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TaxCorp Daily Digest
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Edition: March 21, 2026
⚡ Quick Summary
- Income Tax Act 2025 goes live: CBDT notifies Income-tax Rules, 2026 effective April 1, 2026 — comprehensive procedural framework covering perquisite valuation, FMV computation, cross-border attribution rules, and mandatory Form No. 4 filing for international transactions
- GST enforcement tightens: Goa makes property owners directly liable for event-related GST evasion; Delhi High Court confirms assessees cannot outsource compliance responsibility to CAs
- SEBI overhauls mutual fund regulation: New Master Circular effective April 1, 2026 consolidates the entire MF regulatory framework under SEBI (Mutual Funds) Regulations, 2026, rescinding 34 prior circulars
- Critical ITAT rulings favour assessees: Multiple landmark decisions on reassessment validity, Section 56(2)(x) safe harbour, natural justice in additions, and Section 87A rebate entitlement deliver significant relief to taxpayers
📂 Category-wise Updates
🟦 Income Tax
CBDT has notified the Income-tax Rules, 2026 vide Notification No. G.S.R. 198(E) dated March 20, 2026, operative from April 1, 2026. The rules lay down granular procedural scaffolding under the Income-tax Act, 2025 — covering perquisite valuation (accommodation, vehicles, loans, gifts), FMV computation under Rule 11, income attribution to Indian assets under Rule 12, and Significant Economic Presence thresholds under Rule 13. Assessees with international transactions must file a mandatory accountant-certified Form No. 4 alongside their return.
📌 Action Item: Immediately map existing compliance workflows to Rules 2026 provisions; update payroll software for revised perquisite valuation methodology; ensure Form No. 4 readiness for cross-border assessees before April 1, 2026.
2. A Comprehensive Blueprint of the Income Tax Act 2025: Transitioning from the 1961 Regime
The Income Tax Act, 2025 modernises the tax code by shifting exemptions into dedicated schedules, making Section 202 the default concessional regime, consolidating tax audit reporting into Form 26 (replacing Form 3CD), integrating Chapter VI-A deductions into Schedule XV, and replacing Form 15G/15H with unified Form 121. These are structural changes that affect virtually every taxpayer and practitioner.
📌 Action Item: Update accounting software to align with Form 26 reporting; evaluate the financial impact of Section 202 as the new default regime; train teams on the new section numbering architecture.
Section 393 consolidates all TDS provisions into a single structured section under the Income Tax Act, 2025. Table 1 alone covers eight broad TDS categories including commission, rent, immovable property, interest, contractor payments, and dividends. Key change: the Plant & Machinery rent TDS threshold rises from ₹20,000 to ₹50,000 per month, offering relief to assessees in that segment. The consolidation is primarily structural with no change in most substantive obligations.
📌 Action Item: Revise TDS compliance calendars and deduction logic in ERP systems to reflect the new threshold for plant and machinery rent; update deductor-specific checklists under the 2025 Act framework.
The Lower Deduction Certificate mechanism transitions from Section 197 (1961 Act) to Section 395 (2025 Act), with application shifting from Form 13 to Form 128 via TRACES. The new provision adopts universal applicability across all of Chapter XIX rather than a section-specific list. Certificates retain strict financial year validity, and detailed documentation including ITRs from FY 2021-22 to FY 2025-26 remains essential.
📌 Action Item: Apply for Section 395 certificates via Form 128 on TRACES well ahead of April 1, 2026; maintain updated historical ITRs and income projections as supporting documentation.
Notification No. 24/2026 dated March 20, 2026 grants Tea Research Association, Kolkata (PAN: AAAAT3430E) approval under Section 35(1)(ii) for AY 2027-28 to AY 2031-32. Donors can claim deductions subject to annual donor-wise reporting via Form 10BD (due by May 31 following the financial year) and mandatory issuance of Form 10BE certificates.
📌 Action Item: Verify PAN of the Association before making donations; ensure Form 10BD is filed by May 31 each year and Form 10BE certificates are issued to all donors without exception.
Notification No. 23/2026 authorises The Ahmedabad University to receive tax-deductible donations for scientific research under Section 35(1)(ii) for AY 2026-27 to AY 2030-31. Compliance under Rule 5E and Rule 18AB is mandatory, including annual Form 10BD filing by May 31 and issuance of Form 10BE to each donor.
📌 Action Item: Donors should obtain Form 10BE from the University before filing their ITR; confirm that the donation is aligned with the approved scientific research purpose.
