Bombay HC quashes ₹79.7 crore GST demand on Dharma Productions, Dharmatic

The Bombay High Court ruled that licensing cinematographic film copyrights is not taxable as IT software, even when content is supplied digitally or on hard disks. The order overturns a ₹79.7 crore GST demand covering FY18 to FY21.

— Source publishedWed, 23 Sept, 2026, 15:51 IST·First seen Wed, 23 Sept, 2026, 16:03 IST·Source ET Small Business

What happened

Bombay High Court quashed a Rs 79.7 crore GST demand on Dharma Productions and Dharmatic Entertainment, ruling that cinematographic film copyright licensing is

Key facts

  • Rs 79.7 crore
  • 18% GST
  • 12% GST
  • FY 2017-18 to FY 2020-21
  • September 10

What changed

Bombay High Court quashed a Rs 79.7 crore GST demand on Dharma Productions and Dharmatic Entertainment, ruling that cinematographic film copyright licensing is not IT software even when content is delivered digitally or via hard disks.

Why this matters

The Bombay High Court ruling reduces GST classification risk for media operators licensing film content digitally, supporting cleaner tax treatment for distribution revenues.

What to watch

  • Revenue department filing an appeal or obtaining a stay.
  • CBIC or state GST clarification on copyright licensing versus software licensing.
  • Similar rulings from other High Courts or the GST Appellate Tribunal.
  • A rise in refund claims or withdrawal of comparable GST demands by media companies.
  • Changes in licensing agreements that bundle content rights with streaming, DRM, analytics, cloud delivery or platform access.