Circular No. RBI/CO.DPSS.POLC.No.S56/02.14.003/2026-27, Dated 21.04.2026

The Reserve Bank of India (RBI) has issued the “Digital Payments – E-mandate Framework, 2026”, consolidating all existing instructions on e-mandates for recurring digital transactions.

1. Scope and Applicability

The Directions apply to:

• All Payment System Providers and Participants
• Transactions through:

1. 1. Cards
   2. Prepaid Payment Instruments (PPI)
   3. UPI

• Covers both domestic and cross-border recurring payments

2. Registration of E-Mandate

• Requires one-time validation using Additional Factor of Authentication (AFA)
• Customers must be provided the ability to:

1. 1. Modify the mandate
   2. Withdraw the mandate at any time

3. Authentication Requirements

3.1 First Transaction

• Must be authenticated using AFA

3.2 Subsequent Recurring Transactions

• Can be processed without AFA up to ₹15,000 per transaction

3.3 Higher Limit for Specified Categories

• For transactions such as:

1. 1. Insurance premiums
   2. Mutual fund investments
   3. Credit card bill payments

• AFA not required up to ₹1,00,000 per transaction

4. Customer Protection Measures

The framework mandates:

• Pre-transaction notification at least 24 hours before debit
• Post-transaction notification
• Opt-out facility for customers
• Robust grievance redressal mechanism

5. No Charges to Customers

• Customers shall not be charged any fee for registration or usage of e-mandate facility

6. Objective of the Framework

The Directions aim to:

• Enhance security and user control
• Promote convenience in recurring payments
• Strengthen consumer protection in digital payments

7. Conclusion

The consolidated e-mandate framework provides a balanced approach between convenience and security, ensuring seamless recurring payments while safeguarding customer interests through robust controls and transparency.

Click Here To Read The Full Circular

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Case Details: Liberty Square Apartment Owners Association, In re [2026] 185 taxmann.com 477 (AAR-KARNATAKA)

Judiciary and Counsel Details

• Kalyanam Rajesh Rama Rao & Sivakumar S Itagi, Member
• Ms Deepa K Shetty, CA for the Applicant.

Facts of the Case

The applicant, being a Resident Welfare Association (RWA), filed an application before the Authority for Advance Ruling (AAR), seeking a determination on the GST implications and time of supply in respect of corpus/sinking fund collected from its members. It was engaged in managing and administering common areas of a residential complex and collecting monthly maintenance charges for recurring expenditure such as salaries of staff, upkeep of common areas, and utilities. It was further stated that, in addition to maintenance charges, the applicant collected corpus funds for future contingencies and long-term capital expenditure, which were separately accounted for and governed by the bylaws. It contended that the corpus fund was distinct from monthly maintenance charges and sought a ruling on whether such collections constituted ‘consideration’ and whether GST was payable at the time of collection or utilisation. The matter was accordingly placed before the Authority for Advance Ruling (AAR).

AAR Held

The AAR held that corpus fund collected by RWA constitutes ‘consideration’ for a future supply of services within the meaning of Section 2(31) read with Section 7 of the CGST Act and Karnataka GST Act, and is taxable under SAC 9995 in terms of Notification No. 11/2017-Central Tax (Rate), dated 28-06-2017. It held that such corpus/sinking fund amounts are in the nature of advances and not deposits, as they are collected upfront for future supply of services by the association. The Authority further held that, in view of Section 13(2)(a) of the CGST Act and Karnataka GST Act, the time of supply is triggered at the time of receipt of such corpus fund, since it represents an advance towards future taxable supply. It also observed that corpus fund is distinct and independent from monthly maintenance charges, which relate to ongoing services, whereas corpus fund pertains to future capital requirements. Accordingly, it was held that GST is payable at the time of collection itself on corpus/sinking fund contributions.

List of Cases Referred to

• State of West Bengal v. Calcutta Club Ltd. [2019] 110 taxmann.com 47/29 GSTL545/ 76 GST 614 (SC) (para 8).

The post GST on RWA Corpus Fund Payable on Receipt as Advance | AAR appeared first on Taxmann Blog.

