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September 17, 2026
Show AI Summary
Board chair reappointment validity turns on mandatory nominee-director approval, amid separate listing-compliance and succession disputes.
Tata Sons' board reappointed its executive chairman by majority vote, but Tata Trusts contend that the resolution is void under the Articles of Association because both Trust-nominated directors must approve a chairmanship resolution. The dispute also concerns the effect of the chairman's earlier decision to step aside, an ongoing successor-selection process, and uncertainty over a nominee director's status following a failed general meeting. Separately, the rejection of Tata Sons' deregistration request has revived questions over compliance with the listing requirement applicable to an upper-layer non-banking financial company.
September 17, 2026
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Deep-sea fishing access supports export-oriented harvesting of high-value species, with foreign-port high-seas landings recognised as exports.
Deep-sea fishing policy promotes expansion of fishing operations within India's Exclusive Economic Zone (EEZ) and on the high seas to increase fisherfolk income through exports of high-value species. High-seas catch classification has been altered so that fish caught on the high seas and offloaded at a foreign port are treated as exports rather than imports.
September 17, 2026
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Merchant discount rate on eligible UPI payments places charges on merchants while preserving consumer protections and small merchant exemptions.
Merchant Discount Rate at 0.4 per cent will apply from October 15 to person-to-merchant UPI payments above Rs 2,000, payable by merchants and subject to a cap for high-value transactions. Individual transfers and most everyday merchant payments remain free, while eligible small QR-code merchants are exempt. Essential-service payments and capital-market transactions receive separate fee treatment, and a portion of MDR collections will support small-merchant UPI adoption.
September 17, 2026
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Board reappointment validity depends on shareholder-nominated director consent, directorship quorum concerns, and leadership continuity amid listing compliance.
Tata Sons' board approved by majority vote the Executive Chairman's reappointment for a further five-year term after he reconsidered an earlier decision not to seek renewal. Tata Trusts contest the validity of the resolution, maintaining that the Articles of Association require affirmative votes from both Trust-nominated directors and that a dissenting vote renders a chairmanship resolution legally void. They also cite the accepted succession process and unresolved directorship status arising from a general meeting lacking quorum.
September 17, 2026
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Buyer-seller engagement supports sourcing and export-market opportunities for tools and hardware businesses through an international trade fair.
International Hardware Fair India 2026 is scheduled for 23-25 October 2026 at Bharat Mandapam, New Delhi, as a trade platform for the tools and hardware sector. Organised by Koelnmesse in association with the Federation of Indian Export Organisations, it is intended to facilitate product discovery, sourcing activity and exploration of domestic and international markets. Its Reverse Buyer-Seller Meet will bring hosted international buyers together with Indian manufacturers and suppliers for direct discussions on product presentations, buyer requirements and export-market opportunities.
September 17, 2026
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Financial services technology interoperability drives new card, digital banking and UPI platforms for banks, fintechs and consumers.
86400 has expanded its financial-services technology portfolio through CardsXT as a Service, a UPI app experience and IBMB, extending its activities across card-programme infrastructure, consumer-facing digital payments and digital banking. CardsXT is intended to let banks and fintechs build, launch and manage card programmes through an integrated offering, with flexibility to develop and scale card products while reducing card-lifecycle technology complexity. The UPI app experience provides a platform developed by 86400 for a more seamless consumer UPI payments experience.
September 17, 2026
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Intergovernmental fiscal coordination will guide deliberations on macroeconomic priorities, agricultural transformation, energy transition, growth measurement, and technology-enabled governance.
The thematic programme covers the macroeconomic outlook, financing agricultural transformation, and financing the energy transition. Background material addresses macroeconomic pathways, private financing, implications of GST 2.0 for States, agricultural markets and marketing, agricultural resilience and sustainable resource use, renewable energy and transmission assets, and carbon capture, utilisation and storage. Further sessions address measurement of growth outcomes and the contribution of new-age technology to good governance.
