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Manuals Income Tax
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Taxability of foreign currency translation reserve: opening FCTR to be included in income unless previously recognised, requiring professional judgment.
The opening balance of the Foreign Currency Translation Reserve (FCTR) as on 1 April 2016 relating to exchange differences on monetary items for non integral foreign operations shall be recognised in the relevant previous year as income to the extent not previously included in income computation; the correctness of this recognition is debatable and requires appropriate professional judgment because conversion does not create real income and ICDS treatment may not apply to earlier years.
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Foreign currency liabilities treatment: exchange differences on monetary items hit profit or loss; non monetary differences not taxable or deductible.
Section 43A does not apply to foreign currency liabilities for purchase of assets in India; such liabilities are governed by ICDS VI. Per ICDS VI para 5(i), exchange differences on monetary items are recognised in the profit and loss account, whereas exchange differences on non monetary items are neither taxable nor deductible.
Manuals Income Tax
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Exchange difference recognition requires periodic recognition until final settlement, treated as income or expense for monetary items.
Exchange differences on monetary transactions settled after the end of the previous year must be recognised in each intervening period up to final settlement, with exchange gain or loss on settlement treated as income or expense, except for items relating to nonintegral foreign operations.
Manuals Income Tax
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Foreign exchange differences: monetary item gains and losses recognised as income or expense, non-monetary conversion differences excluded.
Exchange differences on monetary items (cash and assets or liabilities receivable or payable in fixed or determinate amounts of money) arising on settlement or on the last day of the financial year must be recognised as income or expense of that year. Exchange differences on non-monetary items arising on conversion at the last day of the year are not to be recorded as income or expense for that year.
Manuals Income Tax
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Foreign currency transaction recording: use transaction-date exchange rate or a stable weekly/monthly average when fluctuations are insignificant.
Under ICDS VI, a foreign currency transaction must be initially recorded in the reporting currency using the exchange rate on the transaction date; if rates do not fluctuate significantly from actuals, a weekly or monthly average rate may be used instead.
Manuals Income Tax
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Capitalization of test-run and commissioning expenditure: pre-commercial costs capitalized, post-commercial costs treated as revenue excluding general overheads.
Expenditure on start-up and commissioning, including test runs and experimental production, must be capitalized as part of the cost of the tangible fixed asset until commercial production begins; expenditure after commercial production is revenue expenditure. Administration and general overheads not relating to a specific tangible fixed asset are excluded from asset cost and treated as revenue expenditure.
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Valuation of tangible fixed assets requires recording at actual cost including nonrecoverable taxes and directly attributable expenditures.
Valuation of tangible fixed assets under ICDS V requires recording assets at actual cost, comprising purchase price, duties and taxes that are not recoverable, and other directly attributable expenditure necessary to bring the asset to its intended use; recoverable taxes are excluded.
Manuals Income Tax
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Accrual basis interest recognition: interest taxed on accrual must be included when computing capital gain from subsequent sale.
Where interest has been accounted as income on an accrual basis before the sale of a security, the amount already taxed as interest income on accrual basis shall be taken into account for computation of income arising from such sale.
Manuals Income Tax
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Interest on compensation taxed as Income from Other Sources when received; accounting standard ICDS does not displace the statute.
Interest received on compensation or enhanced compensation is taxable in the year of receipt and must be reported under Income from Other Sources, regardless of whether the assessee uses mercantile or cash accounting; where ICDS IV conflicts with the Act the statute prevails.
Manuals Income Tax
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ICDS applicability to gross-basis incomes confirms ICDS governs computation of taxable interest, royalty and fees for technical services.
ICDS IV (Revenue Recognition) applies to incomes taxed on a gross basis, including interest, royalty and fees for technical services payable to non-residents, and such receipts must be computed and recognized under ICDS principles for determining the amount chargeable to tax.
Manuals Income Tax
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Accrual-based revenue recognition: interest and royalty must be recognised despite collection uncertainty; statutory provisions prevail.
Interest is recognised on a time basis and royalty according to contractual terms; later non recovery may be claimed as a deduction under the amended deduction provisions, and applicable statutory provisions prevail over ICDS IV.
Manuals Income Tax
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Revenue recognition for leases: lease treated as income not sale; lessor taxed on rent and entitled to depreciation.
ICDS IV recognises revenue when risk and rewards transfer, so leases are not sales: lease rent is taxable income and the lessor may claim depreciation. Under hire purchase, both parties cannot claim depreciation on the same asset; substance-over-form principles indicate the owner giving the asset on hire should recognise sale while the hirer is entitled to depreciation.
Manuals Income Tax
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Revenue recognition under ICDS IV applies to real estate developers and BOT operators absent a specific exclusion.
In the absence of any specific ICDS notified for real estate developers, BOT projects and leases, the relevant provisions of the Income tax Act and applicable ICDS (including ICDS III and ICDS IV) apply to revenue recognition, income computation and disclosure for those transactions.
Manuals Income Tax
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Work-in-progress treatment: costs to secure construction contracts must be capitalised and not deducted until related work is performed.
Precontract costs to secure construction contracts must be treated as an asset and characterised as work-in-progress, representing amounts due from customers, and therefore should not be claimed as a deduction in the year of incurrence but carried forward and recognised when the related construction or installation work is performed.
Manuals Income Tax
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Incidental income in construction contracts: deduct from contract costs; investment returns taxed separately under income provisions.
Incidental incomes arising from construction contracts are not part of contract revenue and must be reduced from contract costs; examples include sale of surplus materials and disposal of plant and equipment. Income in the nature of interest, dividends and capital gains is excluded from incidental income and is taxed separately under applicable law.
Manuals Income Tax
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Proviso to section 36(1)(iii) inapplicable to construction contracts; interest on contract borrowings is deductible for execution purposes.
Proviso to section 36(1)(iii) does not apply to borrowings by contractors for executing construction contracts because such borrowings are not for acquisition of an asset; therefore interest on capital borrowed attributable to a construction contract is not barred by the proviso and is allowable as a deduction under ICDS III.
Manuals Income Tax
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Retention money recognition: recognise as revenue only when reasonable certainty of ultimate collection exists under ICDS construction rules.
Retention money within a construction contract is part of contract revenue and should be recognised as revenue on billing only when there is reasonable certainty of its ultimate collection, based on the contract's performance criteria and para 9 of ICDS on construction contracts.
Manuals Income Tax
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Contract revenue recognition: recognize only costs incurred when outcome is not reliably estimable; early-stage limit applies.
When the outcome of a construction contract cannot be estimated reliably, revenue is recognized only to the extent of costs incurred, subject to an early-stage completion limit specified in the Income Computation and Disclosure Standard on Construction Contracts.
Manuals Income Tax
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Percentage of completion method recognizes construction contract revenue, expenses and profit by proportion of work completed.
Recognition of revenue and expenses for construction contracts under ICDS III is governed by the percentage of completion method, whereby revenue, costs and profit are recognized by reference to the stage of completion of contract activity on the reporting date and reported in proportion to work completed.
Manuals Income Tax
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Bad debt deduction available without book write off when previously taxed income becomes irrecoverable under the statutory proviso.
If contract revenue was offered to tax under ICDS but not recorded in the books and later becomes irrecoverable, it cannot be written off in the absence of a book entry; instead, deduction may be claimed under the statutory proviso allowing bad debt deduction without book write off where the amount was taken into account in computing income in the previous year in which it became irrecoverable or an earlier year.

