Employee stock option scheme expenditure actually incurred and cross-charged by a parent entity is deductible as business expenditure under Section 37(1) of the Income-tax Act. Characterising the cost as notional, contingent or capital does not justify disallowance where jurisdictional High Court and coordinate bench rulings recognise ESOP costs as revenue expenditure. Consistency also supports deduction where the identical issue on unchanged facts has been accepted for the same taxpayer in an earlier assessment year.

Penalty proceedings for concealment of income or furnishing inaccurate particulars require a notice that clearly specifies the applicable charge. Retaining both alternative limbs in a notice under Section 274 read with Section 271(1)(c), without striking out the inapplicable limb, prevents an effective response and invalidates the proceedings. Assessment context or separately recorded satisfaction does not cure this defect. The penalty was consequently deleted because the notice failed to identify the precise charge.

Interest awarded under Section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsorily acquired agricultural land forms an accretion to the land value and is part of enhanced compensation, unlike Section 34 interest for delayed payment. The Finance (No. 2) Act, 2009 provisions governing taxation of compensation interest addressed timing and did not change the character of Section 28 interest. Where assessment followed enquiry into the receipt and exemption claim, acceptance of the claim was supported by the Supreme Court position or was at least a possible view on a debatable issue. Revision based only on an audit objection and a contrary High Court view lacking consideration of that position was unsustainable.

Cash deposits supported by documentary evidence of land-sale proceeds cannot be treated as unexplained. The sale deed and bank statement established that part of the deposits arose from the land sale, requiring deletion of the addition to that extent. The balance deposit remained unexplained because no satisfactory source was established, and the addition was sustained for that portion.

An alleged legal heir cannot maintain an appeal for a deceased assessee without establishing legal representative status. Representation requires proof that the person represents the deceased's estate or has intermeddled with it, or that proceedings have been initiated against that person in a representative capacity under the applicable statutory provision. In the absence of either proof of representation or representative-capacity proceedings, the alleged heir lacks competence to pursue the appeal.

Failure to file Form 10IC within the prescribed time may be treated as an inadvertent procedural error where a domestic company has elected the concessional tax regime under Section 115BAA in its return of income. Filing the form later with an incorrect assessment year does not by itself defeat the claim where the return evidences the election. Form 10IC should be considered and the claim for concessional taxation examined afresh, subject to verification that all remaining statutory conditions are satisfied.

Cash deposits were explained through an established opening cash balance, current earnings and past savings. A statement of affairs showed the opening balance, and the preceding assessment completed under scrutiny supported the availability of that cash. The unexplained-money addition was therefore unsustainable and was directed to be deleted.

Investment treated as undisclosed was explained through funds of the Hindu Undivided Family. The HUF's existence had been accepted and its substantial agricultural land was supported by the record. Bank deposits were substantially attributable to the HUF's agricultural income, making those funds available for the investments in question. The undisclosed-investment addition was therefore deleted.

Undisputed tax deducted at source reflected in Form 26AS must be credited against an assessee's tax liability when a return is filed in response to a reassessment notice. Tax deducted by the purchaser constitutes an income-tax payment on the assessee's behalf and, after adjustment against the determined liability, any excess must be refunded following verification. Reassessment proceedings cannot deny TDS credit merely because the assessee did not file an original return.

Section 80P(2)(d) permits a co-operative society to deduct interest or dividend income derived from investments with another co-operative society. Co-operative banks remain co-operative societies under the statutory definition; section 80P(4) only prevents co-operative banks themselves from claiming section 80P deductions and does not bar other co-operative societies from deducting interest earned from investments with them. Decisions concerning deduction for banking business under section 80P(2)(a)(i) do not govern claims under section 80P(2)(d). In the absence of a jurisdictional ruling amid divergent views, the interpretation favourable to the assessee applies, allowing deduction for interest on fixed deposits and savings accounts with co-operative banks.

Faceless reassessment required a notified statutory scheme authorising assessment, reassessment and related proceedings. Because the applicable faceless scheme took effect only on 29 March 2022, a faceless assessment framed on 28 March 2022 lacked legal authority. Applying a coordinate-bench ruling on identical facts, the assessment was treated as without jurisdiction and quashed in favour of the assessee.

