Tata Steel Tax Case Revived After Bombay HC Restores Writ Petition:

Bombay HC restores Tata Steel’s tax writ petition, allowing the company to challenge the retrospective reassessment law and contest the Rs 25,185.51 crore loan waiver tax dispute.
Bombay HC Restores Tata Steel Tax Plea

Tata Steel has informed the stock exchanges that the Bombay High Court has restored its writ petition challenging tax reassessment proceedings related to the waiver of a Rs 25,185.51 crore loan involving Tata Steel BSL Limited, which has since merged with Tata Steel.
The tax dispute relates to the reassessment of Tata Steel’s taxable income for the assessment year 2019-20. The Income Tax Department had treated the loan waiver as part of the company’s taxable income and increased the taxable amount accordingly.
Tata Steel had challenged the reassessment before the Bombay High Court in March 2025. In August 2025, the court had quashed the reassessment proceedings on technical ground as the notice had been issued by the jurisdictional Assessing Officer instead of the prescribed Faceless Assessing Officer.
However, the amendments made in the income tax law by the Finance Act, 2026 have now empowered the jurisdictional Assessing Officers to issue reassessment notices with retrospective effect. Post this amendment, the Supreme Court set aside some of the earlier judgments of the courts on the issue and remanded the matters back to the respective High Courts for fresh consideration.
As a result, Tata Steel’s petition was listed before the Bombay High Court on July 20, 2026. The court has now restored the company’s writ petition and listed it for hearing on August 19, 2026.
The court has also allowed Tata Steel to amend its petition to challenge the constitutional validity of the retrospective amendment introduced through the Finance Act, 2026. The Income Tax Department has been directed to file its response after the company makes the necessary amendments.
Tata Steel said it continues to believe that it has a strong case on the merits of the matter. The company also said that the retrospective amendment would not affect its arguments on the merits of the case or other technical issues it has raised before the court.
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Vanshika verma
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