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OthersArticle·25 March 2026

Use and Intended Use

By J the App

Executive Summary

This judgment by Hon’ble Supreme Court addresses a recurring tension in indirect tax law, whether benefits linked to “intended use” can be denied due to practical limitations in tracing actual consumption. 

The Supreme Court leans toward a purposive and pragmatic interpretation, cautioning against speculative demand computation and mechanical invocation of extended limitation. 

The ruling reinforces that absence of mens rea and revenue neutrality are critical in testing penalty and limitation.


The present case arises from a batch of civil appeals filed by M/s Rashtriya Chemicals and Fertilizers Limited, a public sector undertaking engaged in manufacturing fertili...

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