Rationalising Mutual Fund Taxation: A Chartered Accountant’s Perspective on AMFI’s Budget 2026–27 Proposals
Brief / Abstract
The Union Budget in recent years has significantly altered the taxation of mutual funds through changes relating to debt funds, capital gains, surcharge, and compliance requirements. While these reforms have sought to simplify the tax regime, they have also created anomalies that affect investors, mutual fund houses, and tax practitioners.
This article critically examines the Association of Mutual Funds in India’s (AMFI) Budget 2026–27 recommendations for rationalising the taxation of mutual funds. It analyses proposals relating to restoration of indexation for debt mutual funds, reforms to section 50AA, tax treatment of equity-oriented Fund of Funds, ELSS, retirement-linked mutual fund products, winding-up of schemes, side-pocketing, IFSC and section 9A safe harbour reforms, compliance simplification, and other important recommendations such as section 54EC, section 87A, STT rationalisation, surcharge parity, and REIT/InvIT tax parity.
The discussion is supported by relevant statutory provisions, judicial precedents, and practical illustrations from a Chartered Accountant’s perspective. The article evaluates how the proposed reforms seek to improve tax neutrality, administrative efficiency, investor confidence, and certainty while balancing the objectives of equity, simplicity, and economic substance in India’s mutual fund taxation framework.
Introduction
Over the last decade, mutual funds have evolved from being an investment option largely confined to metropolitan investors into one of the principal vehicles for household financial savings. Systematic Investment Plans (SIPs), retirement planning, passive investing and exchange-traded products have substantially widened investor participation. This transformation has been supported by regulatory reforms, greater financial awareness and increasing digital access.
Tax policy, however, has not always kept pace with these developments. During the last few years, the taxation of mutual funds has undergone significant changes. The introduction of section 50AA by the Finance Act, 2023, modifications brought by the Finance (No. 2) Act, 2024, changes in capital gains rates and holding periods, withdrawal of indexation for specified debt mutual funds and a growing number of compliance obligations have considerably altered the tax landscape. Although many of these amendments were introduced with legitimate policy objectives, they have also created interpretational issues and practical challenges for investors, asset management companies (AMCs) and tax professionals.
Against this backdrop, the Association of Mutual Funds in India (AMFI), in its Pre-Budget Memorandum for 2026–27, has recommended a comprehensive set of reforms. Importantly, these recommendations do not merely seek tax concessions. Many of them are intended to restore neutrality between comparable investment products, simplify compliance, remove unintended hardships and align taxation more closely with commercial reality.
From the standpoint of a practising Chartered Accountant, these proposals deserve consideration because tax administration should not only secure revenue but also provide certainty, minimise avoidable disputes and facilitate long-term savings. A predictable tax regime improves investor confidence and reduces the cost of compliance, ultimately contributing to more efficient capital allocation within the economy.
This article examines the principal recommendations contained in AMFI’s memorandum, analyses their practical implications and discusses the judicial principles that support a coherent and rational approach to mutual fund taxation.
Evolution of Debt Mutual Fund Taxation – Understanding Section 50AA
Perhaps the most significant legislative change affecting mutual funds in recent years was the insertion of section 50AA by the Finance Act, 2023.
Prior to this amendment, gains arising from units of debt-oriented mutual funds held for the prescribed long-term period generally qualified as long-term capital gains and were eligible for indexation. The rationale behind indexation was straightforward. Inflation erodes purchasing power over time, and taxing the entire nominal appreciation without adjusting for inflation may result in taxation of amounts that do not represent real economic income.
The Finance Act, 2023 fundamentally altered this position by introducing section 50AA. Broadly, gains arising from specified mutual funds acquired on or after 1 April 2023 are deemed to be short-term capital gains irrespective of the actual holding period. Subsequently, the Finance (No. 2) Act, 2024 refined the definition of specified mutual funds, linking it to investment thresholds in debt and money market instruments.
The legislative intent behind these amendments appears to have been to reduce tax arbitrage between debt mutual funds and conventional fixed-income products such as bank deposits. Since interest earned on deposits is taxed at normal slab rates, Parliament considered it appropriate that economically comparable investments should not continue to enjoy concessional capital gains treatment merely because they were structured through mutual funds.