September 17, 2026
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GST-compliant festive planning helps apparel businesses protect input tax credit, manage price thresholds, inventory, cash flow and peak-season operations.
GST-sensitive festive planning for apparel businesses requires early procurement, phased inventory, supplier reorder commitments and separate stock strategies for the post-Diwali wedding season. Pricing and costing require assessment of the revised GST structure for readymade garments and GST-rate reductions affecting man-made fibres and yarns. Proper purchase documentation is important for protecting input tax credit during high-volume festive transactions. Cash-flow planning, credit limits, return policies, retail staffing, digital campaigns and weekly sell-through monitoring support replenishment and pricing decisions.
September 17, 2026
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Competitive Tender Conditions: allegations question replacement of a public-sector power project with terms allegedly favouring a single supplier.
Allegations of tender tailoring concern the replacement of a proposed UJVN-THDC public-sector thermal project with long-term procurement of 1,320 MW from a private generating plant. Congress alleges that 84 of 86 tender conditions were revised after the public-sector venture was abandoned, producing terms suited to an existing Korba expansion acquired by Adani Power through insolvency proceedings. The objections include plant-location flexibility, transmission costs for supply to Uttarakhand, and a 75% fixed-charge ceiling, which are alleged to narrow competition and shift long-term costs to consumers.
September 17, 2026
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Upper-layer NBFC listing requirements drive Tata Sons' listing process and proposed leadership renewal, subject to shareholder approval.
RBI's refusal to permit Tata Sons to surrender its core investment company registration revives the prospect of a public listing. Classified as an upper-layer non-banking financial company, Tata Sons is subject to a listing requirement whose deadline expired while its deregistration request was under consideration. Its board has agreed to advance the listing process, subject to annual general meeting approval. Any legal challenge to the refusal of deregistration may be pursued by Tata Sons itself rather than directly by the Tata Trusts.
September 17, 2026
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Mandatory listing obligations for upper-layer non-banking financial companies drive leadership continuity planning after deregistration is rejected.
Rejection of Tata Sons' request to deregister as a core investment company leaves it subject to the mandatory listing obligation arising from its upper-layer non-banking financial company classification. The board's majority support for N. Chandrasekaran's third term is linked to maintaining leadership continuity for prospective investors if a public listing proceeds.
September 17, 2026
Show AI Summary
Gulfood partnership expands market access for food exporters through global buyer engagement and broader inclusion of emerging enterprises.
APEDA and InD Events Dubai have entered into a memorandum of understanding to support India's participation as Official Partner Country at Gulfood 2027. The partnership is directed at increasing global visibility for India's agricultural and processed food products, connecting Indian exporters with international buyers, and expanding market-access and business-engagement opportunities. Participation will bring together exporters, farmer producer organisations, MSMEs, startups, commodity boards and government institutions through product showcases, curated business-to-business meetings, conferences and industry engagements.
September 16, 2026
Show AI Summary
Foreign exchange pressure drives rupee depreciation as a stronger dollar, capital outflows, and elevated crude prices weigh on markets.
Rupee depreciation continued for a seventh consecutive session, with the currency closing weaker against the US dollar amid overseas dollar strength and foreign fund outflows. Elevated crude oil prices and rising US Treasury yields increased pressure by raising importers' demand for dollars, while positive domestic equity markets limited the decline. Dollar strength reflected expectations of a US interest-rate increase, while domestic equity gains contrasted with net foreign institutional investor equity sales.
September 16, 2026
Show AI Summary
Perpetual lease termination and public-premises eviction challenge turns on privity, statutory jurisdiction bar, and interim protection.
