Circular no. HO/49/(17)2026-CFD-POD2/I/8965/2026; Dated: 08.04.2026

The Securities and Exchange Board of India (SEBI) has introduced a mechanism for lock-in of pledged shares under the ICDR Regulations, aimed at easing compliance for issuers.

1. Objective of the Mechanism

The initiative seeks to:

• Facilitate compliance with lock-in requirements
• Address practical challenges in handling pledged shares during public issues
• Ensure regulatory clarity and operational ease

2. Framework Issued by Depositories

To operationalise the mechanism, depositories have prescribed a framework for issuers, which includes:

• Amendments to Articles of Association (AOA) – Incorporating provisions to enable lock-in of pledged shares
• Intimation to Stakeholders – Informing lenders/pledgees about the lock-in requirements
• Disclosures in Offer Documents – Providing clear disclosures regarding pledged shares and lock-in conditions

3. System and Process Enhancements

Depositories have:

• Made necessary changes to their systems and processes
• Enabled smooth implementation and tracking of locked-in pledged shares

4. Regulatory Impact

The framework ensures:

• Better alignment between pledge arrangements and lock-in norms
• Reduced operational complexity for issuers
• Enhanced transparency for investors

5. Conclusion

This mechanism reflects SEBI’s effort to modernise compliance processes, ensuring that pledged shares are seamlessly integrated within the lock-in framework, while maintaining investor protection and regulatory integrity.

Click Here To Read The Full Circular

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Press Release: 2026-2027/44, Dated 08.04.2026

Click Here To Read The Full Press Release

The post RBI Invites Comments on Draft Amendment Directions Reviewing IFR Norms appeared first on Taxmann Blog.

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Case Details: Federal Bank Ltd. vs. Federal Bank Officers Association [2026] 185 taxmann.com 196 (HC-Kerala)

Judiciary and Counsel Details

• Sushrut Arvind Dharmadhikari & Syam Kumar V.M., JJ.
• C.U. Singh, Benny P. Thomas, Sr. Advs., Abel Tom Benny, D. Prem Kamath & Tom Thomas (Kakkuzhiyil), Advs. for the Appellant.
• P. Chidambaram, P. Ramakrishnan, Sr. Advs. & P.R. Ajith Kumar, CGC for the Respondent.

Facts of the Case

In the instant case, the appellant was a banking company governed by the Banking Regulation Act, with pan-India operations. The respondent was an officers’ association representing officers in Scales I to III and registered under the Trade Unions Act.

The Central Government, by Gazette Notification dated 5 June 2023, notified services engaged in the banking industry as a public utility service under Section 2(n) of the Industrial Disputes Act, 1947.

The respondent issued a call for a strike or work abstention in relation to employees/officers of the appellant bank. Following the strike call, the Regional Labour Commissioner (Central) issued notices invoking Section 22, calling upon the respondent to participate in conciliation proceedings and restraining it from proceeding with the proposed strike/abstention.

Thereafter, the respondent filed a writ petition challenging the said notices. The Single Judge held that officers represented by the respondent did not fall within the definition of ‘workman’ under Section 2(s) of the Industrial Disputes Act, 1947.

Further, an ‘industrial dispute’ under Section 2(k) of the Industrial Disputes Act, 1947 required an employer–workman relationship; that Chapter V provisions applied to the workmen and employers; that a Conciliation Officer could act only when an industrial dispute existed or was apprehended; and that, since members were not workmen, Section 22 of the Industrial Disputes Act, 1947 could not be invoked.

It was noted that Section 22 of the Industrial Disputes Act, 1947, places a statutory embargo on “any person” and not only on “workmen”.

Further, it was noted that Section 22 of the Industrial Disputes Act, 1947, applies even when the workers are not involved. In contrast, Section 23 of the Industrial Disputes Act, 1947, applies only to disputes involving workers.

Also, it was noted that the right to collective bargaining by resorting to strikes or lockouts by employees of any establishment falls outside constitutional protections of Article 19(1)(c) of the Constitution of India.

High Court Held

The High Court observed that there was no basis for inference that managerial or supervisory employees of higher ranks or cadres were excluded from provisions of the Industrial Disputes Act, 1947.

