ValkyaEditorial

Direct Tax — 57 Valkya Editorial digests

Direct taxation — income-tax assessment and reassessment, the faceless regime, transfer pricing and advance pricing agreements, and the appeals litigated before the ITAT and the courts.

Supreme CourtSupreme Court of India

Anoop Maheshwari v. Oriental Insurance (2025): functional disability, not the medical certificate, governs loss of earning capacity

In an amputee's claim under the Motor Vehicles Act, the Supreme Court held that compensation for loss of earning capacity turns on functional disability — the real reduction in earning power in the claimant's vocation — not the percentage of physical disability certified by a medical board. It also reaffirmed that income-tax returns are cogent proof of pre-accident income and cannot be brushed aside on surmises.

Valkya Editorial··6 min
Supreme CourtSupreme Court of India

Vaneeta Patnaik v. Nirmal Kanti Chakrabarti (2025): a POSH complaint must clear the three-month bar, and later actions extend it only with a direct nexus

The Supreme Court upheld the dismissal of a sexual-harassment complaint as time-barred under section 9 of the POSH Act. A complaint must be filed within three months of the last incident, extendable by three more for recorded reasons, and later administrative actions extend that window only if they share a direct nexus with the harassment.

Valkya Editorial··7 min
TribunalCustoms, Excise and Service Tax Appellate Tribunal, Kolkata

Agarwal Coal Corporation v. Commissioner of Customs (2026): late fee under Section 46(3) is not automatic

CESTAT Kolkata held that the late fee for delayed filing of a bill of entry under Section 46(3) of the Customs Act, 1962 cannot be imposed mechanically — the proper officer has the discretion to waive it where the delay is not attributable to the importer. A digest of the facts, the holding, and what it means for importers facing routine late-fee demands.

Valkya Editorial··6 min
TribunalIncome Tax Appellate Tribunal, Delhi

Bellsonica Auto Component India v. ACIT (2026): a transfer-pricing royalty adjustment must be capped at the rate the CBDT accepted under the assessee's APA

The ITAT Delhi held that where the CBDT has accepted a royalty and technical-fee rate of 1.9% of net sales under the assessee's Unilateral Advance Pricing Agreement, the Transfer Pricing Officer's higher adjustment is excessive and must be capped at the APA-accepted rate. A digest of the facts, the arm's-length question, and why a concluded APA carries persuasive weight.

Valkya Editorial··7 min
TribunalCustoms, Excise and Service Tax Appellate Tribunal, Bangalore

Karinje Sripathi Bhat v. Commissioner of Central Excise (2026): renting residential premises for student accommodation is exempt under the negative list

A Bangalore Bench of CESTAT held that a building rented to an educational foundation for student accommodation falls within Section 66D(m) of the Finance Act 1994 — renting of a residential dwelling for use as residence — and is not service-taxable, because the exemption turns on residential use, not on the identity of the tenant.

Valkya Editorial··6 min
High CourtHigh Court of Jammu & Kashmir and Ladakh

Principal, Woodland House School v. Shakeel Ahmad Malik (2026): AI may assist legal research but cannot replace judicial verification

A salary-execution petition before the Jammu & Kashmir and Ladakh High Court turned on two precedents whose citations would not hold up to scrutiny — one untraceable, one patently wrong. Justice Wasim Sadiq Nargal used the occasion to lay down that every AI-generated citation must be independently verified before it enters a judicial order, and directed the judgment circulated to all judicial officers in J&K and Ladakh.

Valkya Editorial··7 min
High CourtHigh Court of Delhi

PCIT v. Borgwarner Emissions Systems (2025): the DRP must apply its own mind

In December 2025 a Division Bench of the Delhi High Court dismissed the Revenue's transfer-pricing appeal, faulting the Dispute Resolution Panel for merely endorsing the Transfer Pricing Officer's conclusions without recording its own findings. A digest of the facts, the statutory duty of the DRP under Section 144C, and why the Court found no substantial question of law.

Valkya Editorial··7 min
High CourtHigh Court of Kerala

Sainaba Hamza Koya v. ITO (2025): Section 54F and borrowed funds

The Kerala High Court held that a Section 54F deduction does not require the sale consideration itself to be invested in the new house — borrowed funds used to build it can qualify. The relief, however, is not automatic: the assessee must satisfy the authority of a genuine intention to repay the borrowings out of the capital gains. A digest of the facts, the writ relief on a Capital Gain SB Account, and what it means in practice.

