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2025 (4) TMI 2253
Case Laws Income Tax
Uncorroborated loose-paper notings cannot alone sustain additions for unrecorded income or investment where underlying transactions remain unidentified.
Section 14A disallowance cannot be sustained by relying on interest expenditure that was not claimed, notwithstanding exempt dividend income. Additions for unrecorded profit and out-of-books property investments require corroborative evidence; bald loose-paper entries that do not identify the land, seller, date or nature of transactions are insufficient, particularly where no evidence of purchase or development exists. Receipt of shares under a documented gift was not taxable under Section 56 for the relevant year because the relied-on amendment applied only from 1 January 2009. The disputed additions for the three assessment years were accordingly deleted.

2025 (4) TMI 2254
Case Laws Income Tax
Completion-of-work revenue recognition prevents duplicate taxation of incomplete real-estate project profits and preserves capital-gains treatment for fixed assets.
Work-in-progress previously disclosed and accepted on scrutiny cannot support a recast trading account where books have not been rejected; the related addition was deleted. For incomplete real-estate projects, consistently applying the completion-of-work method requires profit recognition in the relevant years, and an estimated gross-profit addition in an intervening year would result in double taxation; those additions were deleted. Profit from sale of a flat recorded as a fixed asset, rather than stock-in-trade, is taxable as capital gains and not business income. The deletions concerning work-in-progress, project profits and the flat sale were sustained.

2025 (4) TMI 2255
Case Laws Income Tax
Reassessment after limitation fails without fresh material or alleged failure of full and true disclosure.
Reassessment initiated after four years requires fresh tangible material supporting a belief that income escaped assessment and an allegation that the assessee failed to make full and true disclosure of material facts. Examination of an increase in capital, without new material before the Assessing Officer, does not meet the jurisdictional requirement for reopening a scrutiny assessment. In the absence of an allegation linking escapement to inadequate disclosure, the conditions for reassessment were not satisfied. The reassessment and consequential assessment were quashed.

2025 (8) TMI 1881
Case Laws Income Tax
Consequential assessment scope bars new bad-debt claims not arising from matters remitted in revision proceedings.
Consequential assessment following revision under section 263 is limited to matters within the revision order. Additional claims for bad debts written off and for provision for bad and doubtful debts, where they do not arise from the consequential assessment, cannot be admitted in those proceedings. The claims were therefore rejected as outside the permissible scope of the consequential assessment.

2025 (8) TMI 1882
Case Laws Income Tax
Search assessment evidence requires corroboration and identifiable taxable events; cryptic seized records alone cannot support additions.
Search additions require seized material that identifies the taxable event, parties, transaction nature and purpose, and relevant assessment year; vague loose sheets and unverified employee statements cannot, without corroboration, support unexplained-income additions. Presumptions for seized records establish genuineness but do not permit speculative readings of cryptic entries. Payments recorded in books or through banking channels are not unexplained, and entries must be assessed, if at all, in the correct assessment year; unsupported expenditure may remain taxable. A sales abstract reconciled with books and bank receipts does not establish suppressed turnover. Income and related expenditure or investment arising from the same material may be telescoped to prevent double taxation. Mere receivables, cheques, or promissory notes without linkage or actual accrual do not establish taxable income.

2025 (10) TMI 1489
Case Laws Income Tax
Withdrawal of an appeal against a final assessment order resulted in dismissal after no serious objection was raised.
Withdrawal of an appeal challenging a final assessment order was sought through written submissions after the hearing notice had been duly served and no appearance was made for the assessee. With no serious objection to withdrawal, permission was granted and the appeal was dismissed as withdrawn. The procedural result concerns final assessment proceedings.