In a landmark ruling in Shreyas Naynesh Modi Vs ITO, the ITAT Mumbai Special Bench confirmed that the 10% safe harbour tolerance under Section 56(2)(x) and Section 50C applies not just to Stamp Duty Value but also to DVO-determined Fair Market Value. When a DVO reference is made, the FMV legally substitutes the SDV as the benchmark, and the statutory tolerance band must be applied to it — providing significant relief in genuine property transactions involving minor valuation discrepancies.
📌 Action Item: In all property transactions involving DVO referrals, apply the 10% tolerance to the DVO value; document the basis for FMV claims and retain valuation reports.
In Srinivasa Rao Sirivuri Vs ITO, ITAT Visakhapatnam quashed reassessment for AY 2015-16 as the Section 148 notice was issued on April 3, 2022 — one day after the six-year limitation expired on March 31, 2022. Relying on the Supreme Court's ruling in Union of India v. Rajeev Bansal (2024), the Tribunal held that the first proviso to Section 149(1) bars notices for pre-April 2021 AYs beyond the old limitation period.
📌 Action Item: Assessees who received Section 148 notices in April 2022 for AY 2015-16 should immediately examine limitation dates; challenge notices issued even one day beyond the prescribed deadline.
In Shairul Impex Vs ITO, ITAT Mumbai held that for Section 149(1)(b) as amended by Finance Act, 2021, the AO must establish that escaped income is represented by an asset (as defined in the Explanation to Section 149). Bogus purchase allegations — being revenue P&L items — cannot satisfy this condition unless directly linked to asset creation on record.
📌 Action Item: Where reassessment notices relate to bogus purchase additions beyond three years, verify whether the "asset" precondition under amended Section 149(1)(b) has been specifically alleged and substantiated by the AO.
In Titiksha Chhajed Vs ITO, ITAT Raipur held that Section 87A rebate cannot be denied on purely technical grounds where total income is below ₹7,00,000 and no Revenue prejudice exists. Both assessees had declared incomes well within threshold and claimed rebates against short-term capital gains. The Tribunal firmly held that where the sole statutory eligibility condition is satisfied, the benefit must be granted as a matter of right.
📌 Action Item: Assessees whose Section 87A claims were denied at CPC processing stage despite income below ₹7 lakh should file rectification applications or appeals citing this ruling.
11. ITAT Mumbai Ruling: Section 11 Exemption Cannot Be Denied Solely Due to Delayed Form 10B Filing
In MIG Cricket Club Vs DCIT, ITAT Mumbai reaffirmed that statutory timelines for filing Form 10B are directory in nature and delay can be condoned at the appellate stage under Section 251, provided there is substantial compliance and no mala fide intent. This provides significant relief to trusts, clubs, and charitable institutions adversely affected by automated CPC rejections.
📌 Action Item: Trusts and charitable institutions facing Section 11 denial solely for Form 10B delay should file appeals before CIT(A) with the audit report and a condonation application.
12. TDS Demand on Inoperative PAN Due to PAN–Aadhaar Non-Linking: Remedies When No CBDT Relief Applies
CBDT relief circulars (including Circular Nos. 03/2023, 06/2024, 08/2024, and 09/2025) on PAN-Aadhaar TDS demands are strictly conditional and date-specific — they do not operate as universal waivers. Where a deductor's facts fall outside the conditions of any applicable circular, a structured remedial approach is required: verify exempt category status → correct statement-level defects → portal-based administrative response → Section 154 rectification → and ultimately, formal appeal.
📌 Action Item: Deductors facing TDS demands for PAN-inoperative deductees should map their specific transaction dates against each CBDT circular's conditions before choosing a remedial path.
13. New Pathways When Section 12AB & 80G Renewal Is Not Granted: Practical Legal Options for Trusts
Where Section 12AB registration or 80G approval renewal is pending, rejected, or not timely filed, trusts must respond in a calibrated manner specific to their procedural stage. There is no concept of deemed renewal for pending applications. Procedural rejections may be remedied through fresh applications; merit-based rejections should be appealed to ITAT under Section 253(3) within strict limitation.
📌 Action Item: Trusts with pending renewal applications should file portal grievances and written representations immediately; those facing rejection orders must evaluate whether the ground is procedural or substantive before deciding on appeal vs. re-application.