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Case Details: Lubrizol Advance Materials India (P.) Ltd. vs. Union of India [2026] 185 taxmann.com 270 (Bombay)

Judiciary and Counsel Details

• G. S. Kulkarni & Aarti Sathe, JJ.
• Bharat Raichandani, Adv. for the Petitioner.
• Ms Jyoti Chavan, Addl. GP & Himanshu Takke, AGP for the Respondent.

Facts of the Case

The petitioner filed a writ petition challenging the rejection of its refund claim. It had entered into agreements with its overseas group entities and provided administrative and sales support services on a principal-to-principal basis. It was submitted that during the service tax regime, the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) had held in its own case that such services were not intermediary services but qualified as export of services. Under the GST regime, it continued to provide identical services under similar contractual arrangements for consideration computed on a cost-plus markup basis, which was received in convertible foreign exchange. It filed a refund application in Form GST RFD-01; however, a show cause notice (SCN) was issued alleging that the services were intermediary services and therefore not export of services. Subsequently, the refund was rejected. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the impugned order rejecting the refund claim under Section 54 of the CGST Act and Maharashtra GST Act was unsustainable due to failure to properly evaluate the petitioner’s contractual arrangements. The Court observed that the failure to consider relevant submissions and agreements amounted to a violation of the principles of natural justice and vitiated the adjudication process. It further held that a proper opportunity of hearing and reasoned examination of agreements was mandatory before determining the eligibility of a refund under Section 54 of the CGST Act and the corresponding provisions of the Maharashtra GST Act. Accordingly, the Court quashed the order rejecting the refund and remanded the proceedings for de novo consideration, with a direction to pass a fresh order after granting an adequate hearing opportunity.

List of Cases Referred to

• Vistex Asia Pacific (P.) Ltd. v. Union of India [2026] 182 taxmann.com 883/106 GSTL 279 (Bombay) (para 5)
• Sundyne Pumps and Compressors India (P.) Ltd. v. Union of India [2025] 175 taxmann.com 685 (Bombay) (para 5).

The post GST Refund Rejection Set Aside for Ignoring Contracts | HC appeared first on Taxmann Blog.

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Notification No. G.S.R. 300(E) dated 21st April, 2026

The Central Government has issued the Companies (Registration Offices and Fees) Amendment Rules, 2026, revising the fee structure for filing Form DIR-3 KYC Web under Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014.

1. Substitution of Fee Schedule

• The amendment substitutes Item VII of the Annexure to the 2014 Rules
• It prescribes a revised fee framework for DIR-3 KYC Web filings

2. Revised Fee Structure

2.1 Filing Within Prescribed Timeline

• No fee payable
• Applicable when DIR-3 KYC Web is filed within the due date under Rule 12A(1)

2.2 Delayed Filing/DIN Reactivation

• Fee – ₹5,000
• Applicable when:

1. 1. Filing is made after the prescribed timeline, or
   2. For re-activation of DIN

2.3 Filing for Changes (Sub-rule 2)

• Fee – ₹500 per filing
• Applicable when Form is filed again for updating or modifying details under Rule 12A(2)

3. Objective of the Amendment

The revised structure aims to:

• Encourage timely compliance by directors
• Rationalise penalty for delayed filings
• Provide clarity on fees for updates and modifications

4. Conclusion

The amendment introduces a clear and structured fee regime, incentivising timely DIR-3 KYC compliance while prescribing defined charges for delays and subsequent updates.

Click Here To Read The Full Notification

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Case Details: Principal Commissioner of Income-tax vs. Sunil Devkishan Panwar [2026] 185 taxmann.com 638 (Gujarat)

Judiciary and Counsel Details

• A.S. Supehia & Pranav Trivedi, JJ.
• Karan G Sanghani for the Appellant.

Facts of the Case

The assessee filed his return of income for the relevant assessment year. The Assessing Officer (AO) completed the assessment under section 143(3). Subsequently, based on the information received from the Investigation Wing, a notice under section 148 was issued. The AO made additions to the assessee’s income, contending that the assessee was engaged in bogus purchases and sales of goods.

