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GSTN Advisory On RSP Based Valuation Of Tobacco Goods

RSP Based Valuation Of Tobacco Goods Under GST

GSTN Advisory, Dated 23-01-2026

1. Introduction: GSTN Issues Advisory on RSP-Based Valuation

The Goods and Services Tax Network (GSTN) has issued an advisory dated 23 January 2026 to guide taxpayers on reporting taxable value and tax liability for notified tobacco and tobacco-related goods under GST. The advisory applies with effect from 1 February 2026 and addresses compliance aspects of Retail Sale Price (RSP)-based valuation.

2. Legal Framework Governing RSP-Based Valuation

The advisory refers to Notification No. 19/2025–Central Tax and Notification No. 20/2025–Central Tax, both dated 31 December 2025. Under these notifications, GST on specified tobacco products is required to be computed on the basis of the RSP declared on the package, irrespective of the actual transaction value agreed between the supplier and the recipient.

3. Computation of Deemed Taxable Value

GSTN has clarified the statutory mechanism for deriving the deemed taxable value and corresponding tax amount from the declared RSP. Even where the commercial consideration differs from the deemed value, taxpayers are required to strictly apply the prescribed RSP-based valuation formula for computing GST liability on the notified goods.

4. Reporting in e-Invoice, e-Way Bill and GST Returns

For reporting purposes in e-Invoice, e-Way Bill, and GSTR-1, GSTR-1A, or IFF, taxpayers must disclose the net sale value, being the commercial consideration, in the taxable value field. However, tax must be calculated strictly as per the RSP-based valuation. The total invoice value should be reported as the aggregate of the net sale value and the tax so computed, even where the deemed taxable value does not align with the transaction value.

5. Conclusion: Compliance Responsibility on Taxpayers

The advisory makes it clear that this reporting mechanism is applicable only to the notified HSNs and places the responsibility of correct self-assessment on taxpayers. Proper identification and classification of goods, accurate computation of tax based on RSP, and verification of reported figures are essential to ensure compliance and avoid disputes under GST.

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[Opinion] Budget 2026 – Key Expectations in Transfer Pricing

Budget 2026 Transfer Pricing Expectations

Rajiv Bhutani – [2026] 182 taxmann.com 609 (Article)

India’s economic journey over the past few years has been marked by remarkable growth and a steady rise in its position on the global stage. India is the fourth largest economy in the world, and the country’s growth reflects a combination of strong domestic demand and policy reforms, positioning the country as a key destination for global capital.

While a strong foothold in global business creates business opportunities, it intertwines with cross border businesses, related party transactions, and international taxation related challenges including Transfer Pricing. With an objective of preventing base erosion and shifting of profits outside the country, India also adopted the Transfer Pricing law back in 2001. And since its inception, India’s Transfer Pricing law has evolved by adapting to market conditions and global developments.

As we approach the Union Budget 2026, it is expected that the Indian Tax landscape will further align itself with the ever-changing global business needs and developments. Some of the key areas, where we expect certain changes and modifications, are listed below:

Removal of ambiguity in the definition of Associate Enterprise for Transfer Pricing Regulations

Currently, the definition of ‘Associated Enterprise’ as per section 162 of the new Income Tax Act 2025 diverges from the existing provisions of section 92A of the Income Tax Act 1961. The Income Tax Act 1961 has two limbs, i.e., section 92A(1) prescribing the basic attributes that must be satisfied for an Associated Enterprise relationship, which include participation in control, management or capital; and section 92A(2) laying down an exhaustive list of conditions to be satisfied by two or more entities to be regarded as Associated Enterprises.

However, Section 162 of the Income Tax Act 2025 has merged the provisions of Section 92A(1) and 92A(2) of the Income Tax Act 1961 into a single segment, and one of the general conditions for an Associated Enterprise relationship has been defined to be one of the specific conditions for establishing an ‘Associated Enterprise’ relationship. The amended definition of Associated Enterprise may result in different interpretations, leading to ambiguity for taxpayers while determining the Associated Enterprises relationship.

To ensure transparency and reduce unnecessary disputes, it is expected that each clause defining an Associated Enterprise be precisely defined, with explicit thresholds for capital, management, and control relationships, so that the scope of the ‘Associated Enterprise’ definition is applied consistently and predictably.