Viewed from the perspective of fiscal policy, this objective cannot be dismissed as irrational. The Supreme Court has consistently recognised that taxation is an area in which Parliament enjoys considerable latitude in designing economic policy. In R.K. Garg v. Union of India [(1981) 4 SCC 675], the Court observed that laws dealing with economic matters should ordinarily receive greater judicial deference because legislative experimentation is often necessary in fiscal administration.
Consequently, AMFI’s proposal should not be understood as questioning Parliament’s legislative competence or constitutional authority. Rather, it seeks a reconsideration of whether the present framework fully reflects the economic characteristics of long-term debt investments and whether certain refinements would produce a more balanced outcome.
Another aspect that deserves attention is the nature of legal fictions. Section 50AA creates a deeming provision for taxation of gains. As explained by the Supreme Court in CIT v. Amarchand N. Shroff [(1963) 48 ITR 59 (SC)], a legal fiction must be confined to the purpose for which it has been enacted and should not be extended beyond its legitimate field. Similarly, courts have repeatedly cautioned that deeming provisions should not be interpreted more broadly than the statutory language requires. This principle becomes relevant while analysing subsequent proposals relating to the characterisation of mutual fund investments.
Restoring Indexation for Long-Term Debt Mutual Funds
Among all the recommendations contained in the AMFI memorandum, the proposal to restore indexation for long-term debt mutual funds is perhaps the most significant.
The debate is not merely about reducing tax liability. It concerns a more fundamental question: should tax be levied on nominal appreciation or on real economic gain?
Inflation gradually reduces the purchasing power of money. When an investment is held over several years, a substantial part of the increase in value merely compensates for inflation rather than representing additional wealth.
Consider a simple example.
Suppose an investor purchased units of a debt mutual fund in April 2020 for ₹10,00,000 and redeemed them in April 2024 for ₹13,50,000. On the face of it, the investor appears to have earned a gain of ₹3,50,000.
However, if inflation averaged around six per cent annually during this period, the inflation-adjusted cost of acquisition would be approximately ₹12,60,000. The investor’s actual increase in purchasing power would therefore be only about ₹90,000.
Taxing the entire ₹3,50,000 effectively taxes inflation as though it were income.
This illustration explains why indexation has historically formed an integral part of India’s capital gains regime. It does not create an exemption; rather, it attempts to measure income more accurately by recognising changes in the value of money over time.
Although CIT v. B.C. Srinivasa Setty [(1981) 128 ITR 294 (SC)] did not deal with indexation, the Supreme Court emphasised the close relationship between the charging provision and the computation mechanism under the capital gains scheme. A charging provision must operate on a workable computational basis. The broader principle emerging from the judgment is that capital gains taxation should reflect genuine gains capable of meaningful computation.
Similarly, the celebrated decision in K.P. Varghese v. ITO [(1981) 131 ITR 597 (SC)] reminds us that tax statutes should not be interpreted in a manner that produces unreasonable or unintended consequences where a purposive construction better advances legislative intent. The Court rejected a purely literal approach and preferred an interpretation that reflected the object of the provision.
AMFI’s recommendation is therefore not simply a plea for tax relief. It is an argument that long-term investment returns should be measured in a manner that better reflects economic substance.
Equality, Classification and Fiscal Rationality
Several constitutional principles also provide an intellectual framework for evaluating tax policy, although they do not compel any particular legislative outcome.
The classic starting point is State of West Bengal v. Anwar Ali Sarkar [AIR 1952 SC 75], where the Supreme Court articulated the two well-known tests under Article 14: a statutory classification must rest on an intelligible differentia, and that differentia must bear a rational nexus to the object sought to be achieved.
These principles have subsequently influenced tax jurisprudence as well.
In Kunnathat Thathunni Moopil Nair v. State of Kerala [AIR 1961 SC 552], the Court made it clear that taxation statutes are not immune from Article 14 scrutiny merely because they concern fiscal matters. Likewise, Khandige Sham Bhat v. Agricultural Income-tax Officer [AIR 1963 SC 591] recognised that while classification in taxation is permissible, it cannot be arbitrary or devoid of rational justification.
The same approach was reaffirmed in Arya Vaidya Pharmacy v. State of Tamil Nadu [(1989) 2 SCC 285], where the Supreme Court held that differential tax treatment must bear a reasonable relationship with the legislative objective.
These authorities do not imply that the present debt fund regime is unconstitutional. Rather, they underline an important legislative principle: where economically similar investments are treated differently, the distinction should be supported by a clear and rational policy objective.