14. CSR Donations & Section 80G: ITAT Mumbai Allows Deduction Despite CSR Tag
In Reliance Retail Limited Vs ACIT, ITAT Mumbai held that CSR donations to Section 80G-registered entities qualify for Section 80G deduction, provided CSR expenditure has already been fully disallowed under Explanation 2 to Section 37(1). Denying Section 80G additionally would create an impermissible double disallowance. The ruling also reaffirms limits on Rule 8D application under Section 14A and validates the three-year deduction mechanism under Section 80JJAA.
📌 Action Item: Corporates making CSR donations to Section 80G-registered entities should claim Section 80G deduction after confirming full disallowance of the same expenditure under Section 37(1); document the dual treatment clearly in tax workings.
In Bhagawati M Jain Vs ITO, ITAT Mumbai struck down an addition under Section 69B based solely on a general third-party search statement, where the assessee was denied access to the underlying material and the right to cross-examination. Relying on the Supreme Court's Andaman Timber Industries ruling, the Tribunal held that denial of cross-examination renders the order a nullity and that the burden of proving undisclosed investment lies with the Revenue.
📌 Action Item: Assessees facing additions based on third-party search statements should formally demand (in writing) the statement, supporting material, and the right to cross-examine — and raise natural justice grounds if denied.
In Erki Krishnamurthy HUF Vs ITO, ITAT Bangalore held that CIT(A) cannot dismiss an appeal in limine for non-prosecution under Section 250 — the appellate authority must adjudicate on merits from the record. Substantively, the Tribunal struck down ad-hoc per-acre income estimations where the assessee had provided RTC land records, crop evidence, and banking trails.
📌 Action Item: Agricultural income assessees must maintain complete documentary evidence — RTC records, crop yield data, trader receipts, and bank statements — to rebut AO estimations.
In United Spirits Limited Vs DCIT, the Karnataka High Court held that an ITAT remand does not constitute a fresh Section 92CA reference, and therefore Section 153(4)'s extended limitation is inapplicable. The correct limitation is Section 153(3). Where the Tribunal's order was received in FY 2022-23, the last permissible date for fresh orders was March 31, 2024 — proceedings beyond that date were quashed as without jurisdiction.
📌 Action Item: TP assessees whose ITAT remand orders were received in FY 2022-23 should verify whether the AO passed fresh orders by March 31, 2024; any subsequent proceedings may be challengeable on limitation grounds.
In S. Sagar Enterprise Vs DCIT, ITAT Mumbai struck down a Section 69C addition of ₹6,65,045 based solely on third-party software entries — where the material was never shared with the assessee and no cross-examination was permitted. The Tribunal held that the assessee cannot be expected to prove a negative when the underlying evidentiary basis is withheld.
📌 Action Item: Where additions are based on third-party data or software records in faceless proceedings, formally request disclosure of all adverse material and specifically assert the right to cross-examination before the first response deadline.
🟩 GST
1. Goa GST Appellate Tribunal: Appeal Filing Deadlines Notified for 2026
Notification No. 38/1/2017-Fin(R&C)/31169 dated March 10, 2026 prescribes GST Appellate Tribunal appeal deadlines for Goa. For orders communicated before April 1, 2026, the last date to appeal is June 30, 2026. For orders communicated on or after April 1, 2026, appeal must be filed within three months from the date of communication.
📌 Action Item: 🚨 URGENT — Review all GST orders received before April 1, 2026 immediately; initiate appeal process well before June 30, 2026 to avoid losing appellate remedy before the Tribunal.
2. Goa GST Order Makes Property Owners Answerable for Event-Related Tax Evasion
The Goa Commissioner of State Tax has invoked Sections 151 and 168 of the Goa GST Act requiring owners and possessors of premises hosting commercial events (concerts, exhibitions, sports events, fashion shows) to report the event at least three days in advance to GST enforcement officials. Failure to report makes the property owner deemed supplier liable for GST, interest, and penalties, with potential criminal liability under Sections 122, 124, and 132 including imprisonment up to six months.
📌 Action Item: Goa property owners must implement an advance event reporting protocol; retain acknowledgments of all filings as proof of compliance; include GST reporting obligations as standard clauses in event hall rental agreements.
In Assistant Commissioner of Central Taxes Vs Merck Life Science, the Karnataka High Court held that the two-year limitation under Section 54 for GST refunds is mandatory and cannot be waived by departmental officers. However, the High Court's writ jurisdiction under Article 226 is not ousted — where an assessee has unquestionable entitlement (e.g., double-tax payment of IGST + CGST/SGST on the same supply), courts can condone delay to prevent the State from retaining tax in violation of Article 265.
