Open API integration on the Trade Connect e-Platform enables eligible exporters to connect ERP, accounting and other systems with the Certificate of Origin process for electronic application submission, certificate issuance and verification. DGFT prescribes onboarding credentials, public-IP whitelisting, PBKDF2 password protection, token-based authentication and digital signing of requests and responses using SHA-256 RSA signatures and 2048-bit X.509 certificates. Access tokens may be reused during their 60-minute validity. Exporters must submit prescribed applicant, certificate, invoice, product, shipment, supporting-document and declaration data through the CoO File API, with agreement-specific validation of origin criteria and shipment r.....

Foreign Portfolio Investors (FPIs) investing only in Government Securities are no longer required to furnish investor group details. The exemption, previously limited to investments exclusively in Government Securities under the Fully Accessible Route, now applies to all FPIs investing only in Government Securities, including through the General Route. The change follows withdrawal of the concentration-limit requirement for Government Securities investments through the General Route, making investor-group identification unnecessary. Depositories, custodians and designated depository participants must update their systems accordingly. The revised compliance requirement takes effect immediately.

CSR fund utilisation by a charitable institution organised as a Section 8 company raises questions on receiving CSR funds from another charitable institution and applying them towards its stated objects. The recipient has issued utilisation certificates. Income-tax scrutiny of the donor has resulted in an information notice to the recipient, raising the compliance issue of whether inter-institutional receipt or onward transfer of CSR funds for utilisation constitutes a regulatory or tax violation.

Section 115BAB was harmoniously construed to avoid requiring an impossible act: a qualifying company must exercise its option through Form 10-ID with its first return, yet manufacturing or production may commence by 31 March 2024. A company whose manufacturing had not begun in assessment year 2023-24 was ineligible for the concessional regime for that year. However, where manufacturing commences on or before the statutory cut-off, entitlement for subsequent assessment years must be considered and cannot be denied solely because the original Form 10-ID was filed before commencement.

A notice under Section 143(2) issued under the compulsory manual-scrutiny criterion for survey cases requires an underlying survey under Section 133A. Where no material establishes that a survey was conducted, selection under paragraph 1(ii) of CBDT Instruction No. 5/2017 exceeds the Assessing Officer's authority. The notice is invalid, and the consequential assessment under Section 143(3) is unsustainable and liable to be quashed.

LTCG computation - Fair market value of capital asset as on 01.04.1981 - Capital gains deduction for investment in specified bonds Fair market value of capital asset as on 01.04.1981 - Reverse indexation method of valuation - Adoption of the fair market value of the co-owned property as on 01.04.1981 for computing long-term capital gains - HELD THAT: - The guideline value reflected in Sub-Registrar records does not always represent fair market value. The assessee's valuation, based on the... ... ...

Transport-payment disallowance for non-furnishing of vehicle-owner declarations - disallowance u/s.40(a)(ia) - allegation of non Compliance with vehicle-owner declaration requirement - violation of provisions of section 194C(7) HELD THAT: - The requirement to obtain declarations from vehicle owners was held to be independent of the requirement for their prescribed filing. CIT(A) has categorically admitted that the Assessing Officer has clearly recorded that the declaration of the vehicle o... ... ...

Exemption u/s 11(2) - delayed filing of Form 9A Entitlement to exemption u/s 11(2) where Form 9A and the return were filed under section 139(4), after the due date under section 139(1), but were available during assessment - HELD THAT: - The requirement of furnishing the prescribed form within the due date under section 139(1) was treated as directory where the form was available on the assessment record. Since Form 9A was available when the original assessment was made and Forms 9A and 10 we... ... ...

Reassessment - non consideration of assessee's reply under section 148A - change of opinion Validity of reassessment initiated on alleged bogus expenditure relating to purchases from a supplier already examined in the original scrutiny assessment - HELD THAT: - An order under section 148A(d) must be founded on the material on record, including the assessee's reply to the show-cause notice. The Assessing Officer neither supplied the third-party statement relied upon nor considered the ... ... ...

Levy of penalty u/s.271B - Period of Limitation for penalty for failure to furnish tax audit report - Reasonable cause for delayed furnishing of tax audit report Limitation for penalty for failure to furnish tax audit report - Validity of penalty proceedings for failure to furnish the prescribed tax audit report for assessment years 2011-2012 and 2012-2013 when initiated after an inordinate delay - HELD THAT: - Penalty proceedings for failure to furnish the tax audit report were independent o... ... ...

