Revised DTAA expands source-based capital gains taxation and lowers withholding burdens while enabling MAP and APA mechanisms.
The revised DTAA establishes source based taxation for capital gains on substantial shareholdings, reduces withholding tax rates on royalties/technical fees and interest to facilitate cross border investment, expands dependent agent Permanent Establishment rules, and provides exclusive residence taxation for international shipping income. It creates explicit access to the Mutual Agreement Procedure and bilateral Advance Pricing Agreements for transfer pricing disputes, provides for suspension of tax collection during MAP on security, updates Exchange of Information to international standards including bank information, adds assistance in collection, and inserts a Limitation of Benefits anti abuse article.

Import regulation for metal scrap: shredded scrap cleared freely; un shredded consignments subject to RMS and scanning requirements.
Shredded metal scrap may be cleared through all ports without a pre shipment certificate. Un shredded, compressed or loose scrap must follow DGFT guidelines and be cleared only at EDI ports with operational Risk Management System, subject to documentary or physical checks selected by RMS. Designated sea ports are to install Radiation Portal Monitors and Container Scanners by the prescribed deadline; until then scanning will occur at ports with existing facilities. Principal Commissioners/Commissioners may allow re warehousing to importer premises at importer's risk subject to RMS and scanning conditions. Instructions are effective immediately.

Simultaneous benefit prohibition clarified: pending cases of concurrent zero-duty EPCG and SHIS to be governed by the public notice.
Incorrect concurrent availing of Zero duty EPCG and SHIS arising from overlapping FTP/HBP wording was addressed by a Department of Commerce Public Notice, which now governs the resolution of pending cases. Following inter departmental review, Customs amended notifications to remove the FTP related bar on dual issuance, and stakeholders are invited to report implementation difficulties to the Customs office.

Bank Guarantee requirements for Advance License/EPCG imports demand unconditional renewal clauses and prescribed certified documentation.
Execution of bonds and Bank Guarantees for clearance under Advance License/EPCG schemes requires BGs with an unconditional self renewal clause and bank forwarding details for genuineness checks. BG exemption is conditional on a clean compliance record and certified proof of export performance or duty payment from designated authorities or professionals. Manufacturer exporters claiming concessional BG must submit certified registration, specified proof (export performance, duty payment or DGFT redemption/EODC) and installation certificates; non-registered manufacturers must provide equivalent council or professional certification and installation evidence, with post-verification where required.

Digital signature authentication on invoices: manual signatures are addressed and guidance issued, traders to follow prescribed procedures.
Authentication of invoices by digital signatures is governed by notified conditions, safeguards and procedures, and the Board's circular clarifies the interaction between digital authentication and manual signatures. Stakeholders are to follow the prescribed procedures; trade bodies must circulate the guidance and report any implementation difficulties to the jurisdictional Range or Divisional Office.

Taxpayer appreciation certificates issued to eligible taxpayers based on tax contribution and timely e filing/verification.
The Central Board of Direct Taxes issued a second round of Certificates of Appreciation to additional individual taxpayers, targeting those who filed returns within the due date and whose ITR V was received well before the 120 day submission period; the initiative distinguishes recipients by tiers based on tax contributed and encourages e filing and timely electronic or ITR V verification to qualify for acknowledgement.

Foreign direct investment liberalization for other financial services allows full foreign ownership via automatic or government routes with regulator conditions.
Foreign direct investment in Other Financial Services and NBFCs is permitted up to full ownership under the automatic route when activities are regulated by a financial sector regulator, subject to regulator- or government-imposed conditions including minimum capitalisation norms; unregulated or partly regulated activities may be allowed full foreign investment under the government approval route with conditions; statutory limits in specific Acts prevail; downstream investments remain subject to sectoral regulations and foreign exchange provisions.

Intimation under section 143(1) relaxed to permit late processing of refund claims with specified exclusions.
Administrative relaxation directs that valid non scrutiny returns claiming refund for specified assessment years, which were not processed within the statutory time for issuing intimation, be processed and intimations and consequential refunds issued expeditiously by a stated deadline. The relaxation excludes returns unprocessed under the special non processing provision and returns showing or likely to show a demand.

Import control of un shredded metallic waste and scrap: procedural conditions for sea port clearance under revised trade policy.
The Director General of Foreign Trade amends Public Notice No.38/ (2015-2020) by inserting a new paragraph (v) in Para 2.54 of the Handbook of Procedures (2015-2020) to set out conditions governing clearance of imports of un-shredded Metallic Waste and Scrap by sea ports, and replaces the wording HMS I and HMS II with un-shredded Metallic Waste and Scrap.

Tax exemption for land acquisition compensation extends to awards under RFCTLARR Act, ensuring non-taxability under income-tax law.
The tax authority clarifies that compensation exempted from levy of income-tax under the RFCTLARR Act shall also not be taxable under the Income-tax Act, 1961, even where the Income-tax Act contains no separate or specific exemption for that compensation, thereby addressing uncertainty on taxability of awards or agreements for compulsory acquisition of both agricultural and non-agricultural land.