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AMENDMENTS TO THE CUSTOMS TARIFF ACT, 1975

1 February, 2026

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Union Budget 2026-27 - Finance Bill, 2026

(a) The First Schedule to the Customs Tariff Act, 1975 is proposed to be amended to carry out changes as under-

A.

Modification in Tariff rate (to be effective from 02.02.2026) * [Clause 136(a) of the Finance Bill, 2026]

*Will come into effect immediately through a declaration under the Provisional Collection of Taxes Act, 2023

Rate of Basic Customs Duty

S. No.

Heading, sub-heading, tariff item

Commodity

From (per cent)

To (per cent)

MSME sector

1.

6601 91 00,

6601 99 00

Umbrellas (other than garden umbrellas)

20%

20% or Rs. 60 per piece, whichever is higher

2.

6603 20 00, 6603 90 10, 6603 90 90

Parts, trimmings and accessories of articles of heading 6601 to 6602

10%

10% or Rs. 25 per kg., whichever is higher

B.

Decrease in Tariff rate (to be effective from 01.04.2026) [Clause 136(b) of the Finance Bill, 2026]

Rate of Basic Customs Duty

1.

9804

All dutiable goods, imported for personal use

20%

10%

C.

Tariff rate changes (without any change in effective rate of duty) [to be effective from 01.05.2026, unless otherwise specified] * [Clause 136(c) of the Finance Bill, 2026]

*Note:

1. The current applied rate of Basic Customs Duty on these commodities operate through their respective exemption/concessional duty notification(s). Such corresponding entries would be omitted from the concerned notification(s) with effect from 01.05.2026, as the same would operate through the Customs Tariff Act, 1975, in the manner as detailed below. It is an exercise for simplification of the Customs tariff structure and applicable Basic Customs Duty rate on these items would remain unchanged.

2. Heading and sub-heading referred in column (2) shall include all tariff items under such heading or sub- heading.

3. The said changes are to be read with consequent amendments related to Social Welfare Surcharge (SWS) and Agriculture Infrastructure and Development Cess (AIDC).