The matter was carried to the Tribunal, which deleted the additions made by the AO. The Tribunal held that the assessee furnished all the details of purchases and sales. The assessee also furnished the purchase and sale bills, and the VAT was duly paid. The assessee also furnished the sales tax assessment, and the input credit was also allowed in favour of the assessee. There was no adverse material brought on record to substantiate the allegation that the assessee had shown purchases from the impugned party.

The AO made the addition without rejecting the books of account and recasting the trading results. Thus, the assessee had discharged the onus cast upon him. The aggrieved AO filed an appeal to the Gujarat High Court.

High Court Held

The High Court held that the AO made the additions based on the information received from the Investigation Wing. The assessee had contended that the reopening of the assessment was not justified, as it was based on information received from the Investigation Wing. However, no material was supplied to him, and no opportunity for cross-examination was also allowed.

The CIT(A) allowed full relief, accepting the assessee’s contentions. The same was challenged before the Tribunal, and after considering the respective submissions, the Tribunal held that the CIT(A) allowed full relief to the assessee by appreciating the facts in the right perspective. Thus, the High Court held that the CIT(A) deleted the entire addition based on the appreciation of facts and affirmed the order of the Tribunal.

List of Cases Reviewed

• ITO v. Sunil Devkishan Panwar IT Appeal No.61/srt/2024, Dated 28-6-2024 (para 8) Affirmed

The post Bogus Purchase Addition Deleted for Lack of Evidence | HC appeared first on Taxmann Blog.

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Mukesh Kohli – [2026] 185 taxmann.com 726 (Article)

Sometimes we professional face a query whether legal heirs are required to prove source of the source in case of death of the Assessee as Finance Act 2022 has inserted new first proviso in section 68 of Income-tax Act, 1961 wef assessment year 2023-24 and the Section 102 (2) of the Income-tax Act, 2025 retains the same provisions.

Let us see the provisions under the old Act and New Act

Section – 68, Income Tax Act, 1961

68. Where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by him is not, in the opinion of the [Assessing] Officer, satisfactory, the sum so credited may be charged to income-tax as the income of the assessee of that previous year:

[Provided that where the sum so credited consists of loan or borrowing or any such amount, by whatever name called, any explanation offered by such assessee shall be deemed to be not satisfactory, unless:

a. the person in whose name such credit is recorded in the books of such assessee also offers an explanation about the nature and source of such sum so credited; and

b. such explanation in the opinion of the Assessing Officer aforesaid has been found to be satisfactory:

Provided further that] where the assessee is a company (not being a company in which the public are substantially interested), and the sum so credited consists of share application money, share capital, share premium or any such amount by whatever name called, any explanation offered by such assessee-company shall be deemed to be not satisfactory, unless:

a. the person, being a resident in whose name such credit is recorded in the books of such company also offers an explanation about the nature and source of such sum so credited; and

b. such explanation in the opinion of the Assessing Officer aforesaid has been found to be satisfactory:

[Provided also] that nothing contained in the first proviso [or second proviso] shall apply if the person, in whose name the sum referred to therein is recorded, is a venture capital fund or a venture capital company as referred to in clause (23FB) of section 10.]

Section – 159, Income Tax Act, 1961

159. (1) Where a person dies, his legal representative shall be liable to pay any sum which the deceased would have been liable to pay if he had not died, in the like manner and to the same extent as the deceased.

(2) For the purpose of making an assessment (including an assessment, reassessment or recomputation under section 147) of the income of the deceased and for the purpose of levying any sum in the hands of the legal representative in accordance with the provisions of sub-section (1):

a. any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of the death of the deceased;

b. any proceeding which could have been taken against the deceased if he had survived, may be taken against the legal representative; and

c. all the provisions of this Act shall apply accordingly.

(3) The legal representative of the deceased shall, for the purposes of this Act, be deemed to be an assessee.

(4) Every legal representative shall be personally liable for any tax payable by him in his capacity as legal representative if, while his liability for tax remains undischarged, he creates a charge on or disposes of or parts with any assets of the estate of the deceased, which are in, or may come into, his possession, but such liability shall be limited to the value of the asset so charged, disposed of or parted with.

