ABSTRACT Public Services - Commercial Taxes Department - Tamil Nadu Commercial Taxes Service - - Orders - Issued. COMMERCIAL TAXES AND REGISTRATION (E1) DEPARTMENT G.O.(Ms) No.50 Dated: 27.05.2026 Read: From the Commissioner of Commercial Taxes Letter No.B1/02-21/4/2026, dated: 25.02.2026. ***** ORDER : The Commercial Taxes Department has transitioned from a phase of administrative reorganization to a high-impact revenue optimization era, driven by advanced digital in... ... ...

SHRI M.BALAGANESH, AM AND SHRI AMARJIT SINGH, JM For the Assessee : Shri R.C.Modi & Ms.Ketki Rajshirke For the Revenue : Shri H.N.Singh ORDER PER M. BALAGANESH (A.M): This appeal in ITA No.602/Mum/2018 for A.Y.2010-11 arises out of the order by the ld. Commissioner of Income Tax (Appeals)-33, Mumbai in appeal No.CIT(A)-33/Rg.23/71/2013-14 dated 09/06/2017 (ld. CIT(A) in short) against the order of assessment passed u/s.144 of the Income Tax Act, 1961 (hereinafter referred to as Ac... ... ...

Income Tax Department verification of suspicious outward foreign remittances focuses on entities with large remittances despite non-filing, negligible reported turnover, unexplained business correlation, or non-operational declared addresses. The scrutiny examines shell entities, persons controlling them, and professionals issuing Form 15CB or Form 146 certificates. Accountants must verify remittance taxability through books of account and relevant records, applying due care, diligence and professional judgment after examining the underlying transactions and relevant facts.

Exports without payment of integrated tax require a registered person to furnish a bond or Letter of Undertaking in FORM GST RFD-11. Exporters not eligible for an LUT must furnish a bond. The bond operates as a running bond covering estimated tax liability, and a fresh bond is required if outstanding export liability exceeds the available bond amount. Bank-guarantee requirements depend on the exporter's track record and should normally not exceed 15% of the bond amount. An LUT remains valid for twelve months, subject to compliance with its conditions.

Foreign-exchange market conditions supported the rupee's appreciation against the US dollar, driven by positive domestic equity markets, a weaker dollar, and declining crude-oil prices. The USD/INR pair remained within a narrow range, with oil-price movements and potential central-bank intervention identified as near-term determinants. A special USD-INR foreign-exchange swap facility covering FCNR(B) deposits, overseas foreign-currency borrowings and external commercial borrowings had mobilised foreign-exchange inflows relevant to currency liquidity.

The PSIA/PSIC process requires same-day electronic generation and issuance of Pre-Shipment Inspection Certificates, with the inspection date recorded in the DD/MMM/YYYY format. Authorised PSIA users may upload inspectors' signature and official stamp images for automatic embedding in PSICs. Inspector details and registered inspection instruments are system-populated and displayed to reduce manual errors. The process also expands permitted inspection photograph and video attachment capacity, while helpdesk channels support users with module-related guidance, issue resolution, suggestions, and feedback.

GST export procedures allow registered persons meeting prescribed foreign inward remittance conditions to furnish a Letter of Undertaking instead of a bond, while status holders may use an LUT irrespective of those conditions. LUTs and bonds are prior requirements for exports and SEZ supplies and should be accepted within three working days when complete documents are submitted. Zero-rating applies to supplies by the actual exporter under LUT or on payment of integrated tax; manufacturer supplies to merchant exporters and supplies to export-oriented units remain taxable. Payment and foreign-exchange conditions govern supplies to Nepal, Bhutan and SEZ recipients.

Export without payment of integrated tax may be made under a Letter of Undertaking by registered persons, except those prosecuted for tax evasion above the prescribed threshold. The LUT is valid for the financial year but is withdrawn on failure to meet export and payment conditions, and restored upon payment. Pending portal availability, FORM GST RFD-11 may be filed before the jurisdictional officer. Bond users must provide the prescribed bank guarantee and maintain a running bond covering outstanding export tax liability. LUTs and bonds not accepted within three working days are deemed accepted.

India's energy-import sourcing has shifted towards supply diversification as disruption in the Strait of Hormuz constrained traditional Gulf supplies. United States cargoes have become particularly important for LPG and LNG, while procurement has also broadened to Atlantic Basin and other non-traditional suppliers. Diversification increases costs through longer voyages, higher freight, insurance expenses, tighter availability and higher commodity prices, reflecting a premium for supply security. Crude sourcing continues to rely principally on Russia, alongside resilient UAE flows and increased Venezuelan heavy crude imports.

