HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE

Cargill India Private Limited v. Central Board of Direct Taxes

Petition for Special Leave to Appeal (C) No. 18119 of 2025
No separate citation stated in the source ·
72A

Interim order / merits openNo merits winner; taxpayer obtained notice

2 judicial members · Ujjal Bhuyan · Arun Palli

01 · Facts of the case

Cargill challenged a Delhi High Court judgment concerning Rule 9C of the Income-tax Rules, 1962 read with section 72A of the 1961 Act.

Source: paragraphs Caption and 2 / PDF pages 1, 2

02 · Discussion by the Hon’ble Court

After perusing the impugned judgment and statutory provisions, the Court stated that the matter required further scrutiny. It did not adopt a construction of Rule 9C or section 72A.

Source: paragraphs 2-3 / PDF pages 1, 2

03 · Judicial decision

Notice was issued, returnable on 18 August 2026, with permission to serve the Central Agency.

Source: paragraphs 4-5 / PDF pages 1, 2

04 · Outcome / in whose favour

In whose favour: No merits winner; taxpayer obtained notice

Notice was issued, returnable on 18 August 2026, with permission to serve the Central Agency.

No final tax-merits ruling in this order

Source: paragraphs 4-5 / PDF pages 1, 2

05 · AKHB REVIEW POINT

Read this together with the separately indexed 21 August 2026 Special Lok Adalat record. The June order expressly prints section 72A. A later record prints 71A when referring back to it; retain the source discrepancy rather than silently changing either original.

Source: paragraphs 2-5 / PDF pages 1, 2

Source & verification

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Complete identified source PDF: 2 pages. Original bytes preserved.

  • Historical procedural status as of the order date only. No assertion that an interim direction remains operative today; inspect later docket orders before relying on it.
  • Submissions recited in this order are not final findings.
  • No citation printed in the source order
  • Not stated in the reviewed order
  • The separately reviewed 21 August 2026 Special Lok Adalat record states that no settlement was reached and directs posting before the appropriate bench; this is not a comprehensive subsequent-treatment check.

Statutory scope

Current statutory equivalence and applicability under the Income-tax Act, 2025 have not been verified.

Later treatment

Source checked 2026-10-04. Subsequent appeals, review proceedings, stays, reversals and later judicial treatment have not been comprehensively checked. This note is not a citator status certificate.

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