Maximum marginal tax rate: trustees taxed at the highest rate when beneficiary shares are indeterminate or include business profits.
Trustees are liable to tax at the maximum marginal rate where income includes profits and gains of business or where beneficiaries' shares are indeterminate; such "relevant income" is chargeable at the maximum marginal rate. Exceptions allow slab-rate taxation where the trust is a testamentary trust exclusively for a dependent relative and is the only such trust, where beneficiaries lack taxable income above exemption limits or are beneficiaries under other private trusts, where certain pre-specified bona fide family or employee funds apply, and where provident or pension funds benefit employees. (AI Summary)

Composite supply principle: printing services for educational institutions treated as principal supply and exempt from GST.
Supply of secure printed materials to educational institutions, when the printing service is the principal element and provided using the supplier's paper and ink, constitutes a composite supply treated as printing services and is exempt from GST under Sr. No. 66(b)(iv) of the Service Exemption Notification; by contrast, isolated sale of printed goods would be classifiable under the printed matter heading and subject to GST. (AI Summary)

GST on online gaming taxed at entry stage on deposits reduces playable value and increases burdens on platforms.
The Council decision imposes GST at 28% on amounts paid, payable, or deposited with online gaming suppliers at the entry stage, replacing taxation of platform fees or GGR. This removes the distinction between games of skill and chance for GST incidence and shifts the taxable base to player deposits, increasing tax burdens on platforms and reducing playable value for participants. The note questions whether deposits constitute consideration for supply, arguing that platform revenue is the fee and deposits are held for play rather than belonging to the operator. (AI Summary)

Minority-owned entity treatment separates minority-owned subgroup from group ETR blending, altering top-up tax allocation.
The GloBE Rules treat Minority Owned Constituent Entities (UPE owns 30% or less but retains control) and Minority Owned Sub Groups as separate for jurisdictional ETR calculations: their Adjusted Covered Taxes and GloBE Income are excluded from the remainder of the MNE Group, so ETR and top up tax may be computed separately (entity level if not a subgroup). These provisions prevent amounts attributable to non group owners from being blended, while Investment Entity rules take priority where applicable. (AI Summary)

E-invoicing compliance: invoice reference number required for notified taxpayers, failure renders invoice invalid and affects input tax credit.
Notified taxpayers must upload invoice particulars in FORM GST INV-01 to the Common GST Electronic Portal to obtain an Invoice Reference Number (IRN); invoices issued by notified persons without an IRN are not treated as invoices, which can prevent fulfilment of input tax credit conditions. Compliance with the electronic issuance procedure replaces the triplicate/duplicate physical-copy requirement. The note summarises applicability, excluded supplies, aggregate turnover computation, IRN and QR code contents, generation modes, cancellation limits, and related enforcement concerns. (AI Summary)

Intermediary service classification affects refund entitlement; correct place of supply hinges on service nature, not recipient presence.
The court found that the service agreement's operative scope did not show procurement or facilitation of third party supplies and that rendering services on behalf of another does not automatically make a supplier an intermediary; it also held that the services did not require the recipient's physical presence in India for place of supply purposes, and that authorities had proceeded beyond the scope of the show cause notice, warranting reconsideration. (AI Summary)

Prosecution under IPC remains permissible even where GST law prescribes punishment; IPC charges for forgery and fraud can proceed.
The High Court held that where a trader produced and used invoices from a non existent supplier, failed to produce books, had ITC rejected and GST registration cancelled, the Revenue's characterization of the activities as fraudulent justified initiation of prosecutions under IPC offences for conspiracy, criminal breach of trust, cheating and use of forged documents; prosecution under the IPC is not barred simply because the GST statute also prescribes penalties or punishment. (AI Summary)

Interest on delayed tax payments cannot be levied absent explicit statutory provision, limiting extra-duty interest and penalties.
Interest and penalty cannot be imposed on additional customs levies not legally linked to basic customs duty without an express statutory mandate; Section 28AB governs interest on basic customs duty only and is not incorporated into other fiscal enactments, so levies of interest or penalties on CVD, SAD, surcharge or IGST require clear legislative authority, and affected taxpayers may seek refunds subject to limitation. (AI Summary)

De minimis exclusion under GloBE Rules can deem top up tax zero where jurisdictional revenue and net income are negligible.
A de minimis exclusion under Article 5.5 allows an MNE to elect annually to deem top up tax zero for all constituent entities in a jurisdiction where three year average GloBE revenue and net GloBE income/loss fall below specified thresholds. The exclusion relieves the MNE from calculating adjusted covered taxes, ETR and top up tax for that jurisdiction for the year, operates on a rolling annual basis with pro rata treatment for unequal fiscal years, includes minority owned entities in jurisdictional aggregates, and excludes stateless and investment entities from the threshold tests. (AI Summary)

Hostel accommodation exemption lapsed mid July; low charge student hostel services became subject to GST under the amended notification.
The AAR found that student hostel accommodation supplied below the per day threshold from August 1, 2021 until July 18, 2022 was exempt under the service exemption notification as renting of residential dwelling (SAC 996322). The AAR treated the service as residential hostel accommodation and observed that a subsequent amendment to the rate notification removed the qualifying language around the threshold, causing similar low charge accommodation to become taxable under the amended notification after mid July. (AI Summary)

