HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Deputy Commissioner of Income Tax v. Zydus Infrastructure Private Limited
Special Leave Petition (Civil) Diary No. 43572 of 2026
No separate citation stated in the source ·
115-Q · 115-O
Sources & disclosures includedDownload original judgment / order
2 judicial members · Manoj Misra · Vijay Bishnoi
01 · Facts of the case
The Revenue challenged the Gujarat High Court’s order in a distributed-profits-tax recovery dispute.
02 · Discussion by the Hon’ble Court
The order records the Revenue’s argument that section 115-Q permits recovery from a defaulting domestic company without reassessment. The Court did not endorse or reject this proposition.
Source: paragraphs 2-3 / PDF pages 1, 2
03 · Judicial decision
Delay in filing was condoned and notice was issued, returnable in six weeks. No stay is stated in this order.
Source: paragraphs 1,4 / PDF pages 1, 2
04 · Outcome / in whose favour
In whose favour: No merits winner; Revenue obtained notice
Delay in filing was condoned and notice was issued, returnable in six weeks. No stay is stated in this order.
No final tax-merits ruling in this order
Source: paragraphs 4 / PDF pages 1, 2
05 · AKHB REVIEW POINT
Index the recovery proposition as an argument for consideration. Issuance of notice is not a ruling that reassessment is unnecessary, and this order does not record a stay of the High Court judgment.
Source: paragraphs 2-4 / PDF pages 1, 2
Source & verification
Download original judgment / order · Open cited source rendition
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
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.
Page references identify the supplied PDF; paragraph references identify the judgment unless stated otherwise.
Identified source links
- official record of proceedings — PDF 2 pages
SHA-256: 6af74b1b565e6b0e8aea0dd026f1c012c68e49de2d348c81d5eb1bcbc0ac281a
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