    The second major issue concerned Section 43(5) of RERA. This provision requires a promoter challenging an order before the appellate tribunal to first deposit at least 30% of the penalty, or such higher percentage as the tribunal directs, or the total amount payable to the allottee, including interest and compensation, depending on the nature of the order.

    The REAT had required CJ Infrastructure to deposit the full adjudicated amounts as a condition for continuing its appeals. When the company did not make that deposit, the REAT dismissed the appeals.

    The Delhi High Court upheld that decision. It emphasised that the statutory wording, including β€œit shall not be entertained,” makes pre-deposit a mandatory threshold condition for a promoter’s appeal. The Court relied on the Supreme Court’s ruling in Newtech Promoters and Developers Pvt. Ltd. v. State of Uttar Pradesh, which had held that this requirement is not unconstitutionally burdensome and serves to protect allottees’ financial interests.

    The Court also rejected the developer’s offer to provide immovable-property security instead of making the deposit. RERA contains no provision permitting such a substitute.

    Judgment and implications

    The High Court found no error in the REAT’s orders and dismissed both appeals. It nevertheless allowed the appellants an opportunity to seek revival of their REAT appeals within 30 days of the judgment, provided they comply with the applicable pre-deposit condition under Section 43(5).

    The ruling reinforces two important principles for real-estate developers:

    1. A deemed occupancy certificate cannot be assumed merely from alleged administrative inaction. The applicant must show compliance with the applicable approval requirements, including supporting documentation, fees and rectification of identified shortcomings.
    2. The RERA pre-deposit requirement is mandatory for promoters’ appeals. A developer cannot ordinarily have an appeal heard by REAT without first making the required statutory deposit, and offering property as security is not an authorised alternative.

    The judgment, pronounced on 29 August 2025 by a Division Bench of Justice Anil Kshetarpal and Justice Harish Vaidyanathan Shankar, underscores the courts’ approach of enforcing RERA’s safeguards for allottees while requiring strict compliance from promoters seeking appellate relief.

    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: Delhi High Court

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  • Karnataka High Court Dismisses Retired FSL Officer’s Plea to Halt Forgery Case

    Karnataka High Court Dismisses Retired FSL Officer’s Plea to Halt Forgery Case

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 02.11.2026

    Karnataka High Court Dismisses Retired FSL Officer’s Plea to Halt Forgery Case

    This Short Article has been prepared & written by Advocate G Sridharamurthy. The views expressed are based on his interpretation of the law. He can be reached at his mob no- +91 9845906418 and email id sriadv3@gmail.com .

    The Karnataka High Court has dismissed a criminal petition by a retired Forensic Science Laboratory officer, holding that his claim that he was forced to sign a disputed experience certificate must be tested at trial rather than decided at the discharge stage.

    Background: recruitment complaint led to criminal case

    The case arose from the recruitment process for the post of Scientific Assistant in the Biology Section of the Forensic Science Laboratory (FSL). The complainant, K. Sridhar, who held an M.Sc. in Biotechnology, applied in response to a notification issued on 25 February 2003.

    After receiving no information about the recruitment outcome, Sridhar sought records through an application under the Right to Information Act in December 2007. Following proceedings before RTI authorities, he received certain documents that he alleged were false or misleading. These records, including documents dated in 2008, formed the basis of a complaint registered by the Madivala Police in July 2010.

    The investigation was subsequently transferred to the COD. After investigating, the agency filed a charge sheet alleging that officials had conspired to facilitate the appointment of another candidate by creating or issuing a false experience certificate.

    Allegations against the petitioner

    Rangegowda, a retired Deputy Director associated with the FSL, was named as Accused No. 3. The prosecution alleged that he and others conspired in relation to the appointment of Accused No. 2 as a Scientific Assistant, despite the candidate allegedly lacking the required qualification.

    The charge sheet invoked offences relating to preparation or signing of incorrect official documents, false certification, criminal conspiracy and provisions of the Prevention of Corruption Act. A central document was a certificate dated 12 March 2003 bearing Rangegowda’s signature.

    Defence: signature was allegedly obtained under pressure

    Rangegowda sought discharge before the trial court, maintaining that he had not committed the alleged offences. His principal defence was that Accused No. 1 had compelled him to sign a pre-typed document in the latter’s chamber and that he had no meaningful alternative.