Threshold for maintaining Transfer Pricing documentation

Currently, the taxpayers undertaking international related party transactions exceeding INR 1 crore, are required to mandatorily maintain the Transfer Pricing documentation. This threshold has been applicable since the inception of Transfer Pricing provisions in India in 2001.

With businesses reaching new altitudes and manifold transaction volumes, the number of related party transactions is much higher than ever before. In light of the massive increase in businesses leading to much higher related party transaction volumes, the existing threshold of INR 1 crore seems modest. Hence, the expectation is that this Transfer Pricing Documentation related threshold may get an upgrade, to a much higher number.
Threshold for secondary adjustment

The Indian Transfer Pricing regulations have a provision of ‘secondary adjustment’ which requires an adjustment in the books of accounts to reflect actual profit allocation after a primary transfer pricing adjustment, treating un-repatriated funds as deemed loans with interest, preventing cash imbalances with Associated Enterprises (AEs). However, the threshold for triggering the secondary adjustment currently stands at a modest INR 1 crore of primary adjustment.

Considering the high volume of related party transactions and the transfer pricing adjustments arising out of disputes of such large related party transactions, it is believed that the threshold of INR 1 crore for triggering secondary adjustments is relatively low and often leads to compliance requirements for minor transfer pricing variations. Increasing the threshold to a higher amount would meaningfully reduce administrative burden, particularly for taxpayers with small or routine adjustments.

Furnishing of Accountant’s Certificate for non-residents

Currently, all non-resident taxpayers entering into taxable transactions with their Indian related parties are required to file an Accountant’s Certificate in India, irrespective of the fact that such non-resident taxpayers are exempted from filing their income tax return in India in certain cases.

To avoid redundant compliance, it is expected that an exemption from filing of the Accountant’s Report might be given to such non-resident taxpayers, where they are exempt from filing an income tax return in India.

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Delay Condonation Denied for Lack of Diligence | HC

delay condonation dismissed by High Court

Case details: T. Srinivasa vs. Chief Traffic Manager B.M.T.C. Central office - [2025] 181 taxmann.com 237 (HC - Karnataka)

Judiciary and Counsel Details

  • K. Somashekar & Venkatesh Naik T., JJ.
  • Shekar L., Adv. for the Appellant. 
  • Smt. H.R. Renuka, Adv. for the Respondent.

Facts of the Case

In the instant case, the appellant-workman of the respondent corporation was dismissed from service for unauthorised absence. At the time of dismissal, an industrial dispute concerning the union was pending, and the appellant asserted that, being a concerned workman, no approval under Section 33(2)(b) was obtained.

The Single Judge passed an order in 2011 in writ proceedings relating to the matter. On appeal to the High Court, the appellant filed a writ appeal seeking condonation of 1202 days’ delay, stating that the corporation had come forward to settle dismissal cases passed during the pendency of ID No.148/2005 and that, believing his case would also be considered, he pursued a complaint under Section 33A and filed an appeal after the respondent invoked res judicata.

The Respondent opposed, contending that appellant remained silent despite the 2011 decision on merits, no similar cases were settled, a nearly four-year delay reflected negligence, and appellant had not discharged duties since 2005

High Court Held

The High Court held that since the appellant was neither diligent nor vigilant in filing an application seeking condonation of the delay, nor in seeking the intervention of the order passed by the Single Judge, the delay application would not survive for consideration.

Consequently, the application filed for condonation of delay was to be dismissed. In view of the dismissal of the delay application, there was no consequence to consider the prayer urged in the appeal, and hence, the appeal was also to be dismissed

List of Cases Referred to

  • Jaipur Zila Sahakari Bhoomi Vikas Bank v. Ram Gopal Sharma AIR 2002 SC 643 (para 4)
  • New Motors (Private) Ltd. v. Morris (KT) 1961 LLJ 551 (para 6)
  • Pradeep Phosphates Ltd. v. Sankar Das 2012 (1) LLJ Ori 519 (para 6)
  • Top Security Ltd. v. Subhas Chander Jha [LLP No. 1044 of 2011, dated 16-7-2012] (para 6)
  • Engineering Laghu Udyog Employees Union v. Judge, Labour court and Industrial Tribunal [2004] 2003 taxmann.com 4513 (SC) (para 6)
  • Chief Traffic Manager, BMTC v. M. Narayana Reddy 2013-iii LLJ KANT 80 (para 6)
  • State of Bihar v. Kameshwar Prasad Singh (2000) 9 SCC 94 (para 15)
  • State of Uttaranchal v. Alok Sharma (2009) 7 SCC 647 (para 15)
  • Gurusharan Singh v. New Delhi Municipal Committee AIR 1996 SC 1175 (para 15)
  • Surya Dev Rai v. Ram Chander Rai 2003(3) KLT 490 (para 16)
  • Mahindra and Mahindra ltd. v. N.B. NaravadeDE 2005 taxmann.com 1958 (SC) (para 17)

