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TaxCorp Daily Digest

AI-curated tax and legal insights delivered daily

Today's Digest Summary

11 Apr 2026 Hide

TaxCorp Daily Digest

April 10, 2026 | Your Daily Compliance Intelligence


⚡ Quick Summary

  • CBDT issues a wave of corrigenda (Notifications No. 57–63/2026) correcting technical errors across ITR-1, ITR-2, ITR-4, ITR-5, ITR-6, ITR-7, and Form U — tax professionals and software providers must update filing tools immediately
  • Gujarat High Court reprimands CBDT over an 11-year pattern of delayed ITR utility releases, directing a compliance affidavit by April 27, 2026, signalling potential systemic reform ahead
  • SEBI, DGFT, and CBIC roll out significant regulatory updates spanning FPI settlement reforms, export compliance for multiple commodities, and customs relief for SEZ exporters disrupted by the Strait of Hormuz closure
  • MSME compliance tightens as three detailed guides on vendor verification, MSME-1 filings, and Section 405 obligations underscore the serious penal consequences of non-compliance with the 45-day payment rule

📂 Category-wise Updates


🔵 Income Tax


1. Gujarat High Court Reprimands CBDT Over Decade-Long Delay in Releasing ITR Utilities

The Gujarat High Court has invoked its 2015 direction in All Gujarat Federation of Tax Consultants vs. CBDT and pulled up the CBDT for failing, for over a decade, to ensure ITR forms and e-filing utilities are available from April 1 of each assessment year. The Court has directed the Department to file an affidavit detailing concrete remedial measures.

⚠️ Action Item: Monitor the official e-filing portal closely for AY 2026-27 utility releases. If your filings are impacted by delayed utilities, document the delay carefully for any interest or penalty waiver claims.


2. Gujarat High Court Pulls Up CBDT for 11-Year Non-Compliance on ITR Form Release Deadlines

In Chartered Accountants Association Vs Union of India, the Court expressed strong displeasure after the Department's Senior Standing Counsel admitted that multiple earlier Court orders also remain unimplemented. The next hearing will evaluate whether the Department has taken concrete corrective steps.

⚠️ Action Item: Affidavit from CBDT due before April 27, 2026. Professionals should track this hearing for its implications on AY 2026-27 filing timelines.


3. Comprehensive Analysis of CBDT Corrigendum on ITR-1 and ITR-4 Forms: Notification No. 57/2026

Corrigendum No. 57/2026 corrects Schedule-IT in ITR-1 (multi-column format for advance tax and self-assessment tax entries) and fixes sub-row sequencing and typographical errors in ITR-4's Schedule Salary. These are structural fixes with no change to substantive tax positions.

⚠️ Action Item: Update ITR-1 and ITR-4 templates and e-filing software to reflect the corrected Schedule-IT format before preparing returns.


4. CBDT Corrigendum Tweaks ITR-2 Schedules: Key Formatting Fixes You Must Know

Notification No. 58/2026 corrects cross-references in Schedule CG and Schedule CFL, renames a label in Part B-TI, eliminates redundant column (1b) in Schedules 112A and 115AD, and removes unnecessary grey shading. Critical reference corrections include "5c – 5d", "B11a", "2xiv", and "v".

⚠️ Action Item: Immediately update ITR-2 filing templates and reconciliation workings to reflect corrected schedule references.


5. CBDT Releases Corrigendum to Rectify Formulaic and Cross-Reference Errors in ITR-5

Corrigendum No. 60/2026 fixes a missing mathematical operator in Schedule CG (row A8 formula corrected to "A8a + A8b + A8c") and incorrect cross-references in Schedule UD. These are essential technical patches to prevent e-filing processing errors.

⚠️ Action Item: Verify that your tax computation software has incorporated the corrected Schedule CG formula and updated Schedule UD cross-references.


6. Revised Income Tax Return Form 6: CBDT Issues Corrigendum to Fix Technical Errors

Corrigendum to Notification No. 61/2026 corrects the spelling of "EQUITY" in Part A-BS, fixes row numbering in Part A-P&L, adjusts formula references in Schedule BP, and inserts a new sub-row in Schedule CG to capture Pass Through Income/Loss in the nature of Short Term Capital Gain from Schedule PTI.

