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Special Additional Excise Duty on Aviation Turbine Fuel cleared for export is revised to Rs. 10.5 per litre by substituting the corresponding table entry in the central excise rate schedule. The revised rate applies from 1 October 2026 to export clearances of Aviation Turbine Fuel, replacing the earlier rate prescribed for that category.

Tariff values for specified edible oils, brass scrap, gold, silver and areca nuts are substituted for customs valuation. Per metric tonne, values are fixed at US$1,229 for crude palm oil, US$1,240 for RBD palm oil, US$1,235 for other palm oil, US$1,248 for crude palmolein, US$1,251 for RBD palmolein, US$1,250 for other palmolein, US$1,280 for crude soya bean oil and US$8,149 for brass scrap. Qualifying gold and specified gold forms are valued at US$1,339 per 10 grams, while specified silver forms are valued at US$1,965 per kilogram. Areca nuts remain at US$11,574 per metric tonne. The substituted tariff-value tables apply from 1 October 2026.

The special additional excise duty schedule governing petrol and diesel exports is amended: the entry in column (4) against serial number 2 is substituted with a rate of Rs. 16 per litre. Effective 1 October 2026, the substituted rate replaces the prior rate specified for that serial number under the existing duty schedule.

Employees' Pension Scheme eligibility is extended to persons who were members of the Employees' Provident Funds Scheme but were not members of the pension scheme, provided their wages on the date the revised wage ceiling is notified are equal to or below that ceiling. The inserted eligibility clause brings qualifying EPF members within pension-scheme coverage based on the revised wage threshold. The amendment takes effect from 17 September 2026.

From 1 October 2026, employer and employee contributions become payable under the Code on Social Security, 2020 for establishments across Niwari and the entire areas of 24 previously partially implemented districts in Madhya Pradesh. Employees of those establishments will receive Employees' State Insurance Corporation benefits under Chapter IV, extending ESIC coverage throughout the specified district areas.

Minimum Import Price condition on imports of Sulfadiazine API under Chapter 29 of ITC HS 2022, Schedule I, is extended until 30 November 2026. Imports remain subject to an MIP of Rs. 1,774 per kg on CIF value. All other conditions governing the MIP continue unchanged, maintaining the existing import-policy restriction for this active pharmaceutical ingredient.

Institute for Financial Management and Research is approved as an institution for social science or statistical research under the university, college or other institution category for the specified Income-tax Act purposes. The approval applies for tax years 2026-2027 through 2030-2031, subject to continued Scientific and Industrial Research Organisation approval in every relevant tax year. The institution must comply with prescribed conditions, submit an annual donation statement in Form No. 15 by 31 May following the tax year of receipt, and issue donors a Form No. 16 certificate stating the donation amount.

UPASI Tea Research Foundation is approved as an 'Other Institution' for scientific research purposes under the Income-tax Act, enabling the specified donation-related tax treatment. The approval applies for tax years 2026-2027 to 2030-2031 and remains conditional on the foundation retaining Scientific and Industrial Research Organization approval throughout each relevant tax year. It must also comply with prescribed conditions, submit an annual donation statement in Form No. 15 by 31 May following the relevant tax year, and provide donors with Form No. 16 certificates stating the donation amount.

Santhigiri Ashram is approved as a university, college or other institution for social science or statistical research under the Income-tax Act, 2025, for tax years 2026-27 to 2030-31. The approval requires continuing Scientific and Industrial Research Organisation status in each effective tax year, compliance with rule 34, annual Form 15 donation statements delivered by 31 May following the tax year in which donations are received, and Form 16 donation certificates issued to donors.

The deadline for TRQ holders to surrender unutilised quantities allocated for import of raw sugar is extended to 15 October 2026. Surrender remains subject to payment of 0.5% of the CIF value of the quantity surrendered, under the existing modalities. All other terms and conditions governing the tariff-rate quota allocation for raw sugar imports remain unchanged.

Stock brokers must prominently display SEBI-supplied investor awareness messages on websites and trading apps under a phased framework. From October 5 to 31, 2026, websites must display both the messages and risk disclosures, while app display is voluntary and may replace risk disclosures on days the messages are shown. From November 1, 2026, brokers must place the specified messages on website landing pages and display investor awareness messages and risk disclosures on alternate days on trading-app landing pages. Stock exchanges and depositories must disseminate the requirements, display the messages unchanged, and amend relevant rules. Existing risk-disclosure requirements otherwise remain unchanged.

2025 (4) TMI 2189
Case Laws Income Tax
Transfer-pricing comparability requires uniform turnover filters, verified FAR analysis, foreign-currency interest benchmarking, and risk-based working-capital adjustments.
Transfer-pricing comparability requires valid economic criteria, including uniform application of a ten-times turnover filter; prior inclusion in a taxpayer's study does not prevent a later comparability challenge. Functional comparability requires verification of functions, assets and risks, including relevant filters for disputed companies. Foreign-currency receivables should be benchmarked to the relevant foreign-currency market rate, with LIBOR plus 200 basis points applied instead of domestic rupee rates. Provisions for bad and doubtful debts are not operating costs because they do not represent actual expenditure. Negative working-capital adjustments require examination of working-capital risk and an adequate opportunity to be heard.

