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Corporate TaxArticle·19 March 2026

Consistency Vs Compliance in Rejection of S 197 Certification

By J the App

Executive Summary

This case addresses a fundamental tension in tax administration, whether past consistency and actual tax position can be ignored in favour of disputed demands. 

The Court held that Section 197 decisions must be reasoned, data-driven, and aligned with Rule 28AA. 

A mechanical rejection based solely on outstanding demand, without examining real tax liability or past practice, is legally untenable.


The present writ petition before the Delhi High Court in MakeMyTrip (India) Pvt. Ltd. v. ACIT & Anr., W.P.(C) 11956/2025, challenged the rejection of an a...

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