This compilation indexes twelve Supreme Court of India rulings in which Section 201 appears as a cited provision. Researchers should note that "Section 201" appears across multiple legal codes — the Income Tax Act 1961, the Indian Penal Code 1860, and the Code of Criminal Procedure 1973 — and several entries in this index relate to the IPC or CrPC rather than to the income-tax TDS default framework. Each case is clearly identified by the sections engaged as recorded in the source data. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who require a consolidated starting point for further primary-source research.

Research index only. This page summarises publicly available court records for reference purposes. Nothing on this page constitutes legal or tax advice. Readers must independently verify the current status of each ruling, including any subsequent appeals, stays, or reversals, before relying on it in any professional matter.

The statutory framework in one paragraph

Under the Income Tax Act, 1961, Section 201 deals with the consequences of failure to deduct tax at source or failure to pay the tax so deducted. Where a person who is required to deduct tax at source fails to do so, or after deducting fails to pay the tax to the credit of the Central Government, that person is deemed to be an "assessee in default" in respect of the tax. The provision operates alongside the TDS deduction obligations set out in various other sections of Chapter XVII of the Act and carries liability for interest in addition to the principal tax amount that ought to have been deducted. The provision is distinct from Section 201 of the Indian Penal Code 1860 (causing disappearance of evidence of an offence) and Section 201 of the Code of Criminal Procedure 1973 (power of a Magistrate not competent to take cognizance to return a complaint); both of those provisions also appear in several rulings indexed below.

The 12 rulings

1. M/S Shri Sendhuragro And Oil Industries vs Kotak Mahindra Bank Ltd

Bench: Supreme Court of India
Date: 6 March 2025
Sections engaged: 138, 142A, 2(d), 201, 21
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the Supreme Court as Transfer Petition (Crl.) No. 608 of 2024, along with several connected transfer petitions. Per the source preview, the proceeding involved a comparative discussion of the powers of civil and criminal courts regarding jurisdiction objections, with the respondent bank's written submissions drawing a distinction between the return of a plaint in civil proceedings under the Code of Civil Procedure and the limited power available to a Magistrate under Section 201 of the Code of Criminal Procedure to return a complaint before taking cognizance.

2. Zakia Ahsan Jafri vs The State Of Gujarat

Bench: Supreme Court of India
Date: 24 June 2022
Sections engaged: 201
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal arose out of SLP (Crl.) @ Diary No. 34207/2018 and was heard in the Supreme Court's criminal appellate jurisdiction. Per the source preview, the matter involved a challenge relating to the investigation conducted by a Special Investigation Team in connection with the Gujarat tragedy, with reference to various evidentiary materials including Tehelka tapes, CDRs, SIB messages, and other documents; the precise role of Section 201 in the final disposition is not elaborated in the available source preview.

3. Director Of I.T New Delhi vs M/S Mitsubhishi Corp

Bench: Supreme Court of India
Date: 17 September 2021
Sections engaged: 143, 191, 201, 209, 234B
Outcome: Outcome not specified in source
Procedural / substantive ground: This batch of civil appeals, arising out of Civil Appeal No. 1262 of 2016 and connected matters, concerned the liability of an assessee to pay interest on short payment of advance tax where the default arose from the payer's failure to deduct tax at source. Per the source preview, the respondent-assessee is a non-resident company incorporated in Japan with operations in India, and notice was issued under the Act for assessment years 1998-99 to 2004-05; the conundrum identified by the Court related to whether interest liability under the provisions cited attaches to the assessee in such circumstances.

4. Anwar Ali vs The State Of Himachal Pradesh

Bench: Supreme Court of India
Date: 25 September 2020
Sections engaged: 166(3), 201
Outcome: Outcome not specified in source
Procedural / substantive ground: This criminal appeal (Criminal Appeal No. 1121 of 2016) was filed against a judgment of the High Court of Himachal Pradesh in Criminal Appeal No. 464 of 2012. Per the source preview, the High Court had reversed an acquittal by the trial court and convicted the appellants for offences under provisions of the IPC including Section 201 IPC in connection with the alleged murder of one Deepak, whose body was found on 2.9.2010 near bypass Bihali Road, Chandigarh; the appellants preferred the present appeal before the Supreme Court against that conviction.

