Author: inavatiq

Notification F. No. IFSCA/GN/2026/007; Dated: 30.03.2026

The International Financial Services Centres Authority (IFSCA) has notified the IFSCA (Pension Fund) Regulations, 2026, establishing a comprehensive framework for the registration, regulation, and supervision of Pension Funds in IFSC.

1. Objective of the Regulations

The regulations aim to:

• Promote long-term retirement savings
• Ensure a secure, transparent, and well-regulated environment
• Protect the interests of subscribers
• Maintain the integrity of the pension ecosystem

2. Mandatory Registration Requirement

• No entity can act as a Pension Fund unless it obtains a certificate of registration from IFSCA
• Applications must be submitted through the SWIT portal
• The application must be accompanied by prescribed fees and documentation

3. Governance and Key Managerial Personnel (KMP)

The regulations prescribe robust governance requirements:

• Minimum two KMPs responsible for:

1. 1. Fund management
   2. Risk management

• Appointment of a Compliance Officer (as a KMP):

1. 1. Responsible for overall compliance
   2. Reports directly to the Board

• The Board composition must include:

1. 1. At least four directors
   2. Minimum 50% independent directors

• All directors, KMPs, and controlling shareholders must satisfy the ‘fit and proper’ criteria at all times

4. Subscriber Flexibility and Rights

The framework ensures subscriber-centric features:

• Subscribers can:

1. 1. Decide the frequency and amount of contributions
   2. Switch Pension Funds up to two times per financial year

• Pension Funds may prescribe a minimum contribution amount (with prior approval of the Authority)

5. Innovative Product Features

• Pension Funds may offer a healthcare benefit option, allowing allocation of a portion of contributions to a dedicated healthcare savings account
• Details of such features must be disclosed in the Scheme Information Document

6. Disclosure and Transparency Requirements

Pension Funds must ensure:

• Availability of educational materials
• Clear disclosure of performance and scheme details
• Information is presented in a simple, accessible, and understandable format for subscribers

7. Conclusion

The IFSCA (Pension Fund) Regulations, 2026, establish a robust, investor-centric regulatory framework, balancing governance, flexibility, and transparency, and fostering the development of a trusted pension ecosystem within IFSCs.

Click Here To Read The Full Notification

The post IFSCA Notifies Pension Fund Regulations 2026 for IFSC Framework appeared first on Taxmann Blog.

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Case Details: Deputy Commissioner of Income-tax (Exemptions) vs. ICT Academy of Tamil Nadu - [2026] 184 taxmann.com 634 (Chennai-Trib.)

Judiciary and Counsel Details

• Manu Kumar Giri, Judicial Member & S. R. Raghunatha, Accountant Member
• C. Sivakumar, Addl.CIT for the Appellant.
• G. Ramachandran, CA for the Respondent.

Facts of the Case

The assessee, a society registered under section 12A, was engaged in skill development, training, certification and employability enhancement programmes. The assessee filed a nil return claiming exemption under sections 11 and 12.

The Assessing Officer (AO) held that the assessee was engaged in activities falling under the limb of ‘advancement of any other object of general public utility’ as specified in section 2(15). He invoked the proviso to section 2(15), which provides that such activities were in the nature of trade, commerce, or business. Consequently, the assessee’s activities were treated as non-charitable, leading to the denial of exemption under section 11.

On appeal, CIT(A) held that the activity carried out by the assessee qualified as ‘education’ in terms of section 2(15), and thus entitling the assessee to claim exemption under section 11. The AO filed an appeal to the Chennai Tribunal.

ITAT Held

The Tribunal held that it is an admitted fact that the assessee is a society registered under section 12A and is engaged in activities relating to skill development, training, certification, and the enhancement of employability of students and faculty, in coordination with Government bodies and educational institutions. The nature of activities, as borne out from the record, indicates that the assessee conducts structured training programmes, faculty development initiatives and vocational courses aligned with national skill development policies.

