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Long-Term Capital Gains Exemption and Development-Right Income Require Fresh Review of Material and Revenue Recognition
Long-term capital gains exemption on share sales requires reconsideration where the initial deletion rested on an absence of investigation or adverse material, but subsequently produced material may affect that factual premise. Its merits and evidentiary value require examination after hearing both sides. Income arising under a real-estate collaboration agreement also requires fresh review where the treatment of receipts did not assess the transfer of development rights and land held as stock-in-trade as an integrated transaction. Revenue recognition and the relevant factual material must be evaluated before either addition is sustained or deleted.
Software copyright rights determine royalty treatment; resale payments to a Singapore vendor escaped withholding tax and disallowance.
Payments to a Singapore non-resident for Turnitin and iThenticate software solutions were not royalty under the India-Singapore DTAA where distribution arrangements granted no interest in, or right to use, the software copyright. The payments related to software supplied for resale to Indian distributors or end-users and did not constitute consideration for use of copyright. As no income taxable in India arose, no tax deduction at source obligation applied, and the related disallowance for non-deduction was deleted.
Unexplained cash deposits cannot be added where documented prior withdrawals provide a plausible source of funds.
Section 69A permits an addition for unexplained money where the assessee does not satisfactorily explain its source. Cash deposits were explained as arising from earlier withdrawals from salary and Kisan Credit Card accounts. Bank statements and Kisan Credit Card records substantiated those withdrawals, while the salary income and the existence of the credit account were undisputed. The documented withdrawals made the stated source of the deposits plausible, supporting deletion of the addition for unexplained cash deposits.
Reassessment limitation barred a delayed Section 148 notice, rendering subsequent reassessment proceedings and the resulting order void.
Reassessment notice under Section 148 for assessment year 2014-15 was required to be issued by 14 June 2022 after applying the surviving limitation period under the transition to the new reassessment regime. The notice issued on 25 July 2022 was therefore time-barred. Consequently, the reassessment proceedings and resulting reassessment order were void from inception and liable to be quashed.
Foreign tax credit remains available despite delayed Form 67 filing, subject to verification of relevant facts and computation.
Foreign tax credit is not denied solely because Form 67 was filed after the due date under Section 139(1) of the Income-tax Act, 1961. The time requirement for filing Form 67 is directory rather than mandatory; therefore, delayed compliance does not by itself defeat entitlement to credit for foreign taxes. Credit remains subject to verification of the relevant facts and computation.
Statutory appellate remedy channels jurisdiction and natural justice challenges away from writ review of show-cause adjudication.
Statutory appellate remedy was available for challenges to a show-cause notice and consequential order, including objections concerning jurisdiction, mechanical adjudication and breach of natural justice. Those grounds were capable of examination through the prescribed appeal mechanism, without any opinion on their merits. The writ petition was disposed of with liberty to pursue the statutory appellate remedy.
Notification No. F A 3-33/2017/1/V(46) Dated:- 5-12-2025 Madhya Pradesh SGST
Schedule III, carrying a 9% rate, inserts woven and non-woven bags and sacks of polyethylene or polypropylene strips or like material, whether laminated or not, when of a kind used for packing goods. It also inserts flexible intermediate bulk containers. Schedule II, carrying a 6% rate, omits serial entries 80AA and 171A and their associated descriptions.
Notification No. CT/8/16/2025-Sec-1-5(CT)(47) Dated:- 5-12-2025 Madhya Pradesh SGST
Madhya Pradesh Goods and Services Tax Rules, 2017 are amended with retrospective effect from 27 May 2020 to permit companies to verify specified GST filings through an electronic verification code. Registered persons incorporated under the Companies Act, 2013 may furnish FORM GSTR-3B returns using EVC from 21 April 2020 to 30 September 2020, and may furnish FORM GSTR-1 outward-supply details using EVC from 27 May 2020 to 30 September 2020.
Notification No. F. No. IFSCA/2021-22/GN/REG16 Dated:- 18-10-2021 Indian Law
Registration is mandatory before insurance or reinsurance business may commence through an International Financial Services Centre Insurance Office. Eligibility requires appropriate domestic or home-jurisdiction authorisation, regulatory compliance, fit-and-proper governance, FATF-compliant jurisdictional status, and applicable capital, Net Owned Fund and solvency compliance. Registered IIOs may undertake permitted life, general, health or reinsurance business in freely convertible foreign currency, subject to restrictions on Domestic Tariff Area business. They must maintain resident key personnel, records, KYC and AML compliance, prudential standards and regulatory reporting. The Authority may inspect, investigate, suspend or cancel registration after giving an opportunity for submissions.
Notification No. FA-3-32-2017-1-V-(44) Dated:- 5-12-2025 Madhya Pradesh SGST
For the relevant State GST entry, bus body building includes building a body on the chassis of any vehicle falling under Chapter 87 of the First Schedule to the Customs Tariff Act, 1975. The clarification applies solely for the purposes of that entry and covers chassis of any vehicle within the stated tariff chapter. The insertion is deemed effective from 22 November 2019.
