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Circular No. PUBLIC NOTICE NO. 16/2021 Dated:- 12-2-2021 Trade Notice Dated:- 12-2-2021 Trade Notice
Sea Cargo Manifest and Transhipment Regulations compliance requires registration by persons delivering arrival or departure manifests and electronic filing by authorised carriers. Stakeholders must submit prescribed sea manifests, entry and departure notifications, cargo summary notifications, allowed-for-shipment requests and customs inland manifests under the phased implementation framework. Full mandatory compliance applies from 1 April 2021. Applicable bond requirements include National Container Bonds for authorised sea carriers or sea agents and National Transhipment Bonds for authorised transhippers. Contravention of SCMTR provisions may attract penalty.
Input service nexus with manufacturing permits CENVAT credit for operational, waste-disposal, maintenance and business-support services.
Rule 2(l) of the Cenvat Credit Rules, 2004 permits credit for input services having a nexus with manufacturing activity, including services incidental to manufacturing operations. Housekeeping supports a clean production environment; hazardous-waste incineration enables disposal of manufacturing waste; power-sharing provides essential electricity; and preventive maintenance and air-drier servicing preserve operational equipment. Membership, communication, travel and training services used for business and manufacturing-related functions also satisfy the required nexus. CENVAT credit is therefore admissible on these disputed input services.
Principal-to-principal film revenue sharing escapes business support tax, while unsupported extended limitation defeats renting demand.
Principal-to-principal revenue sharing for film exhibition, where the theatre owner operates the premises and bears operating costs while ticket collections are preallocated with the distributor, does not involve a taxable business support service. The arrangement is treated as exhibition on the owner's own account rather than a service rendered to the distributor. Extended limitation for renting of immovable property requires a sustainable allegation of suppression. Where no suppression was alleged, the liability was legally disputed during the relevant period, and the entire demand lay outside normal limitation, the renting demand and consequential penalties are time-barred and unsustainable.
Concessional manufacturing tax regime applies from the first operative year, not a pre-commencement nil-return year.
Section 115BAB requires the prescribed option to be furnished for the first assessment year in which the concessional manufacturing tax regime is claimed. A nil return filed after incorporation, before business or manufacturing activities begin, does not constitute that operative first year. Where manufacturing commenced on 3 January 2023, filing Form 10ID within time with the return for assessment year 2023-24 satisfied the requirement. The taxpayer was therefore eligible for the concessional tax rate for that assessment year.
Capital-gains deductions for property improvement and brokerage require evidence, prompting fresh verification of both claimed expenses.
Capital-gains computation requires verification of claimed cost of improvement and brokerage deductions where supporting evidence was not previously established. The contractor's affidavit, produced before the Tribunal, requires examination on oath and consideration with any further evidence to determine whether improvement expenditure is genuine. Brokerage expenditure likewise requires supporting material before its deductibility can be determined. Both claims are remitted to the Assessing Officer for fresh verification and decision, reopening the capital-gains computation only to determine these two deductions.
Consistent inventory valuation requires matching opening-stock adjustments when closing-stock valuation changes to prevent distorted profit computation.
Consistent inventory valuation requires a corresponding adjustment to opening-stock valuation when closing-stock valuation is adjusted. Altering only closing inventory distorts the computation of true profit because opening and closing stock must be valued on the same basis. The computation was restored to the assessing authority to align opening-stock valuation with the revised closing-stock valuation and determine profit consistently.
GST show-cause notice challenge withdrawn, preserving taxpayer's opportunity to reply and attend adjudication hearing before final assessment.
Withdrawal of a writ petition challenging a GST show-cause notice-cum-demand allowed the taxpayer to submit a reply within seven days and participate in the scheduled personal hearing before the adjudicating authority. The taxpayer had already received notice of the personal hearing. The adjudicating authority may pass orders in accordance with law after hearing the parties. No adjudication occurred on the merits of the proposed tax demand, interest, or penalty, and the writ petition was dismissed as withdrawn.
Bogus-purchase disallowance may target embedded income, with full purchase value excluded where transactions are accommodation entries.
Bogus-purchase disallowance was restricted to 6% where purchases originated from undisclosed sources but invoices were obtained from non-genuine suppliers. In accommodation-entry transactions, tax liability is confined to the income component or benefit embedded in the purchases rather than the entire invoiced value. The percentage was supported by the material and financial figures and aligned with earlier treatment of transactions involving the same group. The restriction was sustained because no substantial question of law justified interference.
Circular No. Public Notice No.18/2021 Dated:- 27-2-2021 Trade Notice Dated:- 27-2-2021 Trade Notice
Exporters may seek correction of SB-005 GST invoice and shipping-bill invoice mismatches for all past shipping bills, irrespective of filing date, through permanent officer-interface rectification. The prescribed procedure requires payment of Rs. 1,000 for correlation and verification and submission of a Concordance Table mapping GST invoices to corresponding shipping-bill invoices. Exporters must certify the accuracy of particulars, export of invoiced goods, and filing of relevant GST invoices in GSTR-1 or GSTR-6A for verification and refund.
Depreciation on company-paid vehicle registered to director was not entertained where depreciation had previously been accepted.
Depreciation on a vehicle purchased and paid for by a company, but registered in its director's name, was not pursued as a substantial question of law because depreciation had previously been accepted on the same facts. High Court dismissed the depreciation-related question while admitting the appeal on the remaining substantial questions of law. The stated position treats company payment and accepted depreciation as material circumstances despite registration standing in the director's name.