⚠️ Action Item: Companies filing ITR-6 must update their return preparation processes and ensure the new Schedule CG sub-row for pass-through income is populated correctly.


7. CBDT Corrigendum to ITR-7 Notification No. 62/2026: Schedule-wise Corrections and Amendments Explained

This corrigendum addresses cell interchange errors, omission of incorrect rows, insertion of pass-through income sub-row A(8) in Schedule CG, removal of erroneous grey shading, and critically, the substitution of "xv" with "xiv" in Schedule CYLA cross-references within Part B-TI — a change that directly impacts total income computation.

⚠️ Action Item: Trusts, political parties, and research institutions filing ITR-7 must immediately verify that their software reflects the corrected CYLA cross-reference to ensure accurate total income computation.


8. CBDT Corrigendum Refines ITR Form U Layout for Updated Return Filings

Corrigendum to Notification No. 63/2026 directs that "Wrong heads of income chosen" be displayed as a separate line immediately after "Loss not reported correctly" in Part A-General Information, row A10. This separates two distinct categories of reasons for filing an updated return.

⚠️ Action Item: Use only the latest version of Form U. Ensure the stated reason for the updated return accurately distinguishes between misreported losses and incorrect heads of income.


9. CBDT Corrigendum Notification No. 59/2026: Technical Corrections in ITR Forms for Schedule CG and Schedule OS

Three targeted corrections: a label formatting fix in Schedule CG Part B; a row reference correction from "B13a" to "B12a" in Schedule CG Part E; and removal of grey cell shading from blank columns in Schedule OS row 10(3b). Purely clarificatory, with no substantive tax computation impact.

⚠️ Action Item: Return preparation software providers should push updates incorporating these corrections before AY 2026-27 filing season commences.


10. ITAT Pune Quashes Time-Barred Reassessment for AY 2015-16: Section 148 Notice Dated April 2022 Held Void Ab Initio

In Rahul Purswani Vs ITO, the ITAT Pune held that every Section 148 notice for AY 2015-16 issued on or after April 1, 2021 is legally unsustainable, relying on the Supreme Court's ruling in Union of India v. Rajeev Bansal [2024] 469 ITR 46 (SC). The ruling also reinforces that reassessment cannot be triggered by automated portal alerts without the AO independently verifying the underlying facts.

⚠️ Action Item: Assessees who have received Section 148 notices for AY 2015-16 issued post-April 1, 2021 should immediately seek legal advice to challenge such notices as void ab initio.


11. Decoding Capital Gains Exemptions: Advanced Judicial Perspectives on Under-Construction Properties, JDAs, and Redevelopment

Courts have consistently adopted a purposive approach to Sections 54 and 54F, protecting assessees with genuine intent to reinvest in residential property — whether through under-construction purchases, Joint Development Agreements, or redevelopment projects — provided ultimate statutory deadlines are respected.

⚠️ Action Item: Assessees in JDA or redevelopment arrangements should document their bona fide reinvestment intent carefully and track all statutory completion/possession deadlines under Sections 54 and 54F.


12. Income Tax Act 2025: Key Structural Reforms and What They Mean for Assessees

The Income-tax Act, 2025 introduces a unified "Tax Year" concept, consolidates TDS under Sections 392-393, integrates VDA taxation within the main framework, and creates a dedicated NPO structure — all within a streamlined 536-section architecture aimed at clarity without changing tax rates.

⚠️ Action Item: All assessees and practitioners should begin mapping their existing compliance frameworks to the new section numbering under the Income-tax Act, 2025 to avoid disruptions.


13. Decoding the Transfer Pricing Framework Under the Income Tax Act 2025: A Comprehensive Guide for Assessees

The new TP framework under Sections 161-173 expands the definition of international transactions, consolidates AE criteria, and directly integrates safe harbours and APAs. Critically, Section 457 imposes a 2% transaction value penalty for documentation failures, and Section 170 imposes a 33.99% tax on secondary adjustments.