Challenges concern termination of Delhi Gymkhana Club's perpetual lease and a show-cause notice seeking eviction. The Government maintains that a member who is not party or privy to the bilateral lease has no personal estate in the land or right to restrain contractual resumption. It also contends that the Public Premises (Eviction of Unauthorised Occupants) Act bars civil-court eviction proceedings and injunctions against estate-officer action. The challengers seek a stay or status quo, arguing that the notice prematurely assumes valid lease termination.
September 16, 2026
Show AI Summary
Lawful vehicle repossession requires contractual notice, due process, and safeguards against force, stealth, harassment, and arbitrary recovery methods.
Vehicle repossession by banks and non-banking financial companies must be lawful and fair despite contractual self-help repossession rights. Lenders and recovery agents must not use force, stealth, intimidation, harassment, or arbitrary methods. Legally valid repossession clauses must provide notice periods, lawful possession procedures, a final repayment opportunity, and sale or auction processes. Financial institutions must ensure recovery-agent compliance and prevent unlawful dispossession of borrowers from hypothecated vehicles.
September 16, 2026
Show AI Summary
Credit rating transparency strengthens public enterprise access to debt markets through disclosure, risk assessment, and capital structure optimisation.
Objective and independent credit ratings measure CPSE financial strength, risk, credibility, and public-sector creditworthiness, supporting benchmarking and cost-effective access to global and domestic debt markets. Engagement between CPSE leadership and rating agencies focuses on rating methodologies, risk pricing, debt-market dynamics, transparent disclosures, and capital-structure optimisation. Such engagement is directed toward improving credit assessment, investor information, regulatory compliance, funding access at competitive rates, and market-facing disclosure practices.
September 16, 2026
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Raw-material security and import-duty reform are urged to strengthen ferro-alloy competitiveness amid expanding steel demand.
Ferro-alloy competitiveness depends on raw-material security, commercially viable domestic mineral access and lower input costs as steel demand expands. Faster exploration and development of manganese, chrome and other critical minerals, supported by mine-auction frameworks that encourage operational production, can reduce import dependence. Measures sought include zero import duties on unavailable-grade raw materials for noble alloys, competitive electricity costs and rationalised electricity levies. Cleaner energy, efficient furnaces, automation and improved raw-material utilisation are also necessary to reduce costs and emissions.
September 16, 2026
Show AI Summary
Free trade agreement tariff liberalisation expands market access through phased concessions, services mobility pathways, safeguards, and investment commitments.
The free trade agreement grants duty-free access across all New Zealand tariff lines for Indian exports and provides Indian tariff liberalisation for a substantial share of New Zealand goods, while preserving exclusions for sensitive dairy, agricultural, industrial and other specified products. It provides duty-free entry, phased levy reductions, and quota-based concessions with minimum import price and other safeguards for identified goods. New Zealand also commits market access for Indian service suppliers and establishes skilled-employment, student-mobility and post-study work visa pathways.
September 16, 2026
Show AI Summary
Expedited criminal trials involving real-estate directors require consolidated case details and safeguards against homebuyer inconvenience.
Supreme Court sought case details from the Enforcement Directorate and Delhi Police to facilitate expeditious criminal prosecution of Unitech directors without causing inconvenience to homebuyers. Protection of purchasers and completion of stalled housing projects remain central concerns. Project revival measures include RERA registration exemption for specified projects to enable stalled homebuyer loan disbursals, scrutiny of loan accounts classified as non-performing, and authority for the Centre-appointed board to raise outstanding funds, sell inventory, and monetise unencumbered assets for completion of housing units.
September 16, 2026
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RCMC exemption for eligible small-value exports reduces upfront registration requirements while preserving compliance for larger consignments.
RCMC or Certificate of Registration is not required, wherever otherwise mandated under the Foreign Trade Policy, 2023, for export consignments with a Free-on-Board value of up to Rs. 3 lakh. Export consignments exceeding that threshold continue to require a valid RCMC or Certificate of Registration wherever applicable. The exemption reduces the initial registration burden for MSMEs, artisans, small businesses, first-time exporters and occasional exporters undertaking eligible small-value exports, including through Postal, Courier, e-commerce and other emerging channels.

