Big Relief for Nestlé India: Supreme Court Dismisses ₹101 Crore Income Tax Appeals [Read Order]

TheSupreme Court has granted major relief to Nestlé India Limited by dismissing a batch of income tax appeals filed by the Income Tax Department involving a total amount of about Rs. 101 crore, bringing a long-pending tax dispute to a close in favour of the company.

The dispute related to the disallowance of General Licensing Fees paid by Nestlé India during the financial years 1996-1998, 1999-2001 and 2004-2008. The Income Tax Department had claimed that these payments were excessive and unreasonable and, on that basis, raised tax demands against the company. Nestlé India challenged these disallowances before the appellate authorities under the Income Tax Act.

The matter ultimately reached the Delhi High Court, which decided the issue in favour of Nestlé India and held that the disallowance of General Licensing Fees was not justified. The High Court set aside the tax demands raised by the department for the relevant years.

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Aggrieved by the Delhi High Court’s rulings, the Income Tax Department filed multiple civil appeals before the Supreme Court of India, challenging the High Court’s decisions. These appeals covered several assessment years but involved the same core issue regarding the allowability of General Licensing Fees. The aggregate tax amount involved in the litigation was Rs. 101.21 crore.

When the appeals came up for hearing before a Bench comprising Justice B.V. Nagarathna and Justice Ujjal Bhuyan on 13 January 2026, the Additional Solicitor General appearing for the Income Tax Department informed the Court that she had instructions to withdraw all the appeals. The submission was recorded by the Court.

The Supreme Court observed the statement made on behalf of the department and dismissed all the civil appeals as withdrawn. The Court also directed that all pending applications in the matters would stand withdrawn.

As a result, the judgments of the Delhi High Court in favour of Nestlé India remain final and binding. The dismissal of the appeals has conclusively ended the income tax litigation, giving complete relief to Nestlé India with no further tax liability arising from the disputed General Licensing Fees.

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