Supreme Court Upholds Inclusion of Royalty in Mineral Sale Value to Prevent Evasion
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Case: KIRLOSKAR FERROUS INDUSTRIES LIMITED v. UNION OF INDIA
Court: Supreme Court of India
Date: 13-07-2026
Law: Constitution of India, Mines and Minerals (Development and Regulation) Act.
Highlights of the Judgment:
- Validity of including royalty, DMF, and NMET payments in "sale value" under Section 9 of the MMDR Act.
- Application of the presumption of constitutionality to subordinate mineral concession rules.
- The legal distinction between the "measure of a levy" and the "nature of a levy" in fiscal policy.
- Use of regulatory loading on sale value as a valid mechanism to prevent price manipulation and tax evasion.
- Article 14 discrimination analysis regarding different royalty computation methodologies for coal and iron ore.
- Standard of judicial review for economic policies and the irrelevance of individual hardship in determining constitutional validity.