Treaty benefits for foreign institutional investors to be adjudicated promptly, with securities-related claims subject to expedited decision.
The Central Board of Direct Taxes instructs that claims by Foreign Institutional Investors for treaty benefits under relevant Double Taxation Avoidance Agreements in respect of income from securities must be decided expeditiously, with decisions to be taken within one month from the date the claim is filed, and the directive must be communicated to all concerned for strict compliance.

Tax deduction at source exemption for corporations with income exempt under section 10(26BBB) affirmed under existing TDS circular.
Corporations covered by section 10(26BBB) that have unconditional income exemption and no statutory obligation to file income tax returns are entitled to the benefit of the prior administrative position in Circular No. 4/2002; accordingly, tax deduction at source need not be made on payments to such corporations.

Suspension of tax collection during MAP allows abeyance of recovery upon confirmation of MAP and furnishing prescribed bank guarantee.
Suspension of tax collection during Mutual Agreement Procedure under the India-UK MoU permits assessing officers to keep recovery in abeyance where the Foreign Tax and Tax Research Division confirms MAP pendency and the taxpayer furnishes a model-format bank guarantee. The bank guarantee is treated as sufficient arrangement for extension under Section 220(3) for the MAP duration, is capped at the additional tax demanded (with statutory interest adjustments), may be drawn only after notice between Competent Authorities, and is subject to renewal, substitution and specified termination events; suspension also covers related interest and penalties.

PAN migration to new jurisdiction required; regional webpages must publish updated jurisdiction information and provide assistance.
Completion of PAN migration to revised wards, circles and ranges after restructuring is mandated so taxpayers can identify their correct jurisdiction for filing returns. Regional officers must publish updated jurisdictional boundaries and associated documents on their regional pages of the national income tax website and provide a clear "Jurisdiction" access point. Systems training and upload credentials have been provided to nominated officers; a common format and guide will be circulated and designated contacts are available for technical assistance. This activity is a top-priority administrative task to prevent taxpayer inconvenience.

Long-term capital asset classification altered; roll-over of fixed maturity mutual funds isn't a transfer, taxation on redemption.
The Finance (No.2) Act, 2014 extended the holding period for non-equity mutual fund units to qualify as long-term to over thirty-six months. Rollovers of closed-ended Fixed Maturity Plans under the specified rollover and disclosure regime do not create a new scheme and therefore do not amount to a transfer; no capital gains arise at the time of rollover. Capital gains will arise only upon redemption or when a unitholder opts out and effects transfer, at which point the amended holding-period rule determines short term or long term character.

Interest under wealth-tax rules not chargeable on self-assessment tax paid before the return filing due date.
The Board directs that interest under the Wealth-tax Act shall not be chargeable on amounts of self-assessment tax paid by an assessee before the due date for filing the return of net wealth, aligning the administrative position with the reasoning applied by the Supreme Court to analogous income-tax interest provisions.

Information Security Committee established to ratify and enforce IS policies and oversee incident management and disciplinary action.
Constitution of an Information Security Committee within the Central Board of Direct Taxes, chaired by Member (IT) with CIT (M&TP) as Chief Information Security Officer; the ISC ratifies and ensures implementation of Information Security Policies and Procedures, conducts management and security reviews, initiates corrective security reviews, and oversees disciplinary action, while the CISO prepares and communicates ISPP, manages incident detection and response, provides employee security training, and reports security status and violations to the ISC.

Taxpayer service centre setup: CCITs to propose five ASK sites, determine node needs and submit budgeted proposals promptly.
Directs Principal CCITs to recommend five buildings for setting up Aayakar Sewa Kendras during 2015-16, prioritising government owned or long term rented premises and convening a Local Implementation Committee. CCITs must determine required service nodes per building using annexed yardsticks tied to DAK and paper returns workload (single ITO stations get one node, plus a "May I Help You" node) and submit node requirements with budget estimates based on the annexure's cost norms within the timeline specified in the letter.

Source rule of taxation affirmed: indirect transfer applies to transactions transferring underlying Indian assets, not foreign dividends.
The circular clarifies that Explanation 5 applies where a transaction in shares or interests in a foreign entity effects the direct or indirect transfer of underlying assets located in India, thereby creating an Indian economic nexus and rendering gains taxable in India. It further clarifies that declaration and payment of dividends by a foreign company, even if the shares derive substantial value from Indian assets, do not constitute such a transfer and therefore are not deemed to accrue or arise in India under the Explanation.

March residual transactions: banks must segregate and report March receipts separately to ensure accounting in the same financial year.
Banks must treat collections realized on or before March 31 as transactions of the current financial year and report them as March Residual Transactions in April up to April 15. Nodal/Focal Point branches shall segregate and serially mark separate main scrolls for March Residual transactions and separate scrolls for April transactions, forward daily summaries and separate Daily Memos to the Link Cell for settlement with the Central Accounts Section, and ensure receiving branch accounts through March 31 are not commingled with April transactions.

Tax Deduction at Source compliance: follow up with banks and states to ensure timely remittance and reporting.
Directs tax administrators to pursue compliance from banks to remit tax deducted during March in that month and requests state authorities ensure proper collection of Tax Collected at Source on specified leases, licences and contracts; requires follow-up with assessed banks and state governments and submission of a compliance report to Member (Revenue) by month-end.