Disclosure formats for listed insurance companies require regulator-prescribed quarterly reporting and continued newspaper-format compliance under listing rules.
Insurers listed on stock exchanges must submit quarterly financial results and segment-wise reports in formats prescribed by the insurance regulator for specified quarters; newspaper publication formats remain governed by SEBI-prescribed formats with possible additional regulator-prescribed disclosures; other requirements of earlier SEBI circulars continue to apply.

Rebate of State levies on garment exports: opt in EDI claims, FOB based calculation, payment subject to textiles budget.
ROSL establishes an opt in, item level rebate administered by CBEC alongside Duty Drawback for garments (Chapters 61/62) from specified export dates, with average rebate rates and per unit caps under two schedules. Exporters must declare eligibility, not claim other refunds, and select an EDI scheme code to claim. Rebate is calculated on FOB value, paid subject to Ministry of Textiles budget and EGM filing, and recovery follows Drawback processes with the Textile Commissioner empowered to recover wrongful payments as arrears of land revenue.

Refund of Additional Duty: AEO tiering mandates expedited claim processing timelines for accredited importers under the merged programme.
Refunds of 4% Additional Duty for qualifying importers are now administered under the merged three tier Authorised Economic Operator programme; the ACP pre audit waiver is discontinued and refund claims must be sanctioned within the expedited timeframes prescribed for AEO tiers, with other existing refund provisions remaining applicable.

Registration category requirement prompts jewellery manufacturers to amend registration so they can file the modified ER-8 return.
The modified ER-8 return is being implemented on the ACES portal with a ticker prompting jewellery manufacturers to amend registration to the Business Category Jewellery; divisional offices must prioritise processing of such amendment requests and physical verification is not required at original registration or amendment.

Rebate of State Levies on garment exports: optional scheme requiring exporter declaration and integration with duty drawback process.
Rebate of State levies on garment exports is an optional CBEC-administered scheme integrated with Duty Drawback: exporters must opt in via item-level claim/declaration on shipping bills, rebate is calculated on FOB value using schedule rates and per-unit caps (with special rates for duty-free imported fabric), and payments are processed in parallel with Drawback subject to Ministry of Textiles budgetary allocation. Overpayments, non-realised proceeds, and wrongful declarations follow Drawback-like recovery procedures with coordination between CBEC and the Textile Commissioner.

Financial disclosure requirements mandate comprehensive audited InvIT financials, projections, NDCF framework and detailed related party reporting.
Offer documents must present audited financial information for the last three completed financial years and any necessary interim period (or combined financial statements if InvIT history is insufficient), prepared under Ind AS and adjusted for prior period errors, accounting policy changes and auditor reported modifications. Required statements include balance sheet, profit and loss/income and expenditure, changes in unitholders' equity, cash flows, net assets at fair value, total returns at fair value, and specified notes; additional mandatory disclosures cover project wise cash flows, EPU, contingent liabilities, commitments, related party transactions, capitalisation, debt history, auditor reliance rules, NDCF framework, projections with auditor and manager certification, MDA, and combined statement principles.

Rupee Drawing Arrangement limit capped per transaction; authorised banks must ensure compliance under FEMA and regulatory guidance.
The circular caps permitted trade transactions under the Rupee Drawing Arrangement at fifteen lakh rupees per transaction, directs Authorised Dealer Category I banks to implement this ceiling while other related instructions remain unchanged, notes the amendment in the Foreign Exchange Management (Manner of Receipt and Payment) Regulations, 2016 with an update to Master Direction No.2, and issues the directions under Sections 10(4) and 11(1) of the Foreign Exchange Management Act, 1999.

Foreign investment in Other Financial Services allowed on full automatic route with regulator-specified conditions; government route for unregulated activities.
Full foreign equity participation in Other Financial Services is permitted under the automatic route when activities are regulated by a financial sector regulator, subject to regulator- or government-specified conditionalities including minimum capitalisation norms; statutory limits govern activities specifically regulated by an Act. Unregulated or partly regulated financial services require government approval for foreign investment, and downstream investments must comply with sectoral regulations and the Principal Regulations.

FVCI registration allows direct investment in startups and specified sectors without prior Reserve Bank approval.
Registered FVCIs may invest without RBI approval in equity, equity-linked or debt instruments of unlisted Indian companies in specified priority sectors, in qualifying startups, and in units of SEBI-registered Venture Capital Funds or Category I AIFs; downstream investments by recipient funds must comply with Schedule 11 downstream investment provisions.

Composite foreign investment cap clarified to aggregate direct and indirect investments, with compliance duties on the investee company.
The circular mandates that the composite limit/cap on foreign investment be calculated as the aggregate of all direct and indirect foreign investments, with equity resulting from debt conversion counted within the cap and certain debt-like instruments excluded. It defines Total foreign investment as the sum of direct and indirect investments, assigns the compliance obligation to the investee company, permits portfolio investment up to a prescribed threshold without government approval provided no change of ownership leading to control by non-residents occurs, and allows permitted foreign investment routes in LLPs, automatic-route sectors, NRI non repatriation investments deemed domestic, and share-swap arrangements subject to specified valuation and sectoral conditions.