
Executive Summary
Income Tax
- Amendment in Indian – Mauritius DTAA.
- No TDS on Interest payments to Holders of Maharajah INR Bonds issued by the New Development Bank.
- Income-tax (Seventh Amendment) Rules, 2026: Introduction of Rule 281A and Form No. 173
- Amendment to Rule 231 and Substitution of Form No. 161 for Waiver of Penalty.
Goods And Service Tax (GST)
- Circular Nos. 257/03/2026-GST to 264/10/2026 – GST
- Notifications dated 26–27 October 2026 | Practical client briefing
Companies Act 2013/ Other Laws
- Extension of Annual Filing Deadlines for FY 2025–26
- MCA Notification No. G.S.R. 863(E) – Indian Corporate Law Service Rules, 2026
- SEBI Notification No. SEBI/LAD-DOP/2026/329 dated 12 October 2026 – Amendment to LODR Regulations
- Revamp of Document Number Verification System
- Delegation of Compounding of Certain Contraventions under FEMA, 1999 to Regional Offices
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- Amendment in Indian- Mauritius DTAA.
- The Central Government has notified the Protocol amending the Convention between India and Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains and for the Encouragement of Mutual Trade and Investment.
- The Protocol was signed at Port Louis, Mauritius, on 7 March 2024, and entered into force on 10 August 2026
- Introduction of Article 27B – Entitlement to Benefits (Principal Purpose Test)
Under this benefit, treaty benefits may be denied if, based on all relevant facts and circumstances, it appears that one of the main objectives of a transaction or arrangement was to obtain tax benefits under the DTAA.
However, such treaty benefits may still be granted if it can be demonstrated that granting them is in line with the purpose and intent of the relevant provisions of the DTAA.
- No TDS on Interest payments to Holders of Maharajah INR Bonds issued by the New Development Bank.
The Central Government has notified an exemption from deduction of tax at source (TDS) on interest payments made by the New Development Bank to holders of Maharajah INR Bonds under Section 400(1) of the Income-tax Act, 2025
- Exemption from TDS – No TDS shall be deducted under Section 393(1) [Table: Sl. No. 5] or Section 393(2) [Table: Sl. No. 17], as applicable, on interest payments made by the New Development Bank to holders of Maharajah INR Bonds issued during Tax Year 2026-27 and subsequent tax years.
- Eligible Bondholders –
The exemption is available to the following categories of bondholders:
Residents of India; and
Foreign Institutional Investors (FIIs)
- The New Development Bank shall furnish information as required under Schedule VII as per the provisions of the Income-tax Rules, 2026.
- Income-tax (Seventh Amendment) Rules, 2026: Introduction of Rule 281A and Form No. 173A
- A new rule 281A has been inserted by CBDT.
- As per the newly inserted rule, any assessee claiming exemption under Schedule IV (Table Sl. Nos. 13D and 13E) i.e., tax exemption on interest income and capital gains arising from the sale, exchange, or transfer of Government Securities of the Income-tax Act, 2025, is required to furnish the prescribed information in Form No. 173A.
- A new Form No. 173A has been inserted after Form No. 173 in the Income-tax Rules 2026, prescribing the particulars to be furnished for claiming the above exemptions.
The form requires the assessee to provide the prescribed details, including relevant identification and address particulars, along with applicable financial information.
- Amendment to Rule 231 and Substitution of Form No. 161 for Waiver of Penalty.
- The words “or waiver” have been inserted after the word “imposition” in Rule 231 of the Income-tax Rules, 2026.
This amendment expands the scope of the existing provision to specifically include applications relating to waiver of penalty, in addition to matters concerning its imposition.
- The existing Form No. 161 has been substituted with a revised form titled:
“Application for seeking waiver of penalty under Section 440(2) of the Income-tax Act, 2025.”
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- Circular Nos. 257/03/2026-GST to 264/10/2026-GST
The CBIC has issued eight circulars dated 26 October 2026 to operationalise and clarify selected recommendations of the 57th GST Council Meeting held on 8 October 2026. The circulars cover registration, adjudication, appeal pre-deposits, ISD, ITC and exports. The following is a practical summary for business teams.
