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Income attribution: clarifies tax liability of the legal owner and joint-and-several responsibility for income included in another's return.
Clause 100 assigns tax liability to the person in whose name an asset stands or whose firm membership produces attributed income, imposes joint and several liability for jointly held assets allowing recovery from any co-owner for the whole tax due, applies existing procedural recovery mechanisms to enforce the liability, and overrides contrary provisions in other laws to ensure primacy in determining tax obligations arising from income attribution.
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Clubbing of income: new clause expands inclusion of spouse, minor child and transferred-asset income in assessee's taxable income.
Clause 99 attributes to the individual income arising to a spouse from employment or remuneration in concerns where the individual has a substantial interest, income from assets transferred to a spouse or a son's wife without adequate consideration, and income of a minor child except earnings from the child's manual work or personal skill; it also prescribes a formula for income attributable when transferred assets are invested and treats conversion of individual property to HUF as income of the individual.
Act Rules Bills
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Revocable transfer definitions broaden tax reach, treating arrangements that preserve transferor control as attributable income to transferor.
Clause 98 of the Income Tax Bill, 2025 and Section 63 of the Income Tax Act define transfer to include settlements, trusts, covenants, agreements or arrangements, and define revocable transfer to cover provisions enabling direct or indirect re transfer of income or assets or re assumption of power by the transferor. Both provisions attribute income to the transferor where economic substance shows retention of control or benefit, broadening the tax net over arrangements that preserve transferor influence.
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Chargeability of income in asset transfers: revocable transfers taxed to transferor, with narrow irrevocable-transfer exceptions.
Clause 97 treats income from a revocable transfer of assets as taxable in the hands of the transferor, while providing exceptions for truly irrevocable transfers where the transferor derives no direct or indirect benefit; if a power to revoke later arises the income becomes chargeable to the transferor, thereby aligning taxation with economic control and preventing tax avoidance through strategic transfers.
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Transfer of income without asset transfer: such income is taxed in the transferor's hands to prevent tax avoidance.
Clause 96 and Section 60 provide that income arising by virtue of a transfer, whether revocable or irrevocable and irrespective of timing, is chargeable to tax in the transferor's hands if the asset generating that income has not been transferred, thereby preserving the link between income and its source asset to prevent tax avoidance.
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Remission of liabilities taxable - forgiven debts and other benefits must be included as income when received under revised charge rules.
Clause 95 of the Income Tax Bill, 2025, treats any benefit obtained from the remission or cessation of a liability for which a deduction was previously allowed as taxable in the year received, applying principles from Section 38(1)(a) to non business income heads. Section 59 of the Income tax Act, 1961, applies Section 41(1) similarly to ensure forgiven liabilities are included in taxable income, but both provisions present valuation and timing ambiguities for non cash benefits and assessment year determinations.
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Disallowance of deductions: withholding compliance ties deductibility for cross border payments and personal expenses.
Clause 94 disallows deductions from income from other sources for personal expenses and for interest or salaries payable outside India where tax has not been paid or deducted under the withholding framework; it extends selected business-income deduction rules to other sources, prescribes computation rules for foreign companies, disallows deductions for gambling and lotteries while excepting horse racing maintenance, and links deductibility to compliance with withholding obligations.
Act Rules Bills
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Deductions for income from other sources clarified, aligning allowable expenses and curbing dividend-related deduction claims.
Clause 93 of the Income Tax Bill, 2025 prescribes deductions for Income from other sources, allowing reasonable sums for realising dividends or interest on securities, deductions for specified income categories via cross references, a capped family pension deduction, non capital expenditures wholly and exclusively for earning such income, a 50% concession for certain incomes, and targeted restrictions limiting deductible interest tied to certain dividend incomes to a proportion of that income.
Act Rules Bills
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Taxation of miscellaneous income broadens taxable sources to include modern streams like digital assets and trust distributions.
Clause 92 establishes a residual charging rule that any income not charged under other heads and not excluded is taxable under Income from other sources, enumerating a non exhaustive list of receipts-dividends, gambling winnings, employee fund contributions, specified insurance proceeds, interest including on compensation, rental of machinery or furniture, forfeited advances, employment termination compensation, business trust distributions, life insurance sums outside specified products, and gifts or property transfers-while providing exemptions for transfers from relatives, on marriage, under wills and certain local authority receipts, and setting valuation and definition rules including treatment of digital assets.
Act Rules Bills
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Valuation officer referral: a statutory mechanism to address discrepancies between declared asset values and fair market value.
Clause 91 empowers the Assessing Officer to refer a capital asset's valuation to a Valuation Officer where an assessee's declared amount appears inconsistent with the fair market value, applying to assets valued by registered valuers and to other cases meeting prescribed thresholds or circumstances, and adopts procedural modifications by reference to Section 269(3)-(8).
Act Rules Bills
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Cost of acquisition rules clarified: FMV option and acquisition cost deemed nil when indeterminable, affecting capital gains computation.
Clause 90 defines cost of improvement as nil for intangible assets and permits post reference date expenditure for other assets; sets cost of acquisition as purchase price or previous owner's purchase price and deems cost nil where indeterminable; provides tailored rules for financial assets to avoid taxing non economic gains; and allows a fair market value option as cost of acquisition for earlier acquisitions to reflect market and inflationary changes.
