Angel Funds registered on or before September 10, 2025 must implement the Accredited Investor mandate by March 31, 2027, extending the previous compliance deadline. Until that date, they may offer investment opportunities to no more than 200 non-accredited investors. From March 31, 2027, these Angel Funds must not accept non-accredited investor contributions for investments in investee companies. Existing investors may continue to hold investments already made, subject to the fund's PPM and fund documents. All other provisions governing Angel Funds under Chapter 8 of the AIF Master Circular remain unchanged, and the revised timeline applies immediately.

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.

Fair market value of land for long-term capital-gains computation need not be determined solely from Sub-Registrar guideline values, which are not conclusive evidence of market value. A substantiated valuation report using the reverse indexation method may support adoption of the property's value as on 1 April 1981 where sale instances and guideline data do not displace it. Investment-based capital-gains deduction for specified bonds, however, requires deposit within the prescribed six-month period. Where the Assessing Officer has no power to condone delay, a late investment does not qualify for deduction.

Compliance with the prescribed requirement to obtain and produce vehicle-owner declarations is distinct from compliance with the separate reporting requirement. Where the declarations were obtained and made available to the Assessing Officer, a reporting default alone does not justify disallowance of transport payments. The transport-payment disallowance was therefore unsustainable, as no failure to obtain the required declarations or factual error in the supporting findings was established.

Exemption for accumulation of income under Section 11(2) cannot be denied solely because the return and Form 9A were filed after the Section 139(1) due date. Timely filing of the prescribed form is treated as directory where Form 9A and Form 10 were available in the assessment record during the original and consequential assessments. Procedural delay in filing a return under Section 139(4) and Form 9A does not override a substantive claim to exemption for accumulated income. The assessee was therefore entitled to Section 11(2) exemption for all relevant assessment years.

Section 148A requires the Assessing Officer to consider the assessee's response and all available material before issuing a reassessment notice under Section 148. Reassessment for alleged bogus purchases was impermissible where purchase details had been examined during original scrutiny and were resubmitted in response to the Section 148A(b) notice, but were not evaluated in the Section 148A(d) order. Reliance on an undisclosed third-party statement, without an opportunity for rebuttal, did not independently establish income escaping assessment. Reopening on the same previously examined material constituted a change of opinion. Consequently, the Section 148A(d) order, Section 148 notice and reassessment were quashed.

Section 271B penalty proceedings operate independently of assessment proceedings and require initiation within a reasonable four-year period from the relevant assessment year; initiation after about ten years rendered the earlier-year penalties time-barred. Delay in completion of the State Co-operative Department audit may constitute reasonable cause for delayed submission of the Section 44AB report, although it does not excuse non-submission after the audit is complete. For later years, a Section 142(2A) special audit fulfilled the essential purpose of the Section 44AB audit, and the audit-related delay and absence of prejudice negated penal action.

Donation of current income by one charitable institution to another institution with similar charitable objects constitutes application of income for charitable purposes. The restriction effective from 1 April 2003 applies only to donations made from income accumulated for subsequent application under Section 11(2), not to donations from current income. Consequently, such current-income donations qualify as charitable application, and the related addition is to be deleted.

Deduction for a service co-operative bank is unavailable where the return claiming it was not filed within the due date prescribed for filing returns. Eligibility for the statutory deduction depends on timely compliance with the mandatory return-filing requirement. Applicable jurisdictional precedent requires a co-operative society to claim the deduction through a return filed by the prescribed due date, and a previously contrary precedent was distinguished. Consequently, the deduction remained unavailable for all relevant assessment years despite condonation of the delay in filing appeals.

Cash deposits in specified bank notes during demonetisation may be explained as business sale proceeds where the taxpayer has disclosed the relevant business income and part of the deposits has been accepted as explained. Maintenance of books of account is not compulsory for every taxpayer under the Income-tax Act. In the absence of material disproving the explanation, failure to maintain books alone does not justify treating business-receipt deposits as unexplained money. The unexplained-money addition was therefore regarded as unjustified and liable to deletion.

Section 151 requires reassessment notices issued more than three years after the relevant assessment year to obtain prior approval from the Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General. Approval by a Principal Commissioner does not fulfil this jurisdictional requirement. Consequently, a notice issued beyond that period without approval from the prescribed authority, and all consequential reassessment proceedings, are invalid.

Condonation of delay requires a bona fide and sufficient explanation for the entire period of default. Employment in the Merchant Navy and presence on board a ship did not satisfactorily explain the 560-day delay in filing the first appeal against a penalty order, particularly where the assessee was not on ship when the order was made and the interval between payment of the appeal fee and filing remained unexplained. The first appeal was therefore treated as barred by limitation, and its rejection was sustained.

Alleged bogus purchases may warrant an addition limited to the profit element embedded in those purchases rather than disallowance of the full purchase amount as unexplained expenditure. Applying an estimated 15% profit element confines the addition to the presumed benefit arising from non-genuine purchases and deletes the balance disallowance. The approach distinguishes taxable profit attributable to such transactions from the entire recorded purchase value.

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.