    He also argued that:

    • he was initially treated as a witness, including in a statement recorded under Section 164 of the Criminal Procedure Code;
    • the trial court had not adequately considered the legal ingredients of the offences alleged;
    • certain allegations were barred by limitation; and
    • material from a departmental enquiry supported his position.

    The trial court rejected his discharge application. He then moved the High Court under Section 482 of the Criminal Procedure Code, seeking to have that order set aside.

    High Court’s reasoning: disputed defence requires evidence at trial

    Justice H.P. Sandesh held that the dispute could not be resolved at the discharge stage. The Court noted that Rangegowda did not dispute issuing the certificate dated 12 March 2003 or that it carried his signature. His contention was that the document had been signed under coercion.

    According to the Court, whether the petitioner was actually compelled to sign the certificate is a factual issue requiring examination of evidence. It cannot be decided merely by evaluating the defence version while considering an application for discharge.

    The Court also accepted that the investigating material indicated allegations of a cognizable offence and an alleged conspiracy involving the issuance of the certificate. At this preliminary stage, the court said it could not assess the reliability of the prosecution’s evidence or discard it in favour of the petitioner’s explanation.

    Why the discharge request failed

    The High Court emphasized that discharge is appropriate where allegations and collected material fail to disclose a case requiring trial. Here, however, the existence of the signed certificate was not disputed, and the prosecution had material supporting its allegation that the certificate was connected to an improper appointment.

    The Court treated the petitioner’s explanation, including his reliance on his earlier statements and departmental enquiry material, as a defence that may be raised during trial. It found no error in the trial court’s refusal to discharge him.

    Outcome and legal significance

    The criminal petition was dismissed, leaving the prosecution against Rangegowda to proceed before the trial court. The decision reinforces a key distinction in criminal procedure: at the discharge stage, courts assess whether the prosecution material discloses grounds to proceed, but they generally do not decide contested factual defences.

    Where a document’s issuance is admitted but the circumstances of signing are disputed, the matter ordinarily requires a full trial and evidence-based determination.

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    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: Karnataka High Court

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  • Telangana High Court Quashes Customs Confiscation of Used MFD Imports

    Telangana High Court Quashes Customs Confiscation of Used MFD Imports

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 02.11.2026

    Telangana High Court Quashes Customs Confiscation of Used MFD Imports

    This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .  

    The Telangana High Court has ruled that a later amendment imposing a 100-unit-per-model annual threshold could not be used to confiscate Arka Business Solutions’ consignment of used multi-function devices (MFDs) imported before that amendment took effect.

    Background of the dispute

    Arka Business Solutions, an importer and seller of used digital multi-function devices, imported 73 used MFDs from the United States. The company filed its Bill of Entry on 4 June 2026 at ICD Thimmapur.

    Customs examined the consignment on 19 June 2026. A Chartered Engineer appointed at Customs’ instance found that the machines were functional second-hand capital goods, had more than six years of residual life, were neither hazardous waste nor electronic waste, and each weighed more than 80 kg.

    Those findings were significant because the weight criterion placed the devices within the exemption for Highly Specialised Equipment (HSE) under the Electronics and Information Technology Goods (Requirements for Compulsory Registration) Order, 2021 (CRO 2021).

    Customs’ decision to confiscate the goods

    Despite the technical certification, Customs issued a show-cause notice alleging that the importer required DGFT authorisation under the Foreign Trade Policy, 2023, and had not met BIS registration requirements. The adjudicating authority subsequently divided the 73 machines into two categories:

    • 36 units were treated as prohibited goods because their models allegedly exceeded a 100-unit annual threshold when imports by all importers across India were counted. These units could be redeemed only for re-export, subject to a redemption fine of Rs. 1,33,257.
    • 37 units were treated as restricted goods. Customs allowed redemption for home consumption on payment of a Rs. 3,95,021 redemption fine.

    The order was based on the view that the 100-unit threshold under the amended Paragraph 8 of CRO 2021 applied nationally and across unrelated importers.

