This compilation indexes twelve reported orders — spanning the Income Tax Appellate Tribunal (ITAT) across multiple benches, three High Courts (Telangana, Kerala, and Jharkhand), and the Supreme Court of India — that engage Section 206C of the Income Tax Act, 1961. The rulings cover the period from March 2023 through June 2026 and arise from a range of fact patterns: mining-sector TCS obligations, sale of scrap and forest produce, liquor corporation collections, and parking-fee licensing arrangements. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for locating primary material on Section 206C disputes.

Research index only. This page is a structured index of publicly reported orders drawn from the TaxNoticeAI legal corpus. Nothing on this page constitutes legal or tax advice. Readers must verify each ruling against the full text of the judgment before placing any reliance on it.

The statutory framework in one paragraph

Section 206C of the Income Tax Act, 1961 imposes an obligation on specified sellers to collect tax at source (TCS) from buyers at the time of receipt of sale consideration or at the time of debiting the buyer's account, whichever is earlier. The section applies to the sale of specified goods including alcoholic liquor for human consumption, tendu leaves, timber, forest produce, scrap, minerals (coal, lignite, and iron ore), and certain other categories. The seller who collects tax is required to deposit it with the Central Government within the prescribed time and to furnish returns in the prescribed form. Sub-sections of Section 206C address, among other things, the rate of collection, the consequences of failure to collect or deposit (including interest and penalty), and situations where the buyer furnishes a declaration for non-deduction. The section sits alongside related withholding provisions in the Act and has been the subject of sustained litigation concerning its applicability to government bodies, the scope of the seller's obligation, and procedural requirements for demand proceedings.

The 12 rulings

1. Mohammad Yunus,Kalaburagi vs Income Tax Officer, Ward-1 & Tps

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 15 June 2026
Sections engaged: 194Q, 194Q(5), 206C, 40(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 1886/Bang/2025) was filed by the assessee against the appellate order passed by the National Faceless Appeal Centre, Delhi, dated 30.6.2025, wherein the appeal filed against the assessment order dated 17.3.2024 passed under the Act by the National Faceless Assessment Centre was dismissed. Per the source preview, the assessee is aggrieved and in appeal before the Tribunal on two disallowances confirmed under the Act, and the assessee is described as an individual carrying on a transport business; the Assessment Year in question is 2022-23.

2. The Commissioner Of Income Tax TDS vs Ap Beverages Corporation Limited

Bench: Telangana High Court
Date: 12 June 2026
Sections engaged: 206C, 206C(1), 206C(6), 206C(7), 260A
Outcome: Outcome not specified in source
Procedural / substantive ground: This common judgment was pronounced by the Telangana High Court in a batch of Income Tax Tribunal Appeals (Nos. 275 & 277 of 2007; Nos. 69, 184 & 188 of 2008; and No. 85 of 2010) filed by the Commissioner of Income Tax (TDS), Hyderabad, against A.P. Beverages Corporation Limited. The appeals were filed under section 260A of the Act, indicating they arise from orders of the Income Tax Appellate Tribunal and involve questions of law concerning the obligations under Section 206C; the substantive findings are not captured in the available source preview.

3. Pacific Exports,Jabalpur Road, Katni vs I.T.O, TDS-2, Jabalpur, Jabalpur

Bench: Income Tax Appellate Tribunal - Jabalpur
Date: 8 June 2026
Sections engaged: 206C, 254
Outcome: Outcome not specified in source
Procedural / substantive ground: These are twin stay applications (SA Nos. 01 & 02/JAB/2026) filed under section 254(2A) of the Act, arising out of pending appeals ITA Nos. 279 & 280/JAB/2025 for Assessment Years 2013-14 and 2014-15 (PAN: AALFP3826C), seeking a stay of recovery of demand initiated by the Revenue. The Tribunal heard rival submissions on the limited issue of whether a stay of recovery ought to be granted pending disposal of the substantive appeals concerning Section 206C; no final holding on the merits of the underlying demand is discernible from the source preview.

4. Viswateja Spinning Mills Pvt vs Income Tax Officer (TDS), Ward-1

Bench: Income Tax Appellate Tribunal - Vizag
Date: 3 December 2025
Sections engaged: 206C
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed four appeals (ITA Nos. 575, 576, 577 & 578/VIZ/2025) against different orders of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, for Assessment Years 2017-18, 2018-19, 2019-20, and 2020-21 (PAN: AABCV8759M). The appeals were heard by the Visakhapatnam Division Bench in hybrid mode; the substantive grounds and final holdings are not captured in the available source preview beyond the identification of Section 206C as the provision in dispute.

