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Bombay High Court Rejects Interim Relief in Same-Sex Couple’s Gift-Tax Case

Taxes must be paid pending a December hearing, with any relief limited to refunds if the challenge ultimately succeeds.

Overview

  • A division bench of Justices Burgess P. Colabawalla and Amit S. Jamsandekar declined protection sought by petitioners Payio Ashiho and Vivek Divan.
  • The plea contests Section 56(2)(x) of the Income Tax Act, which taxes gifts over ₹50,000 but exempts transfers from a “spouse.”
  • Petitioners argue the provision produces indirect discrimination by excluding same-sex partners from the exemption.
  • Additional Solicitor General Anil Singh maintained that same-sex unions lack legal recognition, while the Finance Ministry has yet to decide whether to adopt the tax department’s affidavit or file its own.
  • The court set a detailed hearing for the second week of December and signaled it is unlikely to rule before the December 31 compliance deadline.