    Court’s findings: the amendment could not operate retrospectively

    The High Court set aside the confiscation order, holding that the amendment adding the quantitative limit came into force only on 15 June 2026. Since Arka Business Solutions had filed its Bill of Entry on 4 June 2026, the amended provision did not govern the import.

    The Court emphasized that subordinate legislation is presumed to operate prospectively unless it clearly states otherwise. The notification did not contain language giving it retrospective effect.

    Under Section 15 of the Customs Act, the relevant legal position for goods entered for home consumption is determined on the date the Bill of Entry is presented. Accordingly, later events, including the Customs examination, show-cause notice, and adjudication order, could not subject the earlier import to a restriction that was not in force at the relevant time.

    Why the 100-unit interpretation was also flawed

    The Court found additional defects in Customs’ reasoning. The language of the amended provision referred to equipment β€œmanufactured/imported in less than 100 units per model per year,” but did not expressly create an industry-wide cap shared by all importers.

    The Court observed that Customs had not explained why one importer should lose an exemption because unrelated importers had brought in the same model. A restrictive interpretation that limits an exemption on the basis of third-party imports required clear statutory language, which was absent.

    The Court also noted that the show-cause notice did not tell the importer that eligibility would be tested using all-India import data from other importers. Deciding the case on a basis not disclosed in the notice violated the principle that a noticee must know the case it has to answer.

    HSE exemption meant the devices were freely importable

    The Court reaffirmed its earlier interpretation of the relationship between CRO 2021 and the Foreign Trade Policy. Where used MFDs satisfy the HSE exemption, the compulsory registration requirement does not apply. As a result, the import cannot be treated as restricted under the provision dealing with second-hand goods subject to CRO compliance.

    Instead, qualifying goods fall within the category of freely importable second-hand capital goods. Since the Chartered Engineer had confirmed the devices met the weight threshold and were functional capital goods rather than e-waste, there was no basis to classify them as prohibited or restricted.

    The Court therefore found no basis for confiscation under Section 111(d) of the Customs Act. It also held that the record did not support allegations of misdeclaration under Section 111(m) or a penalty under Section 112.

    Outcome and release conditions

    The High Court allowed the writ petition and quashed the Customs order to the extent it:

    • classified the goods as prohibited or restricted;
    • confiscated them under Section 111(d);
    • imposed redemption fines; and
    • imposed any related penalty.

    Customs was directed to release the goods covered by the Bill of Entry, subject to conditions adopted from an earlier Arka Business Solutions decision. These conditions require the importer to deposit the enhanced duty amount after Customs quantifies it, while preserving the parties’ rights to pursue valuation issues separately. The Court also stated that any demurrage-waiver request must be considered objectively.

    Key legal takeaway

    The ruling confirms that import restrictions and exemption conditions must be assessed under the law in force when the Bill of Entry is filed. Customs cannot apply a later quantitative restriction retrospectively, expand an exemption limitation through an unclear all-India interpretation, or rely on grounds that were not put to the importer in the show-cause notice.

    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: Telangana High Court

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    Ravi Shekhar Jha – Advocate, Bar Council of Delhi

  • Himachal Pradesh HC: Bail Can Be Granted Despite Previous NDPS Cases Where Recovery Is Below Commercial Quantity

    Himachal Pradesh HC: Bail Can Be Granted Despite Previous NDPS Cases Where Recovery Is Below Commercial Quantity

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 02.11.2026

    Himachal Pradesh HC: Bail Can Be Granted Despite Previous NDPS Cases Where Recovery Is Below Commercial Quantity

    This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .  

    The Himachal Pradesh High Court has granted post-arrest bail to Vijay Garla in an NDPS Act case involving the recovery of 512 grams of charas, holding that the quantity was below the commercial threshold and that continued pre-trial custody was not warranted on the facts before it.

    The case at a glance

    Justice Chirag Bhanu Singh passed the order on 31 October 2026 in Vijay Garla v. State of HP, arising from FIR No. 164 of 2026 registered at Police Station Sundernagar, District Mandi. The FIR invoked Sections 20, 25 and 29 of the Narcotic Drugs and Psychotropic Substances Act, 1985.

    The petitioner sought post-arrest bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023. The Court allowed the application, subject to strict conditions, including a bail bond of Rs. 50,000 with two local sureties of the same amount.