Further, the High Court observed that the restrictions imposed under Section 22 of the Industrial Disputes Act, 1947, were intended to protect public interests and ensure the smooth operation of a PUS.

The High Court held that the very definition of ‘strike’ under Section 2(q) of the Industrial Disputes Act, 1947, contemplates that officers and non-workmen employees are included within the expression “body of persons employed in any industry”. Therefore, the impugned order of the Single Judge was to be set aside.

List of Cases Referred to

• Narendra Kumar Sen v. All India Industrial Disputes (Labour Appellate) Tribunal AIR 1953 Bom 325 (para 6)
• Mukand Ltd. v. Mukand Staff & Officers’ Association 2004 taxmann.com 2985 (SC) (para 6)
• Workmen of Dimakuchi Tea Estate v. Management of Dimakuchi Tea Estate AIR 1958 SC 353 (para 6)
• T.K. Rangarajan v. Government of Tamil Nadu 2003 taxmann.com 4792 (SC) (para 17)
• Communist Party of India (M) v. Bharat Kumar [1998] 1997 taxmann.com 2114 (SC) (para 17.3)
• Ex-Capt. Harish Uppal v. Union of India (2003) 2 SCC 45 (para 17.3)
• All India Bank Employees’ Association v. National Industrial Tribunal (Bank Disputes), Bombay 1961 taxmann.com 83 (SC) (para 18)
• B.R. Singh v. Union of India (1989) 4 SCC 710 (para 20).

The post Section 22 Strike Curbs Apply to All Bank Staff | HC appeared first on Taxmann Blog.

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Case Details: Srideva Sattva (P.) Ltd. vs. State of Haryana [2026] 184 taxmann.com 595 (SC)

Judiciary and Counsel Details

• Aravind Kumar & Prasanna B. Varale, JJ.
• Amit Deshpande, Suresh V., Ms Urvashi Tyagi, Advs. & Ms Preeti Gupta, AOR for the Petitioner.
• Alok Sangwan, Sr. AAG, Samar Vijay Singh & Harsh Mehta, Advs. for the Respondent.

Facts of the Case

The appellant was registered under GST and had entered into a logistic support agreement for warehouse operations and business management. Upon expiry of the arrangement, it shifted its entire business unit and warehouse operations from Haryana to Delhi. A show cause notice (SCN) was issued proposing reversal of ITC and demand of tax, pursuant to which an order-in-original was passed ex parte confirming the demand. It filed a writ petition challenging the notice and order; however, the same was dismissed on the ground that an alternate remedy was available. The present appeal contending that the SCN was not served after the change of business premises and that the order-in-original was passed without affording an opportunity of hearing, thereby rendering the proceedings without jurisdiction. The matter was accordingly placed before the Supreme Court.

Supreme Court Held

The Supreme Court held that although the order-in-original recorded that the SCN had been served, no material was available on record to substantiate such service in terms of Section 169 of the CGST Act and the Haryana GST Act. It was observed that proper service of notice is a mandatory requirement for valid adjudication and forms the basis of compliance with principles of natural justice. The Court held that passing an ex parte order without establishing service of notice vitiates the proceedings. Accordingly, the impugned order was set aside, with liberty granted to the appellant to file a reply to the SCN, and the matter was remanded to the assessing officer for fresh adjudication in accordance with law.

The post SC Sets Aside GST Order for Lack of SCN Service appeared first on Taxmann Blog.

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Editorial Team – [2026] 185 taxmann.com 304 (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. IFRS Issues Updated Supporting Materials for IFRS for SMEs

The IFRS Foundation has released updated supporting materials for the IFRS for SMEs Accounting Standard, reinforcing its role as a simplified and self-contained framework tailored for small and medium-sized entities. Designed to meet the needs of businesses that make up a significant majority of companies globally, the standard aims to balance usability with high-quality financial reporting.

The framework reduces complexity by excluding topics not typically relevant to SMEs and simplifying recognition and measurement principles. It also significantly cuts down disclosure requirements and uses clearer, more accessible language, making it easier for preparers to apply and for jurisdictions to adopt.

