This compilation indexes twelve Indian High Court rulings in which Section 203 appears as a cited provision — whether in its income-tax incarnation (obligation of a deductor to issue a tax deduction certificate) or, more frequently in this set, as Section 203 of the Code of Criminal Procedure (power of a Magistrate to dismiss a complaint). The compilation is arranged in reverse chronological order and is intended for use by in-house tax teams, Big-4 associates, and law-firm researchers who need a quick reference map of how courts across India have engaged with this section across varying procedural and substantive contexts. The single income-tax-specific ruling most directly engaging Section 203 of the Income Tax Act, 1961 — HMT Ltd vs CIT — is clearly identified in the case entry below.

Research index only. This page is a structured case-law reference, not legal or tax advice. Readers must verify all rulings against the full judgment text, check for subsequent stays or reversals, and consult qualified counsel before acting on any legal position.

The statutory framework in one paragraph

Section 203 of the Income Tax Act, 1961 requires every person responsible for deducting tax at source to furnish to the person from whose income the deduction has been made a certificate specifying the amount of tax so deducted, the rate at which the deduction was made, and such other particulars as may be prescribed. The certificate is to be issued in the prescribed form (for example, Form 16 for salary deductions and Form 16A for non-salary deductions) within the time and in the manner prescribed under the Income Tax Rules, 1962. Separately, Section 203 of the Code of Criminal Procedure, 1973 is a procedurally distinct provision that empowers a Magistrate to dismiss a complaint if, after considering the inquiry or investigation report, the Magistrate finds no sufficient ground for proceeding. Several rulings in this compilation cite the latter provision, not the Income Tax Act — researchers should read the "Sections engaged" field for each case to identify the operative context.

The 12 rulings

1. Dinesh Prajapat vs State Of Rajasthan

Bench: Rajasthan High Court - Jodhpur
Date: 9 July 2026
Sections engaged: 192, 200, 202(1), 203, 204
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as a Criminal Miscellaneous Petition (S.B. Criminal Miscellaneous Petition No. 916/2022) challenging an order dated 09.11.2021 passed by the Additional Senior Civil Judge & Additional Chief Metropolitan Magistrate No. 3, Jodhpur Metropolitan, Jodhpur. Per the source preview, the trial Court, after recording statements on oath of the complainant and witnesses upon the complaint filed by the petitioner, directed an investigation to be made by the Police and forwarded the case to the Police Station, Mahamandir, Jodhpur. The source preview indicates the petitioner-husband had filed a complaint on 11.10.2019 alleging commission of the offence of bigamy; the substantive dimension of the income-tax sections cited cannot be further elaborated from the available preview text.

2. Oil & Natural Gas Corporation Ltd vs State Of Gujarat Through Secretary

Bench: Gujarat High Court
Date: 1 July 2026
Sections engaged: 191, 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition was filed as R/Special Civil Application No. 387 of 2010 before the Gujarat High Court. Per the source preview, ONGC (the petitioner) sought specific reliefs, and at the outset the petitioner's counsel stated that the prayer made in paragraph 25(a) was not being pressed at that stage, with liberty to agitate the same in future; only the prayer in paragraph 25(b) was therefore under consideration by the Court. The source preview does not provide sufficient detail to elaborate the substantive grounds further beyond these procedural notes.

3. Ram Krishan & Another vs Rita Devi & Others

Bench: Himachal Pradesh High Court
Date: 30 June 2026
Sections engaged: 151, 166, 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (CMPMO No. 668 of 2025) arose from an impugned order dated 20.08.2025 passed by the Motor Accidents Claims Tribunal, Sundernagar, District Mandi, H.P., whereby the applications filed by the present petitioners were dismissed. Per the source preview, the petitioners had filed two applications before the Tribunal — one in which the right to re-examine PW-3 was denied, and another for permission to produce an additional witness, which was also rejected; the petitioners challenged both orders before the High Court.

4. Bharatendu Prasad Singh vs The State Of U.P. Thru. Its Addl. Chief

Bench: Allahabad High Court
Date: 30 January 2025
Sections engaged: 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The applicant filed Application U/S 482 No. 431 of 2025 before the Allahabad High Court (Lucknow Bench), challenging the order dated 16.03.2023 passed by the Chief Judicial Magistrate, Lucknow. Per the source preview, the Magistrate exercised power under Section 203 Cr.P.C. to dismiss Complaint Case No. 135 of 2016 instituted by the applicant. The applicant sought quashing of that dismissal order through the High Court's inherent jurisdiction.

5. Kenneth Malcolm Holland vs Deputy Commisiioner Of Income Tax

Bench: Punjab-Haryana High Court
Date: 14 December 2021
Sections engaged: 90, 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (CWP-13703-2021) was filed seeking a writ of certiorari for quashing the order dated 29.12.2020 whereby the claim of the petitioner for grant of a certificate of residence had been rejected by the authorities. Per the source preview, the petitioner is a USA national who was appointed as a Dean-cum-Professor at O.P. Jindal Global University with effect from 01.01.2020, joined service on 01.02.2020, and departed from India on 21.03.2020 owing to the Covid-19 pandemic; he sought benefit under the provisions of Article 22 of the India-US Double Taxation Avoidance Treaty through the writ.