    Alleged recovery following police checkpoint chase

    According to the State’s status report, a police team had set up a checkpoint at Pungh on the four-lane road in Sundernagar on 10 July 2026. At about 5:00 pm, officers noticed a white taxi approaching from the Sundernagar side.

    The taxi allegedly turned around and fled after its driver saw the police team. Police followed the vehicle and, about 500 metres away, found it parked near a truck. Four people were seated in the taxi, including Vijay Garla, who was seated in the rear.

    After associating an independent witness, the police searched the vehicle and reported recovering 512 grams of charas. All four occupants were arrested at the spot.

    Why the Court granted bail

    The Court’s decision turned principally on the quantity allegedly recovered, the stage of the criminal proceedings and the principle that pre-trial detention should not become punitive.

    Quantity was below commercial threshold

    The Court noted that 512 grams of charas was β€œless than commercial” quantity. It held that the stringent restrictions in Section 37 of the NDPS Act would therefore not apply with the same force in the circumstances of this case.

    It also observed that the recovery was not attributed exclusively to Vijay Garla, as the contraband was allegedly recovered from a vehicle occupied by four persons.

    Chargesheet had already been filed

    The investigation had culminated in the filing of the chargesheet. The Court found that the trial was likely to take time and that further incarceration before the case was decided would not be justified merely because the prosecution had been launched.

    Referring to Supreme Court decisions, the order reiterated that courts generally disfavor prolonged pre-trial incarceration, particularly where an accused remains presumed innocent until guilt is established at trial.

    Prior cases did not outweigh the exceptional factors

    The State opposed bail on the ground that two prior NDPS cases were registered against the petitioner and argued that he could repeat similar conduct. The Court acknowledged this concern and described him as a repeat offender.

    However, it concluded that the lower-than-commercial quantity, the shared nature of the alleged recovery and the probable delay in trial constituted peculiar circumstances justifying bail, albeit under stringent safeguards.

    Bail conditions imposed by the Court

    The petitioner’s release is subject to several conditions designed to protect the investigation and trial process:

    • He must not tamper with prosecution evidence or intimidate, threaten or coerce witnesses.
    • He must appear before the investigating officer or court whenever directed.
    • He cannot leave India without the court’s express permission and must surrender any passport to the investigating agency.
    • If he is later found involved in a similar NDPS offence and an FIR is registered, the bail may be cancelled immediately.

    The Court also allowed the State to consider preventive detention or measures for treatment or reformation if the petitioner is implicated in similar future activity.

    Legal significance of the order

    The ruling illustrates how bail decisions under the NDPS Act depend on the specific facts of each case. While prior criminal antecedents can weigh against an accused, they do not automatically rule out bail where the alleged quantity is below commercial quantity, the recovery is not solely linked to one accused, the investigation is complete and the trial may be prolonged.

    Importantly, the Court clarified that its observations were confined to deciding the bail request and do not express any view on the merits of the prosecution’s case. The criminal trial will determine whether the allegations are proved.

    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: Himachal Pradesh High Court

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  • PhonePe Wins Remand in Trademark Dispute After Counter Statement Was Not Served

    PhonePe Wins Remand in Trademark Dispute After Counter Statement Was Not Served

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 02.11.2026

    PhonePe Wins Remand in Trademark Dispute After Counter Statement Was Not Served

    This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .  

    The Delhi High Court has set aside an earlier trademark opposition order involving PhonePe Limited after all parties confirmed that the opponent had not been served with the other side’s counter statement, as required by the Trade Marks Act, 1999.

    Court restores matter to the Trade Marks Registrar

    In PhonePe Limited v. The Registrar of Trade Marks & Anr., the Delhi High Court disposed of PhonePe’s appeal by overturning the order dated 19 December 2025 and remanding the opposition for fresh consideration before the Registrar of Trade Marks.

    Justice A. J. Bhambhani directed that the opposition be reconsidered only after the required notice is issued and pleadings are completed in accordance with law. The Registrar has been asked to decide the matter expeditiously, and in any event within four months from 21 September 2026.