The dominant object of the assessee is to impart skill-based education and training to enhance employability. Such activities, in the present socio-economic context, form an integral part of the educational framework. The programmes conducted by the assessee are structured, curriculum-based and aimed at systematic development of skills and knowledge.

Therefore, the same cannot be equated with mere commercial or business activities. The mere presence of receipts from training or certification programmes cannot, in isolation, lead to the conclusion that the proviso to section 2(15) is attracted. Consequently, the assessee is entitled to an exemption under sections 11 and 12.

List of Cases Reviewed

• ACIT (Exemption) v. Ahmedabad Urban Development Authority [2022] 143 taxmann.com 278 (SC)/[2023] 291 Taxman 11 (SC)/[2022] 449 ITR 1 (SC) (para 21) followed

List of Cases Referred to

• Asstt. CIT (Exemptions) v. Ahmedabad Urban Development Authority [2022] 143 taxmann.com 278 (SC)/[2023] 291 Taxman 11 (SC)/[2022] 449 ITR 1 (SC) (para 9).

The post Skill Development Activities Qualify as Education u/s 2(15) | ITAT appeared first on Taxmann Blog.

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Parveen Kumar Bansal & Ruchesh Sinha – [2026] 185 taxmann.com 40 (Article)

I. Introduction

The evolution of India’s tribunal system reflects a continuous effort by the legislature and the executive to balance specialisation, efficiency, and accessibility in the delivery of justice. Over the years, multiple tribunals have been constituted, merged, and restructured to streamline adjudication in complex domains such as taxation, financial crimes, and property forfeiture. However, with changing legal landscapes and increasing overlap between statutory frameworks, it becomes imperative to periodically reassess whether existing institutional arrangements continue to serve their intended purpose effectively.

One such area requiring urgent reconsideration is the appellate mechanism under the Prohibition of Benami Property Transactions Act, 1988 (“PBPT Act”). The Benami Tribunal constituted under Section 30 of the PBPT Act presently functions within the consolidated “Appellate Tribunal” constituted under the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976 (“SAFEMA”). However, given the nature of its functions, which are adjudicatory, quasi-judicial, and appellate in character, there is a compelling need to reconsider this administrative positioning for enhanced accessibility, expertise, efficiency and improved Ease of Justice.

This issue assumes particular importance in the broader context of ongoing reforms aimed at strengthening India’s tribunal system and ensuring that specialised disputes are adjudicated by forums best equipped in terms of subject-matter expertise and institutional capacity.

This article is firmly rooted in and fully aligned with the thought process that justice must be accessible, affordable, and delivered in a timely manner, regardless of economic or social background, and that Ease of Justice is an essential pillar supporting Ease of Doing Business and Ease of Living. There is a need for decentralisation, simplification of legal processes, reduction of litigation burdens, and enhancement of citizen-centric justice delivery.

In this context, the present article examines the historical evolution, current structure, and practical challenges of the existing appellate framework, and makes a compelling case for transferring jurisdiction over benami matters to the Income Tax Appellate Tribunal (ITAT), a body uniquely equipped in terms of expertise, infrastructure, and nationwide presence to handle such disputes.

II. Background and Evolution of the Appellate Framework

The Appellate Tribunal was originally constituted in the year 1977 as the Appellate Tribunal for Forfeited Property (“ATFP”) under the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976(“SAFEMA”). Being constituted in the late 1970s, it is among the earliest tribunals established in India. SAFEMA applies to persons convicted under the Sea Customs Act, 1878 or the Customs Act, 1962, as well as persons covered under the Foreign Exchange Regulation Act, 1947 (FERA) and FERA, 1973. The SAFEMA Act also extends to persons detained under The Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 (“COFEPOSA”), whose detention orders have not been revoked or set aside, subject to conditions prescribed in Section 2 of the SAFEMA Act. The SAFEMA Act primarily deals with forfeiture of illegally acquired properties of such persons, and includes within its ambit their relatives, associates, and holders of such properties unless they can prove that they are bona fide transferees for adequate consideration.

