IFSC units and OBUs will get a longer 100% deduction period and post-expiry income taxed at 15%. Proposed amendments extend the 100% deduction under section 147 for IFSC units from 10 consecutive years out of 15 to 20 consecutive years out of 25, and for OBUs from 10 consecutive years to 20 consecutive years; business income from IFSC after the deduction period will be taxed at 15%. The amendments apply from 1 April 2026 to the tax year 2026-27 and subsequent years.
Treasury centre dividend exclusion limited to cross border group loans in notified jurisdictions with parent listed abroad. Amendment restricts the dividend exclusion for inter group advances or loans involving a Finance company or Finance unit by requiring the other group entity to be located in a notified jurisdiction outside India and the group's parent or principal entity to be listed abroad; the Central Government will notify eligible jurisdictions. It also defines "group entity" by reference to the IFSCA (Payment Services) Regulations, 2024, and defines "parent/principal entity" by voting power and board control tests; the changes apply from 1 April 2026 for tax year 2026 27 onward.
Minimum Alternate Tax: MAT rate cut to 14% and treated as final in the old regime with limited credit set off. MAT in the old corporate tax regime will be treated as final tax and no new MAT credit will be allowed; the MAT rate is reduced to 14%. Existing MAT credit set off is limited: domestic companies may set off MAT credit only in the new regime up to 25% of annual tax liability, while foreign companies may set off to the extent normal tax exceeds MAT in the relevant year. These amendments apply from 1 April 2026 for tax year 2026 27 and subsequent years.
TCS rates on select receipts revised, including LRS and overseas tour packages, effective April 1, 2026. Proposed rationalisation of TCS rates sets uniform rates and adjusts specific receipts: alcoholic liquor, scrap, and certain minerals rise from 1% to 2%; tendu leaves fall from 5% to 2%. Under the Liberalised Remittance Scheme, TCS for education or medical remittances over the prior threshold is reduced from 5% to 2% (20% unchanged for other purposes). TCS on sale of an overseas tour programme package is set at a flat 2% with the threshold removed. The amendment is effective 1 April 2026.
Reassessment notices will be issued by Assessing Officers, not NaFAC, clarifying the pre-assessment role and scope. The amendment clarifies that the pre-assessment enquiry and the decision to issue a reassessment notice are carried out by the Assessing Officer and that the National Faceless Assessment Centre or its assessment units shall not be deemed to be the Assessing Officer for issuance of reassessment notices or related pre-assessment steps; corresponding amendments align the new income-tax statute and the clarification is made retrospective to 1 April 2021 while the new Act's amendment is effective 1 April 2026.
Computer-generated Document Identification Number: assessments not invalidated for DIN quoting mistakes if referenced in any manner. Assessments and related proceedings under the Income-tax Act, 1961 shall not be invalid for mistakes, defects or omissions in quoting a computer-generated Document Identification Number (DIN) provided the assessment order or proceeding references that DIN in any manner; a reference to the DIN is sufficient compliance even if notices or summons contain minor defects.
Clarifying time-limit: section 144C timelines govern assessment finalisation; sections 153/153B govern draft order stage. Timelines for finalisation of assessments under section 144C govern completion of assessment notwithstanding the time limits in section 153 and section 153B. Acceptance of a draft order requires completion within one month from the end of the month in which acceptance is received or the 30 day objection period expires; where objections go to the DRP, the DRP must direct within nine months and assessment must be completed within one month from the end of the month in which directions are received. Amendments will clarify this in the 1961 Act (with retrospective dates) and in the Income-tax Act, 2025.
Transfer Pricing order timeframe clarified to include the final limitation date and apply retrospectively to past cases Clarifies that when computing the sixty-day timeframe for the Transfer Pricing Officer to pass an arm's length price order, the final limitation date is included in that sixty-day calculation; the amendment operates notwithstanding judicial decisions and is framed to apply retrospectively in the existing law and prospectively in the new tax code to ensure uniform interpretation and reduce litigation.
Tonnage tax scheme extended to inland vessels with registration, training, and tonnage computation changes effective April 2026. Amendments to Chapter XIII-G clarify that tonnage computation uses a "valid certificate" and, for inland vessels, the "certificate of registration" under the Inland Vessels Act, 2021; extend core activity coverage to include inland vessel passenger activities; require compliance with minimum training guidelines issued by the Inland Waterways Authority of India where applicable and adjust the compliance-certificate requirement to refer to the designated authority for inland vessels; add IWAI consultation for average net tonnage computation; and provide a definition of IWAI. Amendments take effect 1 April 2026 and apply to tax year 2026-27 and subsequent years.
Crypto-asset transaction reporting now attracts Rs.200/day for non-filing and Rs.50,000 for inaccurate or uncorrected statements. Prescribed reporting entities must furnish statements on crypto asset transactions; the Finance Bill introduces a penalty of Rs. 200 per day for non furnishing and a penalty of Rs. 50,000 for furnishing inaccurate particulars and failing to correct them by amending the statute governing penalty provisions.