Valkya Editorial··8 min
High CourtKarnataka High Court

Income Tax Officer & CPIO v. Gulsanober: RTI section 8(1)(j) and a spouse's tax returns

On 21 February 2026, the Karnataka High Court set aside a CIC order directing disclosure of a husband's income tax returns to his wife under the RTI Act, holding that IT returns are 'personal information' exempt under section 8(1)(j) and issuing gender-neutral guidelines for financial-disclosure discovery in maintenance proceedings.

Valkya Editorial··9 min
Weekly Report

GST and indirect tax: May-June 2026 roundup

The May-June 2026 cycle in Indian GST and indirect-tax law has produced three threads running in parallel — the s.16(2)(c) constitutional ferment now sitting before the Supreme Court, the operational aftermath of the September 2025 rate-rationalisation in the High Courts, and the migration of anti-profiteering jurisdiction from the dissolved NAA to the GSTAT Principal Bench.

Valkya Editorial··12 min
Supreme CourtSupreme Court of India

HAL v. State of Karnataka: pre-46th amendment works-contract sales tax

On 16 December 1983, a three-judge bench held that HAL's contracts with the Indian Air Force for the servicing and overhauling of aircraft were integral works contracts and not severable into sale-of-goods and labour components, applying the Gannon Dunkerley dominant-nature framework in its last cycle before the 46th Amendment recast the field.

Valkya Editorial··11 min
Supreme CourtSupreme Court of India

Narmada Bachao Andolan v. Union of India: Sardar Sarovar, judicial restraint and the pari passu R&R framework

On 18 October 2000, a three-judge Bench of Chief Justice Dr A.S. Anand, Justice S.P. Bharucha and Justice B.N. Kirpal — by a 2:1 majority — allowed the construction of the Sardar Sarovar Dam to continue, subject to the condition that the dam height be raised in 5-metre slabs only after the Relief and Rehabilitation Sub-Group of the Narmada Control Authority certified that R&R for displaced families had been carried out pari passu with construction. The majority articulated a doctrine of narrow judicial review in major-project PILs, held the Narmada Water Disputes Tribunal Award binding, and treated sustainable development as a balancing exercise. Justice Bharucha dissented. A digest of the holding, the bench's reasoning, the dissent treated as the moral compass of environmental PILs, and the subsequent doctrinal arc.

Valkya Editorial··14 min
LandmarkSupreme Court of India

Gannon Dunkerley I: the works-contract sales-tax wall

On 1 April 1958, a five-judge Constitution Bench struck down the Madras works-contract sales tax as ultra vires Entry 48 List II — the wall that eventually forced the 46th Constitutional Amendment.

Valkya Editorial··12 min
Weekly Report

Arbitration in May 2026: the post-Gayatri-Balasamy modification line, the stamping discipline, and the Section 9 reset

The May 2026 cycle in Indian arbitration law has produced three doctrinal threads running in parallel — the first substantial post-Gayatri Balasamy applications of the Section 34 limited-modification corridor (Bhupesh Bhayana, Gujarat Water Supply, Paramount Learning), the continuing stamping discipline post-In Re Interplay (Tarini Prasad Mohanty), and the Section 9 reset for the unsuccessful party at the post-award stage (Home Care Retail Marts). Read alongside the Section 12(5) appointment discipline (PTC Techno, Andhra Pradesh v. Dataevolve), the Cox & Kings group-of-companies extension (ASF Buildtech, Ocean View Properties), the limitation question (West Bengal v. B.B.M.), and the institutional developments (CIAC launch, IIAC empanelment suspension, pending 2024 Amendment Bill), the cycle discloses the operational architecture within which Indian arbitration practice now operates.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Union of India v. Azadi Bachao Andolan: how the Mauritius treaty route was sustained, and McDowell was read down

On 7 October 2003, a two-judge bench of Justices Ruma Pal and B.N. Srikrishna reversed the Delhi High Court and upheld CBDT Circular No. 789 of 13 April 2000 — which had directed assessing officers to treat a Tax Residency Certificate issued by Mauritian authorities as sufficient evidence of residence and beneficial ownership for the purposes of the India–Mauritius Double Taxation Avoidance Agreement. The bench held that treaty shopping is not per se illegal in the absence of an express limitation-of-benefits clause, that the CBDT acted within its Section 119 power, and that Chinnappa Reddy J.'s anti-avoidance observations in McDowell (1985) were obiter and did not displace the Westminster principle in Indian law. A digest of the bench, the architecture of the DTAA, the doctrinal contribution, and the post-judgment arc through the 2016 Protocol, GAAR, and Tiger Global.

