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A registered person availing the composition scheme cannot make inter state outward supplies; place of supply outside the state requires issuance of a Bill of Supply only, and an inter state supply triggers immediate withdrawal of the composition scheme by operation of law. Withdrawal converts liability to tax under normal provisions, requires filing FORM GST CMP-04 electronically, and exposes the person to additional tax and penalty determination by the proper officer if composition was wrongly availed.
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Composition scheme excludes service providers generally, so a works contractor is ineligible; however, supply of food or drink (excluding alcoholic liquor) provided as a service for consideration is carved out as an exception, permitting restaurant-style vendors to avail composition benefits under the composition levy conditions and restrictions.
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Composition scheme eligibility restricted for certain manufacturers; ice cream, pan masala and tobacco products excluded from composition benefit.
The Composition Scheme allows manufacturers and traders to opt for a simplified levy instead of regular GST, but the government may notify exclusions. Manufacturers of ice cream and other edible ice, pan masala, and tobacco and manufactured tobacco substitutes are explicitly excluded from eligibility to avail the composition benefit.
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The product Soft Serve is to be treated as a prepared foodstuff under Sub-Heading 21.05 rather than as a dairy product or an ice-cream/ice confection; its character and presentation align it with preparations for human consumption covered by the prepared foods heading, excluding headings for dairy or frozen confection classifications and thereby determining the applicable excise and tariff treatment.
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Medicament classification: surgical povidone iodine solutions treated as specific medicinal goods, not generic cleaning preparations.
The product's classification hinges on combined factors-composition, product literature, label, character and intended user-while a miniscule prophylactic ingredient is not relevant. Because the solution is used by surgeons to degerm hands and scrub patient skin to prevent infection, it is classifiable as a medicament under the specific tariff entry rather than under a residuary entry for cleaning preparations.
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Scrabble is classifiable as a board game under the tariff heading for games (Chapter 95) rather than as an educational toy or article of furniture, because its defining elements of chance and skill distinguish it from toys; this classification applies equally to simplified or junior editions which retain the essential game attributes.
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Tariff classification: tooth powder treated as heading 3306 and excluded from Chapter 30 despite medicinal properties.
The tooth powder "Dant Manjan Lal" is classifiable under Sub heading 3306 for tooth powders and similar preparations; despite possessing therapeutic properties, Chapter Note 1(d) of Chapter 30 excludes it from classification under Chapter 30, so the Chapter 33 description governs the tariff classification.
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Tariff classification: Aluminium castings classed under subheading 84.32, altering their excise tariff placement.
Classification dispute over cast metal components turns on tariff interpretation: Aluminium castings are to be classified under Sub Heading 84.32 rather than under 84.09, applying tariff nomenclature and interpretive principles to allocate goods to the aluminium-specific heading for central excise purposes.
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The Supreme Court held that the addition of perfume to a hair oil product results in classification under Sub Heading 3505.10 rather than under the alternate tariff heading previously relied upon, clarifying the proper excise tariff interpretation and product characterisation for assessment purposes.
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Classification of paving blocks as tariff goods under subheading 6807.90 rather than 6807.20 clarifies taxable categorization.
Classification dispute concerns whether Paving Blocks should be assigned to subheading 6807.90 or to 6807.20; the authoritative interpretation establishes that Paving Blocks fall within subheading 6807.90, not 6807.20, thereby determining the applicable tariff classification for such products.
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Product classification for therapeutic or prophylactic use dictates treating composite preparations as medicaments for tariff purposes.
Products described as product uses for Therapeutic or Prophylactics are to be treated as medicaments for tariff classification; mixtures of two or more constituents combined for therapeutic or prophylactic purposes qualify as a medicament and should be classified accordingly, with the intended therapeutic or prophylactic use and composite nature determining the applicable tariff heading.
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Tariff classification: Dimethicone treated as chemical goods heading, not classified under pharmaceutical-medical heading for levy purposes.
Dimethicone is classifiable under Sub Heading 3910 and not under 3003.20 of the Tariff Act, treating it as a product of the chemical/plastic goods heading rather than as a medicament for tariff purposes.

