Belated authorisation by CBDT for reporting in Form 26AS of the information, received since 1st January 2022 under Automatic Exchange of Information (AEOI) framework under an agreement referred to in Section 90 and 90A of the IT Act,1961 . There seems some lacking in Circular and it need clarification and amendment. Relevant statutory provisions Income-tax Act, 1961 • Section 90 - about Agreement with foreign countries or specified territories • Section 90A - about Adopti... ... ...

History: The practice of job work in India is centuries old, originating in traditional society and artisan environment-most notably the pre-colonial "putting-out" system in textiles, metallurgy, and handicrafts, where merchants supplied raw materials to decentralized skilled craftsmen who performed specialized value addition without acquiring ownership. Manufacturing tobacco bidi and agarabathi is one of the oldest forms of job work-the philosophy of work from home-which later became indispe... ... ...

The Calcutta High Court on 16/07/2026 passed an order which may have far reaching consequences. The story goes like this. One of the taxpayers was issued with a show cause notice imposing huge penalties both under CGST as well as WBGST. The SCN was promptly replied with a request for cross examination of two third parties as the case required that cross examination. Despite this OIO was passed on 19/03/2026 even without affording the personal hearing as required under section 75 (4) in gross vio... ... ...

The Threshold Question - Statutory Function or Taxable Activity? The taxation of statutory and governmental authorities has repeatedly raised a difficult question under indirect tax law: does an institution's statutory character protect it from taxation, or must each activity be examined independently to determine whether it is sovereign, statutory, or commercial in substance? The Delhi Bench of CESTAT addressed this question in Delhi Development Authority Versus Commissioner of Servic... ... ...

Authorised person The expression 'authorised person' is defined under Section 2(c) of the Foreign Exchange Management Act, 1999 ('Act' for short) as an authorised dealer, money changer, off-shore banking unit or any other person for the time being authorised under sub-section (1) of section 10 to deal in foreign exchange or foreign securities. Regulations The Reserve Bank of India made the Regulations called as 'Foreign Exchange Management (Authorised Persons) Regulation, 2026... ... ...

Rule 10A - A Small Compliance Provision with Serious Consequences Registration under GST establishes a taxpayer's legal identity within the indirect tax system. However, obtaining a GSTIN is not the end of the registration process. The law also requires certain post-registration compliances to establish that the registered person is genuine and remains traceable through the information furnished on the common portal. Rule 10A of the Central Goods and Services Tax Rules, 2017 is one such p... ... ...

The Directorate General of Foreign Trade (DGFT), Department of Commerce, Ministry of Commerce and Industry, Government of India, has introduced a series of important enhancements to the Pre-Shipment Inspection Agency (PSIA) and Pre-Shipment Inspection Certificate (PSIC) process through Trade Notice No. 22/2026-27 dated August 25, 2026. The latest changes represent another significant step towards the Government's objective of making the PSIA/PSIC framework more digital, transparent, trace... ... ...

Introduction Contracts are the legal and commercial foundation of almost every business relationship. For a large manufacturing organization operating manufacturing units, sales offices, warehouses, distribution networks and international businesses, contracts govern relationships with customers, suppliers, distributors, contractors, employees, logistics providers, technology vendors, financial institutions, consultants, landlords, joint-venture partners and overseas counterparties. The sh... ... ...

For a large manufacturing organization operating multiple manufacturing units, sales offices, warehouses and overseas entities, Compliance and Enterprise Legal Risk Management (ELRM) should be established as a structured, enterprise-wide management system rather than as a collection of statutory checklists. The purpose is not simply to ensure that the organization "complies with the law." A mature framework should enable management to identify legal and regulatory risks early, assign accounta... ... ...

Access to Exclusive Economic Zone for purse seine fishing - Federal distribution of fisheries regulation - Cooperative federalism in regulatory clearances Federal distribution of fisheries regulation - Exclusive Economic Zone and territorial waters - Regulatory competence over purse seine fishing in the Exclusive Economic Zone and in Tamil Nadu territorial waters - HELD THAT: - Fishing and fisheries beyond territorial waters fall within the Union's legislative and executive sphere, whereas fi... ... ...