⚠️ Action Item: MNEs and their advisors must immediately review inter-company pricing arrangements and documentation to align with the new, more aggressive penalty regime under the Income-tax Act, 2025.


14. Priority of Section 10A Exemption Over Brought Forward Losses and Depreciation: An In-Depth Judicial Analysis

In ACPL Products Private Limited Vs ACIT, the tribunal clarified that Section 10A, being a Chapter III exemption, operates at source before loss set-off under Sections 72 and 32(2). Foreign exchange fluctuation gains in EEFC accounts were also held eligible for the Section 10A exemption.

⚠️ Action Item: Export undertakings claiming Section 10A exemptions must apply the exemption before computing gross total income and should document the nexus of EEFC account gains with export activities.


15. Understanding Profits and Gains from Business or Profession: Core Income-tax Provisions Explained

A comprehensive guide covering Sections 28-43D, methods of accounting, speculative vs. non-speculative transactions, capital vs. revenue foreign exchange variations, Section 41 deemed profits, and Section 43B payment-based deductions — with particular emphasis on MSME payment obligations.

⚠️ Action Item: Businesses should cross-check their Section 43B compliance, particularly ensuring MSME payments are made within the 45-day window to preserve deductibility.


16. ESG reporting & assurance: A powerful new practice area for Indian chartered accountants

With SEBI's BRSR and BRSR Core mandates now requiring independent assurance on ESG metrics for top listed entities, a significant and growing market is emerging for CAs who can design ESG data systems and issue assurance reports. ICAI's ESG upskilling initiatives provide a clear entry pathway.

⚠️ Action Item: CA firms should immediately assess their ESG assurance service capability and consider enrolling in ICAI's ESG training programmes to capture this emerging practice area.


🟢 GST


17. Gujarat HC: GST Proceedings Void When Notices Sent to Old Address Despite Updated GST Records

In Sachde Roadlines v. Union of India, the Gujarat High Court quashed a show cause notice, order-in-original, and appellate order because authorities had served notices to an outdated address despite the assessee having updated their address in Form GST REG-06. The Court held this violated Section 169 and principles of natural justice.

⚠️ Action Item: Every registered taxpayer must immediately verify that their current business address is accurately updated in Form GST REG-06 on the GST portal to prevent orders being passed ex-parte on incorrect service.


18. GST Portal Enhancement: Editable Pre-Deposit Percentage Introduced for Form APL-01 Appeals

Effective April 6, 2026, the GSTN has unlocked the pre-deposit percentage field in Form APL-01, replacing the rigidly auto-populated 10% mandate. This accommodates situations where prior payments were made during investigations or where demand ledger errors exist — while the appellate authority retains authority to verify the exact amount during adjudication.

⚠️ Action Item: Assessees filing GST appeals post-April 6, 2026 should carefully compute the accurate pre-deposit amount reflecting prior payments, as the burden of accurate calculation now rests entirely on the assessee.


19. Comprehensive Guide to GST on Expense Recoveries: Valuation, Pure Agent Dynamics, and Reporting Mechanisms

Under Section 15 of the CGST Act, out-of-pocket expense recoveries are absorbed into taxable value by default. The only legitimate escape is strict adherence to Rule 33's pure agent conditions. Internal staff reimbursements remain outside GST scope under Schedule III, but misclassification in either direction carries significant risk.

⚠️ Action Item: Review all expense recovery arrangements with clients against the Rule 33 pure agent checklist and ensure GSTR-1 reporting and e-invoicing data accurately reflect the true nature of each transaction.


20. CBI Trap in GST Registration Bribery Case: Key Facts and Legal Takeaways

The CBI arrested a GST Superintendent and Inspector from Ranipet Range on April 7, 2026 after a trap operation confirmed the Superintendent allegedly demanded ₹15,000 (reduced from ₹30,000) for facilitating GST registration. The Inspector reportedly attempted to destroy bribe money by flushing it, which was nonetheless recovered.

⚠️ Action Item: Assessees facing illegal demands during GST registration or other proceedings should reject such demands and report directly to the CBI. Document all interactions with tax authorities as a protective measure.


