No. The Calcutta High Court order dated 17 November 2025 admitted Tata Consumer Products Limited’s appeal—filed by the company formerly known as Tata Global Beverages Limited—but did not decide the tax dispute. The order also does not substantiate a ₹226 crore win. It records a dispute over a ₹36.88 crore long-term capital-gains addition and different values for the property transfer.
What the High Court decided—and what it did not
In its order dated 17 November 2025, the Calcutta High Court said: “The appeal is admitted on the following substantial questions of law for consideration.” Admission means the court accepted legal questions for consideration; it is not a ruling that the company won or that the tax addition must be removed.
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The appellant is Tata Consumer Products Limited (erstwhile Tata Global Beverages Limited). The respondent is the Principal Commissioner of Income Tax-2, Kolkata. The order identifies the appeal as ITAT/26/2025 and names Justices Rajarshi Bharadwaj and Uday Kumar.
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The dispute concerns land and buildings transferred under a deed dated 11 July 2013. The order identifies three figures:
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- ₹195 crore: the consideration stated in the deed.
- ₹231.06 crore: the stamp valuation.
- ₹36.88 crore: the long-term capital-gains addition upheld by the Tribunal and challenged in the appeal.
These figures describe the case as recorded in the order. The court did not choose between the deed consideration and stamp valuation in this order. Nor does the order identify ₹226 crore as an amount the company won.
What legal questions will the appeal consider?
The admitted questions concern how the transfer should be valued and how tax law applies to the assets involved. They include:
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- Whether capital gain should be computed using the deed’s ₹195 crore consideration or the ₹231.06 crore stamp valuation.
- When a reference to a Valuation Officer under section 50C(2) is mandatory, and whether reasons are required if no reference is made.
- Whether section 50C applies to buildings treated as part of a depreciated block of assets.
- Whether the Tribunal properly dealt with valuation reports, the nature and structure of the consideration, and whether the stamp valuation represented fair market value.
The order admits these issues for consideration; it does not answer them on their merits.
Why are the deed value and stamp value different?
The deed states the transaction consideration, while the stamp valuation is a separate value relevant to the dispute. The company challenged the treatment of the transaction and related findings, including the use of the stamp valuation. The order records both numbers but does not establish why they differ or decide which one should determine the capital-gains calculation.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What happens next, according to this order?
The court directed the appellant to file informal paper books containing relevant material within seven weeks and said the matter should be listed eight weeks hence. It also disposed of the stay application. Those directions do not establish whether a later hearing took place or whether the appeal has since been decided; the order dated 17 November 2025 does not provide a later case outcome.
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