2026 (3) TMI 1772
Case Laws Income Tax
Unexplained cash credits cannot be sustained where documented unsecured loans establish lender identity, creditworthiness, genuineness, and subsequent repayment.
Unsecured loans supported by lender confirmations, audited accounts, corporate records, bank statements, ledger accounts, interest-payment details and tax deduction evidence may satisfy the requirements for proving lender identity, creditworthiness and transaction genuineness. Compliance by creditors with statutory information notices and subsequent repayment of loans with interest further supports the evidentiary record. Where the revenue does not identify defects in this documentation, establish that the lenders or transactions are accommodation entries, or undertake effective further enquiry, an addition for unexplained cash credits under Section 68 is unsustainable.

2026 (8) TMI 1859
Case Laws Income Tax
Section 12AB renewal permits charitable institutions without formal founding documents when reliable evidence proves their public charitable existence.
Section 12AB renewal cannot be refused solely because a charitable educational institution lacks a formal trust deed or memorandum of association. Rule 17A accommodates institutions established otherwise than under an instrument. Public-trust registration, sustained educational operations, earlier income-tax recognition, and records evidencing creation and continuing existence may establish charitable status. In the absence of adverse findings on charitable objects, genuineness of activities, or statutory compliance, such evidence supports continued registration as an existing public charitable trust.

Customs, DGFT & SEZ
Dated:- 12-10-2026
Effective CETA implementation depends on accessible tariff schedules, rules of origin and documentation guidance, together with support for businesses navigating tariff reductions, customs procedures, regulatory requirements and procurement opportunities. Committees, working groups and a joint utilisation review are intended to receive business feedback, address implementation issues and improve use of the agreement. Sectoral round tables, delegations and exhibitions, along with mutual recognition and capacity-building, are envisaged to support new exporters, product lines, investment and partnerships.

Customs, DGFT & SEZ
Dated:- 12-10-2026
CETA implementation includes annual exchanges of utilisation data and business feedback, beginning one year after entry into force, to identify barriers to preferential tariff use and support needs. Committees, working groups and government contact points will be established to maintain operational implementation and address emerging issues. Certificates of Origin issued through self-certification support claims for preferential treatment, while tariff-rate quotas apply to specified vehicle imports.

Notification No. 44/2026-27 Dated:- 12-10-2026 Foreign Trade Policy
Prepared Culture Media exports under ITC(HS) Code 38210000 remain free, with a certification procedure available where an importing country requires shipment clearance or health certification. CAPEXIL is to issue a consignment-wise Shipment Clearance Certificate identifying the exporter, registered plant, product, quantity, invoice, loading port, and destination. After shipment, a Health Certificate is to be provided to the buyer and, where required, jointly issued by CAPEXIL and the Regional Animal Quarantine Officer.

Schedule row 6 now permits a three-year post-Class XII graduation with at least 60% marks, subject to a 50% threshold for reserved SC/ST/PwBD posts, or specified postgraduate and professional qualifications. It prescribes conversion of aggregate grade points to percentages, including normalisation of non-10-point scales, and recognises qualifying foreign postgraduate credentials supported by specified equivalence certificates. The amendment removes the desirable requirement of two years' post-enrolment advocacy experience for Grade A legal-stream officers. It also revises approved postgraduate disciplines for the relevant specialist stream, adding areas such as public policy, securities markets and capital markets. The changes take effect upon Official Gazette publication.

Portfolio managers must register as body corporates, maintain prescribed net worth, infrastructure, qualified personnel and continuing fit-and-proper status, while meeting client-grievance, disclosure and change-in-control obligations. Client arrangements require written investment agreements, pre-contract disclosure documents, transparent fees without assured returns or upfront charges, fiduciary conduct and segregation of client assets. Investment activity is subject to client mandates, prudential limits, restrictions on related-party and prohibited transactions, custody, records, audit, periodic reporting and compliance oversight. Special regimes govern eligible fund managers, co-investment managers and mutual-fund-only services. Inspect.....