📌 Action Item: Assessees with clear double-payment refund claims beyond two years should file writ petitions before the High Court; simultaneously prepare documentation of the dual-tax payment as primary evidence.
In M/s Fone Zone NXT v. Commissioner of DGST, the Delhi High Court held that an assessee cannot escape procedural non-compliance by blaming a CA where the assessee itself linked its GST registration to the professional's email ID. A willingness to deposit part of the disputed demand does not justify the Court overriding the statutory framework under Article 226. Ex-parte orders under such circumstances are valid.
📌 Action Item: All GST-registered businesses must personally monitor the official email ID linked to GST registration; do not rely solely on professional intermediaries for notice tracking — set up independent monitoring systems.
5. Bombay High Court Mandates Restoration of GST Registration Upon Full Settlement of Statutory Dues
In Kishore Nichani v. Union of India, the Bombay High Court held that once an assessee has cleared all outstanding taxes, interest, and penalties under Section 74 proceedings, tax authorities are duty-bound under Section 30 and Rule 23 to revoke the registration cancellation. Retaining cancellation post-settlement of dues is legally untenable and unconstitutionally prejudices the right to conduct business.
📌 Action Item: Assessees who have settled all dues under Section 74 but face continued registration cancellation should file a formal revocation application under Rule 23 and, if not acted upon promptly, approach the High Court.
In M/s. Sona Enterprises v. Assistant Commissioner of Central Tax, the AP High Court held that Section 75(12) can only be invoked where an assessee has independently declared a tax liability in GSTR-3B and failed to pay it — it cannot be used to bypass adjudication for ITC disputes, which are inherently adjudicatory in nature requiring notice, hearing, and a speaking order under Sections 73/74.
📌 Action Item: Assessees facing coercive recovery under Section 75(12) for ITC-related matters should challenge the action as without jurisdiction; insist on the full adjudicatory process under Sections 73/74 before any recovery.
7. GST Personal Hearings: Procedure, Perception, and the Gap in Natural Justice
This comprehensive analysis examines how personal hearings under Section 75(4) of the CGST Act often function as procedural formalities rather than genuine adversarial processes — with Adjudicating Authorities frequently passing orders without genuinely engaging with oral submissions, and the "echo effect" perpetuating the same flaws at the appellate level.
📌 Action Item: Assessees should submit comprehensive written representations before personal hearings and request that specific points be explicitly addressed in the order; if the final order ignores written submissions, this provides strong grounds for appeal on natural justice.
In Gas Trade International Vs State Of UP, the Allahabad High Court quashed a GST appellate order that mechanically confirmed lower authority demands under Section 129(1) without addressing the assessee's evidence of discrepancies in a third-party lab report and the absence of mens rea. The Court remanded the matter and directed a "speaking order" that thoroughly addresses each specific ground raised by the assessee.
📌 Action Item: In transit detention cases, immediately challenge the accuracy of laboratory reports with independent test data; ensure all grounds are submitted in writing and demand that the appellate order specifically addresses each ground.
9. Supreme Court grants bail in fake ITC case due to extended pre-trial detention and trial delay
In Amit Mehra v. Union of India, the Supreme Court granted bail in a fake ITC case where the accused had been in judicial custody for over eight months without framing of charges and trial commencement. The Court balanced liberty rights against enforcement interests by allowing GST authorities to approach the Trial Court for protective conditions.
📌 Action Item: Legal counsel in GST criminal cases should proactively track pre-trial detention duration; consider filing bail applications based on this precedent where custody exceeds eight months without charge framing.
This comprehensive guide covers GST compliance for real estate including the 2019 rate structure, judicial expansions of assessee rights on land deduction challenges, new commercial ITC pathways, and the critical role of development agreement drafting in joint ventures. The article emphasizes that tax rights can only be exercised with impeccable internal documentation and proactive transaction structuring.
📌 Action Item: Real estate developers should integrate GST advisory into project inception planning; review all development agreements for precise ITC allocation clauses and land deduction documentation.
🟧 Company Law & Corporate Law
1. Filing of Financial Statements Under Companies Act 2013: Compliance Guide with Practical FAQs
The Companies Act, 2013 mandates a sequential pathway: Board approval under Section 134(1) → Auditor's and Board's Report attachment → AGM adoption under Section 129(2) → ROC filing under Section 137(1) within 30 days of AGM. Critically, non-holding of AGM or non-adoption of financial statements does not absolve the company of filing obligations — provisional filing of unadopted statements is still required, with final adopted statements filed separately after the adjourned AGM.
