Authority: Supreme Court of India

Order Date: 23 June 2026

Case Overview

  • Petition: Special Leave Petition (C) No. 18119/2025 filed by Cargill India Private Limited challenging the Delhi High Court’s judgment dated 25 February 2025 in W.P.(C) No. 399/2022.
  • Respondent: Central Board of Direct Taxes (CBDT).
  • Core dispute: Interpretation of Rule 9C of the Income Tax Rules, 1962 in conjunction with Section 72A of the Income Tax Act, 1961.
  • The Court examined the impugned judgment and relevant statutory provisions and determined that further examination is required.

Final Outcome

  • The Court ordered issuance of a notice to the Central Agency, with the response to be filed by 18 August 2026.
  • Permission was granted to the petitioner’s counsel to serve the notice upon the Central Agency.
  • No substantive ruling on the interpretation of Rule 9C/Section 72A was made; the matter is remanded for further scrutiny.

Topics: Tax Law, Judicial Review