Annual Tax & Corporate Law Digest 2025: Complete High Court Cases [Part XXI]
This Annual Digest summarises all the High Court Tax and corporate law Decisions in 2025, as reported at Taxscan.in.
No PAN Mandatory for Lower TDS under DTAA: Gujarat HC rules in favour of Adani Wilmar Ltd
COMMISSIONER OF INCOME TAX vsM/S ADANI WILMAR LTD. CITATION: 2025 TAXSCAN (HC) 1181
In a ruling in favour of Adani Wilmar Ltd, the Gujarat High Court has held that the Permanent Account Number (PAN) is not mandatory for lower Tax Deducted At Source (TDS) under the Double Tax Avoidance Agreement (DTAA). The bench affirmed the Tribunal order upholding CIT(Appeals) action in deleting the tax demand relatable to difference between 20% and the actual tax rate on which tax was deducted by the respondent assessee in terms of the relevant DTAAS.
The division bench of Justice Bhargav D. Karia and Justice Pranav Trivedi has concluded that the CIT(A) in deleting the tax demand relatable to difference between 20% and the actual tax rate on which tax was deducted by the assessee in terms of the relevant DTAAs. As the respondent assessee has deducted the tax at source on payment made to non residents on account of royalty and/or fees for technical services at the rates prescribed in respective DTAAs between India and respective countries of non residents and such rate of tax being lower than rate of 20% as provided under section 206AA of the Act, CIT (Appeals) and the Tribunal have rightly arrived at concurrent findings to the effect that as per section 90(2) of the Act, the provisions of DTAA would override the provisions of the Domestic Act where the provisions of the DTAA are more beneficial to the assessee.
Delayed Service of GST Notice Hardcopy: Madras HC Condones 142-Day Delay and Allows Tax Appeal
M/s.Sivasubramanian Laxmanan vsThe Deputy Commissioner (ST) CITATION: 2025 TAXSCAN (HC) 1182
The Madurai Bench of the Madras High Court has condoned a 142-day delay in filing a GST appeal, due to a delay in receiving the physical demand notice, despite it being uploaded online earlier.
The High Court Justice Vivek Kumar Singh noted that the petitioner has demonstrated reasonable cause for the delay, especially since the demand notice was not immediately communicated in physical form. Consequently, the Court condoned the delay, set aside the order rejecting the appeal, and directed the appellate authority to hear the matter afresh on merits, after affording the petitioner an opportunity of hearing.
Patna HC Directs State GST Dept to refund Rs. 10K against Illegal GST Recovery Conducted
M/S Great Eastern Hire PurchasePrivate Limited vs The State ofBihar CITATION: 2025 TAXSCAN (HC) 1183
The Patna High Court has ordered the State GST Department to return the money plus 9% simple interest and Rs. 10,000 in costs after invalidating an unlawful tax recovery made under the Goods and Services Tax (GST) regime.
After seeing that the authorities had violated their previous order, the division bench consisting of Justices Rajeev Ranjan Prasad and Ashok Kumar Pandey sent show-cause notices to the Appellate Authority and the Assistant Commissioner. They were requested to defend themselves against being held personally responsible for paying interest and legal fees resulting from their deliberate disregard for the court's order, as well as why contempt proceedings should not be brought against them. Both officers gave unequivocal apologies and show-cause replies in return.
Dispute Over Email ID in Income Tax Proceedings leading to Ex Parte Order: Madras HC Directs Fresh Consideration
Natarajan Manohar vs Income TaxOfficer CITATION: 2025 TAXSCAN (HC) 1184
The Madras High Court has remanded a case back to the Income Tax Department for fresh consideration after noting that an ex parte assessment order was passed without proper service of notice to the taxpayer.
The fact that the assessment order had been issued ex parte was undeniable, says Madras High Court Justice Krishnan Ramasamy. The Court determined that the petitioner's assertion that he did not receive correspondence at his personal email account seemed sincere and merited review, given the case's involvement with natural justice and tax responsibility issues.
Relief to Hindustan Equipment Pvt. Ltd, 50% Relief Under 2020 Samadhan Scheme Applies to Taxpayers with Pending Appeals: Madhya Pradesh HC
M/S HINDUSTAN EQUIPMENT PVT. LTDvs STATE OF M.P. THROUGHCOMMERCIAL TAX DEPARTMENT AND OTHERS CITATION: 2025 TAXSCAN (HC) 1185
In a recent ruling, the Madhya Pradesh High Court has held Hindustan Equipment Pvt. Ltd eligible under 2020 Samadhan Scheme (The Madhya Pradesh Karadhan Adhiniyamon Ki Puranee Bakaya Rashi Ka Samadhan Adhyadesh, 2020) holding that taxpayers with pending appeals are eligible for 50% relief under the said Scheme.
A division bench of Justices Vivek Rusia and Binod Kumar Dwivedi observed that “Had the petitioner submitted an application for settlement under the Ordinance during the pendency of the proceeding before the Assessment Officer, then certainly this case would have fallen under category 1, but now that stage has crossed. The petitioner’s case is pending before the appellate authority as per the definition of 2(f) the settlement amount is liable to be calculated on the basis of the disputed amount.”
Putting up Non-Commercial Signages on their Property: Karnataka HC Sets aside Ad Tax Demand on Educational Institutions
SRI. B.S. GUPTA vs THECOMMISSIONER BRUHAT BENGALURU CITATION: 2025 TAXSCAN (HC) 1186
While setting aside a demand for advertisement tax against an educational institution, the Karnataka High Court has held that in the absence of any commercial or promotional content, advertisement tax under Section 134 of the Karnataka Municipal Corporation Act, 1976 is not applicable for displaying non-commercial signage and boards on its own property.
A single bench of Justice Sachin Shankar Magadum viewed the placement of signage on the college building as being part and parcel of the institution's physical infrastructure and not intended to solicit business. Such signage lacks the essential character of an advertisement as defined under Rule 2A(1) of the BBMP Advertisement Bye-laws 2006.
Goods Classification under EPCG by DGFT Binding on Customs Department
M/s.Adyar Gate Hotel Ltd vs TheCommissioner of Customs CITATION: 2025 TAXSCAN (HC) 1187
In a notable judgment with implications for importers availing duty concessions under the Export Promotion Capital Goods (EPCG) Scheme, the Madras High Court has held that the classification of goods as ‘capital goods’ under an EPCG licence issued by the Directorate General ofForeign Trade (DGFT) is binding on the Customs Department.