In 1985, the Narcotic Drugs and Psychotropic Substances Act (“NDPS Act”) was enacted to create a comprehensive legal framework to address narcotic drugs, psychotropic substances, trafficking offences, and to implement international conventions. The Act was amended in 1989, introducing Chapter VA relating to seizure, freezing, and forfeiture of illegally acquired properties derived from narcotics-related offences. The provisions of this Chapter were analogous to those under SAFEMA, and the ATFP was consequently vested with jurisdiction to hear cases arising under the NDPS Act as well.

In 2003, the Prevention of Money Laundering Act (“PMLA”) was enacted, following the introduction of the Prevention of Money-Laundering Bill, 1998 and subsequent parliamentary review. Section 25 of the PMLA mandated the Central Government to establish an Appellate Tribunal for hearing appeals against the Adjudicating Authority and other authorities under the Act.

The Finance Act, 2016 introduced significant reforms relating to the merger of various tribunals. It substituted Section 25 of PMLA with a new provision designating the Appellate Tribunal constituted under SAFEMA as the Appellate Tribunal for hearing appeals under PMLA with effect from 01.06.2016. The same Act also renamed the “Appellate Tribunal for Forfeited Property” as simply the “Appellate Tribunal”.

In the same year, following the enactment of the Benami Transactions (Prohibition) Amendment Act, 2016, a notification dated 25.10.2016 was issued by the Central Board of Direct Taxes (“CBDT”) stating that the Appellate Tribunal established under Section 25 of the PMLA shall also discharge the functions of the Appellate Tribunal under the PBPT Act.

Subsequently, the Finance Act, 2017 merged the Appellate Tribunal for Foreign Exchange (“ATFE”), constituted under Section 18 of the Foreign Exchange Management Act, 1999 (“FEMA”) with the Appellate Tribunal under SAFEMA.

As a result of this series of legislative developments and mergers, the present Appellate Tribunal represents a consolidated adjudicatory body comprising the tribunals originally established under SAFEMA, PMLA, and FEMA. It now hears appeals under five central Acts, namely SAFEMA, NDPS Act, PMLA, PBPT Act (as amended in 2016), and FEMA.

The Appellate Tribunal adjudicates appeals and related petitions arising from attachment and forfeiture orders passed by the Competent Authority under SAFEMA and the NDPS Act, orders of the Adjudicating Authority and other authorities under PMLA, orders issued by the Income Tax Department under the PBPT Act, and orders imposing penalties or fines under FEMA issued by Financial Intelligence Unit, India and other authorities. It is a national-level tribunal headquartered in New Delhi and presently has no permanent benches elsewhere, comprising a Chairman and four Members.

Click Here To Read The Full Article

The post [Opinion] Need to Transfer the Jurisdiction of Benami Cases to ITAT appeared first on Taxmann Blog.

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Case Details: Buckbox Infotech (P.) Ltd. vs. Director General of GST Intelligence - [2026] 185 taxmann.com 62 (Gujarat)

Judiciary and Counsel Details

• A.S. Supehia & Pranav Trivedi, JJ.
• Jay S. Shah & Vijay H. Patel for the Petitioner.
• Neel P. Lakhani & Tirth Nayak for the Respondent.

Facts of the Case

The petitioner, a GST-registered technology service provider (TSP) filed a writ petition challenging the provisional attachment of its bank accounts and seeking de-freezing thereof, contending that it had acted as a TSP for Digihub by facilitating payouts through its current account with virtual accounts, and that such attachment was unjustified. The Department of Revenue submitted that Digihub was under investigation for tax evasion in gaming and betting activities, and that the petitioner’s accounts were used for routing payouts to beneficiaries. The petitioner had admitted that it had not verified the credentials or business activities and had relied solely on an undertaking, without conducting any independent verification. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that provisional attachment of bank accounts under Section 83 of the CGST Act, read with Rule 159 of the CGST Rules, was justified in the facts of the case, as the material on record clearly established that Digihub had utilised the petitioner’s platform and bank accounts for routing gaming or betting-related payouts. The Court held that the petitioner had admittedly failed to verify the credentials and nature of the business, and mere reliance on an undertaking was insufficient due diligence. Considering the magnitude of transactions and the ongoing investigation involving multiple linked accounts, the exercise of powers by the jurisdictional officer under CGST. Accordingly, the request to de-freeze bank accounts was rejected, and the writ petition was dismissed.