| CIRCULAR REF. | KEY CLARIFICATION | IMPACT |
| 257/03/2026-GST GST registration | Prescribes guidelines, FAQs and document checklists to streamline processing of registration applications. Clarifies evidence for principal place of business in owned, rented, consent-based, co-working and SEZ premises. Telecom towers and ATMs are not required to be declared as places of business. | Applicants should use the prescribed document checklist and ensure that proof of premises is consistent with the occupancy arrangement. The circular is intended to reduce avoidable queries and rejections. |
| 258/04/2026-GST Demand, adjudication and appeals | Requires specific facts and evidence where a notice alleges fraud, wilful misstatement or suppression. Sections 74/74A should not be invoked merely because tax remains unpaid or a discrepancy is noticed in scrutiny. Emphasises coordination between Central and State authorities, reasoned orders confined to the notice, issue-wise/year-wise quantification and proper hearing records. It also provides procedural guidance on personal hearings and timelines. | Review notices and orders for clear allegations, evidence, jurisdictional coordination and proper quantification. Preserve hearing records and consider whether the statutory ingredients for the invoked provision are actually established. |
| 259/05/2026-GST Appeal pre-deposit | Clarifies refund of pre-deposit paid under section 107(6) or section 112(8). A refund may be claimed in FORM GST RFD-01 under the category “On account of order” after a favourable appellate order. Refund should not be withheld only because the Department proposes to file or has filed a further appeal, unless the favourable order is stayed. The circular also clarifies interest treatment, including reckoning from the date of payment, separately for each appeal level. | Identify favourable appellate orders where pre-deposits remain unrefunded. Check whether any stay operates and evaluate filing RFD-01 with payment and appeal records. |
| 260/06/2026-GST Input Service Distributor | Clarifies that more than one ISD registration may be obtained for different business verticals or places of business within a State/UT, as applicable. ISD is responsible for correct distribution; recipient registrations remain responsible for checking ITC eligibility and making applicable reversals. Documents issued under Rule 54(1A) facilitate transfer of credit and do not represent outward supplies; the related amounts are excluded from turnover computations. | Review ISD registration structure, distribution methodology and recipient-side eligibility/reversal controls. Ensure Rule 54(1A) transfer documents are not treated as taxable outward supplies or included in turnover. |
| 261/07/2026-GST Section 17(4): banks and NBFCs | Provides clarification on the manner and applicability of the 50% ITC option under section 17(4) for banking companies and financial institutions, including NBFCs. The clarification addresses the treatment of separate registrations engaged exclusively in non-lending activities. | Banks and NBFCs should review the activities undertaken under each GST registration and document the basis on which the 50% restriction is applied or considered inapplicable. The conclusion is fact- and registration-specific. |
| 262/08/2026-GST ITC on demonstration vehicles | Withdraws paragraph 4.6 of Circular No. 231/25/2024-GST dated 10 September 2024, which had denied ITC on demonstration vehicles acquired by authorised dealers under the dealer-agency model. ITC is not blocked under section 17(5)(a) where demo vehicles are used to facilitate further supply of similar motor vehicles, consistent with the treatment of traditional dealership models. | Authorised dealers should review ITC previously not availed or reversed on eligible demonstration vehicles. Any reclaim should be assessed against section 16 conditions, time limits, documentation and the facts of the dealership arrangement. |
| 263/09/2026-GST Receipt of export proceeds | Clarifies that consideration for export of services received in repatriable INR accounts, including SNRR and INR Nostro accounts, can satisfy the payment condition in section 2(6)(iv) of the IGST Act. Permitted set-off of export receivables against import payables can also qualify where carried out in accordance with RBI directions. The circular also addresses the realization period for export of goods and Rule 96B where the authorised dealer bank has written off the export proceeds. | Exporters should review payment routes and netting arrangements, retain bank/AD evidence and ensure compliance with RBI/FEMA requirements. For goods exports, track realisation timelines under the applicable RBI directions. |
| 264/10/2026-GST Omission of Rule 96(10) | Clarifies that omission of Rule 96(10) of the CGST Rules is effective retrospectively from 23 October 2017, in line with the Supreme Court decision in Goodluck India Limited. The same treatment applies to omission of Rules 89(4A) and 89(4B). | Exporters facing pending refund denials, demands or litigation based on these provisions should review the relevant periods and procedural status, and assess available relief in light of the judgment and circular. |
Overall Takeaway
The circulars provide operational clarity and targeted relief in selected areas; they do not, by themselves, replace the need to examine the underlying Act, Rules, notifications and facts of each case. Businesses should prioritise reviews where the circular may unlock refunds or ITC, reduce litigation exposure, or require changes to internal GST processes.
- Notifications dated 26–27 October 2026 | Practical client briefing
The following notifications give effect to selected recommendations of the 57th GST Council Meeting. The effective dates differ; businesses should apply each change from its notified date rather than assuming that every amendment took effect immediately.