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FORM NO. 120 – FREQUENTLY ASKED QUESTIONS (FAQS)

April 1, 2026

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FORM NO. 120 – FREQUENTLY ASKED QUESTIONS (FAQS)

Name of form as per I.T. Rules, 1962

Form 34C, 34D, 34DA, 34E & 34EA

Name of form as per I.T. Rules, 2026

Form No. 120

Corresponding section of I.T. Act, 1961

245N to 245W

Corresponding section of I.T. Act, 2025

380 to 389

Corresponding Rule of I.T. Rules, 1962

44E, 44F and 44FA

Corresponding Rule of I.T. Rules, 2026

200 to 202

1. What is Form No. 120?

Ans: Form No. 120 is an application form primarily used by non-resident applicants to seek a determination or ruling from the Board for Advance Rulings (BAR) on questions of law or fact relating to proposed or undertaken transactions by the applicant. These forms facilitate clarity and certainty on tax liability issues in advance, avoiding future disputes and litigations.

2. Who should file Form No. 120 and what is prescribed fee for seeking an Advance Ruling?

Ans: Form No. 120 can be filed by following category of applicants by paying prescribed fee as mentioned against respective category of applicants/transaction value below:

Applicant Category

Basis for Fee Determination

Transaction Value

Application Fee

Non-resident applicants

Aggregate value of transaction(s)

Amount not exceeding Rs. 100 crores.

₹2 lacs

Amount exceeding Rs. 100 Crores but not exceeding Rs. 300 Crores.

₹5 lacs

Amount exceeding Rs. 300 Crores.

₹10 lacs

Resident applicants transacting with non-residents

Aggregate value of transaction(s)

Amount not exceeding Rs. 100 crores.

₹2 lacs

Amount exceeding Rs. 100 Crores but not exceeding Rs. 300 Crores.

₹5 lacs

Amount exceeding Rs. 300 Crores

₹10 lacs

Specified resident applicants (including high-value residents)

Aggregate value of transaction(s)

Amount not exceeding Rs. 100 crores.

₹2 lacs

Amount exceeding Rs. 100 Crores but not exceeding Rs. 300 Crores.

₹5 lacs

Amount exceeding Rs. 300 Crores.

₹10 lacs

Public Sector Companies

In all cases

₹10,000

GAAR applicants

(resident or non-resident)

In all cases

₹10,000

3. When is Form No. 120 required to be filed?

Ans: Form No. 120 is required to be filed only if the applicant/taxpayer intends to seek a determination or ruling from the Board for Advance Rulings (BAR) on questions of law or fact relating to proposed or undertaken transactions by the applicant.

4. What is the time limit for filing Form No. 120?

Ans: There is no time limit for filing Form No. 120. Filing of Form No. 120 purely depends upon the intention of assessee i.e. whether he intends to obtain advance ruling in respect of a transaction already completed or proposed to be completed in future.

5. How many times can Form No. 120 be filed in a year?

Ans: Form No. 120 is transaction/event based and is only filed in case of an applicant intending to obtain advance ruling from the Board of Advance Rulings (BAR). There is no fixed annual frequency; it depends upon the number of transactions in respect of which an applicant wishes to obtain advance ruling. It is quite important to mention here that an applicant cannot file multiple Form No. 120 in respect of a single transaction.

6. What documents are required to file Form No. 120?

Ans: Proof of payment of application fee (challan, bank receipt, etc.).