21. Cum-Tax Benefit Under Section 67(2) of Finance Act 1994: CESTAT Chennai Ruling in Real Estate Agent and Construction Service Tax Dispute

In Vedha Creations Vs Commissioner of Central Excise & Service Tax, CESTAT Chennai upheld the right to cum-tax benefit under Section 67(2) of the Finance Act, 1994 where service tax was not separately charged. The tribunal confirmed that gross consideration must be treated as tax-inclusive and that demands based solely on statutory financial records — without examining actual consideration — are impermissible.

⚠️ Action Item: Real estate and construction sector assessees facing retrospective service tax demands should proactively claim cum-tax benefit and challenge any demands not grounded in actual consideration received.


🟡 Company Law


22. How to Verify MSME Registration Status of Vendors: A Practical Compliance Framework for Finance Teams

Since no public government portal currently enables third-party MSME verification, companies must build their own framework — combining invoice screening for Udyam Registration Numbers and formal written requests to vendors with a 15–20 day response deadline. Non-responding vendors should be treated as unregistered. A structured Vendor MSME Register is essential for audit readiness.

⚠️ Action Item: Finance teams must immediately implement a dual-method MSME verification protocol and maintain a Vendor MSME Register to demonstrate compliance during audits and MSME-1 filing periods.


23. Demystifying MSME Form 1: A Deep Dive into Section 405 Compliance and MCA V3 Portal Updates

The MSME Form-1 half-yearly return under Section 405 of the Companies Act, 2013 carries aggressive daily penalties during adjudication — as evidenced in the Samsung R&D Institute India Bangalore Pvt. Ltd. case. The transition to the MCA V3 portal has expanded de facto reporting requirements, demanding hyper-accurate, real-time vendor payable aging reports.

⚠️ Action Item: Update vendor payable aging systems to real-time status and obtain Udyam Registration Certificates for all active vendors and suppliers before the next half-year end.


24. MSME-1 Half-Yearly Return: Practical Compliance Handbook for Companies under Section 405

MSME-1 becomes mandatory only when dues to Micro or Small suppliers remain unpaid for more than 45 days as on September 30 or March 31. Companies that settle all MSME invoices within 45 days, or clear overdue invoices before half-year end, are not required to file at all.

⚠️ Action Item: Prioritize clearance of all outstanding MSME vendor invoices before the next half-year end date to potentially eliminate the MSME-1 filing obligation entirely.


25. ICAI Widens Mandatory AQMM v2.0 Coverage to Group Entity Audits and Unlisted Public Companies

ICAI's revised announcement brings audit firms conducting group entity audits (holding companies, subsidiaries, associates, JVs) of listed entities, banks, and insurance companies under mandatory AQMM v2.0 from April 1, 2026. A second phase from April 1, 2027 covers firms auditing entities that raised over ₹50 Crores from public/institutional sources and other public interest entities.

⚠️ Action Item: Audit firms engaged in group entity audits of listed entities must implement AQMM v2.0 compliance infrastructure immediately ahead of the April 1, 2026 effective date.


26. MCA Drafts Major Overhaul of Company Incorporation Rules to Simplify Compliance and Digitalise Processes

The draft Companies (Incorporation) Amendment Rules, 2026 propose consolidating multiple forms into streamlined e-forms (E-CHNG and E-CON), rationalising KYC requirements, expanding SPICe+ with higher DIN limits and OTP-based director consents, and overhauling company naming rules with clearer similarity tests and trade mark conflict guidelines.

⚠️ Action Item: Company secretaries and incorporation professionals should review the draft rules and submit stakeholder comments. Begin familiarising teams with the proposed E-CHNG and E-CON form structures.


🔴 SEBI


27. SEBI Proposes Sweeping Reforms to InvIT and REIT Regulations for Greater Operational Flexibility

Four reform pillars are proposed: SPV retention post-concession expiry (with disclosure requirements), expanded liquid mutual fund investment scope (AA-rated and above), greenfield exposure alignment for privately listed InvITs (capped at 10%), and broader permissible borrowing use cases — all without diluting investor protection standards.

