Wednesday, 30 September 2026

TAX DUE DATE- OCTOBER 2026

 

S. No

Due Date

Related to

Compliance to be made

1

11.10.2026

GST

Filing of GSTR 1 for the month of September, 2026

2

13.10.2026

GST

Filing for the month of Sept 2026

3

20.10.2026

 

 

GST

-Payment of GST for the month of September, 2026

-Filing of GSTR 3B for the month of September, 2026

 

 

 

4             

25.10.2026

GST

ITC 04 (Job work) for the half year ended Sept 2026

5

07.10.2026

TDS/TCS

(Income Tax)

· Deposit TDS for payments of Salary, Interest, Commission or Brokerage, Rent, Professional fee, payment to Contractors, etc. during the month of September 2026.

· Deposit TDS from Salaries deducted during the month of September 2026

Deposit TCS for collections made under section 394 including sale of scrap during the month of Sep 2026 if any

Deliver a copy of Form 121(15G/15H), if any to CCIT or CIT for declarations received in the month of Sep 2026, if any

5

31.10.2026

TDS Return

·       Filing of 2nd Quarter (1st July to 30th  September) TDS return.

6

15.10.2026

TCS Return

·       Filing of 2nd Quarter (1st July to 30th  September) TCS return.

7

31.10.2026

Tax Audit

Filing of Audit Reports 3CA, 3CD, 3CEB for the Financial Year 2025-26

 

8

31.10.2026

Income tax

Filing of income tax return for the Corporate assesses (or) non-corporate assesses (Whose books of accounts are required to be audited U/s 44AB of IT act 1961 (or) working partner (of a firm whose books of accounts required to be audit (in case of Assesses not having international or specified domestic transaction).

 

Saturday, 26 September 2026

Emerging Themes from 2026 GST Litigation

The 2026 GST decisions reveal several consistent judicial trends:

Greater Emphasis on Natural Justice

The courts have repeatedly stressed that tax authorities must strictly adhere to procedural safeguards. Whether in the context of Show Cause Notices, valuation disputes or appellate remedies, the judiciary has emphasized fairness and transparency. [taxbymanis...ogspot.com], [taxbymanis...ogspot.com]

Bonus Preference Shares: A New Route for Unlocking Surplus Reserves

 Introduction

Several prominent listed companies, including Siyaram Silk Mills, TVS Motor Company, and Sundaram-Clayton, have recently adopted an innovative mechanism for rewarding shareholders and optimising capital structure through the issuance of bonus redeemable preference shares under schemes sanctioned by the National Company Law Tribunal (NCLT). 

Friday, 25 September 2026

When the CFO Leaves, Who Owns the Digital Keys?

- CA SAKSHI AGARWAL  

 Let’s start with a small story in this regard. Client B, a rapidly growing mid-sized manufacturing firm, recently faced the sudden and less-than-amicable exit of their CFO, Mr. A. Over his five-year tenure, Mr. A had become the absolute nerve center of the company’s financial and regulatory ecosystem. He handled everything: MCA filings, GST portal access, income tax e-filing, and primary banking authorizations.

 

FAQs issued by the Employees’ Provident Fund Organisation on implementation of the revised Provident Fund wage ceiling

 We are pleased to share our latest EY Alert on the Frequently Asked Questions (FAQs) issued by the Employees’ Provident Fund Organisation (EPFO) regarding the implementation of the revised Provident Fund wage ceiling from INR15,000 to INR25,000 per month, effective 17 September 2026.

Thursday, 24 September 2026

5 GST Judgments in 2026 Every Business Should Know

 The year 2026 has already witnessed several landmark GST decisions that are reshaping the contours of tax litigation and compliance in India. These rulings highlight an emerging judicial trend: tax authorities must act strictly within the powers granted by law.  

