ValkyaEditorial

GST & Indirect Tax — 45 Valkya Editorial digests

Indirect taxation — GST (input tax credit, classification, procedure), and the legacy customs, central excise and service-tax regimes litigated before the CESTAT and the courts.

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
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
TribunalCESTAT, Principal Bench, New Delhi

Continental Automotive Brake Systems v. Commissioner of Customs: ABS sub-components denied concessional duty

On 22 April 2026, the CESTAT Principal Bench held that ECUs and sensors imported for assembly into Anti-lock Braking Systems are 'suitable for use' in motor vehicles and are denied the benefit of Notification 50/2017-Customs, but set aside interest and penalty on differential IGST for the pre-16 August 2024 period.

Valkya Editorial··9 min
Supreme CourtGujarat High Court; Supreme Court of India

Filco Trade Centre: rescuing transitional credit

On 22 July 2022, a two-judge Supreme Court bench directed GSTN to reopen the common portal for two months, allowing every aggrieved taxpayer to file or revise TRAN-1 and TRAN-2 to carry forward pre-GST credit.

Valkya Editorial··10 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
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
Supreme CourtSupreme Court of India

Madras Bar Association v. Union of India: the tribunal-reforms arc from the July 2021 striking-down to the November 2025 full invalidation

Across two engagements separated by four years, the Supreme Court has held the Tribunals Reforms architecture introduced by the Union to be inconsistent with the constitutional protection of judicial independence. In July 2021, a three-judge bench struck down provisions of the Tribunals Reforms (Rationalisation and Conditions of Service) Ordinance, 2021 by 2:1. In November 2025, a two-judge bench led by Chief Justice B.R. Gavai held that the Tribunals Reform Act, 2021 was unconstitutional and inconsistent with the basic structure. A digest of both engagements, the doctrinal frame, and the tribunal-independence architecture they leave.

Valkya Editorial··9 min
LandmarkSupreme Court of India

McDowell & Co. v. Commercial Tax Officer: the colourable-device doctrine and the line between planning and avoidance

On 17 April 1985, a five-judge Constitution Bench of the Supreme Court — majority opinion authored by Rangnath Misra J. on behalf of himself and three other judges, with a separate concurring opinion by O. Chinnappa Reddy J. — unanimously held that excise duty paid directly by McDowell's buyers to the State to obtain distillery passes formed part of McDowell's turnover under the Andhra Pradesh General Sales Tax Act, 1957; the structural arrangement was a colourable device. The majority articulated that tax planning within the law is legitimate but colourable devices cannot be part of tax planning; Chinnappa Reddy J.'s concurrence went further, drawing on the UK Ramsay–Burmah Oil–Dawson line to urge a substance-over-form approach. A digest of the bench composition (as independently verifiable), the architecture of the Andhra excise scheme, the doctrinal contribution, and the post-McDowell arc through Azadi Bachao, Vodafone, and the statutory GAAR.

Valkya Editorial··12 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
Supreme CourtSupreme Court of India

Northern Operating Systems: how the Supreme Court read substance over form into cross-border secondment and pulled overseas group transfers into service-tax (and GST) net

On 19 May 2022, a three-judge bench presided by Justice Uday Umesh Lalit — through a judgment authored by Justice S. Ravindra Bhat — held that the secondment of expatriate employees by overseas group entities of *Northern Operating Systems Pvt. Ltd.* constituted a taxable supply of manpower under the Finance Act 1994, attracting reverse-charge service tax. Substance, not the form of the secondment contract, was held to govern; the employment matrix — payroll, social security, the right of repatriation — remaining with the overseas entity was decisive. The Court denied the Revenue the extended period of limitation under *Section 73*. The judgment has since travelled into the GST era through a wave of *Section 74* notices and a moderating CBIC instruction.

Valkya Editorial··13 min
Supreme CourtSupreme Court of India

Safari Retreats v. Union of India: how the Supreme Court read 'plant or machinery' to permit ITC on commercial leasing buildings — and how the Finance Act 2025 retrospectively undid the reading

On 3 October 2024, a two-judge bench of Justices Abhay S. Oka and Sanjay Karol held that the textual choice of 'plant or machinery' — rather than 'plant and machinery' — in *Section 17(5)(d) of the CGST Act, 2017* was deliberate, and that a building could qualify as 'plant' for input-tax-credit purposes if the functionality test was satisfied. The Finance Act 2025 substituted 'and' for 'or' with retrospective effect from 1 July 2017, nullifying the reading; the review petition was dismissed on 20 May 2025; constitutional challenges to the retrospective amendment are now mounting in the High Courts. A digest of the holding, the legislative reversal, and the live constitutional terrain.

Valkya Editorial··15 min
Supreme CourtSupreme Court of India

Sundaresh Bhatt, Liquidator of ABG Shipyard v. CBIC: moratorium, customs and the Section 238 override

On 26 August 2022 a three-judge bench of the Supreme Court, in Sundaresh Bhatt, Liquidator of ABG Shipyard v. Central Board of Indirect Taxes and Customs, held that once a moratorium is imposed under Section 14 or Section 33(5) of the Insolvency and Bankruptcy Code, the Customs Act yields to the IBC by force of Section 238. The Central Board of Indirect Taxes and Customs retains the power to assess and determine the quantum of customs duty payable, but cannot initiate recovery, sale or confiscation of the corporate debtor's goods during the moratorium; the customs claim must be filed before the IRP or liquidator and ranks in the Section 53 waterfall. A close reading of Chief Justice Ramana's judgment, the spheres-of-operation reasoning and the doctrinal arc through Paschimanchal.

Valkya Editorial··12 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 / 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