Overall, the IFRS for SMEs continues to provide a practical alternative to full IFRS, offering a stable and less burdensome reporting framework while maintaining comparability and transparency in financial reporting.

Source – IFRS Foundation

2. IESBA and IAASB Analyse Linkages Between ISQM 1 and Firm Culture Framework

The International Ethics Standards Board for Accountants (IESBA), in coordination with the International Auditing and Assurance Standards Board (IAASB), has released an analysis examining the linkages between ISQM 1 and the IESBA’s Firm Culture and Governance (FCG) viewpoints. The initiative responds to stakeholder calls for greater clarity on how ethical culture frameworks interact with existing quality management standards.

The analysis highlights how both frameworks complement each other in promoting audit quality, while also underscoring key differences in their objectives and scope. ISQM 1 focuses on establishing a system of quality management to ensure consistent engagement quality, with an embedded emphasis on ethical values and firm-wide culture. In contrast, the FCG viewpoints provide a broader, principles-based perspective on fostering ethical culture through defined governance elements.

Importantly, the paper clarifies that while ISQM 1 is a binding standard, the FCG viewpoints are not prescriptive and are intended to support ongoing dialogue on developing a global framework for firm culture and governance.

Overall, the analysis reinforces the interconnected roles of quality management and ethical culture in audit firms, while signalling further developments as the IESBA continues its stakeholder outreach to shape a formal FCG framework.

Source – International Ethics Standards Board for Accountants

Click Here To Read The Full Article

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Case Details: Bhawar Life Style vs. Assistant Commissioner Central Tax [2026] 185 taxmann.com 23 (Karnataka)

Judiciary and Counsel Details

• S Sunil Dutt Yadav, J.
• E.I. Sanmathi., Adv. for the Petitioner.
• Aravind V. Chavan & Unnikrishnan M, Advs. for the Respondent.

Facts of the Case

The petitioner filed writ petitions challenging the Orders-in-Original (OIO), by which the claims for transitional ITC under TRAN-1 and TRAN-2 were rejected. In respect of TRAN-1, the jurisdictional officer under CGST noted the mismatch in input quantity/value vis-à-vis credit claimed and absence of detailed stock records, treating the credit as irregular and confirming demand. For TRAN-2, it was observed that no particulars of stock and no supporting invoices evidencing tax carried forward were furnished. Subsequently, pursuant to the Court’s directions, the petitioner appeared before the authority and submitted additional documents, while the authority sought CA-certified closing stock, purchase invoices, and sales registers for the relevant period. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the impugned orders had been passed in the absence of relevant documents which were subsequently produced by the petitioner pursuant to judicial directions. It observed that the authority itself had sought further certified records, indicating that reconsideration was necessary for proper adjudication under Section 140 of the CGST Act and the Karnataka GST Act. The Court further held that denial of transitional credit without examining the subsequently produced material would be improper. Accordingly, the impugned orders were set aside, and the matter was remanded for fresh consideration.

The post HC Sets Aside TRAN Credit Rejection – Orders Reconsideration appeared first on Taxmann Blog.

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CA Paras K Savla – [2026] 185 taxmann.com 152 (Article)

1. Executive Summary

On 15 January 2026, the Supreme Court of India1 upheld a capital gains tax demand of approximately Rs. 14,500 crore on Tiger Global’s exit from Flipkart, applying GAAR to a pre-2017 investment structure and fundamentally recalibrating India’s treaty-benefit jurisprudence. The CBDT issued Notifications 54 and 55 of 2026 on 31 March 2026, amending Rule 10U (IT Rules, 1962) and Rule 128 (IT Rules, 2026) to exclude income from the transfer of pre-2017 investments from GAAR’s reach.

The amendment has generated two sharply divergent readings in professional discourse. One school reads it as a legislative reversal of Tiger Global on the GAAR question. The other reads it as a codification of the very distinction the Supreme Court drew—between protected “investments” and challengeable “arrangements”—leaving the ruling’s core ratio firmly intact. This article examines both views, the textual puzzle they reveal, and what endures regardless of how the amendment is ultimately read.