AMFI’s recommendations may therefore be viewed as an attempt to restore greater neutrality within the tax system rather than as a challenge to the validity of existing law.
Retirement-focused Mutual Fund Proposals
One noteworthy feature of the memorandum is that it does not confine itself to conventional tax amendments. It also attempts to strengthen long-term retirement planning through mutual funds.
The proposed Mutual Fund Linked Retirement Savings Scheme (MFLRS) seeks tax treatment comparable to the National Pension System. The recommendation broadly envisages an Exempt-Exempt-Exempt (EEE) model so that contributions, accretions and eligible withdrawals receive similar tax treatment.
A related recommendation is the introduction of a Mutual Fund Voluntary Retirement Account (MF-VRA), inspired by internationally recognised retirement savings models such as the United States 401(k). Such a product would allow employer-supported retirement investing through regulated mutual fund structures.
From a policy perspective, these recommendations recognise that retirement planning should not be limited to one investment vehicle. Investors differ in their risk appetite, liquidity preferences and asset allocation requirements. Allowing mutual funds to participate on comparable tax terms would broaden retirement planning options while encouraging disciplined long-term investing.
The Supreme Court’s observations in Bajaj Tempo Ltd. v. CIT (1992) 196 ITR 188 (SC) are particularly relevant. The Court held that provisions granting incentives for economic growth should receive a liberal interpretation so that the legislative purpose is advanced rather than frustrated by an unduly restrictive construction.
Similarly, Federation of Hotel & Restaurant Association of India v. Union of India (1989) 3 SCC 634 recognises that tax classifications are permissible provided they rest upon a rational basis. If retirement security is the underlying policy objective, extending comparable treatment to similar long-term savings products appears commercially logical.
Winding-up of Mutual Fund Schemes
An issue that receives relatively little public attention but has considerable practical importance concerns taxation of investors when a mutual fund scheme is wound up.
Frequently, investors do not receive the redemption proceeds immediately. Realisation of assets may continue for months or even years. Amounts are distributed in several instalments depending upon recoveries from underlying investments.
The present provisions may create uncertainty regarding the point at which capital gains should be regarded as arising.
AMFI has therefore recommended that taxation should correspond with the actual receipt of consideration rather than merely the extinguishment of units.
From a practical standpoint, this recommendation deserves serious consideration. It is difficult to justify taxation of income that may never ultimately be realised or whose quantum remains uncertain.
The principle underlying CIT v. B.C. Srinivasa Setty (1981) 128 ITR 294 (SC) is relevant. The Supreme Court observed that the charging provisions and computation provisions form an integrated code. Where computation itself becomes impracticable, the charging mechanism also becomes difficult to sustain.
Although the case arose in a different factual context, its reasoning supports the broader proposition that capital gains taxation should operate only where a workable method of computation exists.
Likewise, K.P. Varghese v. ITO (1981) 131 ITR 597 (SC) reminds us that tax statutes should be interpreted in a manner that advances their purpose and avoids unreasonable consequences.
Segregated Portfolios (Side-Pocketing)
Another practical recommendation concerns segregated portfolios, commonly referred to as side-pocketing.
Where a debt security suffers severe credit impairment, SEBI regulations permit the affected portion of the portfolio to be segregated from the main scheme.
Economically, the investor continues to hold the same investment. Only the accounting and administrative treatment changes.
Treating such segregation as a taxable transfer creates unnecessary complexity because there is no commercial disposal of the investment.
AMFI has therefore suggested statutory clarification that creation of segregated portfolios should remain tax neutral.
The recommendation reflects commercial substance rather than legal form.
Again, the purposive approach adopted in K.P. Varghese v. ITO provides useful interpretative guidance. Tax consequences should ordinarily follow the real nature of the transaction rather than technical restructuring without economic change.
Compliance Simplification
For practising Chartered Accountants, perhaps the most significant recommendations are not those affecting tax rates but those aimed at reducing avoidable compliance.
Several of the suggested amendments arise from practical difficulties regularly encountered by taxpayers and intermediaries.
These include—
- rationalisation of Forms 15CA and 15CB where tax has already been deducted;
- relief in cases involving inoperative PAN;
- clarification that investment write-offs should not attract section 194R;
- increasing the threshold under section 194K from ₹10,000 to ₹50,000;
- rationalisation of Statement of Financial Transactions (SFT) reporting;
- creation of separate mutual fund reporting fields in income-tax returns.