5. Asstt. Commissioner Of Income Tax vs Jharkhand State Mineral Development

Bench: Income Tax Appellate Tribunal - Ranchi
Date: 9 October 2025
Sections engaged: 206C
Outcome: Outcome not specified in source
Procedural / substantive ground: Five appeals (ITA Nos. 193 to 197/RAN/2024) were filed by the ACIT, Ranchi, against Jharkhand State Mineral Development Corporation Ltd. (PAN: AABCJ 2578 C) for Assessment Years 2013-2014 to 2017-2018. Per the source preview, both the assessee and the Revenue had sought adjournments on the date of hearing; the assessee's adjournment application was rejected as the reasons given were found unsatisfactory, and the matter was proceeded with; the substantive outcome is not captured in the source preview.

6. The District Mining Officer,Bareilly vs Income Tax Officer (TDS), Bareilly

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 30 June 2025
Sections engaged: 206C, 133A
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 246/LKW/2018) for Assessment Year 2008-09 was filed by the assessee against the order of the CIT(A), Bareilly, dated 28.09.2016, dismissing the appeal against an order passed under Section 206C of the Act. Per the source preview, one of the assessee's grounds contended that the impugned order sustaining demand under Section 206C was unsustainable and bad in law as being violative of principles of natural justice, on the basis that no notice was issued by the Assessing Officer before passing the impugned order.

7. District Mining Officer, Durg,Durg vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Raipur
Date: 26 November 2024
Sections engaged: 206C
Outcome: Outcome not specified in source
Procedural / substantive ground: Nine appeals (ITA Nos. 437 to 445/RPR/2024) were filed by the District Mining Officer, Durg (PAN: JBPM05878F), against the Deputy Commissioner of Income Tax (TDS), for Assessment Years 2012-13 through 2020-21. The appeals were heard before the Raipur Bench on 25.11.2024 and pronounced on 26.11.2024; the source preview confirms the involvement of Section 206C but does not disclose the substantive grounds or final holding beyond the identity particulars of the parties and the batch nature of the proceedings.

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

Bench: Supreme Court of India
Date: 8 July 2024
Sections engaged: 206C, 206C(6)
Outcome: Outcome not specified in source
Procedural / substantive ground: This Civil Appeal (No. 2168 of 2007) was preferred before the Supreme Court against the judgment and order dated 13.03.2006 passed by 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 tax collectible at source by the appellant which it failed to collect; the appellant was consequently directed to deposit the amounts so quantified, and interest was also levied, followed by demand notices; the challenge to those orders was negatived first by a learned Single Judge and then by the Division Bench of the High Court, leading to the appeal before the Supreme Court.

9. E.V Premadas vs The Secretary

Bench: Kerala High Court
Date: 18 January 2024
Sections engaged: 206C
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner was a licence holder for collection of parking fees from tourist vehicles parked within the limits of the Guruvayoor Municipal Corporation for the period from 2011 till 2014. Per the source preview, on account of the failure of the Guruvayoor Municipal Corporation to ensure tax collection at source in compliance with Section 206C of the Act, the Income Tax Department initiated proceedings against the Guruvayoor Municipal Corporation; the writ petition (WP(C) No. 43667 of 2023) appears to have been filed by the licence holder in the context of those proceedings and came up for admission on 18.01.2024.

10. Sh. Mohd. Javed Belim, Jodhpur vs ACIT (TDS), Jodhpur

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 6 December 2023
Sections engaged: 206C, 201(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Three appeals (ITA Nos. 20 to 22/Jodh/2017) for Assessment Years 2008-09 to 2010-11 were filed by the assessee (PAN: AEMPB0363H), a trader of scrap, firewood, and iron material, against the ACIT (TDS), Jodhpur. Per the source preview, a survey was conducted at the assessee's business premises and it was found that the assessee had not collected TCS in contravention of Section 206C of the Act against the sale of scrap; the Revenue treated the assessee accordingly. All three appeals were heard and disposed of together with ITA No. 20/Jodh/2022 taken as the lead case.

11. Adhunik Power & Natural Resources Ltd vs Central Coalfields Limited

Bench: Jharkhand High Court
Date: 5 October 2023
Sections engaged: 206C
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P.(T) No. 2023 of 2021) was filed before the Jharkhand High Court at Ranchi by Adhunik Power & Natural Resources Ltd. through its authorised signatory against Central Coalfields Limited and Income Tax Department respondents. Per the source preview, the matter was heard on 5 October 2023 and involves Section 206C; the substantive grounds and outcome are not captured in the available source preview beyond the identification of the parties and the forum.

