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.
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.