Many of these changes may appear procedural. However, anyone advising investors appreciates that procedural uncertainty often consumes more professional time than substantive tax computation.
In practice, the compliance cost frequently exceeds the actual tax involved.
Reducing unnecessary reporting obligations improves voluntary compliance, lowers administrative expenditure and allows tax authorities to focus on genuine areas of risk.
The Supreme Court’s observations in R.K. Garg v. Union of India (1981) 4 SCC 675 acknowledge that fiscal legislation must often accommodate administrative realities and practical considerations.
Clarification regarding Section 194R
One recommendation deserves separate mention.
Where investments are written off because the issuer has defaulted or entered insolvency proceedings, certain interpretational concerns have arisen regarding section 194R dealing with benefits or perquisites.
Commercially, a write-off represents recognition of a loss.
The investor receives no benefit.
Treating such recognition of loss as a taxable benefit stretches the statutory language beyond its ordinary meaning.
An express clarification would substantially reduce avoidable disputes.
Section 194K Threshold
The present threshold of ₹10,000 for deduction of tax under section 194K was introduced several years ago.
Considering inflation and the significant increase in retail participation in mutual funds, the threshold now appears relatively modest.
Increasing it to ₹50,000 would primarily reduce compliance for small investors while having limited impact on revenue collection.
Such periodic revision of monetary limits is consistent with sound tax administration.
IFSC Competitiveness and Section 9A
One of the more strategic recommendations concerns India’s aspiration to develop the International Financial Services Centre as a globally competitive asset management destination.
Section 9A introduced the concept of an eligible investment fund and provided a safe harbour so that offshore funds would not be regarded as having a business connection merely because their fund managers operated from India.
However, certain conditions continue to be viewed by international fund managers as restrictive.
AMFI has therefore suggested rationalisation of these conditions so that Indian fund managers may compete more effectively with established financial centres.
This proposal should not be viewed merely as a tax concession.
Rather, it concerns India’s competitiveness in attracting global asset management business.
The Supreme Court in R.K. Garg v. Union of India recognised that economic legislation often involves experimentation and policy choices that are best left to the Legislature.
Such observations reinforce the importance of periodically reviewing tax provisions in light of changing commercial realities.
Infrastructure Investment and the Section 54EC Proposal
AMFI has also suggested widening the scope of section 54EC by notifying specified mutual fund units investing predominantly in infrastructure projects as eligible long-term specified assets.
At present, exemption under section 54EC is available only where capital gains are invested in notified bonds issued by specified public sector entities. While these instruments have served an important policy objective, India’s infrastructure financing requirements have expanded considerably over the last decade. Professionally managed mutual fund schemes dedicated to infrastructure financing could provide an additional avenue for channelising long-term household savings into productive assets.
From a tax policy perspective, the recommendation is not about enlarging the exemption indiscriminately. Rather, it seeks to recognise that infrastructure can be financed through different regulated investment vehicles. Where the economic objective remains identical, comparable tax treatment deserves consideration.
The observations of the Supreme Court in Bajaj Tempo Ltd. v. Commissioner of Income-tax (1992) 196 ITR 188 (SC) remain instructive. The Court emphasised that provisions intended to promote economic development should receive a liberal interpretation consistent with their underlying purpose. If the legislative object is to encourage investment in infrastructure, extending the benefit to appropriately regulated mutual fund vehicles would not be inconsistent with that principle.
Extending the Section 87A Rebate to Capital Gains
Another recommendation receiving considerable attention relates to section 87A.
At present, taxpayers qualifying for rebate under section 87A cannot always utilise the benefit against tax payable on certain categories of capital gains. This has created situations where individuals with relatively modest overall income still bear tax liability because part of their income consists of long-term capital gains.
AMFI has suggested extending the rebate to such gains, subject to suitable safeguards.
Viewed from a practitioner’s perspective, the proposal primarily benefits small retail investors rather than high-net-worth taxpayers. Many first-time investors participate in mutual funds through systematic investment plans and eventually redeem units for family needs such as education, housing or retirement. The tax treatment should recognise this reality.