The Court observed that the Customs authorities cannot take a contradictory stand or deny concessional duty benefits once such classification is accepted by the licensing authority.
GST Appeal Delayed for 1 day as Due Date was Sunday, Dept Refuses to Condone Delay: Madras HC Condones delay
M/s.Star Cones vs 1.The DeputyCommissioner (ct) Gst-appeal CITATION: 2025 TAXSCAN (HC) 1188
The Madras High Court has condoned a one-day delay in filing a GST ( Goods and Services Tax ) appeal caused by the due date falling on a Sunday. After considering both sides, Justice Krishnan Ramasamy held that the reason for the delay was genuine and unavoidable.
The Court noted that the last date fell on a Sunday, which was beyond the petitioner’s control, and that the subsequent filing on Monday should be treated as within time, especially since the petitioner had acted in good faith and complied with the statutory pre-deposit requirement. The bench found the reasons of the petitioner genuine.
SCN u/s 75(10) of CGST Act issued after 30 days period is without Jurisdiction: Gujarat HC rules in favour of IndusInd Bank
INDUSIND BANK LIMITED vs STATEOF GUJARAT CITATION: 2025 TAXSCAN (HC) 1189
In a recent case, the Gujarat High Court ruled in favour of IndusInd Bank, holding that a show cause notice (SCN) under section 75(10) of the Central Goods andService Tax Act (CGST Act), 2017, issued after a 30-day period is without jurisdiction. It was observed that when the period prescribed is three months as contrasted from 90 days from a specified date, the said period would expire in the third month.
A division bench of Justice Bhargav D. Karia and Justice Pranav Trivedi observed that the three months would be over on 28.11.2024 and therefore, the show cause notice dated 30.11.2024 would be without jurisdiction and as a consequence thereof, the impugned order in original would be without jurisdiction.
GST Notice via WhatsApp Not a Valid Mode of Service u/s 169, Even During COVID-19: Kerala HC
MATHAI M.V vs THE SENIORENFORCEMENT OFFICER CITATION: 2025 TAXSCAN (HC) 1190
In a recent ruling, the Kerala High Court held that GST notices sent via WhatsApp are not a valid mode of service under Section 169 of the CGST Act, even if used during the COVID-19 period.
The court observed that service of notice is a mandatory requirement before confiscating goods or conveyances under Section 130, and the department’s failure to follow the statutory procedure rendered the confiscation illegal. The court set aside the confiscation of the petitioner’s truck, which had been seized by the GST department without issuing a proper statutory notice.
Section 5A Tax on Buildings Valid as It’s Not a Luxury Tax, But Recovery Barred Beyond 3 Years: Kerala HC
ISON GEORGE vs STATE OF KERALA CITATION: 2025 TAXSCAN (HC) 1191
In a recent ruling, the Kerala High Court held that Section 5A of the Kerala Building Tax Act, which imposes tax on large residential buildings, is valid as it is not a luxury tax but a tax on buildings and ruled that recovery of such tax cannot be made for periods beyond three years from the date of the demand notice.
The court set aside the demand for the years 2007-2008 to 2015-2016 while upholding the validity of Section 5A of the Act. It ruled that the department could recover tax dues only for the period from 2016-2017 onwards. The writ appeal was partly allowed.
Madras HC Upholds Continuation of ADD on Viscose Staple Fibre Imports from Indonesia Despite 11-Day Gap Between Expiry and Extension
M/s.PT.South Pacific Viscose vsThe Union of India CITATION: 2025 TAXSCAN (HC) 1192
In a recent ruling, the Madras High Court dismissed a set of writ petitions filed by PT South Pacific Viscose challenging the continuation of anti-dumping duty (ADD) on imports of Viscose Staple Fibre (VSF) from Indonesia despite a gap of eleven days between the expiry of the original notification and the extension.
The court also observed that the petitioner’s reliance on the Kumho Petrochemicals ruling was misplaced, as the decision only applied where the review itself was initiated after the expiry of the levy. The court further observed that the petitioner should have approached the Delhi High Court or the Supreme Court under Section 130E of the Customs Act, given that the case related to the rate of duty, and noted that writ petitions were not the appropriate remedy in such cases.
AO Not Bound By Observations of First Appellate Authority during De Novo VAT Assessment: Madras HC Upholds Sales Tax Tribunal Decision
The State of Tamil Nadu vsTvl.Aro Granite Industries Ltd CITATION: 2025 TAXSCAN (HC) 1193
The Madras High Court recently shed light on the independent authority exercisable by an Assessing Officer (AO) during de novo proceedings under the Tamil Nadu Value Added TaxAct, 2006, confirming that the AO is not bound by the observations of the first appellate authority while conducting a reassessment.
The Division Bench of Justice Anita Sumanth and Justice N. Senthilkumar considered these submissions and observed that, during de novo assessment proceedings, the AO must independently apply his mind to all facts and circumstances of the case, strictly in accordance with law; and should not be constrained by the observations of the appellate authority in the preceding stage.
GST Return Filed and Paid Outstanding Dues Till date of GST Cancellation : Gauhati HC Direct to Revoke Cancellation
Smti Gichak Daniam vs The Stateof AP CITATION: 2025 TAXSCAN (HC) 1194
The Gauhati High Court has directed the revival of GST ( Goods and Services Tax ) registration cancelled by tax authorities, observing that the petitioner had filed the requisite returns and paid all outstanding dues up to the date of cancellation.
The Court observed that the petitioner had complied with requirements, including filing the necessary returns and clearing outstanding dues up to the date of cancellation. Accordingly, the Court directed the respondent authorities to restore the GST registration. It ordered that the revocation of the cancellation be carried out within 25 days from the date of the judgment. Additionally, the authorities were instructed to inform the petitioner of any remaining statutory dues to facilitate the filing of returns, if required.
GST Attachment Order Withdrawn After Appeal Admitted: Orissa HC Dismisses Writ as Infructuous
M/s.Manoj Distributor vs TheChief Commissioner CITATION: 2025 TAXSCAN (HC) 1195
In a recent ruling, the Orissa High Court dismissed a writ petition challenging a GST ( Goods and Services tax ) attachment order after noting that the statutory appeal against the assessment order had already been filed and admitted. The matter was heard via hybrid mode.
