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2024 (7) TMI 1797
Case Laws Income Tax
Borrowed-services receipts retained treaty protection and were not taxable as fees for technical services in India.
Borrowed-services receipts earned by a foreign assessee from its Indian group entity were examined for characterisation as fees for technical services taxable in India. The assessment treated the amounts as consultancy and technical-service fees. Earlier decisions in the assessee's own assessment years had consistently held that such borrowed-services income was not taxable under the applicable treaty. As no new facts or distinguishing material were identified, the established treaty treatment continued to apply, and the receipts were not taxable as fees for technical services.

Circular No. PUBLIC NOTICE No. 10/2026 Dated:- 3-3-2026 Trade Notice Dated:- 3-3-2026 Trade Notice
Voluntary post-clearance revision of Bills of Entry under Section 18A is available through the ICES module. Importers must submit requests on ICEGATE for amendment, deletion or addition of records. Requests undergo Risk Management System treatment and may be facilitated or referred to a Revision Officer, who may approve, query or reject them. Revisions resulting in refund claims are flagged for officer processing and, upon approval, automatically transferred to the Refund Officer under the existing refund workflow.

Corp. Laws / SEBI / IBC
Dated:- 30-7-2026
PTI
The PPP framework permits private operators to modernise, operate and maintain school sports stadiums at their own cost, while providing free organised sports training to enrolled students. Operators may commercially offer paid coaching and facilities to external users outside school hours, subject to student-related obligations. Selection is based on technical eligibility and detailed evaluation of sports, PPP, operational and technology capabilities. Agreements have an initial five-year term, with possible extension based on performance, mutual consent and public interest. Child-protection compliance, bank-routed transactions and disqualification for insolvency or statutory and child-safety violations apply.

Circular No. PUBLIC NOTICE No. 11/2026 Dated:- 1-4-2026 Trade Notice Dated:- 1-4-2026 Trade Notice
Mandatory Body Worn Camera use is required for Customs officers conducting physical examination of import cargo to create a transparent and auditable examination record and minimise disputes. Recording must start before packages or containers are opened and continue through completion, covering goods examination, stakeholder interactions, seal condition, opening, verification of description and quantity, and sampling where required. Interruptions must be recorded with reasons. Recordings must be securely retained for two years, or until final disposal where linked to investigation, dispute or litigation.

Circular No. Standing order no. 12/2022 Dated:- 30-9-2022 Trade Notice Dated:- 30-9-2022 Trade Notic...
The NCLT/NCLAT Cell must monitor insolvency matters, represent the department before resolution professionals and tribunals, and protect Government revenue. It must check daily insolvency announcements against databases of pending arrears and pending demands, file timely claims, record case details, and ensure revenue claims are reflected in the corporate insolvency resolution process. The Cell must track orders on resolution, liquidation and withdrawal, update records, and submit monthly case lists. Revenue-recovery and Commissionerate units must maintain and share regularly updated arrears and pending-demand databases.

Corp. Laws / SEBI / IBC
Dated:- 30-7-2026
PTI
Quarterly financial reporting records revenue growth and improved EBITDA performance across CDMO, Complex Hospital Generics and Consumer Healthcare operations. CDMO growth was linked to order inflows, higher capacity utilisation, pricing discipline and commercial expansion, while quality compliance included an Establishment Inspection Report for the Sellersville facility and continued Zero Official Action Indicated status. The prior-year exceptional item related to one-time insolvency proceeds from a supplier claim filed before the NCLT. Consumer Healthcare growth was attributed to power brands, e-commerce, premiumisation, pricing and cost optimisation.

Circular No. PUBLIC NOTICE NO. 2/2025-26 Dated:- 27-11-2025 Trade Notice Dated:- 27-11-2025 Trade No...
Shri Sunil Kumar Gautam, Additional Commissioner of Customs, is designated as the First Appellate Authority under the Right to Information Act, 2005 for the Office of the Commissioner of Customs (General), Air Cargo Complex, Mumbai Customs Zone-III. The designation takes effect immediately and continues until further orders. The authority's jurisdiction covers the Office of the Commissioner of Customs (General), Air Cargo Complex, Mumbai.

Circular No. PUBLIC NOTICE NO. 4 /2026-27 Dated:- 17-4-2026 Trade Notice Dated:- 17-4-2026 Trade Not...
International transhipment of Full Container Load and Less than full Container Load cargo is permitted from all seaports and international airports amid maritime-route disruptions. Requests are to receive priority processing after due verification by the authorised jurisdictional Assistant or Deputy Commissioner of Customs. For cargo moving to another Customs station for onward transhipment, prior consent must be coordinated with the transit or destination station to ensure secure storage capacity and logistical support before permission is issued.

Circular No. Standing Order No. 7/2026 Dated:- 13-7-2026 Trade Notice Dated:- 13-7-2026 Trade Notice
Dedicated Tax Recovery Cells are established to centrally record, monitor and recover confirmed customs arrears after the appeal period expires without an appeal. TRCs must maintain case files and recovery checklists, prioritise recoverable arrears, and pursue staged measures including payment demands, bank-guarantee encashment, refund adjustment, garnishee recovery, bank-account attachment, system alerts, detention orders and asset identification. Property attachment and sale procedures apply where recovery remains unpaid. Irrecoverable arrears may be proposed for write-off only after documented recovery efforts fail and no relatable property is available.

GST treatment of security personnel services depends on the supplier's status and the recipient's registration. A private limited company, as a body corporate, is liable to charge and pay GST under forward charge. A proprietorship firm supplying security personnel services to a registered person is covered by reverse charge, with GST payable by the recipient. If the proprietorship supplies to an unregistered recipient, GST applies under forward charge and is payable by the supplier.

