New Delhi, Sep 19 (PTI) The India-US trade ties have witnessed a string of tariff-related developments since April 2025 amid the seesawing geopolitical developments. In the latest, US President Donald Trump has signed a law that seeks to impose steep levies on Russia and its top energy buyers such as China and India. Here is a chronology of key tariff-related developments between the two countries, including major duty announcements. April 2, 2025: -------------- Declaring t... ... ...

Income-tax Rules, 2026 now permit faceless assessment, reassessment or recomputation communications to be issued by electronic communication rather than by affixing a digital signature. Recovery-of-tax procedures are revised by deleting specified provisions, omitting an exception for arrest and detention, and correcting a cross-reference. The deadline in the valuer-registration and authorised income-tax-practitioner registration rules is extended to 31 March 2027. Revised Form 169 requires asset-specific valuer applications, eligibility and disqualification disclosures, supporting qualifications and a declaration of impartiality; revised Form 171 requires practitioner eligibility, qualifications, registration and disqualification particulars. The procedural amendments to rules 160, 176 and 225 apply from 1 April 2026, while the remaining changes apply from 17 September 2026.

Risk-based selective physical boarding of vessels at Paradeep, Dhamra and Gopalpur ports will be based on advance profiling of compliance history, voyage details, ports of call, itinerary, cargo, and declarations concerning crew effects, stores and satellite devices. Port operators must provide weekly berth lists, while the Boarding Section must assess risk and report physical boardings with recorded justifications. Where physical boarding is not selected, the master and shipping agent remain responsible for accurate, complete and truthful electronic declarations and compliance with customs requirements for onboard stores. Masters must safeguard declared stores and prevent unlawful unloading or consumption, while agents must promptly report logistical, itinerary and documentation changes. Cargo discharge and sailing operations proceed upon Entry Inward and advance port clearance.

Sea Cargo Manifest and Transhipment Regulations, 2018 will be operationalised across ports in phases from 1 September 2026. Cochin Port is scheduled for implementation from 21 September 2026. Shipping lines, shipping agents and other stakeholders operating through Cochin Customs must comply with the framework and timely file prescribed electronic messages through the Customs Automated System to facilitate smooth cargo operations and clearance.

SHRI N.S. SAINI, HON'BLE ACCOUNTANT MEMBER AND SHRI GEORGE MATHAN, HON'BLE JUDICIAL MEMBER For the Assessee : Pramod Vaidya, Adv. & Samir C. Anvekar, CA For the Revenue : K.M. Mahesh, Ld. DR (Respondent) ORDER PER GEORGE MATHAN : 1. These are appeals filed by the Assessee against the orders of CIT(A)-VI, Bangalore in ITA Nos. 265/266/ACIT, CC Panaji/CIT(A)-VI/ B'lore/2013-14 dt. 11.9.2014 for A.Ys 2006-07 & 2007-08, ITA No. 267/ACIT, CC Panaji/CIT(A)-VI/ B'lore/2013-14 dt. 11.... ... ...

Rectification for a mistake apparent from the record is limited to an error that is self-evident and admits no two views; it cannot be used to review a reasoned conclusion requiring debate, factual evaluation, or legal reconsideration. Adjudicating a deduction under section 80P(2)(d) when no appeal ground concerned that deduction constitutes an inadvertent apparent error. The prior order requires recall and fresh adjudication of the appeal.

Unsecured-loan additions and consequential interest disallowances require verification where a joint overdraft account does not clearly identify individual loan transactions. Bank statements, ledgers and supporting records require examination to establish the nature and source of sums and each creditor's identity, creditworthiness and genuineness. The account's purpose and transaction trail require clarification before a reasoned appellate determination, with a remand report where necessary.

Foreign-leg LTC/LFC reimbursements fall outside the income-tax exemption for travel within India. Employers settling such claims possess the relevant travel particulars and must estimate taxable income and deduct tax at source; failure to do so may trigger assessee-in-default liability and interest. Separately, the statutory limitation for orders treating a deductor as an assessee in default depends, where relevant, on filing of TDS statements. Additional evidence establishing those filings may be admitted under the Tribunal Rules when material to an unadjudicated limitation ground, requiring fresh first-appellate determination for the relevant assessment years.

Cash deposits attributed to opening cash and family savings require material evidence to establish their source. Unsupported claims cannot explain deposits. Bank-certified cash withdrawals made by cheque on the taxpayer's behalf constituted an available source for part of the deposits; consequently, the unexplained-cash addition was partly sustained and partly deleted.