⚠️ Action Item: InvIT and REIT managers should assess how the SPV retention and expanded borrowing use case proposals impact their current fund structures and begin drafting internal impact analyses.


28. SEBI Move to Allow Net Fund Settlement for FPIs: What Changes for Foreign Investors and Markets?

SEBI proposes migration from gross to net fund settlement for FPIs' outright cash market transactions to reduce liquidity and funding pressures, particularly on index rebalancing days. Gross securities settlement is retained; non-outright trades remain under gross settlement. Target implementation: on or before December 31, 2026.

⚠️ Action Item: FPIs and their custodians should engage with the CDSSF consultation process on operational standards and begin systems readiness assessments for net fund settlement implementation.


29. Demystifying SEBI's Proposed 'Inoperative Fund' Regime: A Strategic Exit Pathway for Alternative Investment Funds

SEBI proposes allowing AIFs that cannot achieve nil balance due to tax disputes or legal proceedings to be designated as "inoperative funds," requiring 75% investor consent, with capital parked under Regulation 15(f) and capped operational retention at three years. This eliminates the rigid "NIL balance" barrier that previously trapped AIFs.

⚠️ Action Item: AIF managers currently facing wind-up challenges due to pending tax disputes or legal proceedings should assess eligibility for inoperative fund status and begin investor communication.


30. SEBI Moves to Cut Social Impact Fund Entry Barrier from ₹2 Lakh to ₹1,000 — What It Means for Retail Investors

SEBI proposes reducing the minimum investment threshold for individual investors in Social Impact Funds from ₹2,00,000 to ₹1,000, harmonising AIF Regulations with the ICDR Regulations following the March 2025 downward revision of ZCZP subscription minimums and broadening the Social Stock Exchange's investor base.

⚠️ Action Item: NPOs and Social Impact Fund managers should prepare for increased retail investor inquiries and ensure their investor onboarding and disclosure infrastructure can handle a wider, less sophisticated investor base.


31. Comprehensive Analysis of SEBI's Informal Guidance on Broad-Based Fund Requirements for AIFs Managed by AMCs

SEBI has confirmed that AIFs are "pooled assets" and the broad-based criteria (minimum 20 investors, no single investor holding more than 25%) must be assessed at the individual scheme level — not at the AMC or fund level. In master-feeder structures, both master and feeder funds must independently satisfy this threshold.

⚠️ Action Item: AMCs and their subsidiaries advising or managing AIFs must conduct an immediate scheme-level audit of broad-based compliance, especially in master-feeder structures.


32. SEBI Launches SUPCOMS, e-Adjudication Portal and C-SAC Platform to Digitally Transform Regulatory Operations

SEBI's March 24, 2026 launch of SUPCOMS (centralised correspondence), the e-Adjudication Portal (digitalised enforcement workflows), and C-SAC (AI-powered cybersecurity supervision) marks a major regulatory technology upgrade. Active use of all three platforms is now a direct compliance obligation for regulated entities and market intermediaries.

⚠️ Action Item: All SEBI-regulated entities must register on SUPCOMS immediately, familiarise compliance teams with the e-Adjudication Portal interface, and ensure cyber audit reports are submitted accurately on the C-SAC/SI Portal.


🟠 Customs & Trade


33. RoDTEP & RoSCTL: CBIC Clarifies Benefits on Full FOB Value Despite Short Realisation of Export Proceeds

CBIC Circular No. 20/2026-Customs dated April 10, 2026 confirms that RoDTEP and RoSCTL benefits can be computed on full FOB value provided agency commission and foreign bank charges do not exceed 12.5% of FOB value. Where export proceeds are not realised but ECGC compensation is received with RBI write-off and Indian Foreign Mission certification, such compensation qualifies as sale proceeds.

⚠️ Action Item: Exporters must review all pending RoDTEP/RoSCTL claims involving agency commissions or short realisation scenarios and quantify the impact of the 12.5% cap. Obtain necessary ECGC and RBI documentation proactively.