    Central issue: counter statement was not served

    PhonePe’s case was based on a procedural failure in the opposition proceedings. Its counsel submitted that respondent No. 2’s counter statement had been filed but was never served on PhonePe, which had filed the notice of opposition.

    This was not disputed. The Registrar of Trade Marks confirmed, based on its records, that service had not been completed in accordance with the statutory requirement. Counsel for the contesting respondent also accepted that position.

    Why service is legally important

    Section 21(3) of the Trade Marks Act, 1999 requires the Registrar to serve a copy of the counter statement on the person who filed the notice of opposition. This step is material because it enables the opponent to know the case being advanced in response and to complete its pleadings fairly.

    The Court treated the omission as sufficient reason to set aside the earlier order. Rather than deciding the merits of the trademark dispute itself, it restored the matter to the Registrar so that the opposition process can proceed after due notice and lawful completion of pleadings.

    Direction for a time-bound decision

    While agreeing that the matter should be remanded, the contesting respondent requested an expedited outcome. The Court accordingly required the Registrar to conclude the reconsidered opposition as quickly as possible and no later than four months from the date of the order.

    Key takeaway

    The order reinforces that statutory service requirements in trademark opposition proceedings are substantive safeguards of procedural fairness. Where an opponent is not served with a counter statement, an order passed in the proceedings may be vulnerable to being set aside and remanded for fresh consideration.

    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: Delhi High Court

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  • Supreme Court: DRI Cannot Secure NDPS Conviction Based Only on Statements of Co-Accused

    Supreme Court: DRI Cannot Secure NDPS Conviction Based Only on Statements of Co-Accused

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 31.10.2026

    Supreme Court: DRI Cannot Secure NDPS Conviction Based Only on Statements of Co-Accused

    This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .  

    The Supreme Court of India set aside Surinder Kumar Khanna’s drug-trafficking conviction because the prosecution had no substantive evidence against him beyond statements made by his co-accused.

    Background of the case

    The case arose from a Directorate of Revenue Intelligence operation in Hoshiarpur, Punjab. Officers intercepted a white Indica car after receiving information that narcotics were being transported from Jammu towards Chandigarh. Two occupants, Raj Kumar alias Raju and Surinder Pal Singh, were found in the vehicle.

    A search of the car reportedly led to the recovery of four packets concealed in the boot-door area. The packets allegedly contained approximately 3.990 kg of heroin. The two occupants stated that the consignment had been collected from an individual in Jammu and was intended for delivery near PGI Chandigarh.

    Although Surinder Kumar Khanna was not present at the interception and no contraband was recovered from him, investigators later alleged that he was involved in the trafficking operation. A supplementary complaint was filed against him under Section 21(c) read with Section 29 of the Narcotic Drugs and Psychotropic Substances Act, 1985.

    Conviction by the trial court and High Court

    The trial court convicted Khanna and sentenced him to 12 years’ rigorous imprisonment, along with a fine of Rs. 1 lakh. On appeal, the Punjab and Haryana High Court upheld the conviction but reduced the prison term to 10 years.

    The High Court relied principally on statements made by Raj Kumar and Surinder Pal Singh under Section 67 of the NDPS Act. It held that these statements were admissible and established Khanna’s involvement in drug trafficking.

    The central issue before the Supreme Court

    The Supreme Court considered whether a co-accused’s alleged confession could, by itself, justify another accused person’s conviction.

    The prosecution accepted that, apart from the co-accused’s statements, there was no evidence directly connecting Khanna with the seized heroin or the other accused. Call-data records placed before the Court showed contact with a person in Dubai, but did not show that Khanna was in touch with either co-accused when they were apprehended.

    What the Court held

    The Court reaffirmed a fundamental evidentiary rule: a confession by one accused is not substantive evidence against a co-accused. It may only be considered to support or β€œlend assurance” to other independent evidence that already points to the co-accused’s guilt.

    The judgment relied on established precedents, including Kashmira Singh v. State of Madhya Pradesh and Hari Charan Kurmi v. State of Bihar. Those decisions explain that a court must first assess the evidence against an accused without considering a co-accused’s confession. Only if independent evidence is sufficient to support conviction may the confession be used as an additional source of assurance.