The post Bank Account Attachment Upheld for TSP Aiding Gaming Payouts Without Due Diligence | HC appeared first on Taxmann Blog.

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Case Details: Bhawana Steel Traders vs. Joint Director, DGGI - [2026] 185 taxmann.com 22 (Bombay)

Judiciary and Counsel Details

• Anil L. Pansare & Nivedita P. Mehta, JJ.
• A. J. Bhoot, Adv. for the Petitioner.
• Mrs K. Vaidya, Adv. for the Respondent.

Facts of the Case

The petitioner assailed a consolidated SCN issued by the Joint Director, DGGI for the financial years 2018-19 to 2023-24, alleging suppression and short payment of tax. The writ was filed to question the clubbing of multiple financial years.

High Court Held

The Bombay High Court held that Section 74 did not permit the consolidation of financial years or tax periods while issuing SCN or passing the order. The fraudulent availment of ITC allegation did not create any exception to permit clubbing. Only the distinction under Section 74 concerned the five-year limitation from furnishing the annual return for each financial year. Consolidation would aggregate distinct tax periods with separate due dates and limitations and impair the year-wise statutory scheme. Accordingly, the impugned SCN and composite order were quashed with liberty to issue year-wise notices strictly in terms of Section 74.

List of Cases Reviewed

• Milroc Good Earth Developers v. UOI [2025] 179 taxmann.com 465/112 GST 596/[2026] 104 GSTL 45 (Bombay)
• Rite Water Solutions (India) Ltd. v. Joint Commissioner, CGST & Central Excise [2026] 183 taxmann.com 627 (Bombay) (para 17)followed

List of Cases Referred to

• Milroc Good Earth Developers v. UOI [2025] 179 taxmann.com 465/112 GST 596/[2026] 104 GSTL 45 (Bombay) (para 3)
• Rite Water Solutions (India) Ltd. v. Joint Commissioner, CGST & Central Excise [2026] 183 taxmann.com 627 (Bombay) (para 5)
• Mathur Polymers v. Union of India [2025] 177 taxmann.com 860/103 GSTL 72 (Delhi) (para 9)
• Mathur Polymers v. Union of India [2026] 182 taxmann.com 215 (SC) (para 10)
• CIT v. Smt. Godavaridevi Saraf Tumsar [1978 (2) ELTJ 624 Bombay] (para 13).

The post Section 74 Bars Consolidated GST Notices Across Years | HC appeared first on Taxmann Blog.

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Editorial Team – [2026] 185 taxmann.com 147 (Article)

Taxmann presents Practical Insights on Ind AS and SAs, a weekly series exclusively for Accounts and Audit Module subscribers of Taxmann.com, focusing on the practical application of Ind AS and Standards on Auditing through structured, issue-based analysis.

Each week features a focused topic with real-world relevance. This edition explores the Conceptual Framework for Financial Reporting under Ind AS, covering the objective of financial reporting, qualitative characteristics of useful information, the concept of reporting entities, and the fundamental elements of financial statements.

1. Introduction

The Conceptual Framework for Financial Reporting under Indian Accounting Standards (Ind AS) provides the basic foundation on which accounting standards are developed and financial statements are prepared. It was issued by the Institute of Chartered Accountants of India (ICAI) and became effective for standard-setting in March 2018. For preparers of financial statements, it applies to accounting periods beginning on or after 1 April 2021.