Chief Justice Harish Tandon and Justice M S Raman observed that “Since the order of attachment has already been withdrawn and the original order of assessment is the subject- matter of challenge in the statutory appeal, we thus feel that justice would not be sub-served to keep the instant writ petition pending.”
CBIC Circular Allowing Superintendents to Issue GST Summons Prima Facie Without Legal Authority: Rajasthan HC Grants Interim Stay
M/s Mohit Kirana Store vsCentral Board of Indirect Taxes andCustoms CITATION: 2025 TAXSCAN (HC) 1196
In a recent ruling, the Rajasthan High Court granted an interim stay on the operation of a CBIC circular that allowed Superintendents to issue GST summons, finding that it prima facie lacked legal authority under the GST law.
A division bench led by Chief Justice Manindra Mohan Shrivastava and Justice Maneesh Sharma observed that the petitioner had made out a strong prima facie case, indicating that the circular may have been issued without proper legal authority. The court also observed that since a substantial legal question was involved, the matter required detailed examination at the final hearing stage.
Income Tax Proceedings cannot Survive if Empowering Notices have been Statutorily Quashed: Madras HC
Devaraj Ramasamy Naidu vs TheAssistant Commissioner of IncomeTax CITATION: 2025 TAXSCAN (HC) 1197
In a recent ruling, the Madras High Court reiterated the settled position of law that all proceedings flowing from a foundational or “empowering” notice under the Income Tax Act, 1961 shall stand vitiated if the relevant notice has been quashed by a competent court.
The single-judge Bench of Justice Krishnan Ramasamy observed that the entirety of the reassessment and penalty proceedings would stand unsustainable when the original notice giving rise to such proceedings has already been set aside by the Division Bench.
Button Mushroom Cultivation Under Controlled Conditions Not Exempt as Agricultural Income, Taxable as Business Income: Madras HC
The Principal Commissioner ofIncome Tax-1 vs M/s.British AgroProducts (India) Pvt. Ltd CITATION: 2025 TAXSCAN (HC) 1198
In a recent ruling, the Madras High Court held that income from cultivating white button mushrooms under controlled conditions is not agricultural income and is taxable as business income under the Income Tax Act, 1961.
The bench comprising Justice R. Suresh Kumar and Justice C. Saravanan observed that under Section 2(1A), agricultural income requires a direct nexus with land used for agricultural purposes, and the product must be raised on such land.
The court observed that cultivating mushrooms in controlled factory conditions without using land for agriculture does not meet the statutory definition, regardless of the soil being placed in trays. The court also observed that the ITAT erred in relying solely on the Special Bench decision in Inventaa Industries without independently examining the statutory definition of agricultural income in the present case.
Relief to TVS: Madras HC Quashes Income Tax Notices Issued by JAO, Upholds Mandatory Notice By FAO under Faceless Assessment
TVS Credit Services Limited vsDeputy Commissioner of Income Tax CITATION: 2025 TAXSCAN (HC) 1199
In a Recent ruling, the Madras High Court has quashed income tax notices issued by the Jurisdictional Assessing Officer (JAO) and affirmed that such notices must be issued by the Faceless Assessment Officer (FAO) under the mandatory faceless assessment regime.
The Division Bench ruled that notices issued by the JAO were invalid. It quashed the impugned notices and set aside related proceedings, keeping all rights and contentions of the parties open. The Revenue was granted liberty to seek revival of the petitions if it succeeds before the Supreme Court.
The bench also noted that issues not covered by the Hexaware judgment remain open for adjudication at the appropriate stage. The writ petitions were disposed of in favor of the assessee, TVS Credit Services Limited, with no order as to costs. All connected interim applications were also closed.
Relief for Hyundai: Madras HC Rules Income Tax Assessment Cannot Be Reopened Just for AO's Changed Opinion on Forex Gains
The Commissioner of Income Taxvs Hyundai Motor India Ltd CITATION: 2025 TAXSCAN (HC) 1201
In a recent ruling, the Madras High Court quashed the reopening of Hyundai Motor India Ltd’s income tax assessment, stating that the action was based merely on a change of opinion by the Assessing Officer regarding foreign exchange gains and technical know-how payments.
A division bench led by Chief Justice K.R. Shriram and Justice Sunder Mohan observed that the Assessing Officer had issued extensive questionnaires during the original proceedings and had concluded the assessment after considering Hyundai’s detailed responses. The court held that the reassessment notice lacked fresh tangible material and was solely based on a reappraisal of the same facts already examined.
GST ITC Denial Without Considering Retrospective Relief u/s 16(5) Unjustified: Calcutta HC Remands Case
DYS Impex Private Limited vsAssistant Commissioner of Revenue CITATION: 2025 TAXSCAN (HC) 1202
The Calcutta High Court held that denying Input Tax Credit ( ITC ) under the Goods and Services Tax (GST) Act without considering the retrospective effect of Section 16(5) of the CGST/WBGST Act, 2017 is unjustified.
The High Court noted that the extended benefit provided under Section 16(5) had substantially altered the scope and application of Section 16(4).
The Court stated that since the refund denial rested solely on the limitation under Section 16(4), without accounting for the overriding effect of Section 16(5), such rejection could not be sustained. As a result, the Court quashed both the appellate and adjudication orders and remanded the matter to the proper officer for de novo consideration in light of the amended provision
GST Penalty cannot be Levied when there is No Intention to Evade Tax : Himachal Pradesh HC Quashes Demand for Missing E-Way Bill
M/s Kunal Aluminum Company vsState of Himachal Pradesh &ors CITATION: 2025 TAXSCAN (HC) 1203
The Himachal Pradesh High Court quashed the penalty and tax demand imposed under Section 129 and 130 of the GST ( Goods and Services Tax ) Act for non-generation of an e-way bill, ruling that the absence of intent to evade tax renders such a penalty unsustainable. It reaffirmed the necessity of ‘Men Rea’.
The court noted that penalties under tax law must be reserved for deliberate acts of tax evasion, not for genuine, inadvertent lapses. According to the bench, the burden of proof lies with the tax authorities to establish a taxpayer’s intent to evade, before imposing any penalty.
Nine GSTINs, NIL Returns, and Massive ITC Fraud: Patna HC Says No Prima Facie Case for Interference under Article 226
Mangalam Enterprises vs TheState of Bihar CITATION: 2025 TAXSCAN (HC) 1204
The Patna High Court dismissed a writ petition filed by Mangalam Enterprises, a sole proprietorship, seeking to quash a tax demand of over ₹1.59 crore raised under Section 74(9) of the GST ( Goods and Services Tax ) Act.