6. T. Sunkappa S/O Late Husenappa vs B. Janardhan S/O Smt. B. Thippanna

Bench: Karnataka High Court
Date: 25 November 2020
Sections engaged: 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The Criminal Revision Petition (CRL.RP. No. 2292 of 2011) was filed before the Karnataka High Court, Dharwad Bench, by the complainant aggrieved by the judgment and sentence dated 30.08.2011 passed by the Additional Sessions Court, Bellary in PC No. 07/2008. Per the source preview, the petition sought to set aside the Sessions Court judgment and to allow the complaint filed by the petitioner and direct the lower court to consider the case on merits; the source preview does not provide sufficient detail on the substantive grounds to elaborate further.

7. Ismail Yusuf Pathan vs State Of Karnataka

Bench: Karnataka High Court
Date: 19 November 2020
Sections engaged: 245(1), 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The criminal petition (Criminal Petition No. 100867/2015, heard along with Criminal Petition Nos. 100868/2015 through 100872/2015) was filed before the Karnataka High Court, Dharwad Bench, under Section 482 of the Code of Criminal Procedure. Per the source preview, the petition sought to set aside the order passed by the Fast Track Court-II and Sessions Judge, Belagavi, in Criminal Revision Petition No. 136/2013 dated 24.03.2015, which had confirmed the order of the JMFC II, Belgavi dated 05.03.2013 in CC No. 12/2004, thereby rejecting an application filed under Section 245(1) of Cr.P.C. and declining to discharge the petitioner of the offences alleged; the respondent in the source preview is the State of Karnataka represented through an Income Tax Officer, Belagavi.

8. Dinesh Chander Sharma vs Nirmala Devi And Others

Bench: Himachal Pradesh High Court
Date: 3 January 2020
Sections engaged: 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The complainant, practising as an Advocate, filed Cr.MMO No. 338 of 2017 before the Himachal Pradesh High Court challenging the judgment of acquittal passed by the Sessions Court, Una, which had affirmed the order of dismissal of the complaint under Section 203 CrPC passed by the Judicial Magistrate, Una. Per the source preview, the complainant sought directions to proceed against the accused-respondent for commission of offences; the complaint itself, per the preview, was filed on September 21, 2007, relating to an incident alleged to have taken place on November 21, 1999.

9. Pankaj Srivastava And Ors vs The New India Insurance Company

Bench: Allahabad High Court
Date: 3 September 2019
Sections engaged: 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as First Appeal from Order No. 261 of 2015 before the Allahabad High Court (Lucknow Bench) by the claimants-appellants for enhancement of the compensation awarded by the Motor Accidents Tribunal, Additional District Judge, Court No. 10, Lucknow, vide its judgment and award dated 23.02.2015 in Claim Petition No. 0000638/12. Per the source preview, the underlying accident occurred on 03.01.2012 when the wife of Appellant No. 1 met with a road accident while travelling by scooter to discharge her duties as a teacher; the source preview does not provide further substantive detail on the Section 203 context in this motor accident matter.

10. National Insurance Company Limited vs Smt. Vachan Kaur And Ors 116

Bench: Chattisgarh High Court
Date: 5 December 2018
Sections engaged: 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition was filed as Writ Petition (Art. 227) No. 76 of 2015 before the High Court of Chhattisgarh, Bilaspur, by the National Insurance Company Limited. Per the source preview, the matter involves a motor accident claim and references a TDS deduction made under the provisions of the Income Tax Act, for which a certificate was also filed before the Claims Tribunal; a cheque of ₹1,42,544/- deducted towards TDS was deposited on 17-12-2014. The source preview does not provide further substantive elaboration on the specific Section 203 issue raised.

11. Dr. Zakir Abdul Karim Naik vs State Of U.P. And Another

Bench: Allahabad High Court
Date: 11 April 2018
Sections engaged: 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The applicant invoked the inherent jurisdiction of the Allahabad High Court through Application U/S 482 No. 15306 of 2011, seeking to quash the order dated 07.04.2011 passed by the Additional Session Judge IV, Jhansi in Criminal Revision No. 194 of 2010, and the order dated 30.04.2010 passed by the Judicial Magistrate-X, Jhansi summoning the applicant. Per the source preview, the opposite party no. 2 filed a complaint on 9.1.2018 before the Chief Judicial Magistrate X, Jhansi with allegations arising from a television programme, and the applicant also sought a stay of those proceedings.