Rate of Duty

S. No.

Heading, sub-heading tariff item

Commodity

From

To

(1)

(2)

(3)

(4)

(5)

1.

0207 25 00, 0207 27 00

Meat and edible offal of turkeys, frozen

30%

5%

2.

0306 36 60

Artemia

5%

Nil

3.

0511 91 40

Artemia cysts

5%

Nil

4.

0802 11 00

Almonds, in shell

Rs.42 per kg

Rs.35 per kg

5.

0802 12 00

Almonds, shelled

Rs.120 per kg

Rs. 100 per kg

6.

0802 31 00

Walnuts, in shell

120%

100%

7.

1209 (other than those falling under sub headings 1209 91 and 1209 99)

Seeds, fruit and spores, of a kind used for sowing

30%

15%

8.

1505

Wool grease and fatty substances derived therefrom (including lanolin)

30%

15%

9.

2008 19 21, 2008 19 22, 2008 19 29, 2008 19 91

Makhana, other roasted nuts and seeds

150%

30%

10.

2008 19 92

Other nuts, otherwise prepared or preserved

150%

30%

11.

2309 90 31

Prawn and shrimps feed

15%

5%

12.

2504

Natural graphite

5%

2.5%

13.

2505

Natural sands of all kinds, whether or not coloured, other than metal bearing sands of chapter 26 of the Customs Tariff Act, 1975

5%

Nil

14.

2506

Quartz (other than natural sands); quartzite, whether or not roughly trimmed or merely cut, by sawing or otherwise, into blocks or slabs of a rectangular (including square) shape

5%

2.5%

15.

2530 90 91

Strontium sulphate (natural ore)

5%

Nil

16.

2701, 2702, 2703

Coal; briquettes, ovoids and similar solid fuels manufactured from coal; Lignite, whether or not agglomerated, excluding jet; Peat (including peat litter), whether or not agglomerated

5%

2.5%

17.

2709 00 10

Petroleum crude

5%

Re 1 per tonne

18.

2804 50 20

Tellurium

5%

Nil

19.

2804 61 00

Silicon, containing by weight not less than 99.99% of silicon

5%

Nil

20.

2804 69 00

Silicon, other

5%

Nil

21.

2804 90 00

Selenium

5%

Nil

22.

2805 30 00

Rare-earth metals, scandium and yttrium, whether or not intermixed or inter alloyed

5%

Nil

23.

2809 20 10

Phosphoric Acid

7.5%

5%

24.

2811 22 00

Silicon dioxide

7.5%

2.5%

25.

2816 40 00

Oxides, hydroxides and peroxides, of strontium or barium

7.5%

Nil

26.

2822 00 10

Cobalt oxides

7.5%

Nil

27.

2822 00 20

Cobalt hydroxides

7.5%

Nil

28.

2822 00 30

Commercial cobalt oxides

7.5%

Nil

29.

2825 20 00

Lithium oxide and hydroxide

7.5%

Nil

30.

2825 30

Vanadium oxides and hydroxides

7.5%

Nil

31.

2825 60 10

Germanium oxides

7.5%

Nil

32.

2825 70

Molybdenum oxides and hydroxides

7.5%

Nil

33.

2825 80 00

Antimony Oxides

7.5%

Nil

34.

2825 90 20

Cadmium oxide

7.5%

Nil

35.

2827 35 00

Chlorides of Nickel

7.5%

Nil

36.

2827 39 30

Strontium chloride

7.5%

Nil

37.

2833 24 00

Sulphates of Nickel

7.5%

Nil

38.

2834 21 00

Nitrates of potassium

7.5%

Nil

39.

2836 91 00

Lithium carbonates

7.5%

Nil

40.

2836 92 00

Strontium carbonate

7.5%

Nil

41.

2910 20 00

Methyloxirane (propylene oxide)

5%

2.5%

42.

2918 15 30

Bismuth citrate

7.5%

Nil

43.

3102 30 00

Ammonium nitrate, whether or not in aqueous solution

10%

5%

44.

3801

Artificial Graphite; colloidal or semi-colloidal graphite; preparations based on graphite or other carbon in form of pastes, blocks, plates or other semi- manufactures

7.5%

2.5%

45.

3808 93 30

Gibberellic acid

10%

5%

46.

3904

Polymers of vinyl chloride or of other halogenated olefins, in primary forms

10%

7.5%

47.

4906

Plans and drawings for architectural, engineering, industrial, commercial, topographical or similar purposes, being originals drawn by hand; hand-written texts; photographic reproductions on sensitised paper and carbon copies of the foregoing

10%

Nil

48.

5201 00 25

Other cotton of staple length exceeding 32.0 mm

5%

Nil

49.

7202 60 00

Ferro-nickel

2.5%

Nil

50.