Supreme Court Ruling on GST SCNs – A Landmark Clarification

In M/s G.R. Infra Projects Ltd. v. State of Madhya Pradesh (Civil Appeal No. 11277/2026), the Supreme Court has delivered a ruling that reshapes GST litigation:

🔑 Key Takeaways:
1️⃣ Fraud / Willful Misstatement / Suppression must be evident in the SCN itself.
Mechanical use of these words is insufficient. Without specific allegations, the SCN is unsustainable. This effectively nullifies the Madras High Court’s view in Fastenex Limited (Section 74 batch matter).
2️⃣ Limitation period extended due to COVID suo moto orders.
For AY 2018‑19, the last date for issuance of notice stood extended till 28.02.2025, partially upholding the Madras High Court’s Tata Play ruling.
3️⃣ Important Note:
The Supreme Court did not consider Notification No. 56/2023 while deciding limitation. Despite this, the Court has categorically held the due date as 28.02.2025.
📌 Impact:
Reinforces taxpayer protection by requiring SCNs to contain clear fraud allegations.
Clarifies the interplay of Sections 73 & 74 of the CGST Act.
Establishes binding precedent on limitation extensions due to extraordinary circumstances.
Leaves open questions on how Notification No. 56/2023 will interplay with this ruling in future disputes.
⚖️ A judgment that will influence GST litigation strategy, compliance, and departmental action for years to come

Tuesday, 22 September 2026

Full ITC Principle Continues to Strengthen GST Valuation Framework

 One of the most significant developments under GST valuation jurisprudence has been the consistent recognition that where the recipient is eligible for full Input Tax Credit (ITC), disputes regarding valuation become largely revenue neutral. Over the years, advance rulings, CBIC circulars, and judicial pronouncements have progressively reinforced this principle.

Friday, 18 September 2026

Employees Provident Fund wage ceiling increased from INR15,000 to INR25,000 per month

The Ministry of Labour and Employment has notified revised wage ceiling of ₹25,000 per month for the purposes of Chapter III (Provident Fund) of the Code on Social Security, 2020 (“COSS”), replacing the earlier wage ceiling of ₹15,000 per month with effect from 17 September 2026. The change is intended to align the social security framework with prevailing wage levels and expand access to Provident Fund savings, pension benefit and insurance protection.

Tuesday, 15 September 2026

How AI is Rewriting India’s Permanent Establishment (PE) Rulebook: Key Takeaways

  • Traditional PE rules are under pressure. Historically, a foreign company became taxable in India only if it had a physical presence such as an office, branch, factory, or employees performing business activities in India.   
  • AI challenges the physical presence test. Modern businesses can serve Indian customers through AI-powered platforms, chatbots, cloud infrastructure, and autonomous systems without maintaining any physical footprint in India.   

Cross Border Clarity: No FTC, No Deduction Either

 The Mumbai ITAT, in Tata Communications Transformations Services Ltd. v. DCIT [2026], held that foreign taxes cannot be claimed as a deduction merely because the Foreign Tax Credit (FTC) remains unutilised. The Tribunal clarified that Section 40(a)(ii) disallows foreign taxes that are eligible for relief under Sections 90/91, regardless of whether the credit is actually used. For businesses in loss years, foreign withholding taxes may therefore become a sunk cost, making FTC planning crucial.

Monday, 7 September 2026

5 GST Judgments in 2026 Every Business Should Be Watching

The year 2026 has already delivered several landmark GST decisions that could significantly influence tax compliance, assessments, and litigation strategy. Businesses, tax professionals, and finance leaders should closely track the following developments:

PMS commission allowed as deductible expenses.

 In an important ruling in the case of Ameeta Jagdish Thackersey, the Mumbai ITAT has held that Portfolio Management Service (PMS) fees are deductible while computing capital gains under Section 48 of ITA, 1961. The ITAT noted that Coordinate Benches (Delhi, Mumbai, Pune etc) have taken divergent views on this issue. In the absence of a binding decision from the Jurisdictional High Court or the Supreme Court, the ITAT upheld the view favourable to the assessee. A one pager summary of the ruling is attached below.


The ruling is also a useful reminder that where genuine divergence exists in judicial interpretation, the benefit of a reasonable alternative view cannot ordinarily be denied to the taxpayer merely because the Revenue Authorites prefers the other interpretation.

