Rubicon Research Subsidiary AdvaGen Pharma Receives ₹4.19 Crore Tax Demand Notice
Rubicon Research Limited's material subsidiary AdvaGen Pharma Ltd received a ₹4.19 crore tax demand notice from Mumbai Income Tax authorities for assessment year 2021-22. The demand arises from denial of DTAA exemption on ₹10.04 crore income under India-US tax treaty. The subsidiary plans to appeal before ITAT while seeking a stay on the demand, with the company expressing confidence in its legal position.
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Rubicon Research Limited has informed stock exchanges about a significant tax demand notice received by its material step-down subsidiary AdvaGen Pharma Ltd, USA. The company disclosed this development in compliance with SEBI listing regulations on January 6, 2026.
Tax Demand Details
The subsidiary received a demand notice under Section 156 of the Income-Tax Act, 1961, from the office of Deputy Commissioner of Income Tax, Mumbai, on January 5, 2026. The notice details are summarized below:
| Parameter | Details |
|---|---|
| Total Demand Amount | ₹4,18,84,613 |
| Assessment Year | 2021-22 |
| Income Subject to Tax | ₹10,03,57,800 |
| Issuing Authority | Deputy Commissioner of Income Tax- INT Tax Circle 1(1)(1), Mumbai |
| Date of Receipt | January 5, 2026 |
Reason for Tax Demand
The substantial tax demand stems from the denial of a Double Taxation Avoidance Agreement (DTAA) exemption on income of ₹10.04 crores. The tax authority concluded that the 'Make Available' clause under the India-US DTAA was applicable to AdvaGen Pharma's case, resulting in the rejection of the exemption claim.
Company's Response Strategy
AdvaGen Pharma Ltd has outlined a two-pronged approach to address the tax demand:
- Appeal Filing: The subsidiary will file an appeal before the Income Tax Appellate Tribunal (ITAT)
- Stay Request: Parallel request to the Assessing Officer to stay the demand pending the ITAT decision
- Legal Confidence: Based on advice from tax advisors, the company believes its position is strong and remains confident about the merits of the case
Financial Impact
The expected financial implications on the listed company are equivalent to the total demand payable of ₹4,18,84,613. This represents a significant amount that could impact the subsidiary's financial position if the appeal is unsuccessful.
Regulatory Compliance
Rubicon Research Limited disclosed this information in compliance with Regulation 30(6) and 30(13) of SEBI Listing Regulations, along with relevant SEBI circulars. The company has declared that all information provided is true, correct, and complete to the best of their knowledge and belief.
Historical Stock Returns for Rubicon Research
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -3.25% | -1.53% | +5.43% | +6.71% | +6.71% | +6.71% |


