    The Court also noted that the NDPS Act contains no provision comparable to special statutes that expressly permit a co-accused’s confession to be used against another accused in specified circumstances.

    Importance of Section 67 statements

    The judgment acknowledged that the legal status of statements recorded under Section 67 of the NDPS Act had been referred to a larger Bench in an earlier case. However, the Court held that even if those statements were treated as confessions, they could not alone establish Khanna’s guilt.

    That distinction was decisive. The question was not merely whether the co-accused’s statements could be considered; it was whether they could independently prove a separate accused person’s involvement. The Court answered no.

    Final outcome

    Finding no substantive evidence against Khanna, the Supreme Court allowed his appeal, quashed his conviction and sentence, and acquitted him of the charges. It directed that he be released immediately unless required in custody in another case.

    Key legal takeaway

    Surinder Kumar Khanna v. Intelligence Officer, Directorate of Revenue Intelligence reinforces that criminal conviction must rest on reliable, independent evidence. A co-accused’s statement may corroborate an existing case, but it cannot fill the absence of evidence against another person accused of the offence.

    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: Supreme Court

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  • Rajasthan High Court Quashes 14-Year-Old Customs Drawback Proceedings for Unreasonable Delay

    Rajasthan High Court Quashes 14-Year-Old Customs Drawback Proceedings for Unreasonable Delay

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 31.10.2026

    Rajasthan High Court Quashes 14-Year-Old Customs Drawback Proceedings for Unreasonable Delay

    This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .  

    The Rajasthan High Court has set aside a 2008 customs show-cause notice and a 2022 adjudication order, holding that a 14-year delay without explanation or communication violated procedural fairness and natural justice.

    Case at a glance

    In Shivek Sharma v. Union of India (D.B. Civil Writ Petition No. 19485/2022), decided on 9 September 2025, the Rajasthan High Court at Jaipur examined whether Customs authorities could revive and adjudicate a long-pending allegation concerning duty drawback and DEPB benefits after more than a decade of inactivity.

    The petitioner, Shivek Sharma, was the legal heir of the late proprietor of M/s J. Minakshi International. The Directorate of Revenue Intelligence had investigated alleged misuse of export-promotion schemes involving exports of goods such as readymade garments, leather items and brass items. A show-cause notice was issued on 31 March 2008, but the department did not proceed to adjudicate it until 2021-22. An Order-in-Original creating recovery demands was eventually issued on 18 October 2022.

    The Court ruled that this prolonged, unexplained delay made the proceedings legally unsustainable.

    Background of the dispute

    The DRI’s investigation concerned alleged fraudulent export transactions during 2001-05. It resulted in a show-cause notice against several parties, including M/s J. Minakshi International, a proprietary concern of the petitioner’s father.

    Several developments made the delay especially significant:

    • The notice was issued in 2008, when the petitioner was 13 years old.
    • The proprietor, Pawan Kumar Sharma, died in April 2021.
    • The department began hearing-related action only after approximately 13 years of silence.
    • The petitioner stated that he had neither inherited nor carried on the business and was unaware of the pending proceedings.
    • After receiving hearing notices, he sought the underlying notice and relied-on documents, explaining that he could not reasonably understand or answer transactions dating back many years.

    Despite these objections, Customs passed an order in October 2022, seeking recovery of duty drawback and interest from the petitioner as legal heir.

    The legal issue: Can Customs adjudicate after 14 years?

    The central issue was not merely whether the Customs Act or Drawback Rules contained a fixed limitation period. It was whether administrative and quasi-judicial powers can be exercised after such an extreme delay when the affected party was not informed of the status of the case.

    The petitioner argued that even where legislation does not prescribe a specific deadline, adjudication must occur within a reasonable period. He also relied on the statutory timelines reflected in Section 28(9) of the Customs Act to emphasize the importance of prompt decision-making in customs matters.

    The Customs department argued that the case involved recovery of drawback and DEPB benefits under the Drawback Rules, rather than an ordinary duty-demand case. It also argued that the 2018 amendment introducing timelines under Section 28(9) did not apply retrospectively and that an appellate remedy was available.

    What the Court held

    The High Court rejected the department’s position and held that the doctrine of reasonable time applies to adjudication proceedings generally. The absence of an express statutory deadline does not permit authorities to keep a show-cause notice alive indefinitely.