  • PAN card copy (for residents and non-residents if allotted).
  • Taxpayer Identification Number (TIN) or equivalent for non-residents.
  • Certificate of incorporation/registration (company, trust, partnership, etc.).
  • Address and identity proof of applicant.
  • Proof of being Non-resident.
  • Details and documents regarding business/profession (Memorandum of Association, Partnership/Trust deed, etc.).
  • Question(s) relating to the transaction on which advance ruling is required.
  • Statement of relevant facts having a bearing on the question(s).
  • Statement of interpretation of law or facts.
  • Copies of relevant agreements/arrangements giving rise to transaction, if any.
  • Supporting documents for group structure/beneficial ownership (for non-residents).
  • Details of other parties to arrangement (Identity, PAN, Relation).
  • Document indicating Tax year(s) during which the tax benefit is likely to arise (give year wise break-up).
  • Any relevant assessment orders, appellate orders, or documents if proceedings/arbitrations are pending or decided.
  • Authorization letter/power of attorney if the application is filed by an authorized representative.
  • Any other document as required by the Board or mentioned in instructions relevant to the case.
  • The applicant shall, along with the attachment, provide an index of the documents uploaded with the description and corresponding page numbers.

7. Do I need to attach proof of fee payment?

Ans: Yes. Proof of fee payment (challans/BSR codes) is mandatory for filing of Form No. 120.

8. How and where is the fee paid?

Ans: The fee must be paid online through the Bharat Kosh portal, and the receipt must be attached with the application.

9. If I don’t have PAN and I have never been assessed to tax in India, can I still apply for an advance ruling before BAR?

Ans: Yes. If you do not have a PAN and have never been assessed to tax in India, you can still apply for an advance ruling before the Board for Advance Rulings (BAR). In such cases, the Department will allot a PAN after obtaining the required particulars from you.

10. While filling Part A, can I leave mobile number blank?

Ans: Mobile number ensures faster communication and verification; it is recommended to provide it.

11. What if I don’t upload requisite documents at the time of filing Form No. 120?

Ans: Your application for seeking advance ruling will be processed only when the requisite documents are submitted. If your application is found defective, the Secretary, BAR shall seek an explanation from you as to why the application may not be rejected and direct you to submit any relevant material or information in support of such application within such time as allowed by the BAR.

12. Can I file Form No. 120 after filing an appeal against the order of any Income Tax Authority, the Appellate Tribunal or any court?

Ans: No. Form No. 120 can only be filed in respect of question(s) or transaction(s) on which on which the advance ruling is sought, which is/are not pending before any Income Tax Authority, the Appellate Tribunal or any court.

13. Can Form No. 120 be filed offline?

Ans: No. Henceforth, Form No. 120 can only be submitted online through the Income Tax e-Filing Portal.

14. Can I edit Form No. 120 after submission?

Ans: No. Once Form No. 120 is submitted and acknowledgment is generated, it cannot be edited. Ensure all details are correct before submission.

15. What are common mistakes to avoid?

Ans: Following common mistakes should be avoided: -

  • Incomplete or unsigned forms
  • Missing Annexures or Proof of Fee Payment
  • Inadequate disclosure of Group Structure and Beneficial Ownership
  • Submitting from an unregistered Email ID.

16. Is advance ruling available only before entering into a transaction?

Ans: No. An advance ruling can be sought both before or after undertaking a transaction, as long as the issue is not pending before any income-tax authority, Tribunal, or Court (except for PSUs).

17. What type of questions can I ask in an advance ruling application?

Ans: You may ask questions of law, fact, or mixed questions directly relating to your tax liability, including:

  • DTAA interpretation
  • Permanent Establishment
  • Withholding tax
  • Taxability of services, royalties, fees
  • GAAR applicability

18. Can multiple questions be raised in one application?

Ans: Yes. Multiple questions may be raised, provided they arise from the same transaction/arrangement and are clearly framed.

19. Can advance rulings be sought for proposed or ongoing/completed transactions?

Ans: Yes. Advance rulings may be sought for transactions proposed or already undertaken, provided the question is not pending before any income-tax authority, Tribunal, or Court (subject to PSU relaxation).

20. Can I withdraw my advance ruling application?

Ans: Yes. An application may be withdrawn within 30 days from the date of filing.

