GST Section 50(1) Interest: 12 High Court & ITAT Rulings (2023–2026)
Research index of 12 Indian court and tribunal rulings on GST/Income-Tax Section 50(1) interest liability, covering High Courts and ITAT from 2023 to 2026.
This compilation indexes twelve rulings — spanning the Madras, Karnataka, Bombay, Gujarat, and Kerala High Courts, and the Income Tax Appellate Tribunal, Mumbai — in which Section 50(1) was among the provisions cited or in issue. The cases range from April 2023 to September 2026 and arise across a variety of GST and income-tax fact-patterns including interest demands, penalty proceedings, and assessment orders. 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 jurisdiction-wise and provision-wise research on Section 50(1) litigation.
Research index only. This page is a structured index of publicly available judicial orders and is not legal or tax advice. Readers must verify each ruling against the full judgment text and consult qualified counsel before drawing any conclusion for a specific matter.
The statutory framework in one paragraph
Section 50(1) of the Central Goods and Services Tax Act, 2017 (and its State GST mirror provisions) provides that every registered person who fails to pay the tax or any part thereof to the Government within the period prescribed shall, for the period for which the tax or any part thereof remains unpaid, pay on his own, interest at such rate not exceeding eighteen per cent as may be notified by the Government on the recommendations of the Council. The provision accordingly operates as a self-assessed, automatic liability that accrues from the date the tax falls due, and the rate notified under this provision has been a recurring point of contention in the matters indexed below. (Note: Section 50(1) of the Income Tax Act, 1961 — which deals with capital gains on slump-sale of depreciable asset blocks — is a distinct provision; Case 12 below arises under that Income Tax Act provision.)
The 12 rulings
1. M/S.Kappa Chakka Kandhari Foods vs The Commissioner Of GST And Central
- Bench: Madras High Court
- Date: 7 September 2026
- Sections engaged: 107, 122(2)(b), 50(1), 74(9)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner filed WP No. 34361 of 2026 under Article 226 of the Constitution of India challenging Order-in-Appeal No. 43/2026 (CTA-I) dated 17.07.2026, which rejected the petitioner's appeal solely on the ground that the petitioner had not pre-deposited 10% of the penalty. The writ petition sought a Writ of Certiorarified Mandamus to quash the appellate order and direct the respondent to admit and decide the appeal filed on 27.05.2026 without the payment of the pre-deposit, contending that the rejection was contrary to the provisions of the CGST Act 2017.
2. Grauates Self Employment And Super vs The Commercial Tax Officer
- Bench: Karnataka High Court
- Date: 1 September 2026
- Sections engaged: 20, 50(1), 74(9), 79(1)(c)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner, a co-operative society bearing GSTIN 29AAAAG6216D1Z0, filed WP No. 105825 of 2026 under Articles 226 and 227 of the Constitution of India before the High Court of Karnataka at Dharwad, seeking a writ of certiorari to quash an adjudication order passed under the KGST/CGST Act, 2017. The petition also impleaded the manager of Syndicate Bank as a respondent, indicating that recovery-related proceedings were part of the dispute, per the source preview.
3. M/S. Chidambaram Pillai Sankaran vs The Deputy State Tax Officer - 1 (St)
- Bench: Madras High Court
- Date: 2 June 2026
- Sections engaged: 73, 17(5), 50(1)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner filed W.P(MD) No. 14608 of 2026 before the Madurai Bench of the Madras High Court under Article 226 of the Constitution of India, challenging an assessment order dated 28.10.2025 passed by the respondent for GSTIN 33AAQFC4038G1ZJ for the assessment year 2021-22. The petitioner sought to quash the order as cryptic, non-speaking, illegal, arbitrary, and wholly without jurisdiction, and further sought a direction to the respondent to pass a fresh assessment order after affording an opportunity of being heard.
4. President Trade And Exim Corporation vs State Of Maharashtra
- Bench: Bombay High Court
- Date: 12 March 2026
- Sections engaged: 50(1)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner filed Writ Petition No. 5048 of 2025 before the Bombay High Court under Article 226 of the Constitution of India, seeking to challenge a settlement-related order passed by the state tax authorities. The matter was reserved on 12 February 2026 and pronounced on 12 March 2026 after being taken up for final hearing at the stage of admission by consent of parties, per the source preview.