The Framework is broad in scope and lays down the key areas that guide financial reporting. It covers the objective of general purpose financial reporting, the qualitative characteristics that make financial information useful, the concept of a reporting entity, and the elements that make up financial statements. In addition, it also deals with recognition and de-recognition principles, measurement bases, presentation and disclosure principles, and concepts relating to capital and capital maintenance.

The purpose of this Framework is multifold. It assists standard-setters such as the ICAI and other regulators in developing consistent and conceptually sound accounting standards. It also helps preparers of financial statements in situations where no specific Ind AS applies or when they must choose between alternative accounting treatments. Further, it aids users and other stakeholders in understanding and interpreting the requirements of Ind AS.

2. Objectives of General Purpose Financial Reporting

General purpose financial statements present financial information in a structured manner. They provide details about an entity’s assets, liabilities, equity, income, and expenses. This structured presentation helps users understand both the financial position and financial performance of the entity.

Such financial statements are prepared with the objective of meeting the common information needs of primary users. They aim to present a clear and organised view of financial data so that users can analyse and interpret it effectively.

General purpose financial reports are designed to provide financial information about a reporting entity to users who cannot demand tailored reports. These reports focus on delivering information that is useful for making economic decisions.

The information provided in such reports primarily relates to the economic resources of the entity, the claims against those resources, and the changes in both over time. Economic resources refer to what the entity owns or controls, while claims represent obligations or interests of others in those resources.

These reports are particularly useful to primary users such as investors, lenders, and other creditors. Since these users do not have the authority to request specific information directly from the entity, they depend on general purpose financial reports to meet their needs.

3. Features and Benefits of the Conceptual Framework in Financial Reporting

The Conceptual Framework provides a strong foundation for the development of Ind AS. One of its key benefits is that it promotes international comparability of financial statements, making it easier for users to compare financial information across different entities and jurisdictions.

It also strengthens accountability by ensuring that financial reporting reflects the economic reality of transactions. By helping generate comparable and consistent financial information, the Framework contributes to overall economic efficiency.

Another important benefit is that it helps bridge the information gap between providers of capital (such as investors and lenders) and management. By improving the quality of disclosures and supporting risk assessment mechanisms, it enhances users’ ability to make informed decisions.

Click Here To Read The Full Article

The post Practical Insights on Ind AS and SAs | Conceptual Framework for Financial Reporting appeared first on Taxmann Blog.

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Case Details: Managing Director vs. PM.T. Kamgar Sangh (INTUC) - [2026] 184 taxmann.com 648 (Bombay)

Judiciary and Counsel Details

• Amit Borkar, J.
• Mrs A.P. Purav, Girish B. Badiger, A. S. Rao, Shivram A. Gawade, Deepak K. More, Rakesh R. Bhatkar, Mohan N. Devkule, Mohit Dalvi & Ms Sakshi Kamble for the Appearing Parties.

Facts of the Case

In the instant case, the petitioner-company, engaged in public transport, was formed upon the merger of Pune Municipal Transport (PMT) and Pimpri Chinchwad Municipal Transport (PCMT), with employees absorbed with continuity of service.

In 1999, the respondent-union raised a charter of demands, and Clause 15 of the settlement dated 20-5-1999 recorded that the pension scheme may be extended to all PMT employees, subject to Government approval.

On failure to implement the said clause, the union filed a complaint alleging unfair labour practice. The Industrial Court allowed the complaint and directed implementation of the settlement.

High Court Held

The High Court held that the petitioner, being a successor-in-interest employer, was bound by Clause 15 of the settlement, and refusal to extend pensionary benefits amounted to unfair labour practice under Items 5 and 9.

Further, the Industrial Court’s direction to implement the settlement was within its jurisdiction. The petitioner was liable to implement Clause 15 and extend pensionary benefits, subject to statutory compliance.

The post Denial of Pension Settlement Is Unfair Labour Practice | HC appeared first on Taxmann Blog.

