Case of DCIT vs District Mining Office, SC Judgement Dated 27th February 2026. The apex court held that compounding fees collected from illegal miners/transporters under the Chhattisgarh Minor Mineral Rules, 2015, being in nature of punitive fines do not constitute royalty or licensing fees for mineral rights. Thus it does not attract Tax Collected at Source (TCS) under Section 206C(1C) of the Income Tax Act.