Delayed charitable-trust registration renewal may be filed as an application with delay, supported by a condonation petition, founder's death certificate, trustee-appointment resolution, and evidence of administrative disruption. The commentary identifies Form 105 as the replacement for Form 10AB after transition to the Income-tax Act, 2025, while noting continued relevance of legacy condonation mechanisms through transitional provisions. Death and consequential management change may support condonation, but relief is discretionary and requires proper documentation.

Notification No. F.17(131)ACCT/GST/2017/17837751 Dated:- 17-9-2025 Rajasthan SGST
Registered persons with aggregate turnover in any financial year not exceeding the prescribed threshold are exempted from filing the annual return under the Rajasthan Goods and Services Tax Act, 2017 for financial year 2024-25 onwards. The exemption takes effect from 22 September 2025.

Notification No. F.6(286)CTD/DCIT/2024/BIOMETRIC/286-962 Dated:- 14-10-2025 Rajasthan SGST
GST registration biometric authentication facilitation centres in Rajasthan are amended under the Rajasthan Goods and Services Tax Rules, 2017. The centre at serial number 24 is renamed Statue Circle, Jaipur, with a substituted address at the Office of the Principal Commissioner, CGST and Central Excise. The centre at serial number 72 is renamed Vidhyadhar Nagar, Jaipur, with a substituted address at the Office of the Deputy/Assistant Commissioner, CGST and Central Excise. The substitutions take effect from 9 October 2025.

Notice issued by SGST against DRC-01A u/s 74.
Discussion Forum VAT / Sales Tax
Input tax credit following retrospective cancellation of a supplier's GST registration depends on whether the recipient can establish a genuine transaction and compliance with credit conditions. Original invoices, e-way bills and timely bank payment may support the claim but may not alone prove actual receipt of goods. The recipient should provide stock records, purchase ledgers, goods-receipt notes, consumption or sale records, and delivery evidence. Cancellation from the supplier's initial registration date may invite stricter scrutiny, with inadequate proof creating exposure to reversal of credit, interest and penalty.

Circular No. PUBLIC NOTICE NO. 61/2024 Dated:- 30-7-2024 Trade Notice Dated:- 30-7-2024 Trade Notice
Drawback adjudication proceedings concern alleged non-realisation of export proceeds and recovery of allegedly ineligible drawback with applicable interest and penalty. Noticees must file written replies and foreign-remittance evidence, including bank realisation certificates, and may attend personally, through an authorised representative, or by video conference. Virtual participants must provide identification and contact details in advance. Noticees who do not require a hearing may communicate this in writing. Failure to make representation by the scheduled hearing date may lead to an ex parte decision on available records and evidence.

Notification No. 102/2026 Dated:- 29-7-2026 Income-Tax Act, 2025
Tax exemption is notified for the Kerala Real Estate Regulatory Authority under Schedule III read with section 11 of the Income-tax Act, 2025, covering registration fees, fees for compensation claims and complaints, and government grants. The exemption for the tax year 2026-27 requires that the Authority not undertake commercial activity, file its return of income as required, and maintain unchanged activities and specified income. Non-compliance results in withdrawal of exemption and initiation of proceedings under the Act.

Circular No. F.17 (134) ACCT/ GST/ 2017 PART-II-1613 Dated:- 7-7-2026 Rajasthan SGST Dated:- 7-7-202...
GST return scrutiny is to be conducted through data-based selection and specified discrepancy parameters, with mandatory scrutiny for identified mismatches and risk-based selection for other parameters. Officers must issue Form GST-ASMT-10 stating all discrepancies and consider replies in ASMT-11. Proceedings may be dropped through ASMT-12 where explanations are accepted or liabilities are paid through DRC-03. Cases involving unsatisfactory replies or failure to correct accepted discrepancies must be transferred to the jurisdictional proper officer for demand action under the applicable provisions, subject to prior approval for higher-value adjudication cases.

2026 (4) TMI 1900
Case Laws Income Tax
Notice authentication under Section 282A(2) does not require a digital signature when the officer's name and designation appear.
Authentication of a notice under Section 148 is satisfied under Section 282A(2) where the designated income-tax authority's name and office are printed, stamped or otherwise written on the notice. A computer-generated notice displaying the issuing officer's name and designation does not require a digital signature under that provision. Authorities from an earlier non-digital context do not govern this statutory authentication requirement. Accordingly, absence of the Assessing Officer's signature does not invalidate the notice or the reassessment proceedings.

Circular No. PUBLIC NOTICE NO. 63/2024 Dated:- 2-8-2024 Trade Notice Dated:- 2-8-2024 Trade Notice
Exporters who missed the first hearing in drawback-related proceedings are scheduled for a second personal hearing and may appear personally, through an authorised representative, or by video conferencing. They must file a written reply with foreign remittance and export-proceeds documents, including BRCs. Virtual participants must provide identification and contact details in advance. Exporters may waive the hearing in writing. Absence of representation by the scheduled date may result in an ex parte decision on available records and evidence.

Notification No. 101/2026 Dated:- 29-7-2026 Income-Tax Act, 2025
Tax exemption under section 10(46) of the Income-tax Act, 1961 applies to specified income of the Kerala Real Estate Regulatory Authority, including registration fees, fees for compensation claims and complaints, and government grants. The Authority must not engage in commercial activity, must maintain the same activities and nature of specified income, and must comply with applicable income-tax return filing requirements. Failure to meet these conditions may result in penal action and withdrawal of exemption. The notification operates retrospectively for the stated relevant assessment years.

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