Customs & Trade
Dated:- 15-9-2026
PTI
Merchandise exports increased sharply in August, led by petroleum product shipments, while imports also rose year-on-year. Reduced gold imports contributed to a narrower merchandise trade deficit. During the first five months of the fiscal year, the cumulative deficit widened as higher imports reflected domestic expansion, energy requirements and manufacturing-input demand. Energy commodities and electronic goods were principal contributors to the deficit, while export growth was supported by engineering goods, petroleum products, chemicals and textiles.
GST
Dated:- 15-9-2026
Bribery allegations concerning CGST redevelopment approvals led to registration of a case against a CGST Superintendent and unknown persons. The Superintendent allegedly sought undue advantage for issuing a no-objection certificate and handing over CGST-owned flats. Following verification, a trap was laid after the complainant was allegedly directed to deliver cash to a CGST consultant. Both the Superintendent and consultant were arrested, produced before the competent court, and placed in police custody. Further investigation remains in progress.
Notification No. 36/2026-27 Dated:- 15-9-2026 Foreign Trade Policy
Foreign Trade Policy, 2023 introduces a de minimis exemption from the requirement to hold a Registration-cum-Membership Certificate (RCMC) or Certificate of Registration for export consignments whose Free-on-Board (FOB) value does not exceed Rs. 3,00,000. Export consignments exceeding the prescribed FOB-value threshold remain subject to the requirement to possess a valid RCMC or Certificate of Registration wherever that requirement otherwise applies.
FEMA / RBI
Dated:- 15-9-2026
PTI
Global Fintech Awards 2026 recognised financial-technology innovation across banking, fintech, artificial intelligence, digital trust and identity, payments, lending, insurance, wealth management and cybersecurity. Its theme emphasised trusted, connected and inclusive financial systems, identifying Agentic AI, tokenisation and quantum technologies as areas of transformation. AI-powered financial innovation recognition covered AI applications in payments, banking, lending, insurance, and asset or wealth management.
Notification No. F A 3-26/2019/1/V(48) Dated:- 5-12-2025 Madhya Pradesh SGST
The special-procedure framework under the Madhya Pradesh Goods and Services Tax regime extends the deadline in the first proviso to the third paragraph of the specified GST notification. The date of 31 August 2020 is replaced by 31 October 2020, and the revised deadline is deemed effective from 31 August 2020.
Notification No. 38/1/2017-Fin(R&C)(15/2025-Rate) Dated:- 17-9-2025 Goa SGST
Goa SGST revises service taxation for containerised rail transport, multimodal goods transportation, goods-carriage renting, delivery services, job work, tailoring and beauty services. Concessional rates for specified transport, renting and beauty supplies depend on restrictions on input tax credit, while multimodal transport credit for higher-taxed transport inputs is capped at the concessional rate. Job work receives differentiated treatment for diamonds, specified goods, alcoholic liquor and residual supplies. Definitions are added for goods transport agency, mode of transport and multimodal transporter, and recognised sporting events receive a specified clarification.
FEMA / RBI
Dated:- 15-9-2026
PTI
IIFL Finance completed a tokenised bond transaction under the SEBI Regulatory Sandbox framework for securities tokenisation. The transaction used the Metropolitan Stock Exchange of India bidding platform, with Trust Investment Advisors Private Limited as sole arranger and advisor, and the bonds are intended to be listed on the National Stock Exchange of India. Securities tokenisation digitally represents securities through blockchain and distributed ledger technology to support more efficient, transparent and faster debt-market processes.
Customs & Trade
Dated:- 15-9-2026
PTI
BharatBenz's product transformation is directed toward safer, more productive and efficient commercial transport. The truck and bus portfolio is being prepared with Advanced Driver Assistance Systems calibrated to Indian operating conditions in advance of evolving safety requirements. Automated Manual Transmission technology is being expanded to improve driver comfort, reduce fatigue, support fleet safety and efficiency, and lower total cost of ownership. Customer support combines connected fleet technology, service assurance, parts availability and service-network expansion.
Customs & Trade
Dated:- 15-9-2026
PTI
India-New Zealand Free Trade Agreement is expected to enter into force in the latter half of October 2026, subject to both parties completing operationalisation processes and procedures. The agreement grants duty-free access to New Zealand for 100 per cent of Indian exports, replacing existing peak tariffs on key Indian products. It is intended to expand bilateral trade in goods and services, promote investment, and includes New Zealand's investment commitment in India.
Notification No. CT/8/1/2026-Sec-1-5(CT)(3) Dated:- 30-1-2026 Madhya Pradesh SGST
New rule 31D establishes retail sale price-based valuation for specified pan masala, tobacco and inhalation products. Supply value is deemed to be the declared retail sale price less applicable IGST, CGST, SGST or UTGST, determined under the prescribed formula. The highest of multiple declared package prices, any increased declared price, and relevant area-specific prices govern valuation. Registered persons other than manufacturers receive a limited rule 86B exemption only for covered goods where the supplier has paid tax on the retail sale price basis.