The Court observed that no prima facie case had been made out for invoking its extraordinary jurisdiction under Article 226 of the Constitution of India. While dismissing the petition, the Division Bench of Justice Rajeev Ranjan Prasad and Justice Ashok Kumar Pandey held that “No ground for entertaining this writ application under Article 226 of the Constitution of India… has been made out. The statements made in the counter affidavit have not even been controverted by the petitioner.”
Mandatory Personal hearing u/s 28(8) of Customs Act cannot be denied by relying on special provision S.122A: Kerala HC
M/S. PREMIER MARINE FOODS vsUNION OF INDIA CITATION: 2025 TAXSCAN (HC) 1205
The Kerala High Court has held that a mandatory hearing opportunity is to be granted under section 28(8) of the Customs Act, 1962 and it cannot be denied by the department by relying on a special provision under section 122A of the act.
On going through the notice, the single bench of Justice Ziyad Rahman A.A. found that apart from requiring the petitioner to submit evidence of realization of the export proceeds within 30 days and also intimating that if the exporter desires to be heard, they may request for the same in writing, no specific date was fixed for personal hearing. Thus, the 2nd respondent had only extended an option to the petitioner to avail an opportunity for personal hearing, if they desire.
Kerala HC Upholds validity of SCN Served on Adult Member of Noticee u/s 153 of Customs Act
MANU VALIYAVEETTIL MADHU vsADDITIONAL COMMISSIONER OF CUSTOMS CITATION: 2025 TAXSCAN (HC) 1206
The Kerala High Court upheld the validity of a show cause notice served on the adult member of the noticee under Section 153 of the Customs Act, 1962. The contentions of the petitioner that the proper opportunity was denied to contest the matter cannot be accepted while upholding the validity of the notice served.
The bench viewed that the contentions that the petitioner was denied a proper opportunity to contest the matter cannot be accepted as the notice was served upon the petitioner through the elderly member of the family is admitted and later, an opportunity to appear through virtual mode was availed by the petitioner. By utilizing the said opportunity, the petitioner appeared before the adjudicating officer concerned and offered his explanation without raising any contention with regard to the non-receipt of the show cause notice or denial of opportunity to submit an explanation to the notice.
Absence of Express Reference for Conveyance in Confiscation Order does not Exclude It from Confiscation u/s130 CSGT Act: Kerala HC
ASGAR ALI vs UNION OF INDIA CITATION: 2025 TAXSCAN (HC) 1207
The Kerala High Court, in its recent ruling, held that the absence of an express reference to the conveyance in the confiscation order does not exclude it from confiscation under section 130 of the Central Goods and Services Tax (CGST) Act, 2017.
The court denied the petition, ruling that the operative component of the directive, which was issued in lieu of confiscation, stipulated that the sums must be collected prior to the release of goods and conveyance in order to collect taxes, penalties, and fines. In these situations, the order did not call for the forfeiture of the conveyance.
Madras HC Dismisses writ petition against SEBI on availability of remedy u/s 15T of SEBI Act
M/s.SAS Cityscapes Pvt.Ltd vsThe Securities and Exchange Boardof India CITATION: 2025 TAXSCAN (HC) 1208
In a recent case, the Madras High Court dismissed the writ petition against the Securities and Exchange Board of India (SEBI) on availability of remedy under section 15 T of the SEBI Act , 1992.
A single bench of Justice N. Anand Venkatesh on the ground of availability of an effective and efficacious alternative remedy to the petitioner, this Court is not inclined to exercise its jurisdiction under Article 226 of Constitution of India. Section 15 (T) (1) (a) of the SEBI Act, 1992 provides for an appeal to the Securities Appellate Tribunal and such appeal has to be filed within a period of 45 days and the Tribunal has also been given the power to condone the delay, if any appeal is filed after the expiry of 45 days, if sufficient cause is shown for the delay.
Dispute Over Ownership of Property during Liquidation Process under Company Law: Madras HC directs Official Liquidator to value building through ITCOT within 60 days
M/s.Team Associates vs TheOfficial Liquidator CITATION: 2025 TAXSCAN (HC) 1209
In a recent case, the Madras High Court directsed the official liquidator to value the building through ITCOT within 60 days while a dispute over the ownership of property arose during the liquidation process under company law.
Judge Senthilkumar Ramamoorthy's single bench ruled that the Official Liquidator had sixty days to value the building on S.F. No. 79/1 using ITCOT. Within 30 days of obtaining the valuation report, the applicants (Team Associates & Vangili Feeds) must give the Official Liquidator the building's worth.
No Double GST Action on Same Issue: Karnataka HC Quashes State Notice to Toyota Kirloskar Amid Central Proceedings
M/S TOYOTA KIRLOSKAR AUTO PARTSPVT. LTD vs UNION OF INDIA CITATION: 2025 TAXSCAN (HC) 1210
In a recent ruling, the Karnataka High Court quashed a State GST ( Goods and Services Tax ) notice issued to Toyota Kirloskar Auto Parts Pvt. Ltd., holding that the State authorities could not initiate proceedings on the same issue when the Central GST authorities had already begun action.
The court directed Toyota Kirloskar Auto Parts to file its reply to the notice issued by the Central GST authorities, allowing the department to reconsider the petitioner’s ITC claim in accordance with applicable laws and recent circulars. The court also granted liberty to the petitioner to apply for relief under the Amnesty Scheme, allowing the proceedings to be considered under Section 73 of the CGST Act, which could potentially enable the petitioner to resolve the dispute on favourable terms. The writ petition was allowed.
Income Tax Dept. Can’t Deny Adequate Time for SCN Reply Citing Limitation, Must Initiate Proceedings Earlier: Madras HC Grants Relief to Tamil Nadu Power Corp.
The Tamil Nadu PowerDistribution Corporation Ltd. vs Jointcommissioner of Income Tax CITATION: 2025 TAXSCAN (HC) 1211
The Madras High Court recently granted relief to the Tamil Nadu Power Distribution Corporation Ltd. (TNPDC) in a dispute concerning the Income Tax Department’s denial to provide TNPDC adequate time to respond to a Show Cause Notice (SCN) issued by the Income Tax Department citing reasons of being barred by limitation.
The Bench of Justice Krishnan Ramasamy, observed that if limitation truly was the basis for restricting the time for reply, the department ought to have acted with greater diligence and issued the show cause notice much earlier.