Levy the penalty u/s 10A of the Central Sales Tax Act - Mens rea or false representation for penalty for false representation in use of Form C HELD THAT: - The revisionist was admittedly engaged in civil work contracts involving mining and excavation, and the excavator was purchased for execution of such work. Its registration was subsequently amended to include civil contractor. In these circumstances, there could be no false representation merely because Form C had been issued for the purch... ... ...

Enhancement of turnover without proof of suppression - Input tax credit and subsequent cancellation of supplier registration Enhancement of turnover without proof of suppression - Whether turnover could be enhanced and books of account rejected without quantified suppression or supporting adverse material? - HELD THAT: - The penalty proceedings arising from the seizure had been dropped and no material was shown to establish their reversal or pendency before a higher forum; consequently, no ad... ... ...

Challenge to consequential demand notices after finality of assessment - Maintainability of challenge to demand notices issued pursuant to assessment orders that had been unsuccessfully challenged in the available appellate and revisional proceedings HELD THAT: - The demand notices were merely consequential to the assessment orders. Since the assessments had attained finality after the petitioner had exhausted challenges before the competent authorities, a challenge to the consequential notic... ... ...

Railways as dealer under sales-tax law - Sale of rolling stock under financing and lease arrangement - Territorial taxability of rolling-stock sales Railways as dealer under sales-tax law - statutory capacity of the Railways to be treated as a dealer in respect of the rolling-stock transactions - HELD THAT: - The statutory definitions cover the Central Government when it carries on the business of selling goods, and profit motive is immaterial. The settled position that disposal of goods inci... ... ...

Inclusion of amortised tooling cost in assessable value - Extended limitation and penalty for alleged suppression of tooling advances Inclusion of amortised tooling cost in assessable value - Inclusion in assessable value of buyer-funded tooling advances used for manufacture of automobile seats - HELD THAT: - The valuation scheme requires inclusion of the value of buyer-supplied tools only to the extent appropriately apportioned to the excisable goods produced with their aid; it does not perm... ... ...

Excise valuation of batteries supplied under buyback arrangements - Extended limitation for excise duty demand - Penalty for undervaluation of excisable goods Transaction value where price is below cost of manufacture - Buyback arrangement and arm's-length price - Valuation of batteries supplied to torch manufacturers under arrangements requiring co-packing of the batteries with torches and sale of the co-packed products back to the appellant - HELD THAT: - The buyers were contractually b... ... ...

Central excise refund limitation - Payment of duty under protest Refund of central excise duty for the disputed period where the appellant could not produce protest letters or contemporaneous endorsements of payment under protest - HELD THAT: - The final determination that no duty was payable did not exclude the operation of the limitation prescribed for refund claims; refund of duty not payable remains subject to the statutory refund provision. The earlier remand directing examination of lim... ... ...

Manufacture by lamination of fabric with plastic - Job-work exemption conditional on principal manufacturer's undertaking - SSI exemption for laminated HDPE fabrics - Valuation of job-work clearances and cum-duty valuation - Extended limitation for duty on unexempted job-work clearances - Penalty on authorised signatory in absence of confiscation Manufacture by lamination of fabric with plastic - Lamination of cotton, jute or man-made fabrics with LDPE, PP or HDPE amounts to manufacture -... ... ...

Cash refund of revised CENVAT credit under transitional provisions - Revised return filed under the existing law Entitlement to cash refund of differential CENVAT credit disclosed through a revised ST-3 return filed within the prescribed time, where the credit had not been transitioned through TRAN-I - HELD THAT: - The revised return having been filed within the stipulated period and the differential CENVAT credit being undisputed, the Tribunal held that section 142(3) of the CGST Act require... ... ...

Service tax on construction of residential complexes before 1 July 2010 - Builder's works contracts as self-service Liability to service tax on construction of residential complexes undertaken by a builder under works contracts before insertion of the Explanation with effect from 1 July 2010 - HELD THAT: - The Explanation introduced with effect from 1 July 2010 expanded the taxable scope by deeming construction intended for sale by a builder to be a service to the buyer. Before its insert... ... ...