2. The Supreme Court’s Ruling in Tiger Global—A Structural Brief

2.1 The Structure and the Dispute

Tiger Global held its Flipkart stake through a layered structure: Mauritius-incorporated holding entities (Tiger Global International II, III and IV Holdings) owned Singapore-incorporated intermediate companies, which in turn held shares in Flipkart India. The investments were assembled before April 1, 2017 i.e., before GAAR came into force. In 2018, when Walmart acquired Flipkart for approximately USD 16 billion, the Mauritius entities received aggregate consideration exceeding Rs. 14,500 crore on the transfer of their Singapore interests.

The Mauritius entities claimed capital gains exemption under Article 13(4) of the India-Mauritius DTAA, relying on Tax Residency Certificates (TRCs) and the grandfathering protection under Rule 10U(1)(d). The Authority for Advance Rulings ruled against Tiger Global in 2020. The Delhi High Court reversed in August 2024. The Supreme Court, on 15 January 2026, reversed the High Court and upheld the tax demand.

2.2 The Court’s Five Core Holdings

Critically, the Revenue had consistently argued before the Court—as recorded in Para 45 of the judgment—that Rule 10U grandfathered only genuine “investments” made prior to 1 April 2017, and not “arrangements” or structures designed to obtain treaty benefits. The Supreme Court accepted this distinction as the correct reading of Rule 10U’s architecture. This point becomes central to understanding what the March 31 amendment actually achieves.

Click Here To Read The Full Article

The post [Opinion] GAAR Grandfathering Restored—But Tiger Global’s Sting Endures appeared first on Taxmann Blog.

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Case Details: DCM Shri Ram Industries Ltd. vs. Deputy Commissioner of Income-tax [2026] 184 taxmann.com 679 (Delhi-Trib.)

Judiciary and Counsel Details

• Challa Nagendra Prasad, Judicial Member & S. Rifaur Rahman, Accountant Member
• Pradeep Dinodia, Ravi Kumar & Ms Shruti Gupta, CAs for the Appellant.
• Ms Anima Barnwal, CIT DR for the Respondent.

Facts of the Case

The assessee company was engaged in manufacturing activities and operated an eligible power unit that supplied steam to its non-eligible units. For this specified domestic transaction, the assessee adopted the ‘other method’ and valued the transfer of steam at its cost of production without any mark-up.

During the transfer pricing proceedings, the Transfer Pricing Officer rejected the methodology adopted by the assessee and determined the arm’s length price of steam at nil on the ground that generation of steam was incidental to power generation and its cost was subsumed therein, resulting in a transfer pricing adjustment of about Rs. 107.01 crores. Accordingly, a transfer pricing adjustment was made and incorporated in the final assessment. Aggrieved, the assessee filed an appeal before the Tribunal.

ITAT Held

The Tribunal held that steam is a commercially viable product and cannot be treated as having nil value. Reliance was also placed on decisions in the assessee’s own case for earlier assessment years and in the case of group concerns, wherein similar adjustments had been deleted.

The issue was covered by earlier decisions in the assessee’s own case and that steam, like electricity, is a commercial and marketable product. It was held that the cost of steam cannot be taken as nil merely because it arises during the process of power generation. The Tribunal further noted that ignoring the value of steam would lead to an unrealistic determination of arm’s length price.

Accordingly, the Tribunal held that the transfer pricing adjustment made by the TPO by determining the arm’s length price of steam at nil was unsustainable in law. The addition was deleted, and the issue was decided in favour of the assessee.

List of Cases Reviewed

• Pr. CIT v. DCM Shriram Ltd. [2025] 170 taxmann.com 631/478 ITR 385 (Delhi) (para 15 & 25) Followed.
• Asstt. CIT v. Vireet Investment (P.) Ltd. [2017] 82 taxmann.com 415/165 ITD 27 (Delhi – Trib.) (para 44) Followed.

