Supreme Court of India · GST · AKHB case note
Commercial Taxes Officer v. M/s Shree Mahesh Oil Products & Ors.
SLP(C) No. 16138/2022.
No neutral or reported citation is printed in the official source PDF. ·
Final SLP dismissal expressly applying Mohit Minerals; no grant of leave is recorded.
Shree Mahesh Oil Products and the other respondents, on dismissal of the Commercial Taxes Officer’s SLP.
01 · Facts of the case and issues
The Commercial Taxes Officer sought special leave against the Rajasthan High Court’s judgment dated 13 July 2021 in DBCWP No. 14177/2019 at Jodhpur. The respondents included Shree Mahesh Oil Products.
The Supreme Court disposed of the challenge by reference to its decision in Union of India v. M/s Mohit Minerals Pvt. Ltd. through Director, Civil Appeal No. 1390/2022, decided on 19 May 2022. The one-page order does not independently narrate import transactions or quantify any monetary claim.
Source: Official PDF p. 1, High Court case metadata, paragraph 1 and footnote 1.
02 · Discussion and reasoning of the Hon’ble Court
The Hon’ble Court stated that the petition stood dismissed in view of Mohit Minerals. It gave no additional statutory analysis in this order.
The cited judgment’s relevant conclusion is that a separate IGST levy on the Indian importer for shipping services violates the composite-supply principle where the CIF import already attracts IGST on the composite supply of goods, transportation and insurance. That explanation comes from Mohit Minerals, paragraph 148(v), and is not a separately reasoned holding in Shree Mahesh Oil.
Source: Shree Mahesh official PDF p. 1, paragraph 1 and footnote 1. Mohit Minerals official PDF p. 152, paragraph 148(v).
03 · Judicial decision and operative relief
The Supreme Court dismissed SLP(C) No. 16138/2022 in view of Mohit Minerals and disposed of the pending application, if any. It did not separately direct a quantified refund, award interest, fix a payment deadline or reopen the factual record.
Source: Official PDF p. 1, paragraphs 1–2; footnote 1 identifies the applied decision and its date.
04 · In favour of
The petitioner obtained no interference with the High Court result. The order is a narrow application of a named Supreme Court precedent. It should not be presented as a fresh comprehensive ocean-freight judgment or blanket approval of every reason in the High Court decision.
Source: Official PDF p. 1, paragraphs 1–2 and footnote 1.
05 · AKHB REVIEW POINT
AKHB analysis: Use this order as a subsequent application of Mohit Minerals and cite the substantive reasoning of that judgment for the composite-supply issue. Verify the contract, relevant tax period and exact levy before comparing a new dispute; the one-page order supplies none of those transaction details.
Keep the September SLP distinct from any similarly named appeal within the May 2022 common judgment. Use the petitioner, SLP number and Rajasthan High Court docket to identify this proceeding.
A successful challenge to the levy does not, through this order alone, quantify a refund or decide interest, limitation and payment procedure. Check the applicable refund route and later law separately. No present refund entitlement or unchanged-law position is certified here.
Source: AKHB analysis based on Shree Mahesh official PDF p. 1 and Mohit Minerals official PDF pp. 152–153, paragraphs 148(v)–150.
Source and verification
Official Supreme Court PDF containing the complete order and case metadata. · Individual hosted copy of the original judgment
Complete 1-page official order reviewed, including High Court metadata, both numbered paragraphs and footnote 1. The cited Mohit Minerals conclusion and operative paragraphs were checked for context.
Source checked 2026-10-12. Paragraph references follow the identified official judgment; PDF-page references follow that source file. The court’s printed paragraph numbers may differ from commercial reporting.
Statutory scope
This note describes the historical 2022 litigation. It does not certify the present ocean-freight statutory or notification position, or extend the CIF composite-supply conclusion to every shipping arrangement.
Later treatment and present applicability
This note records the decision as delivered. Later judicial treatment, present law and compliance have not been comprehensively verified. A bounded public-source search does not establish that no later proceedings exist.
Additional identified sources
- Mohit Minerals, Civil Appeal No. 1390/2022 and connected appeals, 19 May 2022 · Official PDF pp. 152–153, paragraphs 148(v)–150: composite-supply conclusion and operative disposal.
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General research information only; not legal or tax advice, a certified judgment or a substitute for the full order. Applicability depends on the facts, tax period, statutory version and jurisdiction. Subsequent treatment is unverified unless the note expressly identifies the sources checked. Downloading does not create a professional engagement. Obtain case-specific advice before reliance.