    The Court identified several decisive failures:

    • Inordinate delay: The order was passed more than 14 years after the show-cause notice.
    • No explanation: Customs did not provide a cogent reason for the delay.
    • No communication: The petitioner and his father were not told that the matter remained pending or had been placed in a β€œcall book.”
    • No supporting record: The department did not produce material proving any transfer to the call book or explaining the basis for it.
    • No fault of the petitioner: The delay was not attributed to the petitioner or his late father.
    • Ignored submissions: The adjudicating authority did not meaningfully address the petitioner’s arguments and cited case law on stale proceedings.

    The Court described the 14-year delay as incompatible with lawful, fair and effective quasi-judicial adjudication. It reiterated the principle expressed in the maxim lex dilationes abhorretβ€”the law abhors delay.

    Why lack of communication mattered

    A key part of the ruling is that delay becomes particularly unfair when the noticee is left uninformed. The Court noted that communication is necessary where proceedings are kept in abeyance or transferred to a call book.

    Without notice, the affected person may lose access to records, witnesses and other evidence needed for a proper defence. Long silence can also reasonably lead a person to believe that the proceedings have been abandoned or concluded.

    Here, the department was silent for more than a decade. The Court found that this lack of transparency caused grave prejudice and violated natural justice.

    Writ petition allowed despite an appellate remedy

    The department argued that the petitioner should pursue an appeal against the Order-in-Original. The Court held that the availability of an appeal did not bar the writ petition in these circumstances.

    The challenge was based on a fundamental procedural defect: the arbitrary and delayed revival of proceedings, coupled with a breach of natural justice. Because the very adjudication process was found to be vitiated, the Court considered writ jurisdiction appropriate.

    Final outcome

    The Rajasthan High Court allowed the writ petition and quashed:

    1. The show-cause notice dated 31 March 2008, insofar as it concerned the petitioner; and
    2. The Order-in-Original dated 18 October 2022 passed under Section 122 of the Customs Act.

    The Court concluded that the petitioner was justified in treating the long-dormant proceedings as abandoned.

    Significance of the ruling

    This decision reinforces an important safeguard in customs and tax administration: authorities must adjudicate show-cause notices within a reasonable time, even where the governing provision does not specify a strict deadline.

    For businesses, proprietors, legal heirs and other noticees, the judgment confirms that a prolonged and unexplained revival of old proceedings can be challenged when it causes prejudice, particularly where the department failed to disclose the status of the case or preserve procedural fairness.

    For revenue authorities, it underscores that public-revenue objectives require diligence and timely action, not indefinite pendency.

    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: Rajasthan High Court

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  • CESTAT Mumbai- Customs Cannot Calculate Import IGST on Exempted BCD

    CESTAT Mumbai- Customs Cannot Calculate Import IGST on Exempted BCD

    Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

    Date: 30.10.2026

    CESTAT Mumbai- Customs Cannot Calculate Import IGST on Exempted BCD

    This Short Article has been prepared & written by Advocate Ravi Shekhar Jha-Delhi High Court, New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com .  

    The CESTAT Mumbai has held that where imports qualify for a Basic Customs Duty (BCD) exemption under a valid Duty-Free Import Authorisation (DFIA), IGST must be calculated without adding the notional tariff-rate BCD to the assessable value.

    In TGI International v. Commissioner of Customs, Nhava Sheva-III, the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), Mumbai set aside an order that had rejected the importer’s challenge to IGST assessments on 105 Bills of Entry. The Tribunal ruled that the relevant statutory test is the customs duty actually β€œchargeable” after giving effect to a valid exemption notification, not the BCD shown in the tariff schedule.

    Background: 105 DFIA-based fabric imports

    TGI International, a fabric trader, imported polyester viscose fabrics through 105 Bills of Entry. It claimed full exemption from BCD under Notification No. 19/2015-Customs dated 1 April 2015, which applies to eligible imports made against a valid DFIA issued by the Directorate General of Foreign Trade (DGFT).

    The DFIA scheme permits duty-free import of specified inputs subject to prescribed conditions, including production of the authorisation at clearance and endorsements relating to the export obligation and resultant product. In this matter, the Tribunal found that the importer had complied with the applicable DFIA and notification requirements.