No Interference with Order by Income Tax Settlement Commission Unless Contrary to Law or involves Bias, Fraud, or Malice: Madras HC
M/s.Sri Krishna Tiles andPotteries vs Commissioner of WealthTax CITATION: 2025 TAXSCAN (HC) 1212
The Madras High Court has ruled that courts cannot interfere with orders passed by the Income Tax Settlement Commission unless they are contrary to law or involve bias, fraud, or malice.
The Division Bench of Chief Justice K.R. Shriram and Justice Sunder Mohan, undertook a detailed review of Supreme Court and High Court precedents, including the decision of the Bombay High Court in Principal Commissioner of Income Tax (Central-3) vs. Income Tax Settlement Commission (ITSC) and others, (Wadhwa Group Holding Pvt. Ltd) (2019) to reiterate that the Settlement Commission operates as a forum for self-surrender and relief, not as a tribunal for contesting the legality of assessment orders.
Reopening Based on Information in Audited Statements Invalid: Madras HC Finds No Failure by Company to Disclose Material Facts
Sterling Tree Magnum India vsThe Assistant Commissioner ofIncome Tax CITATION: 2025 TAXSCAN (HC) 1213
In a recent ruling, the Madras High Court held that reopening the assessment of Sterling Tree Magnum India Ltd was invalid as the reassessment was based solely on information already available in the company’s audited statements and reports, with no failure on the company’s part to fully and truly disclose material facts necessary for the original assessment.
The court observed that the Assessing Officer had the opportunity to examine these details during the initial scrutiny, and the reopening was not justified merely because the officer did not notice or interpret the disclosures earlier.
Dismissal of Customs Appeal on Limitation Set Aside: Madras HC Allows Reconsideration of Duty Drawback Claim Upon Full Deposit
M/s.Sangeetha Tex vs TheCommissioner of GST and C.EX (Appeals) CITATION: 2025 TAXSCAN (HC) 1214
The Madurai Bench of the Madras High Court has set aside the dismissal of the firm’s customs appeal on the grounds of limitation and remanded the matter back to the customs authorities for reconsideration.
However, Justice C. Saravanan, in the interest of justice, considering that the petitioner’s willingness to make deposit and as the matter is on the export incentive, rescued the petitioner by directing to remit the whole disputed amount of Rs.2,59,517/- within a period of thirty days from the date of receipt of a copy of this order.
Transfer of Tata Projects’ ECL under GST: Rajasthan HC Directs GSTN to Act on Grievance Within Two Months
M/s Tata Projects Limited vs TheDeputy Commissioner CITATION: 2025 TAXSCAN (HC) 1215
The Rajasthan High Court, with regards to the transfer of Electronic Cash Ledger ( ECL ) under GST has directed the Goods and Services Tax Network ( GSTN ) to address the grievance raised by Tata Projects Limited within two months.
The division bench comprising Justice Avneesh Jhingan and Justice Mukesh Rajpurohit passed this order while disposing of a writ petition filed by the company.
The Rajasthan High Court, with regards to the transfer of Electronic Cash Ledger ( ECL ) under GST has directed the Goods and Services Tax Network ( GSTN ) to address the grievance raised by Tata Projects Limited within two months. The division bench comprising Justice Avneesh Jhingan and Justice Mukesh Rajpurohit passed this order while disposing of a writ petition filed by the company.
CIT’s Order to Recompute Tamil Nadu Cements’ Set-Off Valid as Method Used Was Faulty: Madras HC
Tamil NaduCements Corporation Ltd. vs The Income Tax Officer(OSD) CITATION : 2025 TAXSCAN (HC) 1216
In a recent ruling, the Madras High Court upheld the CIT’s direction to the Assessing Officer to recompute Tamil Nadu Cements Corporation’s set-off of past losses and depreciation, holding that the method used by the company was faulty.
A division bench led by Chief Justice K.R. Shriram and Justice Sundermohan observed that the CIT had correctly used its powers under Section 263 to direct the Assessing Officer to recompute the income and ensure correct application of the law on set-offs of past losses and depreciation. The court also noted that the company had accepted the recomputation and had not challenged the subsequent ITAT orders, indicating there was no reason to entertain the appeal further.
Life Membership Fee received by Private Club is Capital Receipt, Not Taxable to Income: Madras HC
ChennaiCorporate Club (P) Ltd vs The Asst. Commissioner ofIncome Tax CITATION : 2025 TAXSCAN (HC) 1217
The Madras High Court recently clarified that life membership fees collected by private clubs are classifiable as capital receipt and not revenue receipt, thus not being taxable to the income of the entity.
The Bench of Chief Justice K.R. Shriram and Justice Sunder Mohan analyzed the legal character of the life membership fee and the circumstances under which it was collected by the appellant. The Court observed that the one-time, non-refundable payment was to secure life membership rights, and not to pay for periodic services or regular amenities which may be enjoyed by the members upon the payment of a separate regular monthly subscription amount, paid as cost of participation.
TDS Deducted, Physical Verification Done, Payments by Cheque : Madras HC Upholds ITAT Order Allowing Development Expenses, Rejects Revenue’s Appeal
TheCommissioner Of Income Tax vs M/s Bharat Promoters CITATION : 2025 TAXSCAN (HC) 1218
The Madras High Court has upheld the order of the Income Tax Appellate Tribunal ( ITAT ) which allowed development-related expenses claimed by M/s Bharat Promoters as it was backed with physical site verification and evidence.
The Court also upheld the ITAT's acceptance of commission payments to a broker named Maruthanayagam, which was corroborated both by the broker and the purchaser in their sworn statements. Observing that the factual findings were based on a proper evaluation of evidence, the Court held that the Department’s claims of lack of documentary support were insufficient to disturb concurrent findings of fact by CIT(A) and ITAT. Income Tax Dept Arbitrarily Recovers Demand from Refund While Appeal Pending: Madras HC Orders Refund, Stays Recovery
SCN and OIO under Customs not Served to Tapioca Exporter: Madras HC Grants Opportunity for Hearing and Production of BRCs or CA Certificate
M/s.Spac StarchProducts (India) Private Ltd vs The AssistantCommissioner of Customs CITATION : 2025 TAXSCAN (HC) 1219
The Madras High Court has quashed an ex-parte order passed by the Customs Department. It found that the order-in-original and show cause notice was served to the exporter.