5. Genpact India Private Limited vs Deputy Commissioner Of Income Tax

Bench: Supreme Court of India
Date: 22 November 2019
Sections engaged: 115Q, 143(2), 144, 147, 150, 154, 155, 163, 170, 171, 185, 186
Outcome: Outcome not specified in source
Procedural / substantive ground: This civil appeal (Civil Appeal No. 8945 of 2019, arising out of SLP(C) No. 20728 of 2019) arose from a final judgment of the High Court of Delhi in Writ Petition No. 686 of 2017. Per the source preview, the appellant had bought back 2,50,000 shares in May 2013 at Rs. 32,000 per share for a total consideration of Rs. 800 crores, and the matter centred on Chapter XIIDA inserted by the Finance Act 2013 regarding tax on distributed income from buy-back of shares; Section 201 does not appear in this case's sections_list and this ruling is included solely on the basis of the CASE_FACTS record as provided.

6. Gorusu Nagaraju vs The State Of Andhra Pradesh

Bench: Supreme Court of India
Date: 23 March 2018
Sections engaged: 201, 235(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Criminal Appeal No. 1032 of 2007) was filed from jail through the Supreme Court Legal Services Committee against the judgment of the High Court of Judicature at Andhra Pradesh at Hyderabad in Criminal Appeal No. 955 of 2005. Per the source preview, the High Court had affirmed the conviction of the appellant (A-1) for offences under Sections 302 and 201 of the Indian Penal Code 1860 and under Section 235(2) of the Criminal Procedure Code 1973, with the Sessions Court having sentenced the appellant to rigorous imprisonment for three years and a fine of Rs. 100/- for the offence under Section 201 IPC, to run concurrently with the life imprisonment sentence under Section 302 IPC.

7. Vikas Yadav vs State Of U.P And Ors. Etc. Etc

Bench: Supreme Court of India
Date: 3 October 2016
Sections engaged: 201, 28, 34
Outcome: Outcome not specified in source
Procedural / substantive ground: This batch of criminal appeals (Criminal Appeal Nos. 1531-1533 of 2015 and Criminal Appeal Nos. 1528-1530 of 2015) involved appellants who stood convicted for offences under provisions of the IPC including Section 201 read with Section 34 IPC. Per the source preview, one set of connected appeals questioned the propriety of the sentence where the High Court had imposed a fixed term sentence of 25 years; the proceedings before the Supreme Court included consideration of compensation amounts awarded in connection with the matter.

8. Itc Limited Gurgaon vs Commr.Of I.T(TDS) Delhi

Bench: Supreme Court of India
Date: 26 April 2016
Sections engaged: 15(b), 17(1)(iv), 17(3), 192(3), 201(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: These civil appeals (Civil Appeal Nos. 4435-37 of 2016 and connected matters, arising out of various SLPs) arose from a common judgment of the Delhi High Court dated 11.5.2011. Per the source preview, surveys at the business premises of the assessees — engaged in owning, operating, and managing hotels — allegedly revealed that the assessees had been paying tips to employees without deducting taxes thereon; the Assessing Officer treated the tips as income under the head "salary" and held the assessees liable to deduct tax at source, treating them as assessees-in-default under Section 201(1) of the Income Tax Act, 1961.

9. Madhu @ Madhuranatha & Anr vs State Of Karnataka

Bench: Supreme Court of India
Date: 28 November 2013
Sections engaged: 201, 34
Outcome: Outcome not specified in source
Procedural / substantive ground: These criminal appeals (Criminal Appeal Nos. 1357-1358 of 2011 and Criminal Appeal No. 109 of 2013) were preferred against the judgment of the High Court of Karnataka at Bangalore in Criminal Appeal Nos. 833, 855 and 864 of 2008. Per the source preview, the High Court had affirmed the death sentence imposed by the District and Sessions Judge in Sessions Case No. 152 of 2005, with the appellants having been convicted under Section 201 read with Section 34 IPC and sentenced to undergo RI for 5 years and a fine of Rs. 10,000/- each, with the High Court making certain observations about the charging sections of the IPC.

10. Vimal Kanwar & Ors vs Kishore Dan & Ors

Bench: Supreme Court of India
Date: 3 May 2013
Sections engaged: 192, 201
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Civil Appeal No. 5513 of 2012, arising out of SLP(C) No. 6367 of 2012) was filed against a judgment of the Rajasthan High Court, Jaipur Bench in S.B. Civil Misc. Appeal Nos. 1831 and 2071 of 2003. Per the source preview, the matter arose from a motor accident on 14 September 1996 in which one Sajjan Singh Shekhawat was fatally injured when a jeep struck his parked scooter; the source preview does not elaborate on the substantive role of the cited section numbers in the context of this civil compensation matter.