Aadhaar authentication for GST registration: biometric and facilitation centre verification required for identified risky applicants from specific jurisdictions.
Rule 8(4A) now mandates Aadhaar authentication for GST applicants and, for portal identified risky cases, biometric Aadhaar authentication, applicant or representative photography, and in person original document verification at Commissioner notified Facilitation Centres before registration is complete. Notifications also continue an aggregate turnover exemption from annual return filing, permit consent based sharing of GST data with RBI regulated Account Aggregators, allow limited enrolment for non GST persons to supply goods via e commerce under PAN validation, centralise adjudication of notices for distinct GSTINs in a single Central Tax office, and restrict export with tax benefits for specified goods. (AI Summary)

GST on joint venture services: supply by co venturer to the joint venture treated as taxable supply.
The AAR found that a joint venture constituted a distinct person because the parties agreed to share risk and revenue; consequently, services provided by a co venturer to the joint venture-input and managerial services in return for a share of profit-constitute taxable professional, technical and business services and are liable to GST under the service rate notification. The author disputes this, arguing that an owner's profit share as an actionable claim should not be treated as supply subject to GST. (AI Summary)

Income tax compliance ensures timely filing, PAN identification, TDS and audit obligations to avoid penalties.
Taxpayers must obtain and quote a Permanent Account Number, file accurate income-tax returns within prescribed timelines, classify income by source for correct tax treatment, and comply with collection mechanisms such as Tax Deducted at Source. Those with significant liabilities must pay advance tax during the year. The tax administration may conduct assessments and audits to verify returns; businesses and NRIs have parallel obligations including books of account, statutory audits, and reconciliation of indirect-tax records. Noncompliance attracts interest, penalties and potential legal proceedings. (AI Summary)

Battery charging service classified as taxable service, with charging fees treated as service consideration and taxed accordingly.
Charging of electric vehicle batteries at public charging stations is treated as a battery charging service, not as sale or distribution of electricity, because the station consumes electricity on its premises to convert electrical into stored chemical energy. Fees billed as an "Electric Vehicle Charging Fee," including energy and service components, constitute consideration for that service, require issuance of tax invoices, and are taxable as a service under the applicable service classification. (AI Summary)

Limitation on departmental appeal: only points arising from the adjudication order may be pursued on appeal.
Departmental appeals via the Commissioner's review are limited to points arising out of the adjudication order; a ground not raised in the Show Cause Notice was not considered in the order and therefore does not arise out of it. Authorisation to appeal on issues absent from the SCN or the adjudication is ineffective, and appeals founded on such unauthorized grounds are liable to be invalidated. (AI Summary)

GST exemption for imported rare-disease medicines limited to personal imports, pending formal notification and facing practical constraints.
GST Council decisions grant IGST exemptions for specified imported health-care goods-an identified oncology biologic when imported for personal use; medicines and FSMP for treatment of rare diseases under the national policy; and FSMP imported by centres of excellence or recommended by them-subject to a CBIC notification which remains pending. The article notes the exemptions are limited by personal-import conditions, import licensing challenges for products already registered domestically, and exclusion of commercially available approved domestic products, and recommends broader extension of duty and GST relief to lifesaving and rare-disease medicines. (AI Summary)

Tariff classification of solar home lighting systems under 9405 confirms GST applicability at the prescribed goods rate.
The assembled solar home lighting system-comprising photovoltaic modules, batteries, charge controllers and LED lamps-best fits the specific description for lamps and lighting fittings under tariff heading 9405, and accordingly aligns with the goods rate notification entry covering solar lamps and solar lighting products, which determines the HSN reporting and GST treatment for such systems. (AI Summary)

TCS increase on foreign remittances raises compliance costs and may shift spending domestically, while raising refund and double-taxation concerns.
The amendment substantially increases Tax Collection at Source on remittances under the Liberalized Remittance Scheme, to be collected by authorized dealers or sellers at the time of receipt or debit. Remittances for medical treatment and education receive a limited exemption up to a prescribed threshold and a lower collection rate beyond that threshold. The change aims to curb outward spending and raise revenue but raises concerns about legislative intent, informal remittance channels, blocked refundable credits, potential double taxation, and tensions with international remittance-cost commitments. (AI Summary)

Registration threshold: suppliers owe GST only from the date they become liable to register, not before.
GST liability to pay is limited to persons who are registered or liable to be registered; registration and payment obligations commence from the date a supplier becomes liable to register. Procedural provisions, including the limited scope for issuing revised invoices, apply only from that effective registration date, indicating tax is payable only on supplies occurring after the registration-liability date. Because unregistered suppliers cannot legally collect tax, requiring payment for earlier turnover that was not charged would be inconsistent with the statutory scheme. (AI Summary)

Finality of approved resolution plan: sanctioned plans are binding and cannot be altered post approval, including trademark ownership shifts.
Section 31 mandates approval of a resolution plan by the adjudicating authority where the committee of creditors' approved plan satisfies statutory requirements and provides for effective implementation, rendering the plan binding on the corporate debtor and stakeholders; Section 60 vests jurisdiction in the National Company Law Tribunal over corporate insolvency and related claims and excludes moratorium periods from limitation computations. Judicial guidance reinforces that an adjudicating order cannot modify an approved resolution plan: the approved plan may grant perpetual exclusive use rights to the successful resolution applicant but does not effect post-approval transfer of ownership, and any adjudicatory declaration altering those allocations constitutes an impermissible modification. (AI Summary)