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.
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.
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.
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.