(5) The provisions of sub-section (2) of section 161, section 162, and section 167, shall, so far as may be and to the extent to which they are not inconsistent with the provisions of this section, apply in relation to a legal representative.

(6) The liability of a legal representative under this section shall, subject to the provisions of sub-section (4) and sub-section (5), be limited to the extent to which the estate is capable of meeting the liability.

Click Here To Read The Full Article

The post [Opinion] Whether the Legal Heir is Liable to Prove the Source of the Deceased Assessee? appeared first on Taxmann Blog.

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Editorial Team – [2026] 185 taxmann.com 727 (Article)

Global Financial Insights is a weekly feature for the Accounts and Audit Module subscribers of Taxmann.com. It provides you with the latest updates on financial reporting and auditing practices from across the globe. Here is this week’s financial update:

1. ISSB Proposes Guidance on Nature-Related Disclosures through a Practice Statement

The International Sustainability Standards Board (ISSB), at its April meeting in Beijing, has agreed to develop proposed requirements for nature-related disclosures in the form of an IFRS Practice Statement. The initiative aims to provide additional clarity on reporting such risks and opportunities without introducing new mandatory requirements.

The proposed guidance is intended to complement existing standards, particularly IFRS S1 and IFRS S2, which already require companies to disclose material sustainability-related information, including nature-related risks where relevant. The Practice Statement will explain how such disclosures should be made in practice, ensuring consistency while avoiding disruption for entities currently implementing the ISSB framework.

The development builds on prior work, incorporating elements of the Taskforce on Nature-related Financial Disclosures (TNFD), reflecting growing emphasis on nature-related financial reporting. The ISSB plans to issue an exposure draft in October 2026, inviting stakeholder feedback on both the proposed content and the suitability of using a Practice Statement for this purpose.

Source – IFRS Foundation

2. FRC Invites Stakeholder Feedback on the Audit Standard for Less Complex Entities

The Financial Reporting Council (FRC) has invited stakeholders to participate in roundtable discussions as part of its ongoing engagement on the International Standard for Auditing for Less Complex Entities (ISA for LCE). This initiative aims to gather practical insights to support its contributions to the International Auditing and Assurance Standards Board’s (IAASB) project to develop further and maintain the standard.

The discussions will focus on how audits of less complex entities can be carried out in a more proportionate manner, while still maintaining the same level of assurance and audit quality expected under full auditing standards. The feedback will help the FRC better understand stakeholder perspectives as the IAASB continues its work on the standard through to 2027.

Importantly, the FRC has clarified that this exercise does not relate to the adoption of the current version of the ISA for LCE in the UK. Instead, it is intended to inform future considerations once a revised version of the standard is finalised.

Source – Financial Reporting Council

Click Here To Read The Full Article

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Editorial Team – [2026] 185 taxmann.com 725 (Article)

World Corporate Law News provides a weekly snapshot of corporate law developments from around the globe. Here’s a glimpse of the key corporate law update this week.

1. Securities Law

1.1 ASIC Outlines Roadmap and Guidance for Digital Asset Licensing Regime Under DAF Act from April 2027

On 20 April 2026, Australian Securities and Investments Commission (ASIC) announced its intention to issue new regulatory guidance and prescribe certain operational standards as part of the implementation of new laws bringing digital asset platforms (DAPs) and tokenised custody platforms (TCPs) within the financial services licensing regime from April 2027.

The Corporations Amendment (Digital Assets Framework) Act 2026 (DAF Act) was passed by Parliament on 1 April 2026, received Royal Assent on 8 April 2026, and is scheduled to commence on 9 April 2027. The Act provides for an 18-month implementation period.

Under the new regime, ASIC will be responsible for licensing and supervising DAPs and TCPs, as well as enforcing compliance with the applicable legal framework.

To support industry participants, ASIC has outlined a roadmap for implementation. This includes the expected timeline and its approach to consultation on the proposed standards and guidance, along with early indications of the key areas to be covered.