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Life Interest Assignment Not Transfer; Sec. 50C Inapplicable | ITAT

Framework of GoA 3

Case Details: Vanraj Ranchhoddas Merchant vs. Income-tax Officer - [2026] 182 taxmann.com 18 (Mumbai - Trib.)

Judiciary and Counsel Details

  • Smt. Beena Pillai, Judicial Member
  • Makarand Vasant Mahadeokar, Accountant Member
  • Ms Kinjal Bhutta, Ld. AR for the Appellant.
  • Ms Kavitha Kaushik, Ld. DR for the Respondent.

Facts of the Case

The assessee, an individual, was holding a 20 per cent undivided share, along with his four brothers, in an ancestral family trust property. Out of his 20 per cent share, the assessee assigned 10 per cent undivided share in the said property to his nephew for a consideration of Rs. 28 lakhs vide registered deed.

The Assessing Officer (AO) issued a show cause notice stating as to why the provisions of section 50C should not be invoked. The assessee contended that what was transferred was only rights in land and building, and therefore, section 50C was not applicable. Unsatisfied with the assessee’s response, AO completed the assessment accordingly. On appeal, CIT(A) affirmed the order of AO. The aggrieved assessee filed the instant appeal before the Tribunal.

High Court Held

The Tribunal held that the assessee had not transferred land or building in his own right. The deed did not convey the corpus of the immovable property, nor did it divest the trust of its ownership in the land or building. The ownership of the immovable property continued to vest in the trust at all material times, and the assessee merely assigned a limited, determinable and beneficial interest arising therefrom.

In law, a life interest represents a limited estate, the duration of which is co-terminous with the life of the holder and which stands extinguished upon his death. Such an interest does not confer absolute ownership of the immovable property, nor does it vest in the holder the power to deal with the corpus of the property as an owner, which is a necessary incident of ownership under property law. The life tenant is entitled only to use, occupy or enjoy the income or usufruct of the property during his lifetime, subject to an overriding obligation to preserve the property for the benefit of the remaindermen.

This principle is statutorily reflected in sections 108(B)(m) and 108(B)(o) of the Transfer of Property Act, 1882, which, though framed in the context of leases, embody the broader doctrine that a person in limited possession cannot commit acts destructive or permanently injurious to the property. Where such a life interest arises under a trust arrangement, the position is even more restrictive. Under the Indian Trusts Act, 1882, the legal title vests in the trustee, and the beneficiary’s enjoyment is circumscribed by fiduciary and preservative obligations imposed on the trustee for the benefit of all beneficiaries, including remainder men.

The beneficiary holding a life interest acquires only a beneficial interest and not ownership of the trust property. Accordingly, the invocation of section 50C in the facts of the present case was not warranted.

List of Cases Reviewed

  • V.S. Chandrashekar v. Asstt. CIT [2021] 129 taxmann.com 273 (Karnataka)/[2021] 282 Taxman 244 (Karnataka)/[2021] 432 ITR 330 (Karnataka) (para 31) Followed.

List of Cases Referred to

  • Vidharbha Veneer Industries Ltd. (In Liquidation) v. ITO [ITA No. 34 of 2022, dated 1-4-2025] (para 9)
  • V.S. Chandrashekar v. Asstt. CIT [2021] 129 taxmann.com 273 (Karnataka)/[2021] 282 Taxman 244 (Karnataka)/[2021] 432 ITR 330 (Karnataka) (para 17).

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Writ Against GST Assessment Not Maintainable | HC

writ against assessment order not maintainable

Case Details: Balagan Beedi Company (P.) Ltd. vs. State Tax Officer - [2026] 182 taxmann.com 428 (Madras) 

Judiciary and Counsel Details

  • Krishnan Ramasamy, J.
  • Sudalai Muthu N. for the Petitioner.
  • R. Suresh Kumar, AGP for the Respondent.