    Although the BCD claimed on the imports was nil, the Indian Customs EDI System (ICES) calculated IGST by adding BCD at the normal tariff rate of 20% to the transaction value. The importer paid the system-calculated IGST because the Bills of Entry could not be amended through the system, then appealed the assessments.

    The core legal issue

    The dispute concerned the meaning of β€œduty of customs chargeable” when determining the value on which IGST is levied on imported goods.

    Section 3(8) of the Customs Tariff Act, 1975 requires IGST to be calculated on an aggregate value comprising:

    1. the value of imported goods determined under Section 14 of the Customs Act, 1962; and
    2. any customs duty chargeable on the goods under Section 12 of the Customs Act.

    TGI International argued that once the DFIA exemption reduced BCD to zero, there was no BCD amount to add to the assessable value for IGST. Customs authorities, however, treated the tariff-rate BCD as part of the IGST base, even though the importer did not pay that duty in cash.

    Tribunal’s findings

    Effective duty, not tariff duty, governs the IGST base

    The Tribunal held that an exemption notification issued under Section 25 of the Customs Act must be given effect while determining the customs duty β€œchargeable” under Section 12. Although the tariff rate of BCD on the goods was 20%, the effective BCD was nil because the imports were covered by the DFIA exemption.

    Accordingly, the Tribunal concluded that the effective duty liability, rather than the unadjusted tariff rate, must be added to the import value when calculating IGST.

    No duty debit was made under the DFIA

    The Commissioner (Appeals) had reasoned that the customs duty was effectively discharged through debit in the DFIA authorisation. CESTAT rejected this conclusion as factually unsupported.

    The Bills of Entry showed β€œzero” against the duty-debit field. The DFIA documentation recorded the permitted CIF value and quantity of dyed polyester fabrics, but did not require debit of the BCD amount as a precondition for the exemption. The Tribunal therefore found that it was incorrect to treat the tariff BCD as a duty discharged through the authorisation.

    ICES could not override the legal valuation rule

    The Tribunal noted that ICES had added a notional BCD amount while computing IGST and had not taken account of the exemption claimed under Notification No. 19/2015-Customs. System-generated assessments cannot displace the statutory requirement to use the duty actually chargeable after the applicable exemption is applied.

    Reliance on earlier decisions

    CESTAT found support in earlier Tribunal rulings that distinguish the tariff rate from the effective rate after exemptions:

    • In Morarjee Brembana Ltd., the Tribunal held that only the effective customs duty, after applying the applicable exemption notification, should be added for calculating additional customs duty.
    • In Parasrampuria International, the Tribunal held that where BCD is nil due to an exemption, no BCD amount can be added to the assessable value merely because a tariff rate otherwise exists.

    The Revenue relied on Poddar Pigments Ltd., but CESTAT held that the case was distinguishable because it concerned interest on delayed IGST payment, not the correct BCD component for IGST valuation.

    Why the ruling matters

    The decision clarifies an important valuation principle for DFIA and other exemption-based imports: the IGST base must reflect the effective customs-duty liability, not a hypothetical duty calculated at the tariff rate.

    For eligible DFIA imports, this means a nil BCD exemption should result in zero BCD being added to the IGST valuation base. The ruling also reinforces that customs assessment systems must apply the substantive benefit of a valid exemption notification rather than mechanically loading tariff-rate duty into the calculation.

    Conclusion

    By allowing TGI International’s appeals, CESTAT Mumbai confirmed that a valid BCD exemption under the DFIA scheme must be fully reflected in IGST valuation. Where the effective BCD is nil, Customs cannot add the tariff-rate BCD notionally to inflate the IGST payable on imported goods.

    Aadrikaa Legal Services is a trusted legal and regulatory support partner providing end-to-end legal solutions to law firms, corporate organizations, and businesses across India. We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

    Our services include comprehensive paralegal support, drafting and documentation, legal research, case management, litigation handling, and representation support across various judicial and quasi-judicial forums. We also assist in direct and indirect tax matters, customs, GST, corporate regulatory compliance, and legal advisory.

    Source: CESTAT Mumbai

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