Friday, 4 September 2026

Safe Harbour vs. Advance Pricing Agreements: Choosing the Right Path to Transfer Pricing Certainty

 While Safe Harbour focuses on standardization, an Advance Pricing Agreement (APA) provides a customized solution.

An APA is a binding agreement between a taxpayer and the tax administration that determines in advance the appropriate transfer pricing methodology, margins, critical assumptions, and pricing parameters for specified international transactions.

𝗗𝗲𝗳𝗲𝗿𝗿𝗲𝗱 𝗽𝗮𝘆𝗺𝗲𝗻𝘁 𝗱𝗼𝗲𝘀 𝗻𝗼𝘁 𝗺𝗲𝗮𝗻 𝗱𝗲𝗳𝗲𝗿𝗿𝗲𝗱 𝗮𝗰𝗾𝘂𝗶𝘀𝗶𝘁𝗶𝗼𝗻: 𝗜𝗧𝗔𝗧 𝗮𝗹𝗹𝗼𝘄𝘀 𝗱𝗲𝗽𝗿𝗲𝗰𝗶𝗮𝘁𝗶𝗼𝗻 𝗼𝗻 𝗲𝗻𝘁𝗶𝗿𝗲 𝗥𝘀 𝟮𝟲𝟴 𝗖𝗿 𝗜𝗣𝗟 𝗙𝗿𝗮𝗻𝗰𝗵𝗶𝘀𝗲 𝗰𝗼𝘀𝘁

 Mumbai ITAT held that depreciation on Rajasthan Royals franchise rights is allowable on the entire acquisition cost of ₹268 crore, even though only ₹26.8 crore was paid during the year. Acquisition occurs upfront, while payment may be deferred. Any later adjustment in consideration would require corresponding WDV revisions

How Do Investors Choose Between CCPS and CCDs?

 At first glance, the distinction appears straightforward. Compulsorily Convertible Preference Shares (CCPS) are preference shares, while Compulsorily Convertible Debentures (CCDs) are debentures. Each is governed by separate provisions of the Companies Act, though the mechanics of issuance and conversion are largely comparable.

Wednesday, 2 September 2026

Refund of pre-deposit cannot be withheld merely because litigation continues on the balance demand

 In a significant judgment in IBM India Pvt. Ltd. v. Union of India (2026-VIL-955-BOM), the Bombay High Court has reaffirmed an important principle governing GST appeals and pre-deposits.

Taxability of Stock Option Buy-Backs: Salary or Capital Gains?

 . Introduction

Employee Stock Option Plans (ESOPs) are widely used to attract and retain talent by aligning compensation with performance. The lifecycle of an ESOP traverses five stages: grant, vesting, exercise, allotment, and sale. Each carries distinct tax implications.

S𝐮𝐜𝐜𝐞𝐬𝐬 𝐟𝐞𝐞 𝐩𝐚𝐢𝐝 𝐭𝐨 𝐚 𝐭𝐫𝐚𝐧𝐬𝐚𝐜𝐭𝐢𝐨𝐧 𝐚𝐝𝐯𝐢𝐬𝐨𝐫 𝐟𝐨𝐫 𝐭𝐡𝐞 𝐬𝐚𝐥𝐞 𝐨𝐟 𝐬𝐡𝐚𝐫𝐞𝐬 𝐢𝐬 𝐚𝐥𝐥𝐨𝐰𝐚𝐛𝐥𝐞 𝐰𝐡𝐢𝐥𝐞 𝐜𝐨𝐦𝐩𝐮𝐭𝐢𝐧𝐠 𝐜𝐚𝐩𝐢𝐭𝐚𝐥 𝐠𝐚𝐢𝐧𝐬.