34. CBIC Relief Measures for SEZ Export Cargo Disrupted by Strait of Hormuz Closure

CBIC Circular No. 19/2026-Customs dated April 10, 2026, invoking Section 143AA of the Customs Act, 1962, eliminates the requirement to physically return stranded cargo to originating SEZs by enabling fully digital communication between gateway ports and SEZs for LEO cancellations, de-stuffing permissions, and bonded warehouse storage.

⚠️ Action Item: SEZ exporters with cargo stranded due to the Strait of Hormuz closure must act swiftly to leverage digital relief mechanisms before the deadline under this circular. Contact gateway port officials immediately to initiate the digital process.


35. Extension of Minimum Export Price for Natural Honey: DGFT Mandates USD 1400/MT Limit Until December 2026

DGFT Notification No. 09/2026-27 dated April 10, 2026 extends the Minimum Export Price for natural honey (ITC HS Code 04090000) at USD 1,400 per Metric Ton FOB from March 31, 2026 to December 31, 2026.

⚠️ Action Item: All exporters of natural honey must immediately verify that active and upcoming contracts are priced at or above USD 1,400 FOB per MT and update internal billing and shipping documentation accordingly.


36. DGFT Relaxes EIC Inspection Norms for Rice Exports to Select European Destinations

Notification No. 07/2026-27 dated April 10, 2026 confines the mandatory EIC/EIA Certificate of Inspection requirement for rice (HSN 1006) to EU Member States and five specified countries (UK, Iceland, Liechtenstein, Norway, Switzerland). For all other European destinations, the EIC/EIA requirement is suspended for six months from April 10, 2026 to October 1, 2026.

⚠️ Action Item: Rice exporters targeting non-EU European markets should check whether their destination falls outside the five specified countries and, if so, proceed without an EIC/EIA certificate for the six-month window while honoring any contractual obligations with buyers.


37. DGFT Announces Deadline Extension for FY 2026-27 TRQ Applications Under India-Mauritius CECPA and India-Nepal Trade Agreements

Public Notice No. 03/2026-27 extends the deadline for online Tariff Rate Quota applications for FY 2026-27 under the India-Mauritius CECPA and India-Nepal Treaty to April 25, 2026. The framework covers agriculture, marine products, textiles, and industrial metals, with strict quantitative limits and source conditionalities.

⚠️ Action Item: Importers under India-Mauritius CECPA and India-Nepal Treaty must submit TRQ applications through the official DGFT portal before April 25, 2026. Verify IEC validity and compliance with all Appendix-2A conditions before submission.


38. CBIC: Customs Duty Refunds and the Unjust Enrichment Doctrine: Statutory Framework, Judicial Precedents, and Practical Guidance for Exporters

Under Section 27 of the Customs Act, 1962, no customs duty refund is available to claimants who have already recovered the duty cost through pricing arrangements. Export refund claims are further complicated by a presumption of duty pass-through where FOB values diverge from actual export realisations, as confirmed in M/s. Sesa Sterlite Ltd.

⚠️ Action Item: Exporters filing customs duty refund claims must maintain meticulous documentation establishing non-pass-through of duty to buyers — mere assertions will not suffice. Review commercial documents proactively.


39. DGFT Notification No. 08/2026-27: Revised Export Compliance Requirements for Feathers, Skins and Related Products Under Chapter 5

Notification No. 08/2026-27 dated April 10, 2026 inserts Policy Condition 5 under Chapter 5 of ITC(HS) 2022, requiring mandatory consignment-specific Veterinary Certificates or Shipment Clearance Certificates from CAPEXIL before export, and post-shipment Production Process Certificates or Veterinary Health Certificates to buyers, for ITC(HS) codes 05051090, 05059029, and 05059099.

⚠️ Action Item: Exporters of feathers, skins and related products must immediately register with CAPEXIL and establish pre-shipment certification workflows compliant with EU/UK veterinary standards.


40. DGFT Opens Import Quota Applications for Petroleum Coke: CPC and RPC Allocation Framework for FY 2026-27

DGFT Public Notice No. 02/2026-27 establishes import allocations of 0.8 million MTs for Calcined Petroleum Coke (aluminium sector) and 1.9 million MTs for Raw Petroleum Coke (CPC manufacturing sector) for FY 2026-27. Applications are strictly online through the DGFT portal with a deadline of April 20, 2026.