Facts of the Case

The petitioner received a show cause notice and submitted a response. Afterwards, multiple notices were issued to provide opportunities for personal hearings, but the petitioner failed to appear on any of the scheduled dates. The submitted replies were considered inadequate, and the officer subsequently passed the assessment orders ex- parte. These orders were challenged by filing writ petitions, contending that the assessment was made without adequate hearing and in violation of natural justice. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the petitioner had been afforded multiple opportunities for a personal hearing after filing replies, and therefore no breach of natural justice occurred. It was observed that the petitioner’s failure to attend hearings and the inadequacy of the replies amounted to a waiver of the right to be heard. The Court further held that once an adequate hearing opportunity had been provided, writ jurisdiction was not available. Consequently, the writ petitions were dismissed with liberty to file an appeal under Section 107 read with Section 75 of the CGST Act.

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GST Demand Quashed on Limitation Issue | HC

GST demand quashed on limitation issue

Case Details: Bangalore Matics (P.) Ltd. vs. Union of India - [2026] 182 taxmann.com 429 (Karnataka)

Judiciary and Counsel Details

  • S.R. Krishna Kumar, J.
  • Harish Vashisth, Adv. for the Petitioner. 
  • Jeevan J. Neeralgi, Adv. & K. Hema Kumar, AGA for the Respondent.

Facts of the Case

The petitioner was issued a show cause notice under Section 73 of the CGST Act, alleging that excess ITC was claimed in Form GSTR-3B compared to Form GSTR-2A. It did not respond to the notice, and an ex-parte adjudication order was passed confirming the demand along with interest and penalty. The petitioner challenged the order, arguing that the proceedings were barred by limitation and that the notice went unnoticed, thereby preventing the filing of a reply. The matter was accordingly placed before the High Court.

High Court Held

The High Court observed that the issue of limitation depended on the validity of the extension of limitation, which was pending adjudication before the Supreme Court. As the decision would directly affect the legality of the proceedings, the Court held that deciding the matter at that stage would be inappropriate. It was further noted that it would avoid multiplicity of proceedings and conflicting outcomes by awaiting the Supreme Court’s decision. Accordingly, the High Court set aside the demand order passed under Section 73 of the CGST Act and remanded the matter for fresh consideration.

List of Cases Reviewed

List of Cases Referred to

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Deferred Tax on Revaluation and Fair Value | Ind AS 12

deferred tax under Ind AS 12

1. Facts

Delight Solutions Limited (hereinafter referred to as “the Company”) is engaged in the manufacturing of agro-machinery.The company prepares its financial statements in accordance with Ind AS framework. During the financial year ended 31st March 2025, the company undertook several revaluation and fair value measurements in compliance with various Ind AS requirements. These measurements resulted in differences between the carrying amounts of certain assets and liabilities in the financial statements and their corresponding tax bases, thereby giving rise to temporary differences and the need to evaluate deferred tax recognition under Ind AS 12.During the year under consideration, the company undertook the following transactions:

2. Revaluation of Freehold Land under Ind AS 16

The company revalued its freehold land by applying the revaluation model under Ind AS 16. The resulting revaluation surplus was recognised in Other Comprehensive Income (OCI) and accumulated in equity, giving rise to a question on whether the related deferred tax should also be recognised in OCI or routed through profit and loss.

3. Fair Value Gain on Strategic Equity Investments under Ind AS 109 – FVOCI

The Company held strategic equity investments designated as fair value through OCI. During the year, the fair value of these investments increased and the resulting gains were recognised in OCI, leading to differing views on whether deferred tax arising from such OCI-recognised gains should likewise be recognised in OCI or in profit and loss.

4. Fair Value Gain on Long-term Debentures Ind AS 109 – FVTPL

The Company had issued long-term debentures designated at fair value through profit or loss. Due to changes in market conditions, the fair value of the debentures decreased, resulting in a gain recognised in profit and loss.

Accordingly, the central issue in the aforementioned casesis the appropriate recognition and presentation of deferred tax under Ind AS 12, particularly whether deferred tax should be recognised in other comprehensive income or in profit and loss based on the component of the financial statements in which the underlying revaluation or fair value adjustment is recognised?