 𝐁𝐚𝐧𝐠𝐚𝐥𝐨𝐫𝐞 𝐓𝐫𝐢𝐛𝐮𝐧𝐚𝐥in the case of Mohan Rajashekhar  𝐡𝐞𝐥𝐝 𝐭𝐡𝐚𝐭 𝐬𝐮𝐜𝐜𝐞𝐬𝐬 𝐟𝐞𝐞 𝐩𝐚𝐢𝐝 𝐭𝐨 𝐚 𝐭𝐫𝐚𝐧𝐬𝐚𝐜𝐭𝐢𝐨𝐧 𝐚𝐝𝐯𝐢𝐬𝐨𝐫 𝐟𝐨𝐫 𝐭𝐡𝐞 𝐬𝐚𝐥𝐞 𝐨𝐟 𝐬𝐡𝐚𝐫𝐞𝐬 𝐢𝐬 𝐚𝐥𝐥𝐨𝐰𝐚𝐛𝐥𝐞 𝐰𝐡𝐢𝐥𝐞 𝐜𝐨𝐦𝐩𝐮𝐭𝐢𝐧𝐠 𝐜𝐚𝐩𝐢𝐭𝐚𝐥 𝐠𝐚𝐢𝐧𝐬. 𝐓𝐡𝐞 𝐓𝐫𝐢𝐛𝐮𝐧𝐚𝐥 𝐡𝐞𝐥𝐝 𝐭𝐡𝐚𝐭 𝐰𝐡𝐞𝐫𝐞 𝐚𝐝𝐯𝐢𝐬𝐨𝐫𝐲 𝐬𝐞𝐫𝐯𝐢𝐜𝐞𝐬 𝐡𝐚𝐯𝐞 𝐚 𝐝𝐢𝐫𝐞𝐜𝐭 𝐧𝐞𝐱𝐮𝐬 𝐰𝐢𝐭𝐡 𝐭𝐡𝐞 𝐭𝐫𝐚𝐧𝐬𝐟𝐞𝐫 𝐚𝐧𝐝 𝐭𝐡𝐞 𝐞𝐱𝐩𝐞𝐧𝐝𝐢𝐭𝐮𝐫𝐞 𝐢𝐬 𝐢𝐧𝐜𝐮𝐫𝐫𝐞𝐝 𝐰𝐡𝐨𝐥𝐥𝐲 𝐚𝐧𝐝 𝐞𝐱𝐜𝐥𝐮𝐬𝐢𝐯𝐞𝐥𝐲 𝐢𝐧 𝐜𝐨𝐧𝐧𝐞𝐜𝐭𝐢𝐨𝐧 𝐰𝐢𝐭𝐡 𝐬𝐮𝐜𝐡 𝐭𝐫𝐚𝐧𝐬𝐟𝐞𝐫, 𝐭𝐡𝐞 𝐞𝐱𝐩𝐞𝐧𝐬𝐞 𝐢𝐬 𝐚𝐥𝐥𝐨𝐰𝐞𝐝 𝐚𝐬 𝐝𝐞𝐝𝐮𝐜𝐭𝐢𝐨𝐧.

Monday, 31 August 2026

TAX DUE DATE - SEPTEMBER 2026


S. No

Due Date

Related to

Compliance to be made

1

11.09.2026

GST

Filing of GSTR-1 for August 2026.

2

13.09.2026

ISD

Filing for the month of Aug 2026

3

20.09.2026

GST

- Payment & filing of GST return for the Month of August 2026 - Form GSTR 3B

Sunday, 30 August 2026

Key Changes in FEMA Export and Import Regulations Effective 1 October 2026

The Reserve Bank of India has introduced a new framework governing export and import transactions under FEMA. These regulations are effective from 1 October 2026 and will apply only to transactions initiated on or after that date. Transactions undertaken up to 30 September 2026 will continue to be governed by the earlier FEMA regulations.

Tuesday, 25 August 2026

SC holds extended period cannot be invoked if allegations are not justified in the show cause notice issued under section 74

 This Tax Alert summarizes a recent judgement of the Supreme Court (SC) [1] on whether a show cause notice (SCN) under Section 74 of the Central Goods and Services Tax Act, 2017 (CGST Act) can be sustained merely on a generic allegation of fraud or concealment of facts, without the notice itself setting out the grounds for such allegation.