The broader constitutional principles discussed in State of West Bengal v. Anwar Ali Sarkar, AIR 1952 SC 75, Kunnathat Thathunni Moopil Nair v. State of Kerala, AIR 1961 SC 552, and Arya Vaidya Pharmacy v. State of Tamil Nadu (1989) 2 SCC 285 remind us that classifications in taxation should rest upon an intelligible differentia having a rational nexus with the legislative objective. Whether section 87A should extend to capital gains is ultimately a legislative choice, but the recommendation raises a legitimate issue of equity for smaller investors.
Rationalisation of Surcharge
Another practical issue concerns the varying surcharge rates applicable to different categories of taxpayers and different forms of investment income.
AMFI has recommended greater uniformity, particularly in relation to non-resident investors. Frequent changes in surcharge rates increase complexity in tax computation, withholding obligations and advisory work.
For foreign investors evaluating competing investment jurisdictions, certainty is often as important as the effective tax rate itself.
A stable surcharge framework also reduces interpretational disputes and improves predictability for long-term investment decisions.
The Supreme Court in R.K. Garg v. Union of India (1981) 4 SCC 675 recognised that fiscal legislation necessarily involves economic choices. Rationalisation of surcharge provisions falls squarely within that sphere of policy reform.
Securities Transaction Tax
The memorandum also recommends rationalisation of Securities Transaction Tax (STT).
Although STT was originally introduced as a simplified mechanism accompanying concessional capital gains taxation, subsequent amendments have altered the overall balance between transaction taxes and income taxes.
The mutual fund industry has therefore suggested a review to ensure that transaction costs remain proportionate and consistent across comparable investment products.
Lower frictional costs encourage wider retail participation and improve market efficiency without necessarily compromising tax administration.
REITs, InvITs and Similar Investment Vehicles
Another recommendation deserving attention relates to achieving greater parity between mutual funds, Real Estate Investment Trusts (REITs) and Infrastructure Investment Trusts (InvITs).
These products differ in legal structure but often serve comparable investment objectives by pooling investor resources into professionally managed portfolios.
Unnecessary differences in tax treatment may influence investment decisions for reasons unrelated to commercial merit.
The constitutional principle emerging from Federation of Hotel & Restaurant Association of India v. Union of India (1989) 3 SCC 634, Arya Vaidya Pharmacy, and Khandige Sham Bhat v. Agricultural Income-tax Officer, AIR 1963 SC 591 is that legislative classification must bear a reasonable relationship with its objective. Where investment vehicles perform substantially similar economic functions, consistency in taxation promotes neutrality and reduces market distortions.
MF Lite, Scheme Hive-offs and Option Consolidation
The memorandum also addresses several operational issues that may appear technical but have significant practical implications.
One recommendation seeks tax neutrality when passive mutual fund schemes are transferred pursuant to regulatory restructuring under the MF Lite framework. Another concerns clarification that consolidation of Growth and IDCW options, or similar internal restructuring exercises undertaken pursuant to SEBI directions, should not trigger unintended capital gains taxation.
These events do not ordinarily represent commercial exits by investors. Rather, they arise from regulatory or administrative changes within the mutual fund itself.
Providing statutory clarity would reduce avoidable litigation while ensuring that investors are not taxed merely because the legal form of their investment changes without any corresponding economic realisation.
A Practitioner’s Perspective
Having advised investors across different categories, one observation repeatedly emerges.
Clients rarely complain about paying tax where the law is clear and the commercial outcome is understandable.
Most disputes arise because similar investments receive different tax treatment, compliance obligations become disproportionately burdensome, or procedural requirements outweigh the underlying tax involved.
For example, obtaining Forms 15CA and 15CB for routine transactions, addressing inoperative PAN issues, reconciling Statement of Financial Transactions reporting, or analysing the implications of section 194R often consumes substantially more professional time than the tax liability itself.
From this perspective, several recommendations contained in the AMFI memorandum are less about reducing revenue collection and more about improving the efficiency of tax administration.
That distinction is important.
A well-designed tax system should not merely collect revenue; it should do so with certainty, simplicity and minimal compliance cost.
Judicial Principles Underlying the Recommendations
The proposals discussed throughout this article do not depend upon constitutional litigation. Nevertheless, established judicial principles provide a useful analytical framework.
CIT v. B.C. Srinivasa Setty (1981) 128 ITR 294 (SC) explains the relationship between the charging and computation provisions governing capital gains. It supports the broader proposition that capital gains taxation should operate on a workable and commercially meaningful basis.