Certification requirements for securities-market personnel now use "specified person" in place of "associated person", except in the proviso to regulation 3(1). A specified person includes a principal or employee of an intermediary, agent, distributor or other natural person engaged in securities-market business, and employees working in India for foreign portfolio or foreign venture capital investors. Certification may be obtained through an NISM-specified course or programme, in consultation with SEBI, alongside existing routes; related timing provisions are aligned accordingly. Certificate validity and renewal may extend beyond three years where specified by SEBI. Consequential terminology changes apply to the Debenture Trustees and Self Regulatory Organizations Regulations. The amendments took effect on 8 October 2026.

Vault Managers storing bullion underlying Electronic Gold Receipts, bullion ETFs, bullion derivatives, or other permitted instruments must comply with an expanded vaulting framework. They must ensure underlying bullion has never exited the vaulting system, reconcile physical holdings with relevant records, segregate holdings instrument-wise and entity-wise, deliver bullion to prescribed standards, and indemnify beneficial owners for losses. Entities may use vaulting services for such bullion only from registered Vault Managers; existing providers may continue for three months if they apply for registration within that period. Every Vault Manager must appoint a compliance officer for independent non-compliance reporting and quarterly investo.....

Authorised Dealers must not permit rebooking of cancelled INR foreign exchange derivative contracts, whether deliverable or non-deliverable, with any Authorised Dealer. Rollovers of such contracts at maturity remain permissible, subject to the applicable risk-management requirements. The thresholds for hedging contracted exposures and for taking long or short INR currency-pair positions without establishing underlying exposure are reduced to USD 5 million equivalent outstanding across all Authorised Dealers or recognised stock exchanges, as applicable. Dealers must obtain and retain user undertakings confirming whether the underlying exposure has been hedged elsewhere, maintain supporting documents for at least two years, and ensure compliance with these requirements with immediate effect.

"Power Bank" under the relevant customs concessional-duty entry means only a lithium-ion battery device with charging and discharging ports designed to externally charge cellular mobile phones or portable electronic devices. Stationary, grid-scale and industrial lithium-ion Battery Energy Storage Systems classified under the specified tariff item do not fall within the power-bank exclusion. They therefore remain eligible for the concessional Basic Customs Duty treatment available under that entry, subject to its other stated exclusions and conditions.

Supplementary filing for console cargo under SCMTR is temporarily permitted at Kolkata Customs from 9 October 2026 until midnight on 10 October 2026 where the requisite CSN has not been filed and cargo details are required to be added. The facility is limited to that purpose and does not restore general supplementary filing for import cargo. Shipping lines, agents and console agents must provide complete, accurate, document-supported particulars; reconcile them with MBL/HBL, IGM/CSN and related messages; avoid duplicate or inconsistent declarations; and use prescribed SCMTR amendment procedures for subsequent changes. Stakeholders encountering system errors must retain and submit specified technical and shipping records. The facility ceases after the stated period unless extended.

Sea Arrival Manifest amendments must delete and re-file a Bill of Lading when its reference type, consolidator PAN, or previous reference changes; in-place updates are barred. Where a Master Bill of Lading was filed as straight, the amendment must either link forwarder-filed CSN and House Bill details after reclassification as consolidated, or include House Bill details directly where no CSN exists. SAA transmissions must carry the amendment message flag and appropriate addition, deletion, or update indicators. Container ISO Code and agent PAN validation now applies only at SAM level. ANC may cancel a CSN before corresponding SAM filing and submit corrected particulars. System enhancements target faster manifest acknowledgements and submission-status tracking.

Notification No. S.O. 3347(E) Dated:- 26-7-2023 Information Technology
YES Bank's core banking and specified payment-system infrastructure, including associated computer-resource dependencies, is declared a protected system under section 70 of the Information Technology Act, 2000. Access is restricted to written-authorised bank employees, need-based authorised managed-service-provider or third-party-vendor personnel, and case-specific authorised consultants, regulators, Government officials, auditors and stakeholders. The declaration takes effect upon publication in the Official Gazette.

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