2025 (4) TMI 2190
Case Laws Income Tax
Minimum Alternate Tax excludes nationalised banks outside the Companies Act financial-statement regime for book-profit taxation.
Minimum Alternate Tax under section 115JB is inapplicable to a corresponding new bank constituted under the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970. The book-profit computation provision applies only where the second proviso to section 129(1) of the Companies Act, 2013 applies. Such a bank is neither formed nor registered under the Companies Act and is not a banking company for that provision. Its deemed status as an Indian company for Income-tax Act purposes cannot extend to Companies Act status; therefore, book-profit tax cannot be levied.

2025 (4) TMI 2191
Case Laws Income Tax
Mandatory response opportunity for reassessment notices cannot be curtailed, and later proceedings remain invalid despite assessee participation.
Section 148A(b) requires a minimum seven-day period for an assessee to respond before a reassessment notice is issued. Allowing only five days breaches the mandatory hearing requirement, creates a substantive jurisdictional defect, and violates principles of natural justice. Participation in assessment proceedings does not cure that defect under sections 292B or 292BB. The section 148A(b) notice, ensuing section 148A(d) order, section 148 notice, and reassessment order were quashed.

2025 (4) TMI 2192
Case Laws Income Tax
Cooperative society deposit interest qualifies for tax deduction, while bank deposit interest remains taxable after expense verification.
Interest income earned by a cooperative society from investments with another cooperative society qualifies for deduction under section 80P(2)(d). Interest on fixed deposits and savings accounts with cooperative banks or scheduled commercial banks is assessable as Income from Other Sources, rather than as income from providing credit facilities to members or investments with another cooperative society; it does not qualify under section 80P(2)(a)(i) or section 80P(2)(d). Administrative or other expenditure connected with earning that taxable interest may be deducted under section 57, subject to verification.

2025 (4) TMI 2193
Case Laws Income Tax
Brokerage commission estimation replaces peak-credit addition where seized cash records show finance-brokering transactions rather than unexplained cash balances.
Cash receipts and payments recorded in seized material reflected finance-brokering transactions undertaken for commission rather than balances supporting a peak-credit addition. Where the assessee acted as a broker arranging finance, commission income is to be estimated at 3% of total cash receipts, consistent with the approach applied in earlier assessment years. The cash-flow pattern does not support retaining an addition calculated on peak credit.

2025 (11) TMI 2079
Case Laws Income Tax
Faceless reassessment procedure and statutory approval requirements can invalidate notices issued beyond the prescribed period.
Reassessment initiation under the post-1 April 2021 regime must comply with the notified faceless procedure. Notices issued by a jurisdictional Assessing Officer outside that procedure are treated as jurisdictionally defective and liable to be quashed. For notices issued more than three years after the relevant assessment year, Section 151(ii) requires sanction from the Principal Chief Commissioner or Principal Director General; approval solely from a Principal Commissioner is insufficient. Invalid initiation on either ground renders the consequential reassessment void ab initio.

2026 (6) TMI 1518
Case Laws Income Tax
Unexplained money additions require corroborated evidence beyond WhatsApp chats to establish receipt of unrecorded property-sale proceeds.
Section 69A requires material demonstrating that the assessee owned or received unrecorded money and that its source was unexplained. Uncorroborated WhatsApp chats concerning alleged Dubai property-sale proceeds, without cash, foreign-currency or banking evidence, third-party confirmation, or a live and proximate nexus to the assessee, cannot alone establish receipt. Where the property is legally owned by a third-party entity, an unexplained-money addition based only on such electronic records rests on conjecture and suspicion. The proposed addition and consequential taxation under Section 115BBE were therefore unsustainable.

2025 (12) TMI 1918
Case Laws Income Tax
Genuine hardship in delayed return claims requires liberal consideration of pandemic disruptions and cannot be negated by available deductions.
Genuine hardship under Section 119(2)(b) requires a liberal assessment of the reasons for delay in filing a return. Pandemic restrictions, reduced staff capacity, limited access to business records and compliance duties at construction sites may constitute material circumstances supporting condonation. Circular No. 09/2015 on belated refund claims and carry-forward of losses did not govern the application. Availability of a deduction under Section 80-IBA could not justify refusing condonation. The refusal to condone the 13-day delay was unsustainable and required reconsideration after addressing the stated hardship factors.

2025 (11) TMI 2078
Case Laws Indian Laws
Independent Sanction Review and Timely Investigation: non-speaking sanctions and unexplained prolonged investigation undermine criminal prosecution.
Arms-licensing discretion requires a police report before grant unless the statutory proviso permits action without it after the prescribed period; where no period is prescribed, the authority must allow reasonable time in the circumstances. Prosecution sanction for public servants requires visible, independent application of mind, identifying the material considered and the basis for prima facie satisfaction; generic references to case-diary material are insufficient. The right to speedy trial extends to investigation, including further investigation. Exceptional, unexplained delay requires continuing judicial oversight and recorded justification, and may support relief under applicable inherent-jurisdiction provisions. Invalid sanction and unjustified prolonged investigation make continuation of criminal proceedings untenable.

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