Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Tax & Customs LawSupreme Court of India

M/s Bilag Industries P. Ltd. & Anr. vs. Commr. of Cen. Exc. Daman & Anr.

Civil Appeal · 2023 INSC 274Decided 22 Mar 2023
Civil Appeal Nos. 9195-9196 of 2010
S. Ravindra Bhat · Dipankar Datta

Background

Bilag Industries (BIL), an Indian pesticide manufacturer, became a subsidiary of a foreign company, AgrEvo SA, after a joint-venture agreement, and AgrEvo SA separately owned 100% of another Indian company, Aventis CropScience (India) Ltd., to which BIL sold its products (like Esbiothrin) for onward sale to end customers. The excise department claimed BIL and Aventis CropScience (India) were "related persons" under Section 4(4)(c) of the Central Excise Act, since both were linked through their common foreign parent, and demanded higher excise duty by valuing BIL's goods at the price Aventis CropScience later charged end customers, rather than BIL's own sale price. The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) upheld this "related person" treatment and the resulting demand.

Decision Breakdown

The Supreme Court reviewed a long line of its own precedents on what makes two companies "related persons" for excise valuation, holding that the test requires mutual interest: each company must have a direct or indirect interest in the other's business, not just a one-way relationship through a common parent. Common shareholding by a foreign parent, without more, does not by itself show that BIL had any interest in Aventis CropScience's affairs, or vice versa; their transactions were on a principal-to-principal basis, and the department had not shown BIL's prices to Aventis CropScience were suppressed compared to market prices. The Tribunal had wrongly inferred relatedness from the overall commercial arrangement without applying this proper legal test. Decision Breakdown (continued: outcome): The appeals were allowed, and the CESTAT's order (and the excise demand based on treating the companies as related persons) was set aside, with no order as to costs.

Lesson Learnt

Two companies sharing a common parent or majority shareholder are not automatically "related persons" for tax valuation purposes. The law requires proof that each company actually has a stake in the other's business, not merely a shared corporate ownership structure.

M/s Bilag Industries P. Ltd. & Anr. vs. Commr. of Cen. Exc. Daman & Anr. – Legal Case Shots | LegalAware