| NOTIFICATION / EFFECTIVE DATE | WHAT IT CHANGES – IN SIMPLE TERMS | IMPACT |
| 03/2026–Central Tax 26 Oct 2026 Effective 1 Nov 2026 | Brings into force amendments relating to post-supply discounts, credit notes and refunds. A post-sale discount can reduce taxable value where the supplier issues a GST credit note and the recipient reverses the ITC attributable to that discount. The earlier requirement for a pre-existing agreement and invoice-wise linkage is removed. The 90% provisional-refund facility is extended to eligible inverted-duty refund claims. The ₹1,000 minimum refund threshold is removed for refund of tax paid on goods exported. | Update discount agreements and credit-note workflows. Obtain and retain recipient ITC-reversal confirmation. Review eligible inverted-duty refund claims for provisional refund and small export-of-goods refund claims. |
| 04/2026–Central Tax 26 Oct 2026 Effective 1 Jan 2027 | Expands the notified e-invoicing transaction categories to expressly include specified inward supplies liable to reverse charge from unregistered suppliers and import of services, in addition to supplies to registered persons and exports. | Review RCM and import-of-service invoice processes, including self-invoice / document generation and IRP readiness. Confirm system changes before 1 January 2027; do not treat the notification as requiring an ordinary supplier e-invoice from an unregistered overseas supplier. |
| 05/2026–Central Tax 26 Oct 2026 Mainly effective 1 Nov 2026; specific provisions later | Makes wide-ranging changes to the CGST Rules and forms. Key changes include a simplified registration route for certain small sellers using an e-commerce operator’s warehouse in another State; revised registration amendment/cancellation procedures; faster refund processing (including a 10-day acknowledgement/deficiency timeline and deemed acknowledgement in specified cases); and changes to refund calculations. From 1 April 2027, eligible capital-goods ITC will be considered proportionately over 60 months for refunds relating to zero-rated supplies and inverted-duty structure. Eligible input-service ITC for inverted-duty refunds is included for credit availed on/after 1 November 2026. | Map the effective dates provision-wise. Review registration and cancellation SOPs, refund application controls and forms. Exporters under LUT should maintain a separate capital-goods ITC register for eligible purchases from 1 April 2027. Blocked or otherwise ineligible ITC remains excluded. |
| 06/2026–Central Tax 27 Oct 2026 Effective 1 Nov 2026 | Removes the registration exemption for suppliers dealing in specified categories: used cooking oil, plastic waste/scrap, tyre waste/scrap, metal scrap and electrical/electronic waste and scrap. Such suppliers can no longer rely on the earlier exemption merely because their supplies are covered by reverse charge. | Businesses supplying these specified goods should check GST registration status and obtain registration where required before continuing taxable supplies from 1 November 2026. |
| 07/2026–Central Tax 27 Oct 2026 Effective 1 Nov 2026 | Expands the specified goods for which registered buyers must deduct GST TDS when purchasing from another registered person. The list now covers used cooking oil, plastic scrap, tyre scrap, metal scrap and electrical/electronic waste and scrap. | Registered buyers in these sectors should update vendor masters, purchase controls and TDS processes. Check the prescribed threshold and other section 51 conditions before deducting TDS. |

- Extension of Annual Filing Deadlines for FY 2025–26
- The Ministry of Corporate Affairs (MCA), vide General Circular No. 05/2026 dated 24 October 2026, has provided an extension for filing specified financial statements and annual returns for FY 2025–26 without additional fees.
- The extended deadlines are 31 December 2026 for Forms AOC-4 and applicable variants and 31 January 2027 for Forms MGT-7 and MGT-7A. The relaxation does not extend the statutory timeline for holding AGMs. Companies are advised to complete their annual filings within the revised deadlines to avoid additional filing fees and ensure statutory compliance.
- MCA Notification No. G.S.R. 863(E) – Indian Corporate Law Service Rules, 2026
- The Ministry of Corporate Affairs, vide Notification No. G.S.R. 863(E) dated 6 October 2026, notified the Indian Corporate Law Service Rules, 2026, superseding the earlier 2015 Rules.
- The Rules prescribe provisions relating to recruitment, promotion, service conditions and cadre structure of officers of the Indian Corporate Law Service. This notification marks an administrative development in the framework governing MCA’s corporate law service C. Extension of Accredited Investor Compliance Timeline for Angel Funds.
- SEBI Notification No. SEBI/LAD-DOP/2026/329 dated 12 October 2026 – Amendment to LODR Regulations
- The Securities and Exchange Board of India (SEBI) notified the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) (Third Amendment) Regulations, 2026, amending Regulation 62A of the SEBI (LODR) Regulations, 2015.
- Under the revised provision, listed entities whose non-convertible debt securities are listed on or after the amendment’s publication in the Official Gazette must list all non-convertible debt securities issued after that listing date on the stock exchange(s). The amendment also omits sub-regulations (2) and (3) of Regulation 62A and came into force upon publication in the Official Gazette on 14 October 2026.
- Revamp of Document Number Verification System
The Securities and Exchange Board of India (SEBI) has revamped its Document Number Verification System to strengthen the authentication of official letters and notices issued by SEBI. The revised system makes the subject matter of the communication a mandatory field for verification and aligns the system with the outward number format generated through SEBI’s E-Office system. Recipients can verify the authenticity of SEBI communications using the prescribed details. However, successful verification confirms the issuance of the communication and does not validate its contents.
- Delegation of Compounding of Certain Contraventions under FEMA, 1999 to Regional Offices
- The Reserve Bank of India has delegated powers to compound specified FEMA contraventions relating to overseas investments, borrowing and lending, and guarantees to designated Regional Offices.
- Applications must be submitted to the appropriate office based on the nature of the transaction and applicable jurisdiction or overseas investment identification number (UIN). The change is intended to facilitate the processing of compounding applications.
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Disclaimer Information in this note is intended to provide only a general update of the subjects covered. It is not intended to be a substitute for detailed research or the exercise of professional judgment. KNM accepts no responsibility for loss arising from any action taken or not taken by anyone using this publication. Updates for the period 31.08.2026


