List of Cases Referred to

• DCM Shriram Industries Ltd. v. ACIT [IT Appeal nos. 539 (Delhi) of 2021 and others, dated 15-3-2023]1841/Del/2020] (para 6)
• Distributors (Baroda) (P.) Ltd. v. Union of India [1985] 22 Taxman 49/155 ITR 120 (SC) (para 10)
• DCM Shriram Ltd. v. Addl. CIT [2022] 140 taxmann.com 217 (Delhi – Trib.) (para 13)
• Radhasoami Satsang v. CIT [1992] 60 Taxman 248/193 ITR 321 (SC) (para 14)
• CIT v. Excel Industries Ltd. [2013] 38 taxmann.com 100/219 Taxman 379/358 ITR 295 (SC) (para 14)
• CIT v. GE India Technology Centre (P.) Ltd. [2020-TII-50-HC-KAR TP] (para 14)
• Godrej & Boyce Manufacturing Company Ltd. v. Dy. CIT [2017] 81 taxmann.com 111/295 CTR 121/394 ITR 449/247 Taxman 361 (SC) (para 14)
• Pr. CIT v. DCM Shriram Ltd. [2025] 170 taxmann.com 631/478 ITR 385 (Delhi) (para 15)
• Rachna Infrastructure (P.) Ltd. v. Pr. CIT [2022] 138 taxmann.com 416 (Gujarat) (para 21)
• ITO v. Jagtap Patil Promoters & Builders [2023] 147 taxmann.com 199 (Pune – Trib.) (para 21)
• Pr. CIT v. Wipro Ltd. [2022] 140 taxmann.com 223/288 Taxman 491 /446 ITR 1 (SC) (para 21)
• Patel Brass Works Pvt. Ltd. v. ACIT [ITA no. 60/RJT/2020, dated 10-8-2022]] (para 21)
• Pr. CIT v. Oracle (OFSS) BPO Services Ltd. [2019] 102 taxmann.com 396 (Delhi) (para 24)
• Shree Bhavani Power Projects (P.) Ltd. v. ITO [2024] 165 taxmann.com 733/[2025] 475 ITR 155 (Delhi) (para 24)
• Dy. CIT v. DCM Shriram Ltd. [2025] 176 taxmann.com 51 (Delhi – Trib.) (para 25)
• CIT v. My Home Power Ltd. [2014] 46 taxmann.com 314/225 Taxman 8/365 ITR 82 (Andhra Pradesh) (para 29)
• Essel Mining & Industries Ltd. v. Dy. CIT [TS-531-ITAT-2022(Mum) (para 31)
• Dwarikesh Sugar Industries Ltd v. Assessing Officer, NFAC, Delhi [2022-TIOL-889-ITAT-MUM] (para 31)
• Rajasthan State Electricity Board v. Dy. CIT (Assessment) [1993] 200 ITR 434 (Rajasthan) (para 32)
• Commissioner of Wealth-tax v. Tulsi Dass [2002] 123 Taxman 790/256 ITR 73 (Rajasthan) (para 32)
• Vivek Jain v. Asstt. CIT [2011] 14 taxmann.com 146/202 Taxman 499 /337 ITR 74 (Andhra Pradesh) (para 32)
• Modipon Ltd. v. CIT [2000] 113 Taxman 44 (Delhi)/[2001] 247 ITR 40 (Delhi) (para 32)
• B.M. Parmar v. CIT [1999] 102 Taxman 552/235 ITR 679 (Punjab & Haryana) (para 32)
• Greatway (P.) Ltd. v. Asstt. CIT [1992] 64 Taxman 421/199 ITR 391 (Punjab & Haryana) (para 32)
• CIT v. R.J. Trivedi & Sons [1990] 53 Taxman 485/183 ITR 420 (Madhya Pradesh) (para 32)
• Federation of Andhra Pradesh Chambers of Commerce and Industry v. State of Andhra Pradesh [2001] 115 Taxman 143/247 ITR 36 (SC) (para 32)
• CIT v. Kasturi & Sons Ltd. [1999] 103 Taxman 342/237 ITR 24 (SC) (para 32)
• Asstt. CIT v. Vireet Investment (P.) Ltd. [2017] 82 taxmann.com 415/165 ITD 27 (Delhi – Trib.) (para 44).