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Punit Agarwal – [2026] 185 taxmann.com 97 (Article)

1. Introduction

Employee Stock Option Plans (“ESOPs”) have emerged as a powerful tool for talent acquisition and retention, particularly in India’s burgeoning start-up and technology ecosystem. However, the income tax framework governing ESOPs creates a peculiar practical difficulty i.e. the perquisite arising on exercise of stock options is taxable as salary under Section 17(2)(vi) of the Income-tax Act, 1961 and the employer is obligated to deduct TDS under Section 192. The fundamental problem arises when the perquisite value is disproportionately large relative to the employee’s cash salary, leaving the employer with an insufficient salary pool from which to effect TDS recovery.

This article examines the legal provisions, practical challenges, and available solutions when an employer faces the classic question: “How do I deduct TDS of Rs. 30 lakhs when the monthly salary is only Rs. 3 lakhs?”

2. Taxability of ESOPs

ESOPs are taxed at two distinct points in time:

2.1 Stage 1—At the Time of Exercise (Perquisite Under “Salary”)

Under Section 17(2)(vi) read with Rule 3(8) and 3(9) of the Income-tax Rules, 1962, the difference between the Fair Market Value (“FMV”) of the shares on the date of exercise and the exercise price paid by the employee is treated as a perquisite taxable under the head “Salaries.” The employer is required to deduct TDS on this perquisite under Section 192 in the month of exercise.

For listed shares, the FMV is the average of the opening and closing price on the date of exercise on the recognised stock exchange. For unlisted shares, the FMV must be determined by a Category-I Merchant Banker as on the exercise date or a date not earlier than 180 days before the exercise date.

2.2 Stage 2—At the Time of Sale (Capital Gains)

On subsequent sale of the shares, capital gains arise with the FMV at the exercise stage serving as the cost of acquisition. For listed shares with STT, LTCG (holding period > 12 months) is taxable at 12.5% under Section 112A on gains exceeding Rs. 1.25 lakh, and STCG at 20% under Section 111A. For unlisted shares, the LTCG threshold is 24 months, taxable at 12.5% under Section 112, with STCG at slab rates.

3. The Core Problem

Consider the following scenario, which is increasingly common in Indian companies:

Particulars	Amount (Rs.)
Monthly Salary	Rs. 3,00,000
Annual Salary	Rs. 36,00,000
ESOPs Exercised — FMV	Rs. 1,00,00,000
Exercise Price Paid	Rs. 10,00,000
Perquisite Value (FMV – Exercise Price)	Rs. 90,00,000
Total Income (Salary + Perquisite)	Rs. 1,26,00,000
Approximate Tax Liability (Old Regime)	Rs. 38–40 Lakhs
Tax Attributable to ESOP Perquisite	Rs. 28–30 Lakhs (approx.)

The employer’s dilemma is immediately apparent. Even if the employer were to withhold the entire remaining salary of the employee for the balance of the financial year (approximately Rs.33 lakhs), it would barely cover the TDS on the ESOP perquisite alone, leaving the employee with zero take-home pay for 11 months. This is neither commercially feasible nor practically sustainable.

Click Here To Read The Full Article

The post [Opinion] ESOP Taxation and TDS Mismatch | Need for Reform appeared first on Taxmann Blog.

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Case Details: Hasmukhbhai Jayantibhai Patel vs. Income-tax Officer - [2026] 184 taxmann.com 725 (Ahmedabad-Trib.)

Judiciary and Counsel Details

• Siddhartha Nautiyal, Judicial Member & Smt. Annapurna Gupta, Accountant Member
• Chirag Shah, AR for the Appellant.
• Girish Parihar, Sr. DR for the Respondent.

Facts of the Case

The assessee is a purchaser of immovable property from multiple co-owners. The AO observed that no TDS under section 194-IA was deducted, even though the total consideration for the property exceeded Rs. 50 lakhs. The AO held that TDS at 1% under section 194-IA was required, and for failure to deduct, treated the assessee as an assessee in default under section 201(1) and levied interest under section 201(1A).