Justice Abdul Quddhose observed that the impugned order was in violation of the principles of natural justice. The Court observed that before taking coercive action or concluding non-compliance, authorities must ensure that proper notice is served. Accordingly, the bench quashed the impugned order and directed the first respondent to re-adjudicate the case after affording a personal hearing to the petitioner. The company was also permitted to submit its BRCs or Chartered Accountant certificates in support of its case. The final decision is to be rendered within twelve weeks from the receipt of the court order.
Madras HC Allows to file GST Appeal Despite Missed Deadline and Rejected Rectification, Subject to Additional 10% Pre-deposit
Tvl.PatilConstructions vs The State Tax Officer CITATION : 2025 TAXSCAN (HC) 1220
The Madras High Court, recently has permitted assessee to file a belated GST ( Goods and Services Tax ) appeal, despite the statutory time limit for filing having expired and a rectification application being rejected earlier on additional 10% pre-deposit over and above the statutory deposit requirement.
JusticeKrishnan Ramasamy, taking a balanced view, observed that though there was no legal bar preventing the petitioner from filing an appeal earlier, in the interest of justice, an opportunity should be provided to substantiate their case. The Court directed that after such payment, the appeal shall be taken on record and decided on merits and in accordance with law, after granting sufficient opportunity to the petitioner. The writ petition was disposed of with these directions, and no costs were imposed.
₹50 Lakh GST Demand Order Issued Without Stating Reasons: Madras HC Intervenes in Favour of Taxpayer, Quashes Order
Tvl.One PlusTechnology vs The State Tax Officer CITATION : 2025 TAXSCAN (HC) 1221
The Madurai Bench of the Madras High Court quashed a ₹50.48 lakh GST ( Goods and Services Tax ) demand order issued by the State Tax Officer on grounds of non-application of mind and absence of proper reasoning.
Accordingly, the High Court quashed the order and remitted the matter back to the assessing authority for fresh adjudication. It directed that a new speaking order be passed after granting the petitioner an opportunity for a personal hearing. The petitioner has been granted 30 days to file a detailed reply, treating the earlier impugned order as an addendum to the show cause notice.
GST Facilitation Operator Diverts Client’s ₹1.29 Crore Entrusted to Clear GST Dues: Orissa HC denies Pre-arrest Bail
Balidi vsBallidi vs State of Odisha CITATION : 2025 TAXSCAN (HC) 1222
The Court has refused to grant pre-arrest bail to an operator of a GST (Goods and Services Tax) facilitation centre who is accused of diverting over ₹1.29 crore meant for payment towards the GST dues of a client firm.
The Court, considering the allegations, observed the wider ramifications of such financial misconduct on the tax administration system and cited the recent decision of the Supreme Court in Serious Fraud Investigation Office v. Aditya Sarda to reiterate that economic offences require strict scrutiny. The Court dismissed the application for anticipatory bail, rescinding the previous temporary protection, and denied to extend the advantage of pre-arrest bail, noting that there was enough evidence in the record to substantiate the claims prima facie.
No Two Assessment Orders for the Same Tax Period Can Operate Simultaneously: Orissa HC Invalidates Ex Parte Order
Palem AshokReddy vs The Commissioner CITATION : 2025 TAXSCAN (HC) 1223
In a recent ruling, the Orissa High Court held that two GST ( Goods and Services Tax ) assessment orders for the same tax period cannot operate at the same time and set aside an ex parte assessment order issued without notice to the taxpayer. The court directed that the valid order passed on merits by the Nashik Commissionerate should stand.
A division bench led by Chief Justice Harish Tandon observed that when two assessment orders exist for the same period, the one made after providing an opportunity for a hearing and on the merits of the case should prevail. The court observed that the ex parte order passed without notice was without jurisdiction and could not stand.
Taxpayer Fails to Respond to GST SCN Due to Illness and 30% Disability: Calcutta HC Grants Opportunity to File Reply
Sanjit Acharyavs Assistant Commissioner of Revenue CITATION : 2025 TAXSCAN (HC) 1224
In a recent ruling, the Calcutta High Court allowed a taxpayer to file a fresh reply to a GST show-cause notice after the taxpayer failed to respond earlier due to illness and 30% disability.
The court set aside the orders passed by the GST department and the appellate authority. It directed the petitioner to file his reply to the show-cause notice by July 16, 2025. The court clarified that this timeline would not be extended. The court also quashed the attachment order issued against the petitioner’s property and directed that the pre-deposit already made would be retained and adjusted according to the final outcome. The writ petition was allowed.
Income Tax Dept Arbitrarily Recovers Demand from Refund While Appeal Pending: Madras HC Orders Refund, Stays Recovery
GreavesElectric Mobility Limited vs The Assistant Commissionerof Income Tax CITATION : 2025 TAXSCAN (HC) 1225
In a recent ruling, the Madras High Court directed the Income Tax Department to refund Rs. 3 crore to Greaves Electric Mobility Limited and to stay recovery proceedings while the company’s appeal and rectification petition are pending.
The single-judge bench comprising Justice Krishnan Ramasamy observed that the department’s action of adjusting the entire refund while the appeals and rectification were pending was arbitrary. The court also observed that the company had complied with the requirement to pay 20% of the demand to secure a stay and that the department’s conduct was unfair given the pending legal proceedings.
GST Act Proceedings Governed by CrPC Unless Excluded: Himachal Pradesh HC Upholds Trial Court’s Decision to Record Pre-Charge Evidence
Gagandeep Singhand another vs State of H.P. and another CITATION : 2025 TAXSCAN (HC) 1226
In a recent ruling, the Himachal Pradesh High Court held that proceedings under the GST Act are governed by the Code of Criminal Procedure (CrPC) unless specifically excluded and upheld the trial court’s decision to record pre-charge evidence in a GST prosecution case.
A single bench led by Justice Rakesh Kainthla observed that the CrPC applies to GST proceedings when there is no provision to the contrary in the GST Act and that the trial court was right in treating the matter as a warrant case requiring pre-charge evidence. The court observed that the allegations of the petitioners regarding improper investigation did not justify quashing the complaint at this stage and that the trial court should proceed to examine the evidence on record.
Export Incentive Cannot Be Denied for Technical Breach of GST S.129: Madras HC Orders ₹2.4L Excess Penalty to be Adjusted against Future Tax Liability
M/s.AthiyanExports vs State Tax Officer CITATION : 2025 TAXSCAN (HC) 1227
The Madurai Bench of the Madras High Court recently held that export incentives cannot be denied for a technical and venial breach of Section 129 of the Central Goods and Services Tax (GST) Act.