5. Tvl. Palepu Pharma Private Limited vs The State Tax Officer
- Bench: Madras High Court
- Date: 3 March 2026
- Sections engaged: 50(1)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner filed WP No. 8187 of 2026 before the Madras High Court under Article 226 of the Constitution of India, challenging an order in Form GST DRC-07 dated 23.08.2024 bearing reference no. ZD330824205296G and a suo moto rectification order dated 27.12.2024 bearing reference no. ZD331224246238K, both pertaining to the assessment year 2019-20, seeking to quash those orders. The court record indicates the petitioner sought relief against a demand confirmed by the impugned order dated 23.08.2024 for assessment year 2019-2020, per the source preview.
6. Tvl.Sri Balaji Enterprises vs The Assistant Commissioner (St)
- Bench: Madras High Court
- Date: 9 December 2025
- Sections engaged: 50(1), 74
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner filed W.P. No. 47291 of 2025 under Article 226 of the Constitution of India challenging impugned proceedings dated 10.09.2025 in reference No. GSTIN 33AKPRM9025A1Z9/2023-24, seeking to quash the same as being without jurisdiction and authority of law. The source preview discloses that the demand confirmed against the petitioner included interest at 18% under Section 50(1) from 20.04.2024 with an interest due of Rs. 3,626,433/-, in addition to penalty proceedings, reflecting the quantified interest liability that was in dispute.
7. Bombay Art vs Union Of India
- Bench: Gujarat High Court
- Date: 10 October 2025
- Sections engaged: 50(1), 75(12)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner filed R/Special Civil Application No. 16855 of 2024 before the High Court of Gujarat at Ahmedabad. The Gujarat High Court delivered an oral judgment on 10 October 2025 in this matter, which was approved for reporting per the source preview. The text preview references bank account details with HDFC Bank and Bank of Baroda, suggesting the dispute may have involved attachment or recovery proceedings, though the substantive ground is not fully determinable from the available source preview.
8. Reliance Formulation Private Limited vs Assistant Commissioner Of State Tax
- Bench: Gujarat High Court
- Date: 27 June 2025
- Sections engaged: 50(1), 79
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner filed R/Special Civil Application No. 5453 of 2025 under Article 226 of the Constitution of India before the High Court of Gujarat at Ahmedabad. The source preview indicates the court issued notice returnable forthwith at the interlocutory stage, with the respondent waiving service. The text preview references provisions concerning differential tax liability, suggesting the dispute involved quantification of tax and associated interest liability, per the source preview.
9. M/S. G.P. Construction vs The Commissioner
- Bench: Madras High Court
- Date: 13 June 2025
- Sections engaged: 50(1), 73(9), 122(2)(a)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner filed W.P.(MD) No. 16014 of 2025 before the Madurai Bench of the Madras High Court under Article 226 of the Constitution of India, seeking a Writ of Certiorarified Mandamus to quash the impugned order passed by the second respondent in O.C. No. 22/2025 dated 12.02.2025. The grounds raised were violation of natural justice, lack of jurisdiction, and non-compliance with statutory procedure, and the petitioner sought a direction to drop all further proceedings pertaining to the impugned order.
10. M/S Mitsubishi Elevator India Pvt. Ltd vs Union Of India
- Bench: Karnataka High Court
- Date: 3 April 2025
- Sections engaged: 50(1), 6(2)(b)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed as Writ Petition No. 24798 of 2023 under Article 226 of the Constitution of India before the High Court of Karnataka at Bengaluru. The source preview for this matter shows the petition caption references M/S Toyota Kirloskar Auto Parts Pvt. Ltd. as the party in the body of the document, and the respondents included the Union of India, State of Karnataka, the Additional Commissioner of Central Tax (Bengaluru West Commissionerate), and the Deputy Commissioner of Commercial Taxes; the substantive ground is not fully determinable from the available source preview.
11. Venukuttan Kunju Pillai vs Union Of India
- Bench: Kerala High Court
- Date: 12 February 2025
- Sections engaged: 62, 50(1), 47
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner, proprietor of Sowparnika Traders, Alappuzha, filed WP(C) No. 30782 of 2022 before the High Court of Kerala at Ernakulam, and the court delivered judgment on 12 February 2025 on the date the matter came up for admission. The respondents included the Union of India, State of Kerala, the Commissioner of State GST Department, the Joint Commissioner, and the State Tax Officer, indicating a multi-tier challenge involving state and central authorities, per the source preview.