Valkya Editorial··11 min
LandmarkSupreme Court of India

CIT v. Vatika Township: how the Constitution Bench restated the presumption against retrospective taxation

On 15 September 2014, a five-judge Constitution Bench of the Supreme Court — R.M. Lodha C.J., J.S. Khehar J., J. Chelameswar J., A.K. Sikri J. and R.F. Nariman J. — unanimously held that the proviso to Section 113 of the Income-tax Act, 1961, imposing a surcharge on tax computed in block assessments and inserted by the Finance Act 2002 with effect from 1 June 2002, operates prospectively only and does not apply to block periods ending before that date; the bench overruled the contrary view in CIT v. Suresh N. Gupta (2008) that had treated the proviso as clarificatory. The judgment is the modern leading authority on the presumption against retrospective operation of tax statutes — particularly statutes that levy a new tax, increase a rate, or impose a surcharge. A digest of the bench, the statutory architecture, the doctrinal contribution on the substantive–clarificatory distinction, and the post-judgment arc through Sankaracharya University (2023) and the GST retrospective-amendment challenges now mounting in High Courts.

Valkya Editorial··12 min
Supreme CourtSupreme Court of India

Kotak Mahindra Bank v. A. Balakrishnan: the DRT Recovery Certificate as financial debt and a fresh cause of action under Article 137

On 30 May 2022 a three-judge bench of the Supreme Court, in Kotak Mahindra Bank Ltd v. A. Balakrishnan, held that the liability arising from a Recovery Certificate issued by a Debts Recovery Tribunal under Section 19 of the RDDBFI Act is a 'financial debt' within the meaning of Section 5(8) of the IBC, that the holder of such a Certificate is a 'financial creditor' under Section 5(7) entitled to file a Section 7 application, and — most consequentially for limitation practice — that the Certificate creates a fresh cause of action so that limitation under Article 137 of the Limitation Act runs from the date of its issuance, not from the date of the original default. A close reading of the bench's reasoning, its extension of the Dena Bank v. C. Shivakumar Reddy line, and what the ruling has come to mean for banks, ARCs and corporate debtors at the s.7 admission stage.

Valkya Editorial··13 min
Supreme CourtSupreme Court of India

Mohit Minerals v. Union of India: how the Supreme Court struck down IGST on ocean freight — and held GST Council recommendations non-binding

On 19 May 2022, a three-judge bench of Justices D.Y. Chandrachud, Surya Kant and Vikram Nath struck down the levy of IGST on ocean freight in CIF imports under the Reverse Charge Mechanism — holding that an Indian importer who has already paid IGST on the composite supply of CIF-imported goods cannot be separately charged IGST on the ocean-freight component of the same supply. The judgment is doctrinally significant for a connected reason: the Bench held that recommendations of the GST Council have persuasive value and are not binding on the Union or State Legislatures. A digest of the holdings, the doctrinal architecture, and the refund consequences.

Valkya Editorial··9 min
Weekly Report

Tax law in May 2026: the online-gaming GST ruling, the Income-tax Act 2025 first compliance cycle, and the GSTAT backlog deadline

The May 2026 cycle in tax law has produced one of the most consequential indirect-tax rulings of the calendar year — the Supreme Court's affirmation of 28 per cent GST on online gaming on full face value in *DGGI v. Gameskraft Technologies* — alongside the first full compliance cycle of the Income-tax Act 2025, the GSTAT 30 June 2026 backlog deadline, the GST 2.0 dual-rate regime in its first full fiscal year, and the practitioner fallout from the *Tiger Global* GAAR ruling of 15 January 2026. Read together, the cycle discloses the doctrinal and administrative architecture within which tax practice now operates.