5. Relevant Provision

Ind AS 12 – Income Taxes

  • Para 58 of Ind AS 12

Current and deferred tax shall be recognised as income or an expense and included in profit or loss for the period, except to the extent that the tax arises from:

(a) a transaction or event which is recognised, in the same or a different period, outside profit or loss, either in other comprehensive income or directly in equity, or

(b) a business combination (other than the acquisition by an investment entity, as defined in Ind AS 110, Consolidated Financial Statements, of a subsidiary that is required to be measured at fair value through profit or loss)

  • Para 61A of Ind AS 12

Current tax and deferred tax shall be recognised outside profit or loss if the tax relates to items that are recognised, in the same or a different period, outside profit or loss. Therefore, current tax and deferred tax that relates to items that are recognised, in the same or a different period:

(a) in other comprehensive income, shall be recognised in other comprehensive income.

(b) directly in equity, shall be recognised directly in equity.

  • Para 62 of Ind AS 12

Indian Accounting Standards require or permit particular items to be recognised in other comprehensive income. Examples of such items are:

a) a change in carrying amount arising from the revaluation of property, plant and equipment; and

b) exchange differences arising on the translation of the financial statements of a foreign operation

6. Analysis

Based on the relevant provisions of Ind AS 12, the following analysis can be made in respect of the above cases:

  • Revaluation of Freehold Land:

The company revalued its freehold land under the revaluation model, with the surplus recognised in OCI and accumulated in equity. Considering the Paras 58, 61A, and 62, deferred tax arising from such temporary differences must also be recognised in OCI, consistent with the treatment of the underlying revaluation. This ensures that neither profit or loss nor retained earnings are affected by deferred tax on revaluation gains.

  • Fair Value Gain on Strategic Equity Investments – FVOCI

The fair value gains on strategic equity investments designated as FVOCI were recognised in OCI. As per Ind AS 12, Para 58 and 61A, the deferred tax attributable to these gains must also be recognised in OCI, aligning the tax effect with the component in which the gain is recorded. This treatment preserves the integrity of OCI and ensures that the profit or loss is unaffected by such deferred tax.

  • Fair Value Gain on Long-term Debentures – FVTPL (Ind AS 109):

The company recorded a gain due to changes in fair value of debentures designated at FVTPL in profit or loss. Consistent with Ind AS 12, Para 58, the related deferred tax should also be recognised in profit or loss, ensuring that the tax effect follows the accounting treatment of the underlying FVTPL instrument. This prevents mismatch between the recognition of the gain and the associated deferred tax.

7. Conclusion

In accordance with Ind AS 12, deferred tax must be recognised in the same component of the financial statements as the item that gives rise to the temporary difference. Accordingly, deferred tax on items recognised in OCI, such as the revaluation surplus on freehold land and FVOCI equity investments, should also be recognised in OCI, while deferred tax on items recognised in profit or loss, such as fair value gains on FVTPL debentures, should be recognised in profit or loss. This approach ensures consistency, avoids distortion of profit or loss, and faithfully reflects the tax consequences of the underlying transactions.

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Directors Absolved of Liability for Technical Violations | HC

directors absolved from liability for technical violations

Case Details: Shyam Emco Infrastructure Ltd. vs. Registrar of Companies West Bengal - [2025] 181 taxmann.com 869 (Calcutta)

Judiciary and Counsel Details

  • Ravi Krishan Kapur, J.
  • Jayanta Kumar Mitra, Sr. Adv., Rishav DuttAnuj Singh, Ms Patrali Ganguly and Ms Shrishti Roy Barman, Advs. for the Petitioner. 
  • Ms Rashmi Bothra, Ms Shreya Choudhury and Jeet Barman, Advs. for the Respondent.

Facts of the Case

In the instant case, the respondent authorities, on the ground of alleged violations under section 129(1) read with Schedule III, found the company and its directors, namely the petitioners, to be in violation of the provisions of the Act and threatened prosecution against the petitioners by calling upon the company and its directors to file an application for compounding under the Act.

It was noted that the petitioners had throughout acted reasonably and had complied with all acceptable norms of accountancy, and this had been specifically brought to the attention of the respondent authorities. However, while issuing the impugned notice, the respondent authorities failed to consider and ignored the representations and responses submitted by the petitioners.

Further, the alleged violations could have been easily resolved through proper scrutiny of the company’s financial statements and records.

High Court Held

The High Court held that an infraction of such a technical and trivial nature did not warrant issuance of the impugned notice. Further, the respondent authorities had knowledge of the commission of the alleged offences beyond a period of one year and had remained inactive, in violation of the limitation period prescribed under section 129(1) read with Schedule III. Thus, the impugned notice was liable to be quashed.