⚠️ Action Item: Aluminium and CPC manufacturers must submit their import quota applications through the DGFT portal before April 20, 2026, ensuring all prior utilisation history, capacity certificates, and MoEF&CC-aligned environmental undertakings are in order.


🟣 FEMA / RBI / Banking


41. RBI Updates Framework for Non-Resident Investment in Indian Debt: Key Features of the 2025 Directions and 2026 Amendment

The April 10, 2026 amendment to RBI's Master Direction on Non-resident Investment in Debt Instruments consolidates the General Route, VRR, and FAR frameworks, clarifies FPI access to Government and corporate debt including Sovereign Green Bonds, and assigns clear responsibilities to AD Category-I banks, custodians, CCIL, and depositories.

⚠️ Action Item: FPIs, NRIs, and their custodians should review the updated Master Direction in detail and map all existing investment positions against the revised maturity, short-term, issue-wise, and concentration caps.


42. IFSCA Regulatory Update: Mandatory Prior Approval for PSPs in Rupee Drawing Arrangements

The April 10, 2026 IFSCA directive makes prior approval mandatory for Payment Service Providers wishing to participate in the Rupee Drawing Arrangement (RDA), linking approval to RBI's January 1, 2016 Master Direction and 2022 AML/CTF/KYC guidelines. Only vetted non-resident exchange houses may process international remittances under this framework.

⚠️ Action Item: PSPs currently operating or seeking to operate under the RDA must immediately review the April 10, 2026 IFSCA directive, initiate the prior approval process, and assess their AML/CTF/KYC infrastructure against the 2022 guidelines.


43. RBI's Strategic Blueprint to Neutralize Digital Payment Frauds: A Comprehensive Analysis of Proposed Safeguards

RBI's discussion paper proposes four major safeguards: a one-hour transaction delay for transfers exceeding ₹10,000; a mandatory trusted secondary authenticator for transfers over ₹50,000 by vulnerable demographics; a ₹25 lakh cap on unverified annual account credits with a 30-day shadow credit system; and a universal digital "kill switch" enabling instant lockdown of all digital payment channels.

⚠️ Action Item: Stakeholders — including banks, fintechs, and payment service providers — must submit comments to RBI before May 8, 2026. Begin assessing the technical infrastructure changes required for the proposed controls.


44. RBI's 2026 Draft Rules on NBFC-UL: Asset Size Benchmark, Government NBFC Coverage & State Guarantee Treatment

RBI's 2026 draft amendment replaces the earlier parametric scoring model for NBFC-UL classification with a simple ₹1,00,000 crore asset threshold, subject to five-yearly review. Government-owned NBFCs will be evaluated on the same footing, and State Government guarantees attract a 20% risk weight without quantitative caps.

⚠️ Action Item: NBFCs with assets approaching the ₹1,00,000 crore threshold should model the regulatory and capital implications of potential NBFC-UL classification and engage with the RBI consultation process.


45. Supreme Court Rules Against Mandatory Personal Hearing Before Bank Fraud Account Classification

In State Bank of India Vs Amit Iron Private Limited & Ors., the Supreme Court clarified that Rajesh Agarwal confers no right to a personal/oral hearing before fraud account classification. What is mandated is a detailed show cause notice, a minimum 21-day response window, genuine consideration of submissions, and a reasoned order.

⚠️ Action Item: Borrowers facing fraud account classification proceedings must respond comprehensively and in writing within the 21-day window. Preserve all written submissions as judicial review of personal hearing denials is now foreclosed.


46. IFSC Fund Schemes: New IFSCA Rules on Independent Fiduciaries and Conflict-Free Governance

IFSCA's April 10, 2026 circular prohibits Fund Management Entities from appointing a fiduciary that also provides fund administration, valuation, audit, or lending services (directly or through associates) to the same scheme. Existing schemes must comply by September 30, 2026; new schemes must comply from inception.

