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Customs DutyArticle·2 January 2026

Taxation in the Dark Is No Taxation at All

By J the App

Executive Summary

When does a tax law truly become law? The controversy surrounding Section 25(4) of the Customs Act was never merely about an increase in duty rates or the mechanics of Gazette publication. At its core, it raised a far more fundamental question, whether the State can impose tax consequences before the law itself is made known to those governed by it. A consistent line of High Court decisions, culminating in the Karnataka High Court’s ruling in Patanjali Foods (formerly Ruchi Soya), has reaffirmed a constitutional first principle, delegated taxation cannot operate in legal darkness. J the App by JustIDT takes a look.

The Core Constitutional Question: When Does a Tax Law Become Law; In the case of M/s Patanjali Foods Limited (formerly M/s Ruchi Soya Industries Ltd.)...

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