Section 194C(6) exempts payments to transport operators from tax deduction at source where they furnish PAN, provided they are engaged in plying, hiring or leasing goods carriages and fall within Section 44AE, including its ownership condition for goods carriages. Eligibility therefore depends on factual verification that each recipient transport contractor satisfies the Section 44AE requirements. The Assessing Officer must determine the TDS liability after conducting that verification. Compliance with Section 194C(7) is not separately addressed.

Tamil Nadu Taxes (Settlement of Arrears) Rules, 2023 require electronic filing of Form-I with assessment or demand records and proof of electronic payment, followed by submission of a signed hard copy within fifteen days. The designated authority may verify particulars, require rectification, and issue a demand notice for any payment shortfall. On payment of the determined amount, a Certificate of Settlement certifies full and final settlement and waiver of balance arrears. The framework also provides for appeals, revocation for suppression or false particulars, electronic payment, and electronic service of notices and orders.

Cross-border illicit trade enforcement should move beyond isolated seizures to intelligence-led disruption of organised criminal networks. Risk-based profiling, predictive analytics, container scanning and shipment-data analysis should support targeted action against misdeclaration, port-hopping, concealment and digital distribution. Right holders should share specific intelligence with customs targeting mechanisms, and goods entering Domestic Tariff Areas from warehousing and special economic zones require enhanced examination. Digital enforcement should trace suppliers, financial flows, data trails and small-parcel movements, supported by coordinated feedback between online marketplaces, police and customs.

System-based reconciliation compares tax liability and input tax credit in FORM GSTR-3B with the details furnished in FORM GSTR-1 and FORM GSTR-2, which auto-populate FORM GSTR-3. Errors in FORM GSTR-3B may be corrected through the outward- and inward-supply statements. Tax shortfalls or excess input tax credit utilised must be paid through the electronic cash or credit ledger with applicable interest, while additional eligible input tax credit is credited to the electronic credit ledger. Reduced output liability, after credit adjustment, is carried forward to the next month's return. FORM GSTR-3 becomes valid only after full tax payment.

NRI banking arrangements require segregation of overseas earnings, India-sourced income, savings, remittances and expenditure after residential status changes. An NRE account holds overseas income remitted to India, with interest exempt from income tax in India. An NRO account is intended for Indian income, including rent, dividends and pension, while FCNR deposits retain funds in a chosen foreign currency. A structured arrangement can align these accounts with domestic obligations, overseas spending, remittances, investments and compliant digital banking access.

Small service provider threshold exemption applies after excluding the portion of consideration covered by the available abatement, so service tax liability does not arise where the resulting taxable value remains below the prescribed limit. Bus supply on a per-kilometre remuneration basis, without an arrangement granting use through renting, constitutes a contract of hire rather than taxable rent-a-cab service. Accordingly, service tax demands fail where both the exemption threshold applies and the activity is wrongly classified; no penalty consequence survives.

Sections 92C and 92CA of the Income-tax Act, read with binding CBDT transfer-pricing instructions issued under section 119, allocate arm's-length price determination roles between the Assessing Officer and the Transfer Pricing Officer. Where the prescribed circumstances require a reference, the Assessing Officer cannot conduct a detailed examination of the international transaction price at the reference stage or determine the arm's-length price directly. Non-reference to the Transfer Pricing Officer breaches the mandatory instructions. Consequently, a transfer-pricing adjustment made directly by the Assessing Officer without the required referral procedure is invalid.

Raw sugar imports were permitted, while stock limits were imposed on bulk consumers. States were directed to strengthen inspections, and nationwide flying squads were deployed to identify hoarding and speculative conduct. These measures target sugar availability and distribution across wholesale and retail channels. Ex-mill prices declined following the measures, although wholesale and retail prices had not yet reflected the reduction.

Service tax appeals and pending applications were permitted to be withdrawn; they consequently stood dismissed as withdrawn. The related application seeking withdrawal was disposed of. No substantive service-tax issue, legal principle, or merits determination appears in the material. The disposition therefore ended the proceedings without deciding the underlying service-tax dispute.

RBI's concessional Foreign Currency Non-Resident Bank deposit swap window closes on August 31, replacing the previous September 30 cut-off. Separately, the special US dollar-rupee foreign-exchange swap window remains available until December 31, 2026, providing concessional currency-hedging support to public sector undertakings raising external commercial borrowings. SBI expects to mobilise predominantly through deposits from non-resident Indians and foreign investors, with external commercial borrowings also visible.

Revisionary jurisdiction under Section 263 cannot be sustained merely because the revisional authority considers further inquiry desirable where reassessment specifically examined the relevant share transactions. Supporting material, including bank-account details, broker statements and transaction particulars, was furnished, and the transactions formed part of regular trading through an established broker. In the absence of an identified inquiry deficiency, ignored material, evidentiary defect or necessary further inquiry, the reassessment view remains a plausible view. The requirements of an erroneous order prejudicial to Revenue interests are therefore not met, making revision unsustainable.