12. Shree Ram Smokeless Industries Through vs Central Coalfields Ltd

Bench: Jharkhand High Court
Date: 15 March 2023
Sections engaged: 206C
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P.(T) No. 7525 of 2017) was filed before the Jharkhand High Court at Ranchi by seven petitioners — including Shree Ram Smokeless Industries, Economical Coke Company, Laddu Enterprises, Mahalaxmi Fuel, Durga Chemical, Samrat Fuel Enterprises, and Jai Durga Fuel Industries — against Central Coalfields Ltd. and its officers. Per the source preview, the matter was heard on 15.03.2023 and involves Section 206C; the substantive grounds are not fully captured in the source preview, though the batch nature of the petition and the identity of Central Coalfields Ltd. as a coal-selling entity are consistent with TCS disputes arising from the sale of coal under Section 206C.

Patterns across these 12 rulings

Government and quasi-government sellers as recurring appellants. Multiple rulings — including the District Mining Officer, Bareilly (case 6), the District Mining Officer, Durg (case 7), Jharkhand State Mineral Development Corporation (case 5), Central Coalfields Limited (cases 11 and 12), and the Guruvayoor Municipal Corporation context in case 9 — involve State or Central Government entities or their instrumentalities as the party against whom Section 206C obligations are being enforced or contested. This suggests that the applicability of TCS obligations to government bodies operating in mining, minerals, and allied sectors is a recurring litigation theme.
Batch proceedings covering multiple assessment years. Several matters in this compilation are batch proceedings covering long runs of assessment years: the District Mining Officer, Durg covers AYs 2012-13 to 2020-21 (nine years, case 7); ACIT vs. Jharkhand State Mineral Development covers AYs 2013-14 to 2017-18 (five years, case 5); and Viswateja Spinning Mills covers AYs 2017-18 to 2020-21 (four years, case 4). This pattern indicates that Section 206C disputes often crystallise over extended periods before being brought to the Tribunal or court.
Natural justice as a procedural ground. The District Mining Officer, Bareilly (case 6) explicitly raises, per the source preview, the ground that the order was passed in violation of principles of natural justice owing to the absence of a prior notice by the Assessing Officer. This procedural challenge to Section 206C demand orders — distinct from substantive questions of liability — appears as a distinct strand of litigation in the compilation.
Coal sector and Central Coalfields Limited as a focal point. Two separate writ petitions before the Jharkhand High Court (cases 11 and 12) are directed against Central Coalfields Limited as respondent, with multiple fuel and coal-trading entities as petitioners in case 12. This clustering suggests that the manner in which Central Coalfields Limited was collecting or not collecting TCS on coal sales under Section 206C was a systemic dispute affecting multiple purchasers simultaneously.
Supreme Court and High Court oversight of long-running disputes. Case 8 (Supreme Court, Civil Appeal No. 2168 of 2007, decided 8 July 2024) and case 2 (Telangana High Court, batch of tribunal appeals originating from 2007 and 2008, decided 12 June 2026) illustrate that certain Section 206C disputes have remained in appellate proceedings for well over a decade before final resolution, underscoring the importance of tracking the current status of any cited ruling.

How to use this compilation

This compilation is structured as a research starting point, not a definitive statement of the law. Each entry identifies the forum, date, sections engaged, and the procedural or substantive ground as disclosed in the available source preview. Because several source previews in this compilation are limited to header and introductory material — and the outcome field is recorded as "Outcome not specified in source" for all twelve cases — researchers must obtain and read the full text of each judgment before drawing any conclusions about the holding, ratio, or precedential value of the ruling. Full texts are available on indiankanoon.org and on the official websites of the respective courts and tribunals.

Researchers should also verify whether any of these orders have been subsequently stayed, appealed, reversed, or affirmed at a higher forum. The Supreme Court ruling (case 8) arose from a High Court order dated 2006 and was itself decided in July 2024; the Telangana High Court batch (case 2) arose from tribunal appeals filed in 2007 and 2008. The long appellate timelines visible in this compilation mean that intermediate orders may exist that are not reflected here. Parallel CBDT circulars, notifications, and clarifications relating to Section 206C — including those addressing rates, exemptions, and the interaction with Section 194Q — should also be checked for the relevant assessment years, as the statutory framework has been amended on multiple occasions.

Finally, this index is organised by date of pronouncement and does not represent a hierarchical or precedential ranking of the rulings. High Court and Supreme Court decisions carry different weight from ITAT orders, and rulings from one ITAT bench are not binding on another. Researchers building a litigation note or opinion should independently assess jurisdictional relevance, the specific sub-section of Section 206C engaged, and whether the facts of the cited ruling are sufficiently analogous to the matter under consideration.

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 206C TCS: 12 Indian Court & ITAT Rulings (2023–2026)