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Comparison of section 511 "Furnishing of report in respect of international group." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

17 September, 2025

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Section 511 Furnishing of report in respect of international group

Income-tax Act, 2025

At a Glance

The document reproduces Clause 511 - Income Tax Bill, 2025 - Old Version, setting out reporting obligations for constituent entities of international groups (country-by-country reporting style). It matters for multinational groups with Indian resident constituent entities - both taxpayers (resident constituent entities, parent entities, alternate reporting entities) and the tax administration. Effective date or commencement is Not stated in the document.

Background & Scope

Statutory hooks: Clause 511 sits within miscellaneous provisions of the Income Tax Bill, 2025 and proposes a standalone reporting obligation for "international groups". The clause creates duties to notify the prescribed income-tax authority and to furnish reports containing consolidated and constituent-level financial and operational information. Definitions and scope are provided within the clause itself. Any subordinate rules, forms, timelines and thresholds are to be set out "as prescribed" (delegated rule-making).

Statutory Provision Mode

Text & Scope

Clause 511 imposes three principal obligations:

  • Notification (sub-section (1)): Every constituent entity resident in India that is part of an international group whose parent is not resident in India must notify the prescribed income-tax authority in the prescribed form and manner by the prescribed date whether it is the alternate reporting entity and/or provide details of the parent or alternate reporting entity and their jurisdictions.
  • Reporting (sub-section (2)): Every parent entity or alternate reporting entity resident in India must, for each reporting accounting year, furnish a report to the prescribed income-tax authority within twelve months from the end of that reporting accounting year, in the prescribed form and manner.
  • Fallback reporting (sub-section (4)): Where an Indian resident constituent entity is not the parent/alternate reporting entity, it must furnish the report within a prescribed period if the parent is resident in a jurisdiction that (a) is not obligated to file such a report; (b) lacks an agreement with India for exchange of the report; or (c) has experienced a "systemic failure" and that failure has been intimated by the prescribed income-tax authority.
  • Sub-sections (3) and (6) detail report content and exceptions; (7) grants the authority the power to issue notices and require supporting information; (8) provides a consolidated-revenue threshold exemption; and (9) permits application "as prescribed".

Interpretation

The text indicates a legislative intent to implement a country-by-country reporting regime targeted at large international groups with constituent entities resident in India. The use of express definitions (e.g., "consolidated financial statement", "parent entity", "constituent entity", "reporting accounting year") demonstrates an intent to align reporting obligations with financial reporting and with international standards for transfer pricing transparency. Several interpretive principles are signalled by the text: alignment with parent-jurisdiction financial periods, deference to prescribed forms and procedures, and reliance on intergovernmental agreements for automatic exchange.

Exceptions/Provisos

Key carve-outs and conditions:

  • Threshold exemption (sub-section (8)): The section will not apply if the total consolidated group revenue for the preceding accounting year does not exceed the prescribed amount - the specific monetary threshold is Not stated in the document.
  • Non-application where an alternate reporting entity files in its jurisdiction and certain conditions are met (sub-section (6)): Conditions include the foreign report being required by local law, presence of an exchange agreement between that country and India, absence of any systemic failure communicated by the Indian authority, written designation of the alternate reporting entity, and prior notification under sub-section (1). These are cumulative preconditions.
  • Fallback allocation where multiple Indian resident constituent entities exist (sub-section (5)): If more than one Indian constituent entity exists, any one designated entity may furnish the report provided the group has designated that entity and the information has been conveyed in writing to the prescribed authority.

