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Section 156 Demand Notices: 11 Supreme Court Rulings Across Tax and Allied Laws

11 Supreme Court rulings citing Section 156 across income-tax, customs, SEBI, and allied laws — a structured research index for tax professionals and legal researchers.

Rangoli Bansal13 min read

This compilation indexes eleven Supreme Court of India rulings in which Section 156 — or a statutory provision bearing that number in an allied enactment — was among the sections cited by the court. The cases span income-tax demand notices, customs valuation rule-making authority, TCS compliance, penalty jurisdiction, and securitisation law, reflecting the breadth of legislative schemes that carry a section numbered 156. Each entry is drawn verbatim from the TaxNoticeAI structured legal corpus and is presented solely as a research reference.

Disclaimer: This page is a structured research index compiled from publicly available court records. Nothing on this page constitutes legal or tax advice. Readers must verify each ruling against the full text of the judgment and check for subsequent stays, reversals, or legislative amendments before placing reliance on any entry.


The statutory framework in one paragraph

Under the Income-tax Act, 1961, Section 156 provides that when any tax, interest, penalty, fine, or any other sum is payable in consequence of any order made under the Act, the Assessing Officer shall serve upon the assessee a notice of demand in the prescribed form specifying the sum so payable. The notice issued under Section 156 is the formal vehicle through which a tax demand crystallises into a recoverable liability; non-payment within the stipulated period attracts interest under Section 220(2) and may trigger recovery proceedings. Separately, Section 156 of the Customs Act, 1962 is a rule-making power provision that authorises the Central Government to make rules for carrying out the purposes of that Act, and it is in this capacity that the section appears in several customs valuation and enforcement rulings indexed below. Researchers should therefore confirm which statutory scheme's Section 156 is in play before reading across cases.


The 11 rulings

1. Jaykishor Chaturvedi vs Securities And Exchange Board Of India

  • Bench: Supreme Court of India
  • Date: 15 July 2025
  • Sections engaged: 15, 156, 15E, 15Z, 220(2), 28A
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The appeal was filed under Section 15Z of the Securities and Exchange Board of India Act, 1992, challenging the common judgment and order dated 29.09.2022 passed by the Securities Appellate Tribunal, Mumbai, in Appeal Nos. 626 to 628 of 2022. Per the source preview, the Tribunal had dismissed the appellants' challenge to notices of attachment dated 23.06.2022 issued against them; the appellants are described as promoter-directors of M/s. Brijlaxmi Leasing and Finance Limited, a company listed on the Bombay Stock Exchange. The reported citation for this judgment is 2025 INSC 846.

2. The Excise Commissioner, Karnataka vs Mysore Sales International Ltd And Ors

  • Bench: Supreme Court of India
  • Date: 8 July 2024
  • Sections engaged: 156, 206C, 206C(6)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The appeal (Civil Appeal No. 2168 of 2007, citation 2024 INSC 484) was preferred against the judgment dated 13.03.2006 of a Division Bench of the High Court of Karnataka in Writ Appeal No. 7926/2003. Per the source preview, the assessing officer had declared certain sums as income tax collectible at source by the appellant, which it failed to collect; the appellant was accordingly directed to deposit the quantified amounts along with interest, followed by demand notices, and the challenge to those orders dated 17.01.2001 was negatived by both the Single Judge and the Division Bench below.

3. Union Of India vs The State Of Maharashtra

  • Bench: Supreme Court of India
  • Date: 1 October 2019
  • Sections engaged: 154, 156
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This matter arose as Review Petition (Crl.) No. 228 of 2018 in Criminal Appeal No. 416 of 2018, filed by the Union of India seeking review of the judgment and order dated 20.03.2018 passed by the Supreme Court. Per the source preview, the review concerned guidelines issued by the Court in paragraph 83 of the earlier judgment while dealing with the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989; the Union of India raised questions regarding the separation of legislative and judicial powers in the context of those guidelines.

4. Union Of India Tr.Dir.Of I.T vs M/S Tata Chemicals Ltd

  • Bench: Supreme Court of India
  • Date: 26 February 2014
  • Sections engaged: 156, 195(1), 240, 244A, 244A(1), 244A(1)(b)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The appeal was filed as Civil Appeal No. 6301 of 2011 along with a large batch of connected civil appeals. Per the source preview, the matter involved multiple civil appeals consolidated before the Supreme Court; the sections engaged include provisions relating to tax deduction at source on payments to non-residents, refunds consequent upon orders, and interest on refunds. The full reasoning is not reproduced in the available source preview beyond the case caption and list of connected appeal numbers.