📌 Action Item: Companies that did not hold their AGM within the statutory period must still file provisional financial statements with ROC within the prescribed timeline; legal counsel should be engaged to ensure compliance with Sections 137(1) and 137(2) simultaneously.
Under the EPF Act, 1952 and EPF Scheme, 1952, international workers from non-SSA countries are subject to the age-58 retirement threshold for PF withdrawal — with no early-access provision available merely on account of employment cessation or departure from India. Employer obligations for record maintenance, KYC management, and PF disclosure persist for years — sometimes decades — after the assignment ends.
📌 Action Item: Employers must incorporate SSA assessment and PF disclosure obligations into pre-assignment onboarding; maintain long-term records and proactively manage KYC updates for international workers even post-assignment.
3. From Farm to Tawa: Legal Architecture Behind India's Everyday Supply Chains
Using the supply chain of a masala dosa as a case study, this article maps India's layered legal framework across agriculture, energy, mining, manufacturing, warehousing, logistics, retail, digital platforms, finance, and telecom. Every segment carries its own statutes, licences, contracts, and compliance obligations — making a proactive legal strategy essential for supply chain resilience.
📌 Action Item: Businesses should map all supply chain stages to their applicable regulatory frameworks; engage multi-disciplinary legal teams to audit sector-specific licences, contracts, and compliance requirements across the value chain.
🟪 SEBI
SEBI's comprehensive Master Circular dated March 20, 2026 under Section 11(1) of the SEBI Act consolidates the entire mutual fund regulatory framework under SEBI (Mutual Funds) Regulations, 2026 effective April 1, 2026. It rescinds 34 earlier circulars (listed in the Appendix) while replacing the Master Circular of June 27, 2024. A robust savings provision ensures that all ongoing proceedings, pending applications, rights, and liabilities under rescinded circulars are fully preserved.
📌 Action Item: All AMCs, trustees, and compliance teams must immediately review the new Master Circular, map their internal policies against the consolidated framework, update SOPs by March 31, 2026, and verify that no ongoing regulatory action is inadvertently treated as extinguished by the rescission of prior circulars.
🟨 Customs
1. Revised Customs Tariff Values for Gold, Silver, Edible Oils and Areca Nuts Effective 21 March 2026
Notification No. 28/2026-Customs (N.T.) under Section 14(2) of the Customs Act substitutes TABLE-1, TABLE-2, and TABLE-3 of Notification No. 36/2001-Customs (N.T.) effective March 21, 2026. While the legal tables are formally replaced, the underlying tariff values for crude/refined palm oil, palmolein, soybean oil, brass scrap, gold, silver, and areca nuts remain unchanged from Notification No. 27/2026. This is a procedural consolidation with no change in duty incidence.
📌 Action Item: Update all internal documentation references to cite Notification No. 28/2026-Customs (N.T.) from March 21, 2026 onwards; no change to import duty calculations is required.
2. DGFT Modifies SION A-2005: Revised Input Allowances for Phenoxyethanol Exports under FTP 2023
Public Notice No. 52/2025-26 dated March 20, 2026 modifies SION A-2005 by broadening the export product description from "Phenoxyethanol (Preservative Grade)" to simply "Phenoxyethanol", and reduces the Ethylene Oxide import allowance from 0.325 kg to 0.323 kg per unit. Both changes are effective immediately under FTP 2023 and are legally binding.
📌 Action Item: Update ERP systems to reflect the revised export product description; recalibrate raw material import quantities for Ethylene Oxide in procurement plans to reflect the new 0.323 kg allowance; revise customs documentation accordingly.
Notification No. 29/2026-Customs (N.T.) dated March 20, 2026 consolidates adjudication of six show cause notices issued to KPR Sugar Mills Ltd. and Quantum Knits (2022–2025) under a single authority — the Additional/Joint Commissioner of Customs, Custom House, Tuticorin — replacing four separate authorities in Coimbatore, Tiruchirappalli, and Chennai. This covers drawback SCNs, IGST refund disputes, and preventive enforcement actions.
📌 Action Item: KPR Sugar Mills and Quantum Knits should immediately redirect all future correspondence, replies, and legal submissions to the Custom House, Tuticorin; update matter-tracking registers to reflect the new centralized forum.