12. Hmt Ltd vs CIT

Bench: Punjab-Haryana High Court
Date: 12 August 2004
Sections engaged: 272A(2)(g), 203
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed an appeal under Section 260A of the Income Tax Act, 1961 against the order of the ITAT, Chandigarh Bench, dated 22-7-2003, which had allowed the Revenue's appeals against the order of the Commissioner (Appeals) dated 25-7-2002 for financial years 1995-96 and 1996-97 and upheld the levy of penalty under Section 272A(2)(g) of the Act. Per the source preview, the assessee had deducted tax at source out of payments made to 8 contractors and was required under the provisions of Section 203 read with Rule 31 of the Income Tax Rules, 1962 to issue tax deduction certificates in Form No. 16A to those parties within the prescribed time; however, the said forms were issued late — for example, the Form 16A for contractor Hansraj Rahul Kumar, due on 31-8-1995, was actually issued on 17-6-1996, a delay of 289 days — and the penalty was levied on that basis. The High Court clarified that the present appeal would be treated as pertaining to assessment year 1995-96.

Patterns across these 12 rulings

Dual identity of "Section 203" across statutes. The most significant cross-cutting observation in this set is that "Section 203" operates in two entirely distinct legal regimes. In Case 12 (HMT Ltd vs CIT), Section 203 is the Income Tax Act provision requiring issuance of TDS certificates in prescribed forms within prescribed time. In the majority of the remaining cases — including Cases 4, 6, 8, 9, 10, and 11 — the section cited is Section 203 of the Code of Criminal Procedure, which empowers a Magistrate to dismiss a complaint for want of sufficient ground. Researchers must always identify which statute's Section 203 is operative before drawing substantive conclusions.
Complaint dismissal and High Court challenge under Cr.P.C. Several cases in this set — including Cases 4, 8, and 11 — share a procedural structure in which a lower court or Magistrate dismissed a complaint invoking Section 203 Cr.P.C. and the aggrieved complainant challenged that dismissal before the respective High Court, typically invoking the High Court's inherent jurisdiction or revision jurisdiction. This pattern of appellate challenge to Magistrate-level dismissal orders is a recurring feature of the Cr.P.C. context across this compilation.
The only direct income-tax substantive ruling is HMT Ltd (Case 12). Across the twelve cases, only HMT Ltd vs CIT engages Section 203 of the Income Tax Act, 1961 in a substantive income-tax enforcement context — specifically the obligation to issue Form No. 16A within the prescribed time and the consequences of late issuance in the form of penalty under Section 272A(2)(g). This case, decided in 2004 and cited at (2004) 191 CTR (P&H) 62, is the anchor income-tax precedent in this compilation.
Motor accident and insurance disputes as incidental hosts for Section 203 references. Cases 9 (Pankaj Srivastava), 10 (National Insurance Company), and 3 (Ram Krishan) arise from motor accident claim proceedings. The appearance of Section 203 citations in these matters reflects either procedural references to Cr.P.C. powers exercised at the Tribunal level or, as in Case 10, incidental references to TDS deductions on compensation awards, rather than core income-tax disputes.
Geographic spread across multiple High Courts with no ITAT representation. All twelve rulings in this compilation originate from High Courts — Rajasthan, Gujarat, Himachal Pradesh, Allahabad, Punjab-Haryana, Karnataka, and Chhattisgarh — and none from the Income Tax Appellate Tribunal. This reflects the broad procedural reach of Section 203 Cr.P.C. references across court systems, and underscores that Section 203 of the Income Tax Act, 1961 generating dedicated ITAT-level litigation is a distinct research stream not represented in this particular dataset.

How to use this compilation

This compilation is a structured research index, not a digest of settled legal propositions. Each entry identifies the court, bench, date, sections cited, and the procedural or substantive ground as far as the available source preview permits. Before relying on any ruling for a legal position, researchers should retrieve and read the full judgment text from the originating court's portal or from indiankanoon.org. The source previews used to generate the case summaries are truncated and may not capture the dispositive reasoning of the court; the outcome field for every case in this set is recorded as "Outcome not specified in source," which means no holding can be attributed to any of these rulings from the data available.

Researchers should also verify whether any of these rulings have been challenged, stayed, overruled, or distinguished in subsequent proceedings. High Court orders, in particular, may have been appealed to the Supreme Court of India, and the status of those appeals is not reflected here. For the HMT Ltd ruling (Case 12, Punjab-Haryana High Court, 2004), researchers should additionally check for any subsequent Supreme Court consideration and for CBDT circulars or instructions issued after the relevant financial years addressing the timing requirements for Form No. 16A issuance.

Finally, given that a large portion of the cases in this set cite Section 203 of the Code of Criminal Procedure rather than Section 203 of the Income Tax Act, 1961, researchers building a compilation specifically on the income-tax TDS certificate obligation should treat only Case 12 as directly on point and use this compilation primarily as a cross-reference index. Parallel searches targeting Section 203 read with Rule 31 of the Income Tax Rules, 1962, Section 272A(2)(g), and CBDT instructions on Form 16 and Form 16A timelines will yield a more complete picture of income-tax-specific enforcement.

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 203 & TDS Certificate Obligations: 12 High Court Rulings Indexed