MRF Wins ₹221 Crore Tax Dispute at CESTAT

The Chennai appellate tribunal ruled in favour of MRF Limited, dismissing a GST and Central Excise duty demand that had been pending since mid-2023.

17 Mar 2026 | 1 Views | By Angitha Suresh

MRF Limited, India's largest tyre manufacturer by revenue, has secured a favourable ruling from the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), Chennai, in a long-running excise duty dispute worth ₹221.31 crore. The final order, dated 16 March 2026, allowed MRF's appeal in full, with consequential relief granted to the company. The order was uploaded to the CESTAT portal on the same day it was pronounced.

The company disclosed the development to the National Stock Exchange of India and the Bombay Stock Exchange on 17 March 2026, as required under Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. This disclosure follows a series of quarterly updates MRF had been making to the exchanges since the matter was first reported in August 2023, in keeping with its obligations to inform shareholders of material litigation.

The dispute originated on 31 May 2023, when the Commissioner of GST and Central Excise, Chennai (Outer Commissionerate), issued Order-in-Original No. 26/2023. The order disallowed the basis of valuation adopted by MRF for its goods — a method used to determine the assessable value on which excise duty is calculated — and raised a duty demand of ₹221.31 crore against the company.

Valuation disputes of this nature are not uncommon in Indian indirect tax litigation. Tax authorities and manufacturers have historically disagreed on whether certain costs and deductions should be included or excluded when arriving at the value of goods for the purpose of duty computation. In MRF's case, the Commissioner held that the company's valuation methodology did not conform to the applicable rules, leading to what the department considered a shortfall in duty payment.

MRF contested this position and filed an appeal before the CESTAT Chennai on 1 September 2023, bearing reference number E/40512/2023. The company maintained that the valuation basis it had adopted was legitimate and in accordance with the law.

The case moved through a series of procedural stages over the following two years. A hearing before the CESTAT was scheduled for 3 July 2025, but the matter was adjourned to 19 August 2025 at the request of counsel representing the tax department. Such adjournments are a routine feature of tribunal proceedings, though they can significantly extend the timeline for resolution.

The tribunal eventually conducted a full hearing on 29 September 2025. Following arguments from both sides, CESTAT reserved its order — a standard practice where the bench takes time to deliberate before issuing a written ruling.

The wait for the final order extended to nearly six months. On 16 March 2026, the Hon'ble CESTAT, Chennai issued Final Order No. 40364/2026, pronouncing its decision in MRF's favour.

The tribunal's order allows MRF's appeal in its entirety, effectively setting aside the original duty demand of ₹221.31 crore raised by the Commissioner. The phrase "consequential relief" in the order indicates that any deposits or pre-deposits made by MRF in connection with the appeal may be eligible for refund, subject to applicable procedures.

The ruling brings to a close a matter that had been listed as a material litigation in MRF's regulatory disclosures for nearly three years. For a company of MRF's scale, the resolution removes a contingent liability that had been noted by investors and analysts since its first disclosure in August 2023.

MRF Limited, incorporated in 1960, is headquartered at 114 Greams Road, Chennai. The company is one of India's most recognised tyre manufacturers and is listed on both the BSE and the NSE. It holds the distinction of having one of the highest share prices among listed Indian companies. The company operates multiple manufacturing plants across India and serves both domestic and international markets.

The regulatory disclosure was signed by S. Dhanvanth Kumar, Company Secretary of MRF Limited, and submitted to the stock exchanges in the prescribed format under SEBI's listing regulations.

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