The single-judge Bench of Justice C. Saravanan noted that while the petitioner had indeed violated the procedural requirements under Section 129, the breach was technical and venial in nature with the question being whether the penalty that was imposed was justified or lesser penalty is to be imposed.
GST Order Incorrectly Recorded Taxpayer Did Not File Reply: Calcutta HC Remands Matter for Fresh Adjudication
Snehashis Duttavs Union of India & Ors CITATION : 2025 TAXSCAN (HC) 1228
In a recent ruling, the Calcutta High Court set aside a GST order that wrongly recorded the taxpayer had not filed a reply and sent the matter back for fresh adjudication.
A single bench led by Justice Raja Basu Chowdhury observed that the petitioner’s reply was indeed filed and acknowledged electronically and that the department did not dispute this fact during the hearing. The court observed that ignoring this reply and recording that no reply was submitted amounted to a violation of natural justice.
[Breaking] Classification of Service under "insurance auxiliary service" is not maintainable before HC: Calcutta HC
COMMISSIONER OFSERVICE TAX vs M/S MEDICARE SERVICE (INDIA) PVTLTD CITATION : 2025 TAXSCAN (HC) 1229
In a recent case, the Calcutta High Court has held that classification of the activity of Medicare Service (India) Pvt Ltd in collecting Premium from club members and remitting to insurance company of under ‘insurance auxiliary service’ isnot maintainable before High Courts.
In terms of the provision of the Central Excise Act read with provision of the Finance Act, an appeal to the High Court is not maintainable if the matter concerns determination of any question having a relation to the ‘rate of duty or the value of the goods for the purpose of assessment’. Admittedly, the issue which falls for consideration in this appeal is the classification issue and, therefore, the appeal is not maintainable before this court.
Challenge against Tender Cum-Auction Sale Notice under SARFAESI Act: Madras HC dismisses Writ petition on availability of Remedy under Statute
KanthinathanPalani Kandasamy vs The Assistant Commissioner CITATION : 2025 TAXSCAN (HC) 1230
The Madras High Court dismissed the writ petition challenging the tender cum-auction sale notice under the Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest (SARFAESI) Act, 2002 on availability of remedy under the statute.
The Apex court held that “In our view, while dealing with the petitions involving challenge to the action taken for recovery of the public dues, etc. the High Court must keep in mind that the legislations enacted by Parliament and State Legislatures for recovery of such dues are a code unto themselves inasmuch as they not only contain comprehensive procedure for recovery of the dues but also envisage constitution of quasi-judicial bodies for redressal of the grievance of any aggrieved person. Therefore, in all such cases, the High Court must insist that before availing remedy under Article 226 of the Constitution, a person must exhaust the remedies available under the relevant statute.”
Writ Jurisdiction Not Maintainable when Alternative Remedy Contemplated under SARFAESI Act: Madras HC
S.Visalatchi vsThe Authorised Officer CITATION : 2025 TAXSCAN (HC) 1231
The Madras High Court has held that writ jurisdiction is not maintainable when an alternative remedy is contemplated under the Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest (SARFAESI) Act, 2002.
The court viewed that while dealing with the petitions involving challenge to the action taken for recovery of the public dues, etc. the High Court must keep in mind that the legislations enacted by Parliament and State Legislatures for recovery of such dues are a code unto themselves inasmuch as they not only contain comprehensive procedure for recovery of the dues but also envisage constitution of quasijudicial bodies for redressal of the grievance of any aggrieved person. Therefore, in all such cases, the High Court must insist that before availing remedy under Article 226 of the Constitution, a person must exhaust the remedies available under the relevant statute.
Question of Nature of Property as Agricultural land or not, decided by DRAT without Considering Evidence Submitted: Madras HC Remands Matter
M/s.MiraExports vs The Authorized Officer CITATION : 2025 TAXSCAN (HC) 1232
The High Court of Madras remanded the challenge on nature of the property as agricultural land or not towards the Debt Recovery Appellate Tribunal, Chennai (“DRAT”) on finding that the tribunal decided the issue without considering evidence submitted.
The court inclined to set-aside the impugned order dated 26.09.2023 and remand the matter back to DRAT for reconsidering the issue by considering/evaluating the evidence let in by both sides and applying the tests laid down by the Supreme Court and the Court and enquire into all relevant aspects including those discussed in paragraphs 10.1 (a) to (d) supra and determine whether subject property in question is agricultural or otherwise.
Section 149 Amendments Prospective, Invalidates Reopening Beyond Limitation : Delhi HC Quashes Income Tax Notices
U.K. PAINTS(OVERSEAS) LTD vs ASSTT.COMMISSIONER OF INCOME TAX CITATION : 2025 TAXSCAN (HC) 1233
The Delhi High Court has quashed several income tax notices issued under Section 148 of the Income Tax Act and held that amendments to Section 149 introduced by the Finance Act, 2012, are prospective and do not permit reopening of assessments where the limitation period had already expired.
The Court observed that 2012 amendment introduced clause (c), extending the period to 16 years for cases involving foreign assets, effective from July 1, 2012. It relied on Supreme Court precedents, including K.M. Sharma v. Income Tax Officer and S.S. Gadgil v. Lal & Co., which established that amendments extending limitation periods are prospective.
Assessment Order Passed Without Personal Hearing u/s 75(4) of GST Act: Patna HC Quashes Order
M/S SinghTraders vs The State of Bihar CITATION : 2025 TAXSCAN (HC) 1234
The High Court of Patna, quashed an assessment order passed against the assessee for the period 2018-2019, observing that it had been issued without affording a personal hearing as mandated under Section 75(4) of the GST Act,2017.
Justice Rajeev Ranjan and Justice Ashok Kumar Pandey, considering the request of the Standing Counsel, directed the petitioner to appear before the Assessing Officer on 30th June 2025. The AO was directed to pass the final order within three months or within the applicable limitation period, if still available, whichever was later.
Calcutta HC Allows Refiling of GST Refund Applications Due to Non-Communication of Deficiencies on Portal
Tarinika &ors. vs Commissioner of Central Goods &Services Tax CITATION : 2025 TAXSCAN (HC) 1235
The Calcutta High Court, in a matter concerning Goods and Service Tax (GST) refund claims, allowed the petitioners to refile their refund applications after finding that deficiency memos were uploaded on the portal without specifying any reasons or attaching supporting documents.
