Singapore Airlines Ltd. v. Union of India
In favour of the assessee
The ruling in brief
Singapore Airlines Ltd. approached the High Court of Bombay in Writ Petition No. 2702 of 2026, decided on 29 June 2026, to challenge IGST demands framed on Computer Reservation System (CRS) services. The revenue treated the airline as the recipient liable under the CGST Act, including proceedings under section 74. The airline contended it neither received the services in question nor paid consideration, so the prior issue was whether it was a "recipient" at all—a question going to jurisdiction rather than mere tax quantification. The Court held the writ petition maintainable despite availability of a statutory appeal, because the dispute touched the competence of the adjudicating authority and warranted deeper examination of sections 5 and 6 read with section 74. The outcome at this stage favoured the assessee on maintainability, leaving substantive liability to be determined in appropriate proceedings. This editorial summary is for professional awareness among chartered accountants and is not legal advice.
For information only — not legal advice. Read the full judgment and applicable law before relying on this summary.
Provisions considered
- CGST S.74 — Determination of tax not paid or short paid involving fraud or suppression.
- CGST S.5 — Levy and collection of CGST on intra-State supplies.
- CGST S.6 — Authorisation of officers and concurrent State tax jurisdiction.
Source documents
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