Act Rules Bills
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Extension of time for reinvesting capital gains tied to receipt of compensation preserves exemption eligibility after compulsory acquisition.
Where an original asset is compulsorily acquired and compensation is delayed, the period for acquiring a new asset or depositing or investing capital gains is calculated from the date of receipt of compensation rather than the date of transfer; Clause 89 of the Income Tax Bill, 2025, states this rule and declares it to operate irrespective of conflicting timelines in specified sections, and Section 54H of the Income-tax Act, 1961, operates on a comparable principle tied to specified reinvestment provisions.
Act Rules Bills
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Capital gains exemption for industrial relocations to SEZs conditions relief on reinvestment in new SEZ assets and deposit rules.
Clause 88 grants a capital gains exemption when assessees transfer assets while shifting an industrial undertaking from an urban area to an SEZ, conditional on reinvesting gains into new SEZ assets within the prescribed investment window; unutilized gains must be deposited in a specified account and any excess of gains over the cost of new assets is taxable. Eligibility centers on assets used in the undertaking and utilisation for notified SEZ investments, with deposits treated as part of the new asset's cost for calculating the exemption.
Act Rules Bills
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Capital gains exemption for industrial relocation to non urban areas conditional on reinvestment and deposit requirements.
Exemption of capital gains on transfer of assets for industrial undertakings shifting from urban to non urban areas is subject to reinvestment in qualifying assets (machinery, plant, buildings, land or rights therein) acquired within the prescribed timeframe; any shortfall between capital gains and cost of new assets is taxable, and unutilised gains must be deposited in a specified bank or institution before filing the return, with untapped deposits taxed after the statutory period; the definition of urban area and scheme specified expenditure govern eligibility.
Act Rules Bills
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Capital gains exemption for residential reinvestment preserved with clearer compliance and monetary caps under the 2025 proposal.
Clause 86 provides a capital gains exemption for individuals and HUFs who reinvest long-term capital gains from specified asset transfers (excluding residential houses) into a residential house in India within prescribed purchase or construction timeframes. The exemption is proportional when net consideration exceeds the replacement cost and full when replacement cost equals or exceeds net consideration. Unutilised gains must be deposited under a notified government scheme before filing returns, and exempted gains become taxable if the replacement asset is transferred within three years. Ownership of multiple residential houses or acquisition of another house within specified periods disqualifies the exemption.
Act Rules Bills
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Capital gains deferral on compulsory acquisition permits tax relief when compensation is reinvested in similar industrial assets.
Clause 84 provides a deferral regime for capital gains on compulsory acquisition where compensation reinvested in similar industrial land or buildings within three years is either exempt or adjusts the cost basis: excess gains over new asset cost are taxed as income and the new asset's cost is set to nil for future computations, while gains equal to or below cost reduce the asset's cost. Unutilised gains must be deposited by the return filing due date and are treated as part of the deemed cost; unutilised amounts after the specified period are charged as income and subject to notified withdrawal rules.
Act Rules Bills
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Capital gains exemption for reinvestment in specified bonds preserves non taxability subject to retention and anti abuse rules.
Clause 85 provides that capital gains from transfer of long term assets are not charged if the assessee reinvests whole or part of such gains in government notified bonds within six months, subject to a per year investment ceiling and a specified retention period; transfers, conversions, or loans against the new asset within the lock in are treated as taxable events and investments claiming this exemption cannot simultaneously claim alternative deductions.
Act Rules Bills
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Capital gains exemption for agricultural land: reinvest sale proceeds in new agricultural land within two years to defer tax.
Capital gains on transfer of agricultural land are not charged if proceeds are reinvested in new agricultural land within two years by individuals or HUFs who used the land for agriculture in the two years prior. Unutilised gains at filing must be deposited in a specified bank account and applied under a government-notified scheme; unused deposits after the prescribed period are taxed and may be withdrawn per the scheme. Excess gains are taxed under the bill's taxing provision and the new asset's cost is treated as nil for subsequent gains if sold within three years; otherwise the cost basis is reduced by the capital gains.
Act Rules Bills
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Capital gains reinvestment relief: deferral for gains when proceeds are reinvested in residential property with deposit safeguards.
Clause 82 permits deferral or exemption of capital gains from sale of residential property where proceeds are reinvested in another residential property, treating gains exceeding the new asset's cost as taxable. Unutilized gains must be deposited in a specified bank or institution under a notified scheme and such deposits count toward the new asset's cost. Deposited amounts not applied within the prescribed period become taxable though the clause provides for withdrawal of unused sums. The clause allows a one time option to invest in two houses subject to a gain threshold and imposes caps on eligible cost and gains to target relief.
Act Rules Bills
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Advance money treatment: deduction from cost of acquisition barred where the advance was included in total income.
Clause 81 requires that advance money retained during negotiations for transfer of a capital asset be deducted from the cost of acquisition (original cost, written down value, or fair market value) but prohibits that deduction where the advance has already been included in the assessee's total income under the statutory provision referenced, aligning with Section 51's objective while differing in the cross references and raising compliance and interpretive issues.

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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.

 


Full Text:

Union Budget 2026-27 - Finance Bill, 2026

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Acts Income Tax