The post ALP of Steam Transfer from Eligible Power Unit to Non-eligible Units Cannot be NIL | ITAT appeared first on Taxmann Blog.

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Circular No.HO/49/11/11(123)2026-CFD-RAC-DIL2/I/8760/2026, Dated: 07.04.2026

Click Here To Read The Full Circular

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Case Details: Jalim Singh vs. Nand Kishore [2026] 185 taxmann.com 145 (SC)

Judiciary and Counsel Details

• Vikram Nath & Sandeep Mehta, JJ.
• Raghavendra S. Srivatsa, Sr. Adv., Ms Komal Mundhra, AOR, Hari Vishnu Tiwari, Ashutosh Singh Rana & Ms Laxita Upadhyay, Advs. for the Appellant.
• Anil Kumar Mishra, Mrs Rachna Gupta, AORs, Anurag Singh, Rajiv Kumar, Ms Neelakshi, Ms Shradha Narayan & Anil Kumar Sinha, Advs. for the Respondent.

Facts of the Case

In the instant case, the appellant was appointed as a Cooperative Supervisor in the respondent Bank in 1971, was suspended in January 1977, and was reinstated in July 1991. He filed a writ petition seeking full salary and emoluments for the suspension period, which the High Court allowed on 17 January 2006; the respondent Bank’s special leave petition was dismissed. He retired on 31 October 2009, but the respondent Bank did not release his retirement benefits.

In 2018, over the non-release of retirement benefits, the respondent, Bank, by order dated 10 July 2018, rejected the appellant’s representation, citing the absence of a substantive post of Cooperative Supervisor and lack of absorption in a Class-III post. On 19 July 2018, the High Court directed the appellant to file a fresh representation, which was again rejected, leading to Writ Petition No. 18568 of 2018.

On 21 January 2019, the High Court allowed the writ petition, set aside the order dated 10 July 2018, and directed the calculation of retirement dues treating the appellant to be absorbed in a Class-III post w.e.f. 16 August 1991.

In an intra-court appeal, by order dated 1 March 2019, the High Court partly allowed the appeal and directed payment within one month of arrears of salary and emoluments due up to retirement, along with all post-retiral dues/benefits of the post of Cooperative Supervisor or an equivalent post, without going into the controversy regarding the existence of the post; it also recorded that the appellant did not possess Intermediate qualification and therefore could not be treated as a Class-III employee. This order formed the basis of the contempt proceedings.

The alleged non-compliance with the order dated 1 March 2019, filed Contempt Application (Civil) No. 1975 of 2019. By judgment dated 7 May 2024, the High Court dismissed the contempt petition, proceeding on the premises that the appellant’s services were not regularised or absorbed in a Class-III post, that he lacked the requisite Intermediate qualification, and that no contribution had been deducted towards gratuity or insurance.

Thereafter, an appeal was made before the Supreme Court.

It was noted that the High Court, in contempt proceedings, ought to have confined its inquiry to compliance with the operative directions contained in the order dated 1 March 2019, which had unequivocally directed the respondent bank to pay to the appellant all arrears of salary and emoluments due up to the date of his retirement, along with all consequential post-retiral benefits.

Further, it was noted that the High Court fell in error in entering into questions relating to regularisation or absorption of the appellant in a Class-III post, instead of enforcing its own directions requiring the respondent bank to pay arrears of salary and emoluments due to the appellant up to date of his retirement, together with all post-retiral dues and benefits attached to post of Cooperative Supervisor or an equivalent post.

Supreme Court Held

The Supreme Court held that the order passed by the High Court dismissing contempt petition was to be set aside and the appellant was entitled to gratuity, which became payable upon his retirement on 31 October 2009, with interest at rate of 8 per cent per annum from 1 November 2009 till date of actual payment and a sum of Rs. 1 lakh towards compensation for prolonged and unnecessary litigation undertaken by the respondent bank.

List of Cases Reviewed

• High Court of Judicature at Allahabad in Contempt Application (Civil) No. 1975 of 2019 Order dated 07-05-2024 (para 15) set aside

The post SC Orders Salary Arrears and 8% Interest on Gratuity appeared first on Taxmann Blog.

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