Source – News

1.2 SEC and CFTC Jointly Propose Amendments to Reduce Private Fund Reporting Burdens

On 20 April 2026, the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly proposed amendments aimed at reducing private fund reporting burdens while continuing to ensure the collection of necessary and relevant information.

The proposal seeks to amend Form PF, a confidential reporting form applicable to certain SEC-registered investment advisers to private funds, including those also registered with the CFTC as commodity pool operators or commodity trading advisors. Form PF is designed to assist the Financial Stability Oversight Council (FSOC) in monitoring systemic risk across financial markets. The SEC and CFTC also rely on the data collected through Form PF to support their investor protection mandates.

Commenting on the proposal, Paul S. Atkins stated that a key priority is to restore balance in disclosure obligations and reduce compliance costs. He noted that prior amendments to Form PF had resulted in overly burdensome requirements for advisers, often without a corresponding regulatory benefit, and that the proposed changes seek to better align disclosure requirements with the form’s intended purpose.

Similarly, Michael S. Selig emphasised that increasing filing thresholds and streamlining Form PF would help reduce compliance burdens. He added that public comments would play an important role in ensuring that the final framework effectively eliminates unnecessary costs while maintaining regulatory objectives.

Source – Press Release

Click Here To Read The Full Article

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Case Details: GU Shipping India (P.) Ltd. vs. Assistant Commissioner of CGST and Central Excise [2026] 185 taxmann.com 162 (Madras)

Judiciary and Counsel Details

• C. Saravanan, J.
• Joseph Prabakar for the Petitioner.
• Mrs Revathi Manivannan, Sr. Standing Counsel for the Respondent.

Facts of the Case

The petitioner was engaged in providing freight and leasing/renting services of vessels with crew members. It initially discharged GST at 18% and later, after amendment and classification as ‘time charter of vessels for transport of goods’, began paying tax at 5% under the concessional entry of the relevant notification. The Department issued a show cause notice (SCN), culminating in an adjudication order confirming tax at 18% along with interest under Section 50 of the CGST Act and 100% penalty on the ground of ineligibility to the concessional benefit. It was contended that the dispute was confined to reversal of wrongly availed ITC with interest and penalty and not denial of concessional rate. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the denial of concessional rate solely on account of alleged wrongful availment of ITC was not sustainable in law. It was observed that the appropriate course, where ITC was wrongly availed, was to direct reversal of such credit along with interest and penalty under Section 74 of the CGST Act rather than imposing a higher tax liability of 18%. The Court further held that authorities could not increase tax liability merely because of inadvertent or technical errors in ITC availment, when statutory mechanisms for correction were available. It was concluded that denial of substantive benefit was unjustified in such circumstances. Accordingly, the impugned order was set aside and the matter was remitted to the jurisdictional officer under CGST for determination of the actual ITC wrongly availed and consequential computation of interest and penalty.

List of Cases Reviewed

• Chandrapur Magnet Wires (P.) Ltd. v. CCE 1996 taxmann.com 736 (SC)
• Unichem Laboratories Ltd. v. CCE 2002 taxmann.com 494/2002 (145) E.L.T. 502 (SC) (Para 39), followed

List of Cases Referred to

• Chandrapur Magnet Wires (P.) Ltd. v. CCE 1996 taxmann.com 736 (SC) (para 8)
• Hello Minerals Water (P.) Ltd. v. Union of India 2004 (174) E.L.T. 422 (All.) (para 9)
• Franco Italian Co. (P.) Ltd. v. CCE 2000 taxmann.com 360 (CEGAT- New Delhi) (para 9)
• Pepsico India Holdings (P.) Ltd. v. CCE [Excise Tax Appeal No. E/41318 of 2015-DB, dated 10-12-2019] (para 10)
• Unichem Laboratories Ltd. v. CCE 2002 taxmann.com 494/2002 (145) E.L.T. 502 (SC) (para 31).

The post Concessional GST Rate Can’t Be Denied for Wrong ITC | HC appeared first on Taxmann Blog.