7402 00 10

Blister copper

5%

Nil

51.

7802

Lead waste and scrap

5%

Nil

52.

7902

Zinc waste and scrap

5%

Nil

53.

8105 20 30

Cobalt powders

5%

Nil

54.

8419 89 12, 8419 89 13, 8419 89 14, 8419 89 15, 8419 89 16, 8419 89 17, 8419 89 19

Reactors, columns or towers or chemical storage tanks

10%

7.5%

NEW TARIFF LINES HAVE BEEN CREATED

S. No.

Chapter/ heading/sub- heading/tariff item mentioned in notification

Commodity

New tariff item being created w.e.f. 01.05.2026

Rate of duty

(1)

(2)

(3)

(4)

(5)

55.

0306 19 00

Krill, frozen

0306 19 10

15%

56.

0802 99 00

Pecan Nuts

0802 99 10

30%

57.

0810 40 00

Cranberries, fresh

0810 40 10

10%

58.

0810 40 00

Blueberries, fresh

0810 40 20

10%

59.

0811 90

Cranberries, frozen

0811 90 11 0811 90 91

10%

60.

0811 90

Blueberries, frozen

0811 90 12 0811 90 92

10%

61.

0813 40 90

Cranberries, dried

0813 40 30

10%

62.

0813 40 90

Blueberries, dried

0813 40 40

10%

63.

1207 99 90

Shea Nuts

1207 99 50

15%

64.

2008 93 00

Cranberries, otherwise prepared or preserved, whether or not containing added sugar or other sweetening matter or spirit, not elsewhere specified or included

2008 93 10

5%

65.

2008 99

Blueberries, otherwise prepared or preserved, whether or not containing added sugar or other sweetening matter or spirit, not elsewhere specified or included

2008 99 15

10%

66.

2106 90

Other than compound alcoholic preparations of a kind used for manufacture of beverages, of an alcoholic strength by volume exceeding 0.5% vol., determined at 20 degrees centigrade

2106 90 (other than 2106 90 51)

50%

67.

2202 99

Cranberry products

2202 99 21, 2202 99 31, 2202 99 91

10%

68.

2529 22 00

Acid grade fluorspar containing by weight more than 97% of calcium fluoride

2529 22 10

2.5%

69.

2615 90

Hafnium ores and concentrates

2615 10 10

Nil

70.

2841

Ammonium metavanadate

2841 90 10

2.5%

71.

29

Gibberellic acid

2932 20 40

5%

72.

29

Triethyl orthoformate

2915 90 96

5%

73.

29

Diethyl malonate

2917 19 22

5%

74.

29

DL-2 Aminobutanol

2922 19 30

5%

75.

29

Aceto butyrolactone

2932 20 50

5%

76.

29

Artemisinin

2932 99 30

5%

77.

29

Thymidine

2934 99 50

5%

78.

3302 10

Mixtures of odoriferous substances of a kind used in food or drink industries other than compound alcoholic preparations of a kind used for manufacture of beverages, of an alcoholic strength by volume exceeding 0.5% vol., determined at 20 degrees centigrade

3302 10 19, 3302 10 99

10%

79.

4104 11 00, 4104 19 00, 4105 10 00, 4106 21 00, 4106 31 00, 4106 91 00

Wet blue leather (hides and skin)

4104 11 10, 4104 19 10, 4105 10 10, 4106 21 10, 4106 31 10, 4106 91 10

Nil

80.

4702

Rayon grade wood pulp

4702 00 10

2.5%

81.

4823 90 90

All goods other than kites

4823 90 90 (kites fall under new tariff item 4823 90 40)

10%

82.

8101 99 90

Tungsten (wolfram) bars and rods, other than those obtained simply by sintering, profiles, plates, sheets, strip and foil

8101 99 20

5%

83.

8415 90 00

All goods other than indoor or outdoor units of split-system air conditioner

8415 90 90

10%

84.

8421 99 00

All goods other than Reverse Osmosis (RO) membrane element for household type filters

8421 99 90

7.5%

85.

8507 90

Battery separators

8507 90 20

5%

86.

8529 10 99, 8529 90 90

Parts suitable for use solely or principally with the apparatus of headings 8525, 8526 or 8527

8529 10 93, 8529 90 30

10%

87.

8609 00 00

Refrigerated containers

8609 00 10

5%

(b) In addition to the above, the First Schedule to the Customs Tariff Act, 1975 has also been amended to create new tariff items which will, inter-alia, help in better product identification; getting actual transaction data of precursor chemicals and help in their effective monitoring; facilitating, tracking exports and deciding policy measures for plant-based extract products. These changes will be effective from 1.05.2026, unless otherwise specified.

 


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Union Budget 2026-27 - Finance Bill, 2026

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