5. Jeewan Kumar Raut & Anr vs C.B.I

  • Bench: Supreme Court of India
  • Date: 7 July 2009
  • Sections engaged: 13(3)(iv), 154, 156, 160, 161, 165, 167, 170, 173, 190, 2(b), 2(d)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The criminal appeals (Nos. 1133–1134 of 2009, arising out of SLP (Crl.) Nos. 1035–1036 of 2009) arose from a judgment dated 29.01.2009 of a learned Single Judge of the Punjab and Haryana High Court in Criminal Revision Nos. 1007 and 1006 of 2008. Per the source preview, the appellants are medical practitioners against whom FIRs were lodged, the investigation was transferred to the CBI, and questions concerning the period of detention and procedural steps before the Magistrate were in issue; the sections cited span the Code of Criminal Procedure and the Transplantation of Human Organs Act (TOHO), and the text_preview does not indicate an income-tax substantive ground.

6. Dilawar Singh vs State Of Delhi

  • Bench: Supreme Court of India
  • Date: 5 September 2007
  • Sections engaged: 154(3), 156(3), 173, 202(1), 210
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The criminal appeal (No. 491 of 2002) challenged the judgment of a learned Single Judge of the Delhi High Court dismissing the appellant's appeal and affirming conviction for offences under the Indian Penal Code, 1860. Per the source preview, the sections engaged are drawn from the Code of Criminal Procedure, 1973, and the appeal raised arguments including the non-compliance with the procedure prescribed for registration of FIRs; the source preview does not indicate an income-tax substantive ground.

7. Commnr. Of Customs (Port), Chennai vs M/S Toyota Kirloskar Motor Pvt. Ltd

  • Bench: Supreme Court of India
  • Date: 17 May 2007
  • Sections engaged: 14(1), 156, 2(22), 2(23), 46, 50
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The civil appeal (No. 3635 of 2006) concerned the customs valuation of capital goods and parts imported by the respondent from Toyota Motor Corporation for establishing an automobile manufacturing plant in India. Per the source preview, the Revenue contended that royalty and know-how fee payments had a direct nexus to the imported goods and were required to be added to the invoice value to arrive at the transaction value under the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988; the dispute centred on the proper method of valuation of those payments.

8. Rabindra Chandra Paul vs Commr. Of Customs (Preventive)

  • Bench: Supreme Court of India
  • Date: 27 February 2007
  • Sections engaged: 111(m), 128A, 130, 14(1), 14(2), 156
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The civil appeal (No. 4498 of 2006) was filed under Section 130E of the Customs Act, 1962 against judgment and order No. M-299/Kol/06 dated 6.7.2006 of the Customs, Excise & Service Tax Appellate Tribunal, Kolkata. Per the source preview, the short question for determination was whether the Department was justified in invoking Rule 7A of the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988 — framed under Section 156 of the Customs Act, 1962 — in respect of two consignments of Refined Soyabean Oil imported from M/s United Edible Oils Ltd., Bangladesh, with invoices dated 4.10.2003 and 30.10.2003.

9. Commissioner Of Customs (Port) vs M/S. J.K. Corporation Limited

  • Bench: Supreme Court of India
  • Date: 2 February 2007
  • Sections engaged: 12, 14, 156
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The Revenue preferred this civil appeal (No. 4663 of 2006) against the judgment and final order dated 15 May 2006 of the Customs Excise and Service Tax Appellate Tribunal, Kolkata, in Appeal No. C-259 of 2002. Per the source preview, the respondent's division M/s. Orissa Synthetics Limited entered into a collaboration agreement with M/s. Samsung Company Limited and M/s. Chiel Synthetics Inc. of Korea on 18 November 1999 for manufacture of Polyester Oriented Yarn and Flat Yarn, and the dispute concerned the customs valuation of imported equipment and lump-sum technology payments under that agreement.

10. M/S Transcore vs Union Of India & Anr

  • Bench: Supreme Court of India
  • Date: 29 November 2006
  • Sections engaged: 12, 13(2), 13(3), 13(4), 156, 19(1), 69, 69A
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The civil appeal (No. 3228 of 2006) was heard with several connected appeals. Per the source preview, the short question of public importance was whether withdrawal of an Original Application under the first proviso to Section 19(1) of the DRT Act, 1993 (as inserted by Amending Act No. 30 of 2004) is a condition precedent to taking recourse to the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002; the appellant had been issued a Possession Notice dated 8.1.2005 under Section 13(4) of the NPA Act in respect of an outstanding amount of approximately Rs. 4.15 crores.