Application of charitable income through donation to another charitable institution - Donation out of current income Treatment of a donation made out of current income by a charitable institution to another charitable institution having similar objects as application of income for charitable purposes - HELD THAT: - The donation made by a charitable institution to another charitable institution amounts to application of income for charitable purpose, as held in the case of CIT v. Aurobindo Mem... ... ...

Deduction under section 80P denied - return of income was not filed within the due date prescribed u/s 139(1) HELD THAT: - The jurisdictional High Court in M/S. NILESHWAR RANGEKALLU CHETHU VYAVASAYA THOZHILALI [2023 (3) TMI 1055 - KERALA HIGH COURT] had held that a co-operative society must claim deduction under section 80P in a return filed within the prescribed due date. Applying that binding ruling, which had distinguished the earlier contrary ruling in THE CHIRAKKAL SERVICE CO-OPERATIVE B... ... ...

Unexplained cash deposits during demonetisation - Cash deposits from business sale proceeds Addition of cash deposits in specified bank notes during the demonetisation period as unexplained money despite the assessee's explanation that they represented business sale proceeds - HELD THAT: - The Act does not compulsorily require every assessee to maintain books of account. The assessee had returned income from the business of dealing in recharge coupons and, in the absence of material to th... ... ...

Reassessment notice - sanction by specified authority - Validity of reassessment notice for AY 2017-18 issued after expiry of three years from the end of the relevant assessment year with approval of the Principal Commissioner HELD THAT: - Where more than three years have elapsed from the end of the relevant assessment year, sanction for issuance of a reassessment notice must be obtained from the higher specified authority under section 151. Approval obtained from the Principal Commissioner, ... ... ...

Condonation of delay in appeal against penalty for misreporting of income - Sufficient cause for delayed appeal HELD THAT: - The Tribunal held that the delay was not supported by a satisfactory or bona fide explanation. The claimed delayed receipt of the penalty order was unexplained, as was the subsequent interval between payment of appeal fee and filing of the appeal. The seafarer's service record did not support the explanation that the assessee was unable to act during the relevant pe... ... ...

Bogus purchases - estimation of profit element - HELD THAT: - In case of PCIT vs. Ramelex Pvt. Ltd. [2025 (10) TMI 808 - BOMBAY HIGH COURT] the Hon'ble jurisdictional Bombay High Court has upheld addition @15% in respect of bogus purchases. The Hon'ble Gujarat High Court in case of CIT vs. Simit Seth [2013 (10) TMI 1028 - GUJARAT HIGH COURT] has also upheld addition @15% of the impugned purchases. The Tribunal noted the consistent judicial approach of sustaining additions in bogus-purchase ca... ... ...

Specified amendments under the Arunachal Pradesh Goods and Services Tax (Eighth Amendment) Rules, 2021 become operative from 1 January 2022. The provisions brought into force are sub-rule (2), sub-rule (3), clause (i) of sub-rule (6), and sub-rule (7) of rule 2. The commencement is made under sub-rule (2) of rule 1 and applies only to the enumerated portions of rule 2.

Assam SGST rate schedules are amended to place biris in Schedule II at 9 per cent and specified tobacco-related goods in Schedule III at 20 per cent. The latter category includes pan masala, unmanufactured tobacco, tobacco refuse other than tobacco leaves, cigars, cigarettes, manufactured tobacco other than biris, tobacco substitutes, and specified non-combustible inhalation products. Schedule VII, prescribing a 14 per cent rate, is omitted. The amendments are deemed effective from 1 February 2026.

GST treatment of hostel accommodation supplied by an Indian university in India to students of a foreign university is considered where the stay is for at least 90 continuous days and monthly charges do not exceed Rs. 20,000 per person. The issue covers regularisation of GST liability on an "as is where is" basis for the earlier period and exemption from 15 July 2024, subject to the monthly-value and continuous-stay conditions.

Time of supply for spectrum usage and similar services under GST is to be clarified in Delhi through mutatis mutandis application of the Central Board of Indirect Taxes and Customs clarification. The approach applies for implementation of the Delhi Goods and Services Tax Act, 2017 and seeks uniformity in the treatment of time of supply for these services.