List of Cases Referred to

  • Girdhar Tracom Private Limited and Narendra Dhanuka v. Registrar of Companies 2024 SCC OnLine Cal 1671 (para 3)
  • AI Champdany Industries Ltd. v. Registrar of Companies [2011] 16 taxmann.com 39/110 SCL 556 (Calcutta) (para 3)
  • Bhagwati Foods P. Ltd v. Registrar of Companies [2008] 88 SCL 56 (Calcutta) (para 3)
  • Deba Prasad Roy v. Regional Director, Department of Company Affairs [2008] 83 SCL 280 (CAL.) (para 8).

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Liquidator Fee Limited After Liquidation Completion | NCLT

Liquidator Fee Restricted To Actual Expenses NCLT

Case Details: P.M. Cold Storage (P.) Ltd. vs. Goouksheer Farm Fresh (P.) Ltd. [2025] 180 taxmann.com 849 (NCLT - Kolkata)

Judiciary and Counsel Details

  • Labh Singh, Judicial Member
  •  Ms. Rekha Kantilal Shah, Technical Member
  • Kuldip Mallick, Ms. Pallavi Ray, S. Dutta, Advs. Niraj Kumar, CS for the Appearing Parties.

Facts of the Case

In the instant case, the corporate Debtor was admitted into the CIRP and, as no resolution plan was received, the liquidation was ordered, and the applicant was appointed as the liquidator.

The liquidator thereafter filed an application seeking dissolution of the corporate debtor. It was noted that all assets of the corporate debtor had been disposed of and distributed in accordance with the Code and rules and regulations framed thereunder, and the final report had been submitted.
Further, it was noted that since the 4th SCC meeting, the Tribunal had considered circumstances necessitating the end of the liquidation process of the corporate debtor; therefore, the Financial Creditor was to be directed to proceed forthwith with the section 66 Application.

NCLT Held

The NCLT observed that since the liquidation process was fully complete and the Liquidator, in compliance, had filed the present application under section 54 of the IBC seeking an order of dissolution of the corporate debtor, dissolution of the corporate debtor was to be ordered and, consequently, the Liquidator stood relieved from his responsibilities, subject to procedural compliances.

The NCLT held that since the Liquidator’s fees claimed to the tune of Rs. 4.80 lakhs were more than double and no tangible basis or supporting rationale had been demonstrated justifying such a fee, the Liquidator was directed to consider the payment already made to be full and final and reduce the fees to the extent liquidation expenses were not paid for.

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SEBI Amends NCS Rules On Retail Investors And Incentives

SEBI NCS Regulations Amendment 2026

Notification No. SEBI/LAD-NRO/GN/2026/296, Dated: 20.01.2026

1. Introduction: SEBI Notifies Amendment to NCS Regulations

The Securities and Exchange Board of India (SEBI) has notified the SEBI (Issue and Listing of Non-Convertible Securities) (Amendment) Regulations, 2026, vide Notification No. SEBI/LAD-NRO/GN/2026/296 dated 20 January 2026. The amendment brings clarity to investor classification and introduces flexibility in structuring incentives for certain investor categories.

2. Definition of Retail Individual Investor Introduced

A key change under the amendment is the formal definition of a “retail individual investor.” SEBI has defined a retail individual investor as an individual who applies or bids for debt securities up to ₹2 lakh. This definition aligns the NCS framework with existing market practices and provides regulatory certainty for issuers and intermediaries.

3. Incentives Permitted for Specified Investor Categories

The amended regulations permit issuers of non-convertible securities to offer incentives to specified categories of investors. Such incentives may include additional interest rates or discounts on the issue price, enabling issuers to attract targeted investor participation while remaining within a regulated framework.

4. Conditions Attached to Offering Incentives

SEBI has clarified that any incentive offered under the amended regulations shall be available only to the initial allottee of the securities. This restriction ensures transparency, prevents misuse in secondary market transactions, and maintains fairness among different classes of investors.

5. Conclusion: Enhanced Clarity and Market Flexibility

The SEBI NCS Regulations Amendment, 2026, strengthens the regulatory framework by clearly defining retail individual investors and permitting structured incentives for specified investor categories. These changes are expected to enhance investor participation, improve disclosure clarity, and provide issuers with greater flexibility while safeguarding market integrity.

Click Here To Read The Full Notification 

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