Valkya Editorial··10 min
Supreme CourtSupreme Court of India

Tiger Global International II Holdings v. AAR: how the Supreme Court read GAAR over the India-Mauritius DTAA and reset the TRC's evidentiary force

On 15 January 2026, a two-judge bench — Justice R. Mahadevan in the principal opinion, with Justice J.B. Pardiwala concurring — held that the General Anti-Avoidance Rule in Chapter X-A of the *Income-tax Act, 1961* applies to any arrangement yielding a tax benefit on or after 1 April 2017, even for pre-2017 investments structured to claim Mauritius treaty benefits. The Tax Residency Certificate, the Court held, remains a relevant factor but is no longer conclusive for GAAR purposes; the *Azadi Bachao Andolan* line on TRC-as-conclusive-evidence is substantially modified. A digest of the holding, the 2016 Protocol grandfathering architecture, and the practitioner fallout that has emerged through May-June 2026.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Vodafone International Holdings v. Union of India: how an offshore share transfer fell outside Section 9(1)(i), and what Parliament did next

On 20 January 2012, a three-judge bench of the Supreme Court — S.H. Kapadia C.J., K.S. Radhakrishnan J. and Swatanter Kumar J. — unanimously held that the transfer of a single share in a Cayman Islands holding company (CGP) between two non-residents did not give rise to capital gains taxable in India under Section 9(1)(i) of the Income-tax Act, 1961, even though the share's value was rooted in the Hutch–Vodafone Indian telecom chain; the look-at test was adopted, and the Revenue's USD 2.2 billion demand was quashed. Parliament responded with the Finance Act 2012 retrospective amendment to Section 9(1)(i); Vodafone then commenced a treaty arbitration under the India–Netherlands BIT and prevailed; the Taxation Laws (Amendment) Act 2021 ultimately rolled back the retrospective amendment. A digest of the judgment, its statutory architecture, and the doctrinal arc that has followed.

Valkya Editorial··13 min
Supreme CourtSupreme Court of India / High Courts

Section 74A's jurisdictional fact: the GR Infra Projects stay and the fraud-narrative requirement

On 21 November 2025, the Supreme Court stayed proceedings in GR Infra Projects Ltd. v. State of Madhya Pradesh, prima facie holding that a show-cause notice under Section 74 of the CGST Act that sets out only figures, without a factual narration of fraud, wilful misstatement or suppression, is legally deficient. The order has shaped the High Court line on Section 74 and, by extension, on Section 74A — which now governs the extended-limitation regime from 1 April 2024 — and reaffirms the jurisdictional-fact doctrine for the extended-limitation framework.

Valkya Editorial··8 min
LandmarkSupreme Court of India

Online gaming and the actionable claim: the Supreme Court's 28% GST ruling, read closely

The 28 May 2026 judgment upholding the 28% GST levy on online money gaming, fantasy sports and casinos is the largest indirect-tax ruling in India in a generation — and the reasoning is more interesting than the outcome. A digest of the actionable-claims doctrine, the rejection of the skill-versus-chance test, and what survives for the practitioner advising in this space.

Valkya Editorial··9 min
Weekly Report

The GST Appellate Tribunal (Procedure) Rules, 2025 and the 30 June 2026 backlog cutoff

The GST Appellate Tribunal was statutorily provided for in 2017 but operationally inert for nearly eight years. The notification of the GSTAT (Procedure) Rules, 2025 on 24 April 2025 — followed by GSTAT becoming operational from September 2025 — has produced an institutional architecture that the GST framework had been missing since inception. The 30 June 2026 special backlog cutoff is the most urgent practitioner item. A digest of the Rules, the operational architecture, and the timeline practitioners must be tracking.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

Indore Development Authority v. Manoharlal: the Section 24(2) framework and the overruling of Pune Municipal Corporation

On 6 March 2020, a five-judge Constitution Bench overruled *Pune Municipal Corporation v. Harakchand Misirimal Solanki* (2014) and substantially restructured the doctrinal architecture under Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013. The substantive reading: 'or' between possession and compensation in Section 24(2) is to be read as 'nor' — the deemed lapse of acquisition proceedings requires that both conditions be unmet, not just one. A digest of the holding, the doctrinal architecture, and the substantive implications for land-acquisition practice.

Valkya Editorial··10 min
Weekly Report

The Income-tax Act, 2025 takes effect: a practitioner's read on the first day of the new regime

On 1 April 2026, the Income-tax Act, 2025 replaced the 1961 Act. The numbering is new, the structure is tighter, and the conceptual architecture has shifted — most visibly in the disappearance of 'previous year' and 'assessment year' in favour of a single 'tax year'. A reading of what has actually changed, what is structural cosmetic, and what the bar needs to know for its first cycle of tax-year-2026-27 work.

Valkya Editorial··10 min