11. Amin Chand Payarelal vs Inspecting Asstt

  • Bench: Supreme Court of India
  • Date: 5 September 2006
  • Sections engaged: 139(1), 139(4), 148, 156, 271(1)(a)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The civil appeal (No. 4114 of 2001) was directed against the order dated 28 September 2000 of a Division Bench of the High Court of Calcutta in FMA No. 1160 of 1990, which set aside the Single Judge's order and dismissed the writ petition filed by the appellant. Per the source preview, the Single Judge had allowed the writ petition on two grounds: first, that imposition of penalty was without jurisdiction because interest had been paid for late filing of returns; and second, that the penalty under Section 271(1)(a) of the Income-tax Act could not be imposed by the Inspecting Assistant Commissioner of Income Tax as only the Income Tax Officer was competent to do so — a position that the respondent-assessee did not dispute before the Division Bench regarding the IAC's jurisdiction to impose penalty for non-filing within the extended period.

Patterns across these 11 rulings

  1. Section 156 as a multi-statute numeral. Across this set, "Section 156" appears in at least three distinct statutory regimes: the Income-tax Act 1961 (demand notices), the Customs Act 1962 (rule-making power underpinning valuation rules), and the SEBI Act 1992 (in the sections-cited field alongside penalty recovery provisions). Researchers must identify the parent statute before reading any proposition about "Section 156" across cases.

  2. Customs valuation as the dominant substantive theme. Cases 7, 8, and 9 all concern the proper valuation of imported goods — royalty and know-how payments, Customs Valuation Rules framed under Section 156 of the Customs Act, and the inclusion or exclusion of technology/licence fees in the transaction value. This cluster suggests that Section 156 of the Customs Act frequently surfaces in disputes over Rule 7A and Rule 9(1)(c) valuation methodology.

  3. Income-tax penalty jurisdiction as a recurring sub-theme. Case 11 (Amin Chand Payarelal) raises a jurisdictional challenge to penalty imposition under the income-tax regime, engaging sections governing return filing obligations and penalty proceedings alongside Section 156. Case 2 (Excise Commissioner Karnataka) similarly involves a demand-and-interest chain following a TCS default. Both illustrate that Section 156 demand notices are downstream outputs of penalty and default determination processes whose validity is often challenged at source.

  4. Absence of final outcome data. All eleven rulings in this compilation carry the outcome tag "Outcome not specified in source." This is a data-completeness limitation of the present corpus extract, not a reflection of the cases being unreported. Researchers should retrieve full judgments from indiankanoon.org or official court portals to confirm dispositive directions before citing these cases.

  5. Broad procedural diversity. The eleven appeals traverse civil appellate jurisdiction, criminal appellate jurisdiction, inherent/review jurisdiction, and writ jurisdiction. This heterogeneity reflects the fact that Section 156 (across statutes) is engaged at multiple procedural stages — from original demand, through revision and writ, to appellate and review proceedings before the Supreme Court.


How to use this compilation

This index is intended as a starting point for locating Supreme Court rulings in which Section 156 — across the Income-tax Act, Customs Act, SEBI Act, or allied legislation — was among the provisions cited. To use it effectively, begin by identifying which statute's Section 156 is relevant to your research question; as the rulings above demonstrate, the section number alone is not a reliable proxy for subject matter. Cross-check the sections engaged list against the specific sub-section or rule under examination in your matter.

Before placing reliance on any ruling identified here, retrieve the full text of the judgment from indiankanoon.org, the Supreme Court of India's official website (sci.gov.in), or a subscription legal database. Verify whether the judgment has been stayed, reversed on review, or distinguished in subsequent decisions. Where the ruling touches a statutory provision, also check whether the provision has been amended, substituted, or repealed by Finance Acts or other legislation enacted after the date of the judgment.

For income-tax demand notice matters specifically, practitioners should additionally consult CBDT circulars and instructions on the administration of Section 156 notices, including any prescribed forms, time-limits for payment, and guidelines on granting instalments or stay of demand pending appeal. CBDT guidance does not carry the force of a judicial precedent but may be directly relevant to the procedural posture of a live notice.


Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

RB

Rangoli Bansal

Editorial Reviewer & CA Finalist

CA Finalist (ICAI), B.Com (Hons.) Delhi University. 7+ years across audit, internal controls, SOX 404, ICFR, RCSA, and GRC. Hands-on experience with GST and income-tax compliance filings, statutory audit, and internal audit. Editorial reviewer for TaxNoticeAI's case-law content.

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Disclaimer: The information provided is for educational and informational purposes only and should not be construed as legal or tax advice. AI-generated content is a draft for professional review — always verify with applicable laws, circulars, and case law before filing. Consult a qualified Chartered Accountant or tax professional before acting on any information presented here.