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1. Query

Aristotle LLP (hereinafter referred to as the “Land Owner”), formed upon conversion from a private limited company, owns a parcel of land which has been contributed for development under a Joint Development Agreement (JDA) entered into with a real estate developer (hereinafter referred to as the “Developer”) for the construction and sale of residential units.

Under the terms of the arrangement, the Land Owner has granted the Developer an irrevocable and exclusive license to enter the land and undertake development activities. However, the legal ownership of the land continues to vest with the Land Owner until the completion of the project and the execution of a conveyance in favour of the ultimate purchasers. A Power of Attorney has also been executed in favour of the Developer, authorising it to obtain regulatory approvals, enter into sale agreements, and carry out all activities necessary for execution of the project. The Developer is responsible for planning, obtaining approvals, construction, marketing, and sale of units, and bears all costs relating to the project.

The revenue from unit sales, including advances and booking amounts, is deposited into a jointly operated escrow account and shared between the Land Owner and the Developer in an agreed ratio. The Land Owner retains involvement in key decisions, such as pricing and terms of sale, and also possesses step-in rights in the event of non-performance by the Developer. Further, conveyance of property in favour of the ultimate buyers is executed by the Land Owner, with the Developer acting as a confirming party, only upon completion of the project and receipt of the entire sale consideration.

The land has been classified as inventory in the LLP’s books. In this context, the LLP is uncertain about the appropriate timing and method of recognising its share of income arising from the JDA, particularly whether such revenue should be recognised during the course of construction, based on collections or receipts, or only upon completion of the project. The LLP has also sought clarification on the accounting treatment in a situation where consideration is receivable for the constructed area that remains unsold.

2. Relevant Provisions

Accounting Standard 27 – Financial Reporting of Interests in Joint Ventures

Para 3 of AS 27

A joint venture is a contractual arrangement whereby two or more parties undertake an economic activity, which is subject to joint control.

Para 12 of AS 27

In respect of its interests in jointly controlled operations, a venture should recognise in its separate financial statements and consequently in its consolidated financial statements:

(a) the assets that it controls and the liabilities that it incurs; and

(b) the expenses that it incurs and its share of the income that it earns from the joint venture.

Accounting Standard 9 – Revenue Recognition

Para 10 of AS 9

Revenue from sales or service transactions should be recognised when the requirements as to performance set out in paragraphs 11 and 12 are satisfied, provided that at the time of performance it is not unreasonable to expect ultimate collection. If, at the time of raising any claim, it is unreasonable to expect ultimate collection, revenue recognition should be postponed.

Para 11 of AS 9

In a transaction involving the sale of goods, performance should be regarded as being achieved when the following conditions have been fulfilled:

(a) the seller of goods has transferred to the buyer the property in the goods for a price or all significant risks and rewards of ownership have been transferred to the buyer and the seller retains no effective control of the goods transferred to a degree usually associated with ownership; and

(b) no significant uncertainty exists regarding the amount of the consideration that will be derived from the sale of the goods

3. Guidance Note on Accounting for Real Estate Transactions

Para 3 of Guidance Note

Revenue recognition in real estate transactions depends upon transfer of significant risks and rewards of ownership, which is to be determined based on the terms of the agreement and substance of the transaction. It further provides that where the transaction is akin to construction contracts, revenue may be recognised using the percentage of completion method; otherwise, principles of AS 9 apply.

Para 4.2 of Guidance Note

The completion of the revenue recognition process is usually identified when the following conditions are satisfied:

(a) The seller has transferred to the buyer all significant risks and rewards of ownership, and the seller retains no effective control of the real estate to a degree usually associated with ownership

(b) The seller has effectively handed over possession of the real estate unit to the buyer forming part of the transaction;

(c) No significant uncertainty exists regarding the amount of consideration that will be derived from the real estate sales; and

(d) It is not unreasonable to expect ultimate collection of revenue from buyers.

Para 4.3 of Guidance Note

Where transfer of legal title is a condition precedent to the buyer taking on the significant risks and rewards of ownership and accepting significant completion of the seller’s obligation, revenue should not be recognised till such time legal title is validly transferred to the buyer.

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