Cash deposits made during demonetisation were not unexplained money where salary slips and bank statements evidenced past salary savings and withdrawals. Assumptions that cash could not be retained for years or deposited in multiple instalments did not rebut the supporting documentary evidence. The addition under section 69A was therefore deleted for the depositor.

Section 12A registration is the statutory basis for assessing a charitable trust as a registered trust rather than as an association of persons, subject to applicable exemption conditions. Registration cannot be denied merely because original departmental records are untraceable where contemporaneous official records, attested certificates and subsequent assessment records recognise its existence and no cancellation order is shown. Exemption under sections 11 and 13 remains conditional on statutory compliance. Delay in filing Form 10B, including possible condonation under CBDT Circular No. 10/2019, and the evidentiary basis for cash deposits require examination on a complete factual record with an effective opportunity to provide supporting material.

Survey surrender arising from business advances, godown construction and stock discrepancies is taxable as business income where it is recorded in the books and audited financial statements and has a direct nexus with the taxpayer's established trading activity. Sections 69 and 69C do not apply without material showing a parallel business, an outside source of funds, or another unexplained source. The enhanced tax treatment under Section 115BBE applies prospectively from assessment year 2018-19 and does not govern assessment year 2017-18; the surrendered income is therefore taxable at normal rates.

Section 153A additions in a completed assessment require incriminating material seized during search; where seized material and search statements indicate undisclosed income, additions remain sustainable. Income additionally declared in the return responding to a search notice may corroborate undisclosed income, and discovery of incriminating material permits other connected additions in the search assessment. Pursuit of a rectification application constitutes sufficient cause for delayed appeal only if pursued bona fide, without negligence or deliberate delay; a vexatious application does not excuse delay or require merits review.

Enhanced taxation under section 115BBE does not apply retrospectively to assessment year 2017-18; the restricted unexplained-money addition remains taxable at normal rates. Cash-intensive brick-kiln operations, including cash sales and expenditure, together with accepted presumptive taxation in the preceding year, support limiting an addition for demonetisation-period cash deposits to an estimated portion rather than treating the entire deposit as unexplained money. Illness, pandemic disruption and death may constitute sufficient cause for condoning delay in filing a first appeal.

Payments for Global Brand, Global Communications, and Global Technology/Knowledge Management services under a shared-services arrangement do not constitute royalty under Article 13(3) of the India-UK tax treaty where they confer no right to use or commercially exploit trademarks, copyrights, confidential know-how, or other intellectual property. Internal access to third-party software, databases and technology tools remains use of a copyrighted article where reproduction, sublicensing, transfer and commercial-exploitation rights are absent. Routine strategy, training, coordination, advisory and communication support does not impart specialised proprietary commercial experience. The payments are therefore not chargeable to tax in India, and no withholding obligation arises under section 195.

Section 69C requires an assessee to substantiate claimed expenditure. Where credible investigation material identifies a supplier as an accommodation-entry provider, invoices, ledger confirmations and banking payments alone may not establish genuine purchases without proof of actual delivery or a satisfactory rebuttal of adverse material. Reassessment may be initiated where specific investigation information directly supports the Assessing Officer's belief that income escaped assessment, provided the belief reflects independent application of mind. The sufficiency of such material is not examined at the reopening stage, and unsubstantiated expenditure may remain included in taxable income.

Judicial discipline required challenges to an income-tax reassessment notice and the associated approval to remain unexamined on their merits while the notice's legality was pending in connected Supreme Court proceedings. Concurrent determination could create parallel adjudication and multiplicity of litigation. Proceedings before the competent authority were therefore stayed until the Supreme Court resolved the connected matters, without any final determination of the notice or approval's validity.

Enforcement Directorate sought registration of an FIR concerning alleged fraudulent payments by Cochin Minerals and Rutile Ltd to Exalogic Solutions, represented as IT consultancy fees. The request relied on evidence gathered through investigation and searches under the Prevention of Money Laundering Act. Registration remained under consideration after receipt of the Advocate General's legal opinion, with the Home Department examining the matter.

Local delivery services supplied through electronic commerce operators are added to the services specified under section 9(5) of the Madhya Pradesh Goods and Services Tax Act, 2017. The added category excludes supplies where the person supplying local delivery services through the operator is liable for registration under section 22(1). The amended treatment takes effect from 22 September 2025.

State tax at 6 per cent applies to intra-State supplies of fly ash bricks, aggregates and blocks; specified bricks; building bricks; and earthen or roofing tiles within designated Customs Tariff classifications. Classification follows the First Schedule to the Customs Tariff Act and associated interpretative rules, notes and explanatory notes. Undefined expressions retain their GST enactment meanings. The rate applies from 22 September 2025.