Best-judgment assessment requires profit-rate estimation, not separate expense disallowances after rejection of books of account.
Rejection of books of account under section 145(3) requires income to be computed on a best-judgment basis under section 144, without relying on the rejected book results. Retaining returned income as the starting point and separately disallowing allegedly unverifiable or bogus expenses is not a valid post-rejection assessment method. Income must instead be estimated by applying an appropriate gross-profit or net-profit rate prevalent in the relevant industry. The assessment was restored for fresh computation on that basis.
FEMA / RBI
Dated:- 9-9-2026
PTI
Digital savings account opening through video KYC enables remote onboarding without a branch visit, physical paperwork, or printed forms. Individuals holding valid Aadhaar and PAN may submit basic particulars, complete a live video interaction, upload identity documents digitally, select account preferences, and activate the account for transactions. Video Banking also provides live assistance for KYC completion, account queries, and service requests. Savings deposits earn daily balance-based interest paid monthly, with tiered rates, while a digital calculator estimates prospective interest earnings using current rate slabs.
Circular No. PUBLIC NOTICE NO. - 22/2021 Dated:- 23-3-2021 Trade Notice Dated:- 23-3-2021 Trade Noti...
Metric Million British Thermal Unit is added as a standard commercial unit of quantity for import and export declarations. Recognised for measuring natural gas by energy content, it is used in commercial negotiations, invoices and ship ullage survey reports. The unit is accepted in the Customs EDI System, and import and export declarations using it must apply the unit quantity code MBT.
Circular No. PUBLIC NOTICE NO. - 25/2021 Dated:- 25-3-2021 Trade Notice Dated:- 25-3-2021 Trade Noti...
Proposed amendment of Section 46 of the Customs Act, 1962 would mandate advance filing of Bills of Entry, subject to enactment of the Finance Bill, 2021. Importers would be required to file a Bill of Entry by the end of the day preceding arrival of the carrying vessel, aircraft or vehicle. The Board may prescribe different time limits in specified cases, but not beyond the day of arrival. Relaxation is under consideration for certain land, airport, neighbouring-country and short-haul imports.
FEMA / RBI
Dated:- 9-9-2026
PTI
Agentic AI-enabled credit assessment uses alternative financial and commercial data to support formal credit access, including rural payment records, UPI transactions, GST data, trade data and banking data. Lending functions include automated assessment, AI-assisted underwriting, data intelligence and document processing. AI applications also support fraud and anti-money-laundering investigations, data-protection compliance, insurance operations, customer servicing and collections actions subject to compliance and policy guardrails.
Rule 8D's recorded satisfaction requirement prevents exempt-income disallowance recomputation without account-based findings by assessing officers.
Sales tax subsidy received under an identical scheme retains its capital-receipt character and is not taxable as revenue where that character has already been determined between the same parties. The prescribed method for disallowing expenditure related to exempt income may be applied only after the Assessing Officer examines the accounts and records specific dissatisfaction with the taxpayer's claim. A broad discussion is insufficient; the absence of an identified nexus between interest expenditure and exempt-income investments prevents recomputation under that method.
Circular No. PUBLIC NOTICE NO. - 29/2021 Dated:- 29-3-2021 Trade Notice Dated:- 29-3-2021 Trade Noti...
Advance filing of Bills of Entry is required to support pre-arrival processing and assessment of imported goods. The general deadline is the end of the day preceding arrival of the carrying vessel, aircraft or vehicle. Sea imports from specified neighbouring countries, and all imports arriving by airport or through a Land Customs Station, may be filed by the end of the day of arrival. Bills of Entry may continue to be presented up to 30 days before expected arrival.
Revisionary jurisdiction requires error, Revenue prejudice, and omitted necessary assessment inquiry before intervention is justified.
Revision under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. A different preference of the revisional authority, inadequate detail in the assessment order, or alleged inadequacy of inquiry does not justify revision where the Assessing Officer made inquiries, considered the material and adopted a legally sustainable view. For a builder using the project-completion method, interest on borrowed capital used for stock-in-trade is revenue expenditure. Disclosure and explanation of that method, interest expenditure and fixed-deposit interest during assessment supported validity of the assessment; revision was invalid because no omitted necessary inquiry or legal unsustainability was established.
Customs & Trade
Dated:- 9-9-2026
PTI
Supply-chain flexibility, interoperable data systems and strategic use of logistics infrastructure are central to the next phase of logistics development. Flexible warehousing can help businesses adjust capacity to changing demand and inventory needs, while specialised third-party logistics providers may add sector-specific value. Digital integration is necessary before artificial intelligence can effectively support forecasting, visibility and route planning. Geopolitical disruption also increases the importance of inventory optionality, rerouting capacity, Special Economic Zones and Free Trade Warehousing Zones.
Circular No. STANDING ORDER No. 11/2026 Dated:- 5-8-2026 Trade Notice Dated:- 5-8-2026 Trade Notice
Deficiency memos for drawback claims under Section 74 of the Customs Act, 1962 must use the standardised format prescribed in Annexure-I to CBIC Circular No. 31/2026-Customs. Immediate adoption is required for all such claims to ensure uniformity, transparency and timely disposal. Supervisory officers must sensitise staff, ensure strict compliance and communicate the requirements through official channels.