Illustrations

  • Example 1: A multinational group with a non-resident parent and one Indian subsidiary that is designated as the alternate reporting entity must notify the income-tax authority in India and, if resident as alternate reporting entity, file the report within 12 months of the reporting accounting year end. (All procedural details - forms/timelines - are Not stated in the document.)
  • Example 2: An Indian permanent establishment (PE) of a foreign enterprise that prepares separate financial statements as a PE falls within "constituent entity" and, if the foreign parent's jurisdiction neither files nor exchanges reports with India, that Indian PE may be required to furnish the report within the prescribed period. (Precise prescribed period is Not stated in the document.)

Interplay

The clause expressly contemplates interaction with:

  • Section 159(1) or (2) (via the definition of "agreement") - signalling reliance on specified intergovernmental agreements for exchange.
  • Section 173(c) (for the meaning of "permanent establishment").
  • Prescribed rules/guidelines/conditions that remain to be issued for form, manner, dates and thresholds. The document does not reproduce any subordinate rules or forms. Specific interactions with existing transfer-pricing or information-exchange regimes are Not stated in the document beyond the express reference to agreements for exchange.

Differences between the Document 1 "Section 511 of Income-tax Act, 2025" and Document 2 "Clause 511 - Income Tax Bill, 2025 - Old Version"

  • Prescription wording: Document 1 repeatedly uses the phrase "as may be prescribed" (e.g., sub-sects (1), (2), (3), (9)), whereas Document 2 often uses the shorter "as prescribed".
    • Practical impact: negligible substantive difference in content; "as may be prescribed" can imply delegation to subordinate legislation, while "as prescribed" is more neutral - both indicate delegated rule-making. In practice, stakeholders should expect rules/guidelines to be issued regardless.
  • Minor phrasing differences: e.g., Document 1 in sub-section (4)(c) reads "where there has been a systemic failure of the country or territory and such failure has been intimated by the prescribed income-tax authority to such constituent entity" while Document 2 reads "where there has been a systemic failure and such failure has been intimated by the prescribed income-tax authority to such constituent entity."
    • Practical impact: none substantive; the enacted text in Document 1 clarifies that the systemic failure is of the foreign country/territory, but Document 2's meaning would be read the same way in context.
  • Overall: there are no material substantive differences in obligations, definitions, thresholds or exceptions between the two texts provided. The principal practical impact arises from the change in status from a Bill clause (Document 2) to an enacted statutory section (Document 1) and minor drafting refinements that preserve the same legal obligations and delegated-rulemaking expectation.

Practical Implications

  • Compliance and risk areas: Indian resident constituent entities of international groups must track whether their group's parent is resident outside India, determine whether they are designated as alternate reporting entity, and ensure timely notification to the prescribed income-tax authority. Parent or alternate reporting entities resident in India must prepare and file the prescribed report within 12 months of the reporting accounting year end. Failure to notify or file may expose entities to compliance actions under the Act and to information requests under sub-section (7).
  • Record-keeping/evidence: The text requires aggregated country-level financial and operational metrics and constituent-level details; accordingly, entities will need robust consolidated financial statements, country allocation methodologies, documentation of designation as alternate reporting entity, and written communications to the Indian authority. The precise content and format are "as prescribed" and therefore entities must monitor subordinate instruments for technical compliance requirements (not specified in the Bill text).

Key Takeaways

  • Clause 511 establishes country-by-country style reporting obligations for international groups with Indian resident constituent entities.
  • There is a dual duty: initial notification by Indian resident constituent entities (where parent is non-resident) and annual reporting by Indian parent/alternate reporting entities within 12 months of reporting accounting year end.
  • Fallback reporting obligations apply to Indian resident constituent entities if the parent's jurisdiction does not file, does not exchange, or has a communicated systemic failure.
  • Exemptions hinge on a consolidated revenue threshold for the preceding year; the specific threshold is to be prescribed and is Not stated in the document.
  • The power to request supporting information and documents within defined timelines is provided to the prescribed income-tax authority.
  • Many operational details (form, manner, prescribed dates, exact thresholds) are left to delegated rules; stakeholders must monitor rule-making for compliance specifics.

Full Text:

Section 511 Furnishing of report in respect of international group

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Acts Income Tax