There are moments in tax litigation when the revenue administration machinery seems to lose sight of first principles. The Bombay High Court judgment in Tata Sons Private Limited v. Union of India & Others, pronounced on April 30, 2026, is one such moment. The Court’s firm, unambiguous rejection of a INR 1,524 crore Goods and Services Tax (“GST“) demand will be cited for years as a corrective to a particular species of over-reach that has afflicted indirect tax administration in India.