The Arbitrator’s Ledger: Financial Forensics in ODR

 Let’s start with a small story in this regard. Client B, a mid-sized electrical components manufacturer registered as an MSME, supplied materials worth ₹2.5 crore to Firm Y, a large infrastructure developer. After receiving the goods, Firm Y delayed the payments well beyond the agreed credit period. Frustrated, Client B filed a delayed payment claim against Firm Y on the government's MSME ODR portal. The dispute was referred to an Online Dispute Resolution (ODR) platform. To counter the claim, Firm Y suddenly produced a complex web of internal debit notes, backdated emails, and quality rejection reports, arguing that the materials were defective and no payment was due. The sole arbitrator was faced with hundreds of digital documents and conflicting accounting entries. This is exactly where CA X was brought in as a financial forensic expert to decode the ledger.

Tuesday, 18 August 2026

Gujarat HC upholds levy of GST on corporate guarantee while reads down mandatory 1% valuation where actual consideration is lower

 This Tax Alert summarizes a recent ruling of the Gujarat High Court (HC)1 on the taxability of corporate guarantee provided by the Petitioners on behalf of their related party located in India and the constitutional validity of Rule 28(2) of the Central Goods and Services Tax Rules, 2017 (CGST Rules).


The key observations of the HC are:

Foreign Assets disclosure scheme operationalized - CBDT prescribes valuation rules, forms and compliance framework

 This Tax Alert summarizes the recent Notification notifying “The Foreign Assets of Small Taxpayers - Disclosure Scheme Rules 2026” (Rules) issued by the Central Government and 50 Frequently Asked Questions (FAQs) issued by Central Board of Direct Taxes[2] (CBDT), pertaining to “The Foreign Assets of Small Taxpayers – Disclosure Scheme 2026” (Scheme) which was introduced vide Finance Act (FA) 2026[3].

Monday, 17 August 2026

Taxability of Crypto Derivatives Under Indian Income-tax Law

 The Finance Act, 2022 introduced India's first dedicated tax regime for Virtual Digital Assets (VDAs) through Sections 2(47A), 115BBH and 194S of the Income-tax Act, 1961. The framework was designed to tax income arising from the transfer of cryptocurrencies, NFTs and similar digital assets.

However, the growing popularity of crypto futures and options traded on offshore exchanges has created an interpretational challenge. Unlike spot crypto transactions, many derivative contracts are cash-settled, meaning parties pay or receive only the price difference without acquiring, delivering or transferring the underlying cryptocurrency.

This raises a crucial question: should profits from cash-settled crypto derivatives be taxed under the special VDA regime of Section 115BBH, or under the ordinary provisions relating to business income and speculative transactions? The answer has significant tax implications because the two regimes operate differently.

Sunday, 16 August 2026

GAAR vs SAAR: A Practical Note for Businesses in India

 Taxation is one of the most significant financial obligations for any business. Alongside managing operations, growth, and profitability, companies must carefully plan their tax affairs to ensure compliance while optimizing cash flows. Effective tax planning begins well before the financial year-end and typically involves using the deductions, exemptions, and incentives provided under the Income-tax Act, 1961.

India’s Position on the OECD Model Tax Convention – At a Glance

 Comparison table highlighting how India’s treaty policy differs from the OECD Model Tax Convention, especially on key articles such as Permanent Establishment (Article 5), Business Profits (Article 7), Royalties (Article 12) and Capital Gains (Article 13).

𝗪𝗼𝗿𝗸𝗶𝗻𝗴 𝗖𝗮𝗽𝗶𝘁𝗮𝗹 𝗮𝗱𝗷𝘂𝘀𝘁𝗺𝗲𝗻𝘁 𝗰𝗮𝗻𝗻𝗼𝘁 𝗯𝗲 𝗺𝗮𝗱𝗲 𝗶𝗻 𝘁𝗵𝗲 𝗮𝗯𝘀𝗲𝗻𝗰𝗲 𝗼𝗳 𝗮𝗻𝘆 𝗳𝗶𝗻𝗮𝗻𝗰𝗶𝗻𝗴 𝗰𝗼𝘀𝘁

 In DCIT v. Coca Cola India Inc., the Delhi ITAT held that a Working Capital Adjustment cannot be made merely because receivables from an AE remain outstanding for an extended period. The Tribunal observed that such adjustments under TNMM are intended to improve comparability and must be supported by evidence of actual financing cost or economic disadvantage. Since the assessee had no external borrowings, incurred no interest cost, and was fully funded by its US Head Office, the Revenue failed to establish any real financial burden arising from delayed receivables. Accordingly, the TP adjustment was deleted.