⚠️ Action Item: FMEs with existing IFSC fund schemes must immediately audit fiduciary arrangements for conflicts of interest and restructure contracts to ensure compliance well before the September 30, 2026 deadline.


47. RBI Designates Union Bank of India as Lead Bank for Newly Created Andhra Pradesh Districts – Polavaram and Markapuram

Following Andhra Pradesh's December 30, 2025 gazette notifications creating Polavaram (code 02X) and Markapuram (code 02Y) districts, RBI has designated Union Bank of India as Lead Bank for both districts under the Lead Bank Scheme. No changes have been made to Lead Bank responsibilities for any other existing district.

⚠️ Action Item: Financial institutions and credit planners operating in the Polavaram and Markapuram regions should update their district-level coordination and reporting structures to align with Union Bank of India's lead bank designation.


⚖️ Insolvency & Restructuring


48. Supreme Court Mandates Strict "Same Line of Business" Test for Multi-State Co-operative Societies Submitting Resolution Plans Under IBC

In Nirmal Ujjwal Credit Co-Operative Society Ltd. Vs Ravi Sethia & Ors., the Supreme Court held that Section 64(d) of the Multi-State Co-operative Societies Act, 2002 prohibits cooperative societies from acquiring businesses outside their registered objects under CIRP. The "same line of business" test is a qualitative legal test based on registered object clauses, not revenue streams.

⚠️ Action Item: Multi-state cooperative societies considering participation in CIRP processes must obtain a detailed legal review of their object clauses before submitting resolution plans, and resolution professionals must include this review as part of applicant vetting under Section 30(2)(e) of the IBC.



49. Corporate Cryptocurrency Holdings in India: Legal Gaps After Rhutikumari vs Zanmai Labs and Lessons from El Salvador

Rhutikumari v. Zanmai Labs Pvt Ltd is the first Indian judicial acknowledgment that cryptocurrencies constitute "property" under civil law. However, the Companies Act, 2013, IBC, 2016, tax statutes, and accounting standards still lack a comprehensive framework for corporate VDA holdings, creating significant legal uncertainty.

⚠️ Action Item: Companies holding or planning to hold cryptocurrencies should document their VDA positions carefully, establish board-approved policies, and monitor legislative developments closely given the current regulatory vacuum.


50. Chhattisgarh High Court Upholds Life Imprisonment in POCSO Rape-Murder Case: DNA Evidence Sufficient for Conviction

In CRA No. 614 of 2023, the Chhattisgarh High Court upheld life imprisonment under Sections 302, 376(AB) IPC and Section 6 POCSO Act, 2012, confirming that DNA profiling supported by medical findings and an extra-judicial confession is sufficient to establish guilt beyond reasonable doubt — even without a firmly established "last seen together" theory.

⚠️ Action Item: For legal practitioners: note the Court's clear affirmation of the evidential sufficiency of DNA evidence in POCSO cases and its guidance on the cumulative weight of circumstantial evidence in heinous crime prosecutions.


📅 Key Deadlines & Action Items

Deadline Compliance Requirement Authority
April 20, 2026 Petroleum Coke (CPC/RPC) import quota applications for FY 2026-27 DGFT Portal
April 25, 2026 TRQ applications under India-Mauritius CECPA and India-Nepal Treaty for FY 2026-27 DGFT Portal
April 27, 2026 CBDT affidavit on remedial measures for ITR utility release delays (Gujarat HC order) CBDT / Gujarat HC
May 8, 2026 Stakeholder comments on RBI's digital payment fraud safeguards discussion paper RBI
March 31, 2026 → December 31, 2026 Minimum Export Price for natural honey at USD 1,400/MT FOB (extended) DGFT
April 10, 2026 → October 1, 2026 EIC/EIA Certificate of Inspection suspension for rice exports to non-specified European destinations DGFT
March 31, 2027 Expiry of all petroleum coke import authorisations issued under Public Notice 02/2026-27 DGFT
April 1, 2026 (effective) AQMM v2.0 mandatory for audit firms auditing group entities of listed companies, banks, and insurers ICAI
April