Tata Steel Writ Petition Restored in Bombay High Court Over Tax Reassessment Dispute

Tata Steel Writ Petition Restored in Bombay High Court Over Tax Reassessment Dispute​

Tata Steel Limited has received an order restoring its writ petition concerning a material tax litigation related to income reassessment for the Assessment Year (AY) 2019-20. The case, which initially challenged the authority of an Assessing Officer regarding a waived loan amount, was listed for further hearing by the Bombay High Court on August 19, 2026.

The dispute originated when Tata Steel received a show cause notice from the Assessing Officer in connection with the waiver of a ₹25,185.51 crore loan granted to Tata Steel BSL Limited (which is now merged with the Company) for the AY 2019-20. Following an Assessment Order issued by the Assessing Officer on March 31, 2025, which increased the taxable income by the waived debt amount, the company filed a writ petition with the Bombay High Court on March 24, 2025.

In August 2025, the Hon'ble High Court heard the matter and set aside the notice along with related consequential orders. The court had determined that the notice was issued by the Jurisdictional Assessing Officer instead of the statutorily prescribed Faceless Assessing Officer. This ruling relied on a precedent that was simultaneously being challenged by tax authorities before the Supreme Court of India.

Impact of Finance Act, 2026​

The legal landscape changed following the introduction of the Finance Act, 2026, which included a retrospective amendment to income-tax law. This amendment empowered the Jurisdictional Assessing Officer to issue reassessment notices. As a result of this legislative change, the favorable judicial precedents related to the original dispute were set aside by the Supreme Court of India and remanded back to respective High Courts for consideration.

The Company’s writ petition, numbered 1561 of 2025, was subsequently listed before the Bombay High Court on July 20, 2026, for restoration in light of these developments.

Status and Future Proceedings​

Tata Steel announced that the writ petition has been restored by the Hon'ble High Court and is scheduled for hearing on August 19, 2026. The High Court granted permission to the Company to amend the petition to specifically challenge the constitutional validity of the retrospective amendment introduced in the Finance Act, 2026.

The tax department has been directed by the court to file a counter affidavit following the restoration. Tata Steel maintains that it holds a strong case on merits and other technical infirmities regarding the Assessment Order. The Company stated that the retrospective amendment introduced by the Finance Act, 2026 would not negate the core merits or the other technical grounds upon which the company is challenging the reassessment proceedings.

TATASTEEL Stock Price Movement​

Today, Tata Steel Limited shares shed 0.80% in the post-market session, settling at ₹182.67. The stock saw significant activity, with approximately 16.12 million shares traded as the market closed.