On appeal, the assessee argued that the Rs. 50 lakhs threshold applied to each co-owner’s share; the CIT(A) rejected the appeal, stating that when a single property is transferred through a common agreement, the threshold should be considered for the property as a whole, and upheld the treatment under section 201(1) and the levy of interest under section 201(1A).

ITAT Held

The aggrieved assessee filed the instant appeal before the Tribunal. The Ahmedabad Tribunal held that the assessee purchased the property from multiple co-owners, and the consideration attributable to each co-owner’s share was below the prescribed threshold of Rs. 50 lakhs. The provisions of section 194-IA, as applicable to the year under consideration, did not contain any stipulation for aggregating consideration in respect of multiple transferors. The amendment providing for such aggregation has been introduced only by the Finance Act, 2024, with effect from 01.04.2024 and is prospective in nature and not applicable to the year under consideration.

Further, the issue was no longer res integra and stood squarely covered in favour of the assessee by a series of decisions of the coordinate benches of the Tribunal. It has been categorically held that where the consideration paid to each co-owner is less than Rs. 50 lakhs, the provisions of section 194-IA are not attracted, and the aggregate consideration cannot be considered for the purpose of determining the threshold, particularly for the period before the insertion of the proviso by the Finance Act, 2024.

Accordingly, the assessee could not be treated as an assessee-in-default under section 201(1), and the demand raised under section 201(1) was deleted.

List of Cases Reviewed

• Aakash Pursottambhai Vaghela v. ITO [2025] 176 taxmann.com 372 (Ahmedabad – Trib.)
• Bhikhabhai Hirabhai Patel v. Dy. CIT [2023] 155 taxmann.com 87 (Ahmedabad – Trib.)
• Archanaben Rajendrasingh Deval v. ITO [2025] 173 taxmann.com 722/212 ITD 414 (Ahmedabad – Trib.)[Para 14] Followed

List of Cases Referred to

• CIT v. Anjum M.H. Ghaswala [2001] 119 Taxman 352/252 ITR 1 (SC) (para 5)
• Aakash Pursottambhai Vaghela v. ITO [2025] 176 taxmann.com 372 (Ahmedabad – Trib.) (para 10)
• Bhikhabhai Hirabhai Patel v. Dy. CIT [2023] 155 taxmann.com 87 (Ahmedabad – Trib.) (para 11)
• Archanaben Rajendrasingh Deval v. ITO [2025] 173 taxmann.com 722/212 ITD 414 (Ahmedabad – Trib.) (para 12).

The post No TDS Default u/s 194-IA Without Aggregation Pre-2024 | ITAT appeared first on Taxmann Blog.

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F. No. IFSCA-PLNP/80/2024-Capital Markets dated: 02.04.2026

The International Financial Services Centres Authority (IFSCA) has mandated a certification requirement for professionals associated with Capital Market Intermediaries (CMIs) operating in IFSCs.

1. Specified Certification Course

The prescribed certification is titled: “Regulatory Framework for Capital Market Intermediaries in IFSC”

• The course is offered by the Institute of Company Secretaries of India (ICSI)
• It is aimed at enhancing regulatory understanding and compliance capabilities

2. Applicability of the Requirement

The certification is mandatory for:

• Key Managerial Personnel (KMPs)
• Employees engaged in core activities of CMIs

3. Compliance Deadline

• The certification must be completed by 30th September 2026

4. Responsibility for Compliance

• CMIs and their controlling persons are responsible for ensuring compliance
• They must ensure that all relevant personnel complete the certification within the prescribed timeline

5. Objective of the Mandate

The requirement seeks to:

• Strengthen regulatory awareness and expertise
• Improve governance and compliance standards
• Enhance investor confidence in IFSC market intermediaries

6. Conclusion

This initiative reinforces IFSCA’s focus on building a well-informed and competent ecosystem, ensuring that key personnel in capital market intermediaries are equipped with the necessary regulatory knowledge and skills.

Click Here To Read The Full Notification

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