Thursday, 13 August 2026

TAX AMENDMENT BILL 2026

The Lok Sabha has passed the Taxation & Other Laws (Amendment) Bill, 2026 (‘Amendment Bill’). The said Amendment Bill replaces the Income-tax (Amendment) Ordinance, 2026 which was earlier passed on 5 June 2026 and also proposes other amendments to the Income-tax Act, 2025 (‘the Act’), the most notable amendment being in respect of taxation of unitholders and SPVs of business trusts.

SC confirms omission of Rule 96(10) applies to even pending proceedings absence any saving clause

 This Tax Alert summarizes a recent judgement of the Supreme Court (SC)[1] dealing with the effect of omission of Rule 96(10) of the Central Goods and Services Tax Rules, 2017 (CGST Rules) on any proceedings pending disposal on the date of such omission.


Rule 96(10) inter alia restricted any person from claiming refund of integrated tax paid on export of goods or services if benefit of specified exemption notifications was availed. The said rule was omitted w.e.f. 8 October 2024[2].

Subsequently, the Gujarat High Court (HC)[3] held that such omission will be applicable to all proceedings/cases which are pending for final adjudication either before courts or adjudicating authorities. Revenue filed an appeal before SC.

The key observations of the SC are:

Thursday, 6 August 2026

Delhi HC holds 10% pre-deposit requirement for penalty-only appeals inapplicable where SCN was issued before amendment

 This Tax Alert summarizes a recent ruling of the Delhi High Court (HC)[1] on whether the newly introduced pre-deposit requirement for filing an appeal against penalty-only order applies where the show cause notice (SCN) was issued before 1 October 2025, while the adjudication order was passed thereafter.


The key observations of the HC are:   

Thursday, 30 July 2026

Karnataka HC holds HSNS Cess framework unconstitutional due to manner of Cess calculation

 This Tax Alert summarizes a recent ruling of the Karnataka High Court (HC) [1] on the constitutional validity of Health Security se National Security Cess Act, 2025 (HSNS Cess Act), the Health Security se National Security Cess Rules, 2026 (HSNS Cess Rules) and the notifications issued thereunder.


The key observations of the HC are:

GSTN keeps proposed e-Way Bill enhancements on hold until further notice

 This Tax Alert summarizes the recent advisory1 issued by Goods and Services Tax Network (GSTN) keeping the proposed enhancements to the e-Way Bill system on hold until further notice.

The key observations of the HC are:

TAX DUE DATE - AUGUST 2026.

 

Sl. No

Due Date

Related to

Compliance to be made

1

11.08.2026

GST

Filing of GSTR – 1 for the month of July 2026

2

31.08.2026

Income Tax

Filing of Form 10 of Charitable Trust

3

13.08.2026

ISD

Filing for the month of July 2026

4

20.08.2026

GST

Payment & filing of GST return for the Month of July 2026 - Form GSTR 3B

5

07.08.2026

TDS/TCS

(Income Tax)

· Deposit TDS for payments of Salary, Interest, Commission or Brokerage, Rent, Professional fee, payment to Contractors, etc. during the month of July 2026.

· Deposit TDS from Salaries deducted during the month of July 2026

Deposit TCS for collections made under section 394 including sale of scrap during the month of June 2026 if any

Deliver a copy of Form 121(15G/15H), if any to CCIT or CIT for declarations received in the month of June 2026, if any

The Forensic Ledger: Spotting Early Warning Signals of Employee Embezzlement in Small Businesses

-Sakshi Agarwal 

 Let’s start with a small story in this regard. Client B runs a highly successful, medium-sized manufacturing firm that produces industrial packaging. Because he spent most of his time on the factory floor and pitching to new clients, he entrusted his entire back-office operations to Mr. A, a loyal senior accountant who had been with the company for over a decade. Mr. A was considered part of the family; he rarely took vacations, worked late on weekends, and single-handedly managed vendor payments, payroll, and bank reconciliations.