Correction of Demand: central action plan mandates verification and certification timelines for assessment, TDS and appellate processing.
Central Action Plan prescribes time bound operational tasks for tax administration: correction and certification of demands (including verification of disputed demands, crediting prepaid taxes shown in Form 26AS, effecting appellate orders, disposing rectification applications and certifying CPC demands where notices under section 245 apply), prioritised uploading and tagging of manual TDS demands and unconsumed challans, completion of post survey enquiries with issuance of notices under sections 143(2)/148, audit reconciliations and settlement of internal audit objections, International Taxation verifications of selected 15CA cases and Transfer Pricing comparable searches, and supervisory monitoring, APAR submission and exemption database updates by senior commissioners.

Responsibility of Standing Counsel: ensure court directions are obtained, pursued with CIT, and escalated if unresolved.
Standing Counsel must actively obtain information called for by a court, secure compliance with court directions through the concerned CIT, and if unresolved, immediately escalate the matter to the CCIT. Instruction No. 3/2012, para 8.5 requires counsel to keep the CIT informed of important developments, and counsel cannot absolve themselves of the duty to ensure High Court directions are complied with; regional offices must ensure strict compliance and factor noncompliance into performance evaluations.

Duty of CIT to assist Departmental Counsel ensures prompt instructions, briefings, and coordination in appellate litigation.
The circular reiterates that the CIT bears responsibility to ensure prompt assistance to Departmental Counsel: attend to requests for instructions or clarifications, brief counsel, provide scrutiny reports for High Court appeals, and personally involve in cases with intricate factual or legal issues or significant revenue stakes. It further mandates a High Court Cell at each station to obtain daily particulars of cases heard from Standing Counsel and promptly transmit summaries to the concerned CIT, with adverse notice against officers for non-compliance.

Processing of time-barred returns via Online TMS enables AOs to address PAN-related system failures under defined conditions.
Two distinct Online TMS workflows permit Assessing Officers to process time barred returns that cannot be handled in AST due to PAN-related system issues. Category 1 covers genuine PAN cases with technical or jurisdictional impediments and allows online tax credit and later integration into AST by the PAN jurisdiction AO after deletion from AST. Category 2 covers invalid or mismatched PANs, disallows online tax credits and refunds, retains processing data in standalone form, and requires the AO to record reasons and attempt PAN correction.

Data migration integrity: correct AIS Old AO flags and hierarchy to enable ITBA rollout and refund banker configuration.
ITBA will replace the legacy ITD application, expanding coverage to all departmental functions via single sign on and role based access; accurate AIS data is required. Identified defects include Old AO flagging errors, incomplete or inaccurate hierarchies, and refund banker misconfigurations. RCCs must update the supplied "AIS_Verification.xls" to mark AO Type as Current or Old, populate destination AO fields, flag old AOs in AIS, assign employee IDs, complete hierarchy entries, update Refund Banker Requirement, submit jurisdiction orders for uniformity, and send refund banker enablement requests to DIT(S)-2 to permit Directorate of Systems to finalise configurations for ITBA rollout.

Time-barred return processing: limited online TMS allows constrained handling when PANs are absent or invalid.
Online TMS (category 2) permits limited processing of time-barred returns for foreign technicians where PAN is absent, invalid, or name mismatch exists; it disallows system crediting of TDS and OLTAS challans and precludes refunds for cases without valid PANs. Use requires the Assessing Officer to record the compelling reason and to have initiated communication to obtain or correct PAN data; standalone TMS remains available for other contingent cases.

Refund caging prevents PAN migration; AOs may block refunds or complete caging to enable PAN transfer.
Non-migration of PANs due to pending refund caging is addressed by procedural rules permitting PAN migration where active AOs either complete caging after verification or block refunds via the AST "Block Refund" function; refunds blocked by originating AOs under the confirmation procedure remain blocked and cannot be unblocked by destination AOs, while refunds blocked after verification of non-existence of manual refunds may be unblocked by the destination AO after due verification and completion of caging. OLD-flagged AOs or inactive AOs follow migration rules that transfer pending caging to destination AOs for completion.

Exclusive tax bench requires daily cause list monitoring and immediate departmental readiness for short notice tax hearings.
A bench constituted to deal exclusively with tax matters requires departmental officers to monitor the Supreme Court cause list daily, prepare for listed matters and brief counsels on short notice, ensure successors are informed during absences, and prioritize requests from the Directorate of Legal & Research through a designated Nodal Officer for coordination and clarifications.

Compounding of TDS/TCS offences permits separate applications by company and responsible directors, with directors paying a reduced portion of the company fee.
The Board clarifies that where corporate entities are prosecuted for TDS/TCS defaults, only those officers whose responsibility or consent/connivance/neglect is established are to be proceeded against. The company and each prosecuted director/partner must file separate compounding applications; each director/partner may be charged a compounding fee equal to ten percent of the fee determined for the company. Director/partner compounding applications will be entertained only after the company has applied and its case is found fit for compounding.