Justice Raja Basu Chowdhury noted that under Section 54 of the WBGST/CGST Act, 2017, a refund application had to be filed in Form RFD 01 within two years, along with the required documents. If any deficiencies were found, Rule 90(3) of the Rules required the officer to communicate them electronically in Form RFD 03 through the common portal.
GST Registration Cancelled due to Non-Filing of Returns: Gauhati HC Allows Restoration Upon Clearing Dues
ABDUR ROFIQUEvs THE UNION OF INDIA CITATION : 2025 TAXSCAN (HC) 1236
The High Court of Gauhati, allowed restoration of Goods and Service Tax (GST) registration that was cancelled for non-filing of returns, after the petitioner cleared all dues and filed pending returns.
Justice Sanjay Kumar Medhi noted that the petitioner’s GST registration was cancelled for not filing returns for over six months. Since cancellation had serious consequences, and Rule 22(4) allowed restoration if returns and dues were cleared, the Court held that the officer could drop the proceedings if the petitioner met these conditions. The bench directed the petitioner to apply for restoration within two months. If all pending returns were filed and dues paid, the officer was to decide on the application within 60 days.
Orissa HC sets aside Interest Demand on Short-Paid GST: Remands Case citing Amended S.50 & GST Council Decision
Jitendra NathKhandual vs Principal Commissioner CITATION : 2025 TAXSCAN (HC) 1237
The Orissa High Court recently set aside an interest demand raised against a taxpayer for alleged short payment of Goods and Services Tax (GST) for the financial year 2017-18, remanding the case for fresh consideration in light of the amendments made to Section 50 of the Central GST Act, 2017 and decisions taken by the GST Council.
A Division Bench of Chief Justice Harish Tandon and Justice Murahari Sri Raman acceded to the petitioner's reliance on the retrospective amendment to Section 50 and the decision of the GST Council. Consequently, the Bench set aside the order dated 30 January 2025 and remanded the matter to the Superintendent of GST & Central Excise, Kendrapara Range, for reconsideration strictly in accordance with law and the directions in the Utkal Automobile judgment.
Income Tax Assessment Invalid If SCN Sent to Old Email After Update Even If Earlier Notices Acknowledged: Kerala HC
MEDIACLOUDSTUDIO PRIVATE LIMITED vs THE ASSESSMENT UNIT CITATION : 2025 TAXSCAN (HC) 1238
Kerala HC held that an income tax assessment is invalid if a show cause notice is sent to an old email after the taxpayer updates their email, even if earlier notices were acknowledged.In a recent ruling, the Kerala High Court held that an income tax assessment is invalid if a show cause notice is sent to an old email address after the taxpayer has updated their email with the department, even if earlier notices were acknowledged on the old email. The court held that the department’s failure to issue the show cause notice to the updated email address justified the invocation of the court’s writ jurisdiction. The court quashed the assessment order and directed the income tax department to issue a fresh show cause notice to the updated email address and to complete the assessment only after giving the petitioner an opportunity to respond. The writ petition was allowed.
Fixed AC Charges Form Part of Rent, Calcutta HC Rules in Favour of Landlord in Eviction Suit
CELICADEVELOPERS (P) LIMITED vs M/S. WADHWANA CITATION : 2025 TAXSCAN (HC) 1239
The Calcutta High Court, in its recent ruling, has held that fixed air-conditioning (AC) charges, when essential for the enjoyment of the tenancy, must be treated as part of rent. Consequently, the total monthly payment made by the tenant crossed the statutory ceiling of ₹10,000 under the West Bengal Premises Tenancy Act, 1997, taking the lease out of the purview of the Act and into the domain of the Transfer of Property Act, 1882.
It asserted that the AC charges were not variable like electricity bills, but fixed and obligatory, and had their genesis in orders of the Supreme Court stemming from prior litigation between the same parties. These undertakings required the tenant to pay for AC services through the landlord’s nominated agent, thus embedding them within the lease framework.
Chhattisgarh HC Directs GST Department to Release Frozen Bank Account of Small Entrepreneur
Smt. ArchanaMishra vs The Superintendent Office Of TheSuperintendent CITATION : 2025 TAXSCAN (HC) 1240
The Chhattisgarh High Court at Bilaspur directed the GST authorities to release a taxpayer’s frozen bank account, while allowing the petitioner, Archana Mishra, trading as Shree Agro Tech, liberty to pursue the statutory appellate remedy against the GST demand raised through ex-parte orders.
The bench consisting of Justice Deepak Kumar Tiwari, recorded the petitioner’s willingness to file an appeal but also acknowledged the urgent financial need. As a result the Court disposed of the writ petition with directions such as that the petitioner was granted liberty to file a statutory appeal within 30 days from the date of the order.
Interest for Belated GST Payment: Madras HC Confirms Interest Levied u/s 50(1) of CGST/ TNGST Act
M/s. G.P.Construction vs The Commissioner CITATION : 2025 TAXSCAN (HC) 1241
The High Court of Madras,confirmed the levy of interest under Section 50(1) of the Central Goods and Service Tax/ TamilNadu Goods and Service Tax (CGST/TNGST) Act, 2017 read with Rule 88B for belated tax payment.
However, with regard to the penalty of ₹5,72,052/- imposed under Section 73(9) read with Section 122(2)(a), the Court found that the petitioner may have a valid ground to challenge it. Accordingly, the petition was disposed of with a direction to pay the interest and liberty was granted to file an appeal against the penalty.
Chhattisgarh HC Dismisses Income Tax Appeal in View of Revised ₹2 Crore Monetary Limit, Following CBDT Circular
The DeputyCommissioner Of Income Tax Circle 1 vs Asha Soni CITATION : 2025 TAXSCAN (HC) 1242
The Chhattisgarh High Court at Bilaspur dismissed the Income Tax Department’s appeal against individual taxpayer holding that the tax effect involved was below the monetary threshold of ₹2 crore as prescribed in the latest CBDT Circular dated 17.09.2024.
The decision aligns with the broader policy direction of the CBDT, which has in recent years sought to unclog the legal system by discouraging the filing of appeals in low tax-effect cases. The move is expected to allow tax officers to concentrate on high-value and legally contentious matters, reducing the backlog of cases pending in appellate forums.
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