Beyond One Nation, One Tax: Constitutional Limits in Mohit Minerals

The Supreme Court’s ruling in Union of India v. Mohit?Minerals Pvt?Ltd (hereinafter “Mohit Minerals”) marks a pivotal moment in India’s GST jurisprudence, scrutinising both the design of the “One?Nation,?One?Tax” model and the constitutional limits of fiscal power. The Court struck down the IGST levy on ocean freight in CIF contracts, holding that a reverse charge impost created solely by delegated legislation contravened the concept of composite supply and Article?265’s requirement of lawful authority. Simultaneously, it characterised the GST?Council as a recommendatory body under Article?279A and affirmed that Parliament and State Legislatures possess simultaneous law-making power under Article?246A, rejecting the notion of binding “pooled sovereignty.” This paper uses Mohit?Minerals to explore three enduring constitutional boundaries: the limits of delegated taxation, the enforceability of fiscal federalism, and the balance between uniformity and autonomy in the post-101st?Amendment order. It shows how the judgment restrains executive tax innovations, reinterprets “cooperative federalism” as equal legislative participation, and reanchors GST accountability in representative institutions rather than technocratic consensus. Ultimately, Mohit?Minerals redefines India’s fiscal federalism by reaffirming legislative supremacy and restoring the constitutional balance between efficiency and democracy.