OthersArticle·21 April 2026
ISD Demand Invalid
By J the App
Executive Summary
Executive Summary
This ruling consolidates three foundational principles:
1. ISD is not the taxable person for recovery purposes
2. Jurisdictional competence is non-negotiable
3. Audit-based demands cannot justify extended limitation
The Tribunal not only quashes the demand but also reinforces that procedural illegality is fatal, irrespective of merits.
Issues for Determination
1. Whether recovery of CENVAT credit can be made from an ISD under Rule 14.
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