Transfer and posting remain within the employer's administrative prerogative and are incidents of service. Employees holding transferable posts have no vested right to remain at a particular station. Judicial interference with repatriation or transfer is limited to orders tainted by mala fides, discrimination, or breach of a mandatory statutory rule. Repatriation from Shillong to employees' original zones under the revised inter-commissionerate transfer policy was not shown to involve any such defect; the challenge therefore failed and the repatriation order remained effective.

Foreign Trade Policy 2023 now permits applicants outside the Gems & Jewelry Sector to obtain One Star Export House status based on export performance in any two of the three preceding financial years, subject to the other requirements of paragraph 1.25. The general requirement of export performance across all three preceding financial years remains applicable for grant of status, while the Gems & Jewelry Sector continues to require performance in both preceding financial years. The amendment takes immediate effect.

Para 4.63 of the Foreign Trade Policy 2023 is amended with immediate effect to remove the reference to exemption from Compensation Cess on imports under Diamond Imprest Authorisation. The amendment reflects discontinuation of Compensation Cess from 1 February 2026. Imports under Diamond Imprest Authorisation continue to be exempt from Basic Customs Duty, additional customs duties, Education Cess, anti-dumping duty, countervailing duty, safeguard duties where applicable, and the whole of Integrated Tax levied under the Customs Tariff Act.

TRQ allocation for raw sugar imports is available online to millers and refiners with functional in-house refining capacity, subject to capacity evidence, scrutiny and preference for import completion by the prescribed date. Quota holders must provide Letters of Credit or confirmed contracts, use or timely surrender allocations, and process imported raw sugar at their own facilities. Each specified quantity of raw sugar must yield refined sugar for domestic sale within the stipulated period; non-compliance may trigger customs duty, interest, cancellation or future allocation restrictions. Existing Advance Authorisation holders under SION E52 may elect one-time conversion to TRQ for eligible imported raw sugar, subject to payment of exempted GST, prescribed documentation and domestic-sale reporting.

Export obligation extensions approved by the PRC/EPCG Committee for Advance Authorisation and EPCG Authorisation will be processed automatically through the DGFT system. Exporters need not submit a separate extension application to the Regional Authority after committee approval. The system will issue a fee-payment letter on the committee file; once the prescribed fee is paid through the portal and the response is submitted, it will create and approve the extension file and generate the extension letter. The revised export obligation expiry date will update the relevant authorisation records and be transmitted to ICEGATE, reducing manual processing and verification.

APM Terminals India Pvt. Ltd. is appointed under Section 45(1) of the Customs Act, 1962 as custodian of imported goods landed at Kamarajar Port and received at its container freight station, until clearance for home consumption, warehousing or transhipment. It is also appointed custodian of export cargo brought into its premises until export from that port. The custodian must comply with Section 45, the Handling of Cargo in Customs Areas Regulations, 2009, and applicable rules, regulations and instructions. The appointment takes effect from 3 August 2026.

International transhipment of FCL and LCL cargo is permitted from all seaports and international airports, including movement through other Customs stations, subject to the Customs Act and applicable rules. Liquid bulk, break bulk and solid/dry bulk cargo diverted to Indian ports may be temporarily unloaded, stored and transhipped or re-exported with case-specific permission, Customs supervision, secure custody, inventory controls, testing and safeguards against home consumption or diversion. Multi-station transhipment requires prior nodal-officer consent and controlled movement. Custodians remain responsible for cargo security, handling, accounting and reporting irregularities. These measures operate until 31 October 2026.

Foreign Portfolio Investors may submit a Power of Attorney to custodians specifying their address through a digital signature compliant with the Information Technology Act, 2000. Such digitally executed Powers of Attorney are admissible as proof of address under the FPI KYC framework, replacing the requirement for notarisation, apostillisation or consularisation. The amendment to the FPI Master Circular takes effect on August 20, 2026, enabling faster digital onboarding of FPI applicants.

IFSCA-regulated entities may access the systems of SEBI-registered KYC Registration Agencies to undertake client KYC, enabling interoperability and information sharing. Entities accessing KRA systems become subject to the SEBI KRA Regulations and must comply with the applicable KYC norms prescribed in the securities-market Master Circular, as amended. Where clients are registered as Foreign Portfolio Investors, such entities must also comply with the prescribed data-security guidelines for FPIs, designated depository participants and eligible foreign investors. These requirements apply with immediate effect.