K.P. Varghese v. ITO (1981) 131 ITR 597 (SC) remains the leading authority for purposive interpretation of tax statutes. It discourages literal constructions that defeat legislative intent or produce unreasonable outcomes.
Bajaj Tempo Ltd. v. CIT (1992) 196 ITR 188 (SC) establishes that incentive provisions intended to promote economic growth deserve liberal interpretation.
R.K. Garg v. Union of India (1981) 4 SCC 675 recognises the wide latitude available to Parliament in matters of fiscal and economic policy while acknowledging the importance of rational legislative choices.
The constitutional foundations of tax classification are reflected in State of West Bengal v. Anwar Ali Sarkar, AIR 1952 SC 75, Kunnathat Thathunni Moopil Nair v. State of Kerala, AIR 1961 SC 552, Khandige Sham Bhat v. Agricultural Income-tax Officer, AIR 1963 SC 591, Arya Vaidya Pharmacy v. State of Tamil Nadu (1989) 2 SCC 285, and Federation of Hotel & Restaurant Association of India v. Union of India (1989) 3 SCC 634. Collectively, these decisions affirm that while taxation permits reasonable classification, such classification must rest upon intelligible criteria having a rational connection with the legislative objective.
Finally, Kasinka Trading v. Union of India (1995) 1 SCC 274 and Shrijee Sales Corporation v. Union of India (1997) 3 SCC 398 recognise that fiscal incentives are matters of economic policy capable of modification or withdrawal as circumstances require. They reinforce the proposition that recommendations such as DLSS, MFLRS or section 54EC expansion fall within the domain of legislative policy rather than judicial entitlement.
Conclusion
The AMFI Budget 2026–27 Memorandum should not be viewed merely as a compilation of tax concessions sought by the mutual fund industry. Read as a whole, it is an attempt to align the tax framework more closely with commercial reality, investor behaviour and efficient tax administration.
Several recommendations, including restoration of indexation for long-term debt funds, parity for equity-oriented fund of funds, retirement-focused mutual fund products, tax neutrality for side-pocketing and scheme restructuring, simplification of compliance obligations, rationalisation of section 9A, and greater consistency across pooled investment vehicles, seek to remove anomalies rather than create preferential treatment.
From the perspective of a practising Chartered Accountant, these proposals also address everyday issues encountered while advising investors. Reducing avoidable compliance, improving certainty and ensuring that tax consequences follow economic substance would benefit taxpayers, intermediaries and the tax administration alike.
The evolution of tax law has consistently demonstrated that certainty, neutrality and simplicity contribute as much to voluntary compliance as favourable tax rates. The judicial principles discussed in this article reinforce these objectives without dictating any particular fiscal policy.
Whether all the recommendations are ultimately accepted is a matter for the Legislature. Even so, the AMFI memorandum provides a valuable blueprint for modernising mutual fund taxation in a manner that balances revenue considerations with investor confidence, administrative efficiency and the long-term development of India’s capital markets.
References
1. AMFI, Pre-Budget Memorandum 2026–27.
2. Income-tax Act, 1961.
3. Finance Act, 2023.
4. Finance (No. 2) Act, 2024.
5. SEBI (Mutual Funds) Regulations, 1996, as amended.
6. CIT v. B.C. Srinivasa Setty (1981) 128 ITR 294 (SC).
7. K.P. Varghese v. ITO (1981) 131 ITR 597 (SC).
8. Bajaj Tempo Ltd. v. CIT (1992) 196 ITR 188 (SC).
9. R.K. Garg v. Union of India (1981) 4 SCC 675.
10. State of West Bengal v. Anwar Ali Sarkar, AIR 1952 SC 75.
11. Kunnathat Thathunni Moopil Nair v. State of Kerala, AIR 1961 SC 552.
12. Khandige Sham Bhat v. Agricultural Income-tax Officer, AIR 1963 SC 591.
13. Arya Vaidya Pharmacy v. State of Tamil Nadu (1989) 2 SCC 285.
14. Federation of Hotel & Restaurant Association of India v. Union of India (1989) 3 SCC 634.
15. Kasinka Trading v. Union of India (1995) 1 SCC 274.
16. Shrijee Sales Corporation v. Union of India (1997) 3 SCC 398.
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