11. Sanjay Dutt vs State Of Maharashtra Tr.Cbi,Bombay

Bench: Supreme Court of India
Date: 21 March 2013
Sections engaged: 20, 201
Outcome: Outcome not specified in source
Procedural / substantive ground: Criminal Appeal No. 1060 of 2007 and several connected criminal appeals were heard together under the Supreme Court's criminal appellate jurisdiction. Per the source preview, the proceedings involved appeals filed under the Arms Act and Explosive Substances Act, with multiple appellants including Sanjay Dutt (A-117) and others against the State of Maharashtra through CBI (STF), Bombay; the source preview is procedural in nature and does not elaborate on the specific grounds relating to the cited sections within the available extract.

12. Sangeetaben Mahendrabhai Patel vs State Of Gujarat & Anr

Bench: Supreme Court of India
Date: 23 April 2012
Sections engaged: 114, 120, 138, 167(8), 201, 26, 300(1), 5(2), 71
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Criminal Appeal No. 645 of 2012) was preferred against the judgment of the High Court of Gujarat at Ahmedabad in Criminal Misc. Application No. 7807 of 2006, by which the High Court dismissed the appellant's application under Section 482 CrPC for quashing I.CR No. 18 of 2004 and Criminal Case No. 5 of 2004 pending before the Chief Judicial Magistrate, Patan. Per the source preview, the appellant argued that the pending criminal case was barred by the principle of double jeopardy as the appellant had already been tried under Section 138 of the Negotiable Instruments Act 1881 for the same offence, invoking Section 300 CrPC and Section 26 of the General Clauses Act 1897.

Patterns across these 12 rulings

Heterogeneous invocation of "Section 201" across legal codes. The most consistent pattern across this compilation is that the section number 201 does not uniformly refer to the income-tax TDS default provision. Across the twelve rulings, Section 201 is cited in the context of the Income Tax Act 1961 (cases 3 and 8), the Indian Penal Code 1860 (cases 4, 6, 7, 9, and others), and the Code of Criminal Procedure 1973 (case 1). Researchers must verify the governing statute before drawing any substantive inference from the section citation alone.
Income-tax-specific TDS default cluster. Of the twelve rulings, the clearest income-tax substantive engagement with Section 201 appears in cases 3 (Director of I.T. vs Mitsubishi Corp., concerning interest liability on short payment of advance tax linked to TDS default) and 8 (ITC Limited Gurgaon vs Commissioner of I.T. (TDS) Delhi, concerning assessee-in-default treatment for non-deduction of TDS on employee tips). These two rulings form the core income-tax research cluster within this index.
Supreme Court as sole forum across all twelve entries. All twelve rulings indexed here were decided by the Supreme Court of India, across a span from April 2012 to March 2025. No High Court, ITAT, or tribunal rulings are included in this particular dataset, which reflects the nature of the source corpus extract rather than the overall universe of Section 201 litigation.
Outcome data uniformly unavailable in source. For every case in this compilation, the outcome direction is recorded as "Outcome not specified in source." Researchers relying on this index for outcome-based analysis must access the full text of each judgment from indiankanoon.org or official court portals to determine the dispositive result.
Procedural and evidentiary previews limit substantive extraction. The available text previews for several rulings (cases 2, 7, 10, 11) are predominantly procedural, listing party names, appeal numbers, and preliminary facts without capturing the Court's holding or reasoning. This is a limitation of the source extract and does not reflect the substantive importance of those rulings.

How to use this compilation

This index is a structured starting point for locating Supreme Court rulings in which Section 201 appears as a cited provision. Before using any entry in professional work, readers should retrieve the full text of the judgment from indiankanoon.org, the Supreme Court of India's official portal (main.sci.gov.in), or an authenticated legal database. The text previews reproduced here are extracts only and do not capture the Court's complete reasoning, the dispositive order, or any concurring or dissenting opinions. Outcome data is unavailable in the source corpus for all twelve entries, and the direction of the final order must be independently verified.

Researchers should also check whether any ruling listed here has been the subject of a subsequent review petition, curative petition, stay order, or modification by a later bench. Indian tax litigation frequently involves multiple rounds of proceedings across the Assessing Officer, CIT(A), ITAT, High Court, and Supreme Court levels, and a Supreme Court ruling on one aspect of a dispute may coexist with ongoing proceedings on separate grounds. Where a ruling touches on TDS default under the Income Tax Act 1961, it is advisable to cross-reference the current CBDT circulars, instructions, and press releases that may have altered the administrative practice in the intervening period.

Finally, because this compilation draws from a structured legal corpus that includes multiple legal codes, researchers focused exclusively on income-tax TDS default should filter entries by the sections_engaged field and prioritise those where the Income Tax Act 1961 sections (such as 192 or 201(1)) appear alongside Section 201. Cases where Section 201 appears only in the IPC or CrPC context are included for completeness of the source data but are not directly relevant to income-tax research.

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.

Section 201 & TDS Default: 12 Supreme Court Rulings Indexed