12. Asuda Holdings Private Limited, Mumbai vs Commissioner Of Income Tax (Appeals)
- Bench: Income Tax Appellate Tribunal - Mumbai
- Date: 3 April 2023
- Sections engaged: 50(1), 50(2)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The assessee filed ITA No. 2854/MUM/2022 for A.Y. 2014-15 (PAN: AAACA6787B) before the Mumbai Bench of the ITAT, aggrieved by the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi dated 20.09.2022. The source preview discloses a computation showing sale consideration of ₹48,00,000/-, less written down value of the block of assets at the beginning of the previous year of ₹3,01,641/-, resulting in a Short Term Capital Gain of ₹44,98,359/-, indicating that the core dispute related to capital gains treatment of a depreciable asset block under the Income Tax Act, 1961.
Patterns across these 12 rulings
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Writ petitions as the dominant litigation vehicle. Eleven of the twelve matters in this index were filed as writ petitions under Article 226 (and in one instance also Article 227) of the Constitution of India before various High Courts, indicating that taxpayers are routinely approaching High Courts directly rather than exhausting statutory appellate remedies, often on grounds of violation of natural justice or lack of jurisdiction.
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Section 50(1) appearing alongside penalty and demand provisions. Across multiple cases in this index, Section 50(1) is cited together with provisions such as Section 74 and Section 73 of the CGST/SGST Acts, reflecting that interest under Section 50(1) is typically confirmed as part of a consolidated demand order rather than through a standalone interest assessment.
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Geographic concentration in Southern High Courts. The Madras High Court features in five of the twelve matters, with the Karnataka and Gujarat High Courts each contributing two matters, and the Kerala and Bombay High Courts one each. This concentration suggests that southern jurisdictions have generated a comparatively higher volume of reported litigation on this provision during the period covered.
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Pre-deposit and appellate access as a recurring procedural flashpoint. At least one matter (Case 1) specifically concerns whether an appeal could be rejected for non-payment of pre-deposit of penalty, highlighting that procedural eligibility conditions for statutory appeals are themselves generating secondary litigation in the Section 50(1) context.
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Income Tax Act Section 50(1) as a distinct stream. Case 12 is the sole ITAT ruling in this index and concerns Section 50(1) of the Income Tax Act, 1961 — a provision governing capital gains on a block of depreciable assets — which is materially different from the GST provision of the same number. Researchers should exercise care to distinguish the two statutory regimes when searching by section number alone.
How to use this compilation
This index is a starting point for locating and categorising reported decisions in which Section 50(1) (GST or Income Tax) was cited. Each entry provides the identity fields drawn from the source data — bench, date, sections engaged, and outcome direction — alongside a brief note on the procedural or substantive ground drawn from the available text preview. Because several text previews in this index are abbreviated or procedural in nature, they do not always disclose the full ratio or final holding of the court. Researchers should treat this index as a discovery tool and retrieve the full judgment text from the relevant court portal (indiankanoon.org, the Madras High Court's judis portal, the High Court of Gujarat's portal, or the ITAT's official website) before citing any ruling or drawing conclusions about its precedential value.
When working with these rulings, researchers should also verify whether any order indexed here has been stayed, reversed on appeal, or subject to a subsequent larger bench ruling. Writ petitions disposed at the admission or interlocutory stage may not reflect a final adjudication on the merits. Additionally, researchers should cross-check whether any relevant CBDT circular, CBIC instruction, or GST Council recommendation has been issued that addresses the same point of law, as administrative guidance can affect the practical significance of a judicial ruling. Parallel proceedings before the GST Appellate Authority, the GSTAT, or other forums in the same matter should also be checked before concluding that a High Court writ ruling represents the final word.
Finally, researchers should note that the outcome direction for all twelve matters is recorded as "Outcome not specified in source" in the underlying data, meaning the final operative relief granted or refused is not confirmed from the available text previews. Any characterisation of a ruling as favourable or unfavourable to the taxpayer must be verified against the complete judgment text.
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.
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.
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.
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