After securing a favourable judgment in the Tiger Global capital gains tax case, the tax department has said that not all tax disputes should be characterised as overreach or “tax terrorism”. Pending tax demands or withheld refunds in such cases should not automatically be viewed as arbitrary or coercive, officials said. Sources in the Central Board of Direct Taxes (CBDT) said many disputes arise from genuine differences in interpretation, particularly in evolving areas of tax law. “Final certainty emerges only when the highest court settles the issue. Until then, both the taxpayer and the tax administration are bound by due process,” a senior CBDT official said.