Cummins India has received a favorable order from the Income Tax Appellate Tribunal (ITAT) dated December 4, 2025, securing substantial tax relief of ₹210.29 crores for Financial Year 2017-18. The tribunal's decision represents a significant victory for the capital goods manufacturer in its ongoing tax dispute with the Income Tax Department.

ITAT Order Details

The Income Tax Appellate Tribunal has granted comprehensive relief to Cummins India, with the order addressing multiple aspects of the tax dispute. The tribunal's decision includes granting relief on adjustments aggregating to ₹210.29 crores, while redirecting ₹13.11 crores to the Assessing Officer for revalidation and upholding a disallowance of ₹0.48 crores.

Company Response and Next Steps

Cummins India has disclosed that it is currently evaluating further action in relation to the disallowance of ₹0.48 crores upheld by the tribunal. The company made this disclosure under Regulation 30 of the SEBI Listing Regulations, demonstrating its commitment to transparent communication with stakeholders.

The company noted a delay in filing the disclosure, explaining that the physically signed order by ITAT has not yet been received. The disclosure was filed based on a copy of the order downloaded from the official ITAT website, with concerned teams analyzing the impact of the order.

Financial Impact and Strategic Significance

This favorable tribunal order provides Cummins India with substantial financial relief and improved cash flow position. The ₹210.29 crore relief amount represents a significant benefit that could enhance the company's financial flexibility and operational capabilities.

The resolution demonstrates Cummins India's effective legal strategy and compliance framework in handling complex tax matters. This development follows the company's earlier communications dated August 14, 2023, and December 19, 2023, indicating a prolonged legal process that has now reached a favorable conclusion for the company.

Cummins India has entered into a comprehensive Shareholders' Agreement and Energy Supply Agreement with Clean Max Yellowstone Private Limited on January 5, 2026, expanding its renewable energy investment commitment to ₹2.70 crores. This development follows the company's earlier completion of the first tranche investment of ₹8,780 for 878 equity shares on December 29, 2025.

Investment Agreement Details

The Shareholders' Agreement signed on January 5, 2026, outlines Cummins India's commitment to invest up to ₹2.70 crores in Clean Max Yellowstone Private Limited through multiple tranches. The company will maintain at least an 8.78% equity stake in the renewable energy firm.

Energy Supply Agreement

Simultaneously, Cummins India has entered into Energy Supply Agreements with Clean Max for procuring renewable power including solar, wind, and hybrid energy solutions for its manufacturing facilities and premises. This strategic move aligns with the company's sustainability objectives and operational efficiency goals.

Regulatory Compliance and Disclosure

Cummins India has filed the disclosure under Regulation 30 of SEBI Listing Obligations and Disclosure Requirements Regulations, 2015. The company confirmed that all relevant details provided in earlier intimations dated December 18, 2025, and December 29, 2025, remain unchanged, ensuring continued regulatory compliance. The disclosure has been uploaded on the company's website at www.cumminsindia.com .

Strategic Significance

This expanded investment framework represents Cummins India's strategic entry into the clean energy sector, positioning the company to establish group captive renewable power plants for its manufacturing operations. The dual agreement structure enables both equity participation in Clean Max's growth and direct access to renewable energy solutions, supporting India's clean energy transition while enhancing operational sustainability.