The Court observed that the Customs Department lacked authority to issue directions under the CGST Act, particularly in relation to GST collection on auction sales conducted by Container Freight Stations (CFSs).. The ruling affirms the statutory autonomy of GST law and protects custodians from conflicting administrative instructions.

The Court noted a clarificatory circular issued by the Ministry of Finance in October 2024, which recognised such training as exempt under GST

The Supreme Court will decide whether Modvat credit used to pay duty on goods later found non-excisable can be refunded or reversed under the Central Excise Act.