Wednesday, 29 July 2026

Kentucky Sales Tax Changes Effective August 1, 2026: What Businesses Need to Know

 

Kentucky has introduced several important sales and use tax developments that take effect August 1, 2026. If your business sells products or services into Kentucky—especially digital offerings or through remote sales channels—now is a good time to review your compliance obligations.

Here are the key updates:

Protecting Taxpayer Rights: Three Landmark Indian Tax Rulings

 Recent judicial pronouncements have provided significant clarity on the rights of taxpayers and the limitations of tax authorities under Indian tax law. Three important rulings—from the Supreme Court on GST input tax credit, the Chennai ITAT on income tax penalties, and the Mumbai ITAT on demergers—offer crucial guidance for businesses navigating complex tax disputes. Each decision reinforces the principle that tax authorities must act within statutory boundaries and cannot penalize taxpayers arbitrarily.

Thursday, 23 July 2026

Mauritian Cabinet approves ratification of Protocol to India-Mauritius DTAA introducing Principal Purpose Test condition

 The India-Mauritius DTAA, which entered into force on 1 April 1983, was amended by way of Protocol signed on 10 May 2016 [1] (2016 Protocol), wherein largely the source country taxation rights were enhanced and Limitation of Benefits (LOB) clause was included apart from the Exchange of Information (EOI) and Assistance in Collection of Taxes related provisions. The 2016 Protocol did not contain the Base Erosion and Profit Sharing (BEPS) related changes.

Tuesday, 21 July 2026

Delhi HC holds secondment reimbursements taxable as Fees for Included Services (FIS) under India–USA tax treaty

 The Delhi High Court (HC) [1] has recently ruled in favor of the Revenue on the issue of taxability of cost reimbursements received by a foreign Taxpayer from Indian entities in respect of secondment of employees. The HC held that such receipts are taxable as Fees for Included Services (FIS) under Article 12 of the India–USA Double Taxation Avoidance Agreement (‘the treaty’) as the secondment arrangement satisfied the “make available” test.

Calcutta HC upholds validity of GST adjudication order digitally signed within limitation, despite subsequent portal upload

 This Tax Alert summarizes a recent ruling of the Calcutta High Court (HC) [1] on whether an adjudication order under Section 73 of the Central Goods and Services Tax Act, 2017 (CGST Act), which was digitally signed within the prescribed limitation period but uploaded on the common portal thereafter, can be treated as validly issued order, enforceable in law.

Friday, 17 July 2026

GST Invoice Rejected in IMS After Tax Paid? Here’s Your Complete Action Plan

 1. The Core Solution: Coordinate with Your Customer and Re-Report

The GST law provides a very clear and straightforward remedy for this situation. The system is designed to capture the "delta" (the net change) rather than penalizing you for a one-off rejection. The golden rule here is reconciliation, not refund.

The most efficient and widely recommended solution involves a simple two-way coordination between you (the supplier) and your customer (the recipient).

Thursday, 16 July 2026

Delhi Tribunal rules that court-approved capital reduction cannot be re-characterized as buy-back

 This Tax Alert summarizes a recent ruling of the Delhi Income-tax Appellate Tribunal (Tribunal) in case of Seaview Developers Pvt. Ltd. (Taxpayer) v DCIT[1] on the issue of characterization of a court-approved reduction of share capital undertaken by an unlisted company. The key issue before the Tribunal was whether a reduction of share capital implemented pursuant to a scheme sanctioned by the Bombay High Court could be recharacterized as a buy-back of shares and subjected to the buy-back tax regime which trigger levy in the hands of the company while the income in the hands of shareholders is exempt.

TAX DUE DATE- OCTOBER 2026

  S. No Due Date Related to Compliance to be made 1 11.10.2026 GST ...