Commodity derivative definition to be added to Income-tax Act, 2025 aligning with the 1961 Act, effective April 1, 2026. Amend the Income-tax Act, 2025 to provide a statutory definition of commodity derivative matching the definition in the Income-tax Act, 1961 for use in the definition of specified derivative transaction. The amendment is contained in Clause 33 of the Finance Bill, 2026 and takes effect from 1 April 2026.
Definition of authorised person clarified as the payor for non resident payments for foreign exchange asset transfers. Adds a statutory definition of authorised person to identify the person responsible for paying when consideration is paid to a non resident for transfer of a foreign exchange asset, aligning the 2025 Act with earlier income tax law and amending the provision governing the person responsible for paying to clarify payor identification and related withholding and reporting obligations.
Union Budget amendment corrects a cross reference to ensure spouse income from transferred assets is properly attributed. Section 99(2) currently misreferences the provision governing spouse income from transferred assets by citing the clause on salary or commission, and the Finance Bill proposes to correct section 99(2) to cite the clause dealing with income arising from transferred assets; the Bill also proposes an amendment to section 402(27), both taking effect from 1 April 2026.
TDS on sale of immovable property reference corrected to Table 3(i); amendment effective 1st April 2026. Note 3 to section 393(1) [Table: Sl. No. 3(i)]-which applies TDS on sale of immovable property where sale consideration or stamp duty value meets the prescribed threshold-erroneously referred to Table Sr. No. 3(iii). The Finance Bill, 2026 proposes to amend Note 3 to correct the reference to Table Sl. No. 3(i) so the TDS provision operates as intended; the amendment takes effect from 1st April, 2026 (Clause 72).
Income from house property and PAN rules amended to include prior-period interest and expand PAN quoting rules. The amendments provide that annual value of property held as stock-in-trade is nil for up to two years after completion certificate; that the aggregate deduction ceiling for interest on borrowed capital for self-occupied property shall include prior-period interest; and that the tax board may make rules requiring PAN quoting in documents for transactions not related to business or profession, effective 1 April, 2026.
Guidelines for TDS/TCS will be binding on persons required to deduct or collect tax from April 1, 2026. The amendment expressly makes guidelines issued to remove difficulties in giving effect to the TDS/TCS chapter binding on income-tax authorities and on the person liable to deduct or collect income-tax, correcting an omission and aligning the provision with the intent of existing law; the amendment takes effect from 1 April 2026.
Tax treatment: previously allowed deductions or excluded amounts will be treated as income under the new Act from 2026 27 onward. Amendment to section 536(2)(h) provides that sums allowed as deductions or not included under the repealed Income-tax Act, 1961 will be deemed income under the Income-tax Act, 2025 if they would have been includible under the 1961 Act, even without any violation of prior conditions, effective 1 April 2026 for tax year 2026-27 onward.
Specified fund definition aligned with income tax provision, effective April 1, 2026 for tax year 2026 27 onward. Amendment aligns the definition of specified fund in Note 1(g) to Schedule VI with the income tax provision definition, so that existing Sl. Nos. 1-4 of Schedule VI apply to any entity that meets the aligned specified fund definition; the amendment takes effect from 1 April 2026 and applies to the tax year 2026-27 and thereafter.
Merger of non-profit organisations exempt from accreted-income tax if same or similar objects and prescribed conditions are met. A new provision exempts registered non-profit organisations from accreted-income tax on merger when the transferee and transferor are registered non-profit organisations with the same or similar objects and the merger meets prescribed conditions; the merger-liability rule is amended to make tax payable where the merging entity is non-registered, where a registered non-profit's merger fails to satisfy prescribed conditions despite similar objects, or where objects are not the same or similar.
Registered non-profit organisations: commercial activity for public utility no longer treated as a specified violation risking registration cancellation. The amendment removes commercial activities by registered non-profit organisations carried out for advancement of General Public Utility from the category of specified violation in section 351, preventing such activity from triggering registration cancellation, and aligns the treatment with other violation provisions; effective 1 April 2026 for tax year 2026-27 and thereafter.
Meaning and scope of supply under GST (Part 1) - Since CGST, SGST or IGST will be levied on supply of goods or services, it is important to understand this term first
23 August, 2016
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Scope of supply under GST includes consideration-based transactions, importation of services, and specified free supplies. The statutory definition of supply under the Model GST Law comprises three categories: supplies for consideration in the course or furtherance of business ... Summary
MODEL GST LAW - GOODS AND SERVICES TAX ACT, 2016 - Draft June 2016
Scope of supply under GST includes consideration-based transactions, importation of services, and specified free supplies.
The statutory definition of supply under the Model GST Law comprises three categories: supplies for consideration in the course or furtherance of business (sale, transfer, barter, exchange, licence, rental, lease or disposal); importation of services regardless of consideration or business purpose; and specified supplies made without consideration as listed in Schedule I. Clause (a) targets domestic, consideration-based transactions; clause (b) treats importation of services as separately taxable; and clause (c) assimilates certain gratuitous transactions into the tax net via Schedule I.
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