21. I want to declare that no question(s) on which advance ruling is sought is pending before any Income Tax Authority, the Appellate Tribunal or any court. Where should this be mentioned?

Ans: This is mandatory part of the Verification Section of Form No. 120.

22. What happens if my application is found defective?

Ans: If the application is defective, the Secretary of the BAR will intimate the defects and grant a reasonable opportunity to rectify them. The application will be treated as filed only after defects are removed.

23. Will my application be rejected automatically if the tax department does not send records?

Ans: If the jurisdictional PCIT/CIT fails to furnish records, the BAR may still proceed to allow or reject the application without waiting for those records.

24. Is the applicant entitled to a hearing before rejection or final disposal?

Ans: Yes. Before rejection or final disposal, the applicant must be given a reasonable opportunity of being heard.

25. Can I modify or reframe questions after filing the application?

Ans: Normally, questions cannot be amended. However, in deserving cases, the BAR may permit modification or reframing of questions before the hearing.

26. What are the conditions which may cause my application to be summarily rejected?

Ans: Under section 384(3) of the Income Tax Act, 2025 certain restrictions have been imposed on the admissibility of the application. The BAR is bound to reject applications which raise the following three categories of questions.

  • The question is pending before any income-tax authority, Tribunal, or Court (except PSU relaxation);
  • It involves determination of fair market value of property; or
  • It relates to a transaction designed primarily for tax avoidance (other than GAAR rulings).

27. What are the legal consequences of a ruling (binding effect, appeal, voidness, limitation)?

Ans:

  • Binding effect: Binding on the applicant and jurisdictional income-tax authorities for the specific transaction.
  • Voidness: Can be declared void ab initio if obtained by fraud/misrepresentation.
  • Appeal: Appeal lies to the jurisdictional High Court within 60 days of communication.
  • Limitation: Pendency period before BAR is excluded while computing limitation for assessment/reassessment.

28. Can BAR ask for additional facts or documents later?

Ans: Yes. BAR may permit or require submission of additional facts, which must be duly verified.

29. Can the advance ruling be appealed?

Ans: Yes. Either the taxpayer or the Department may appeal to the High Court within 60 days of communication.

30. Is the time taken by BAR excluded from limitation periods?

Ans: Yes. The period during which the advance ruling application is pending is excluded while computing limitation periods for assessment.

31. Can an advance ruling be declared void later?

Ans: Yes. If the ruling is obtained by fraud or misrepresentation, BAR may declare it void ab initio.

32. Can the BAR amend or correct its own order?

Ans: Yes. The BAR may rectify mistakes apparent from the record, either on its own motion or on an application by the taxpayer or the Department, after giving an opportunity of being heard.

33. Is an advance ruling binding forever?

Ans: No. The ruling is binding only so long as there is no change in facts or law. Any material change can render the ruling inapplicable.

34. Can Public Sector Companies seek advance rulings despite pendency of proceedings?

Ans: Yes. Public Sector Companies are permitted to seek advance rulings even if proceedings are pending on the same or similar issues before income-tax authorities or appellate forums.

35. Is GAAR determination available to all categories of persons?

Ans: Yes. Any person (resident or non-resident) may seek an advance ruling on whether an arrangement constitutes an impermissible avoidance arrangement under GAAR.

36. What practical benefit does an advance ruling offer in cross-border transactions?

Ans: Advance rulings offer certainty on DTAA interpretation, withholding tax, PE exposure, and income characterization, enabling taxpayers to structure cross-border transactions confidently and compliantly.

37. Who can be an Authorized Representative?

Ans: An applicant’s authorized representative should fulfil the requirements spelt out in section 515(3)(a) of the Income Tax Act, 2025. The expression “authorized representative”, in relation to the PCIT/ CIT, means a person authorized by it in writing to appear, plead and act for it in any proceedings before the BAR.

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Acts Income Tax