🟫 FEMA / Foreign Trade
1. DGFT issues detailed clarifications on Interest Subvention Support for export credit under EPM
Trade Notice No. 33/2025-26 tightens Interest Subvention Support under EPM – Niryat Protsahan. Key changes: subvention applies only to loans disbursed on or after January 2, 2026; mandatory UIN/UDIN generation before disbursal; strict ₹50 lakh per IEC annual cap; UINs are non-portable between banks; benefits cease from the date an account is classified as NPA; and tariff line eligibility is governed by a Positive List with no retrospective benefits.
📌 Action Item: Exporters and their banks must generate UIN/UDIN before every disbursal; confirm tariff line eligibility against the Positive List; maintain NPA monitoring as benefits cease immediately upon NPA classification.
⚖️ Insolvency
The Bombay High Court held that the interim moratorium under Section 96 of the IBC cannot be stretched to disturb transactions that have already attained legal finality — specifically a completed SARFAESI auction with a registered sale certificate. The Court identified the insolvency filing as a strategy to obstruct possession handover, treated it as an abuse of the IBC framework, set aside the blocking order, and directed the secured creditor to proceed with possession delivery.
📌 Action Item: Auction purchasers under SARFAESI facing IBC moratorium challenges should document the timeline of auction completion and registration of sale certificate to establish legal finality, and approach the High Court under Article 226 if possession is being obstructed through IBC proceedings.
⏰ Key Deadlines & Action Items
| Deadline | Compliance Requirement | Applicable Entities |
|---|---|---|
| March 31, 2026 | Last date for AMCs/trustees to align internal policies with SEBI Master Circular 2026 | Mutual Fund AMCs, Trustees |
| March 31, 2026 | Update all compliance systems, ERP, and forms to Income Tax Act 2025 and Rules 2026 framework | All taxpayers, deductors |
| April 1, 2026 | Income Tax Rules 2026 become operative; Form 128 replaces Form 13 for LDCs | All deductors, cross-border assessees |
| April 1, 2026 | SEBI (Mutual Funds) Regulations, 2026 become effective | All mutual fund entities |
| June 30, 2026 | LAST DATE to file GST Appellate Tribunal appeals for orders communicated before April 1, 2026 (Goa) | All GST assessees in Goa |
| Within 3 months of order | GST Appellate Tribunal appeal deadline for orders communicated on/after April 1, 2026 (Goa) | GST assessees in Goa |
| May 31 (annually) | Form 10BD donor-wise reporting by Tea Research Association and Ahmedabad University | Both approved institutions |
| 30 days from AGM | Filing of adopted financial statements with ROC under Section 137(1) | All companies under Companies Act, 2013 |
| At least 3 days before event | Advance reporting of commercial events on premises to GST officials (Goa) | Property owners hosting events in Goa |
| Before disbursal | UIN/UDIN generation mandatory for Interest Subvention export credit claims | Banks and exporters under EPM |
💡 Professional Takeaways
1. The "New Tax Code" Transition Window Is Closing Fast
The simultaneous notification of Income Tax Rules, 2026, the consolidation of TDS under Section 393, the transition of Lower Deduction Certificates to Form 128/Section 395, and the shift to Form 26 for tax audits create an enormous transition compliance burden — all effective April 1, 2026. Tax professionals must prioritise immediate client communication, system migration audits, and form-mapping exercises. The window for error-free transition is now measured in days, not weeks.
2. Natural Justice Is Your Most Powerful GST Litigation Tool
The TaxCorp coverage today features a remarkable cluster of rulings — from the AP High Court on Section 75(12), the Allahabad High Court on speaking orders in transit detentions, the Bombay High Court on registration cancellation, and the Delhi High Court on professional intermediary responsibility — all converging on one message: procedural and natural justice violations are the most consistently successful ground for challenging GST demands. Practitioners should systematically audit every pending GST proceeding for notice adequacy, hearing quality, and speaking order compliance before filing substantive grounds.
3. Documentation Is the Difference Between Winning and Losing
Across today's Income Tax ITAT rulings — whether on agricultural income (Erki Krishnamurthy HUF), Section 69A additions (Kanakapura Madhusudhan Karthik), AIR-based reassessments (Sangeeta Sunil Kadoo), demonetisation SBN deposits, or Section 69B additions (Bhagawati M Jain) — a single consistent theme emerges: assessees who maintain contemporaneous documentary evidence win; those who do not, face remands or additions. The practical implication for advisory professionals is clear — build documentation protocols into year-round compliance, not just during assessment proceedings.
© 2026 TaxCorp India | All content is original TaxCorp analysis. This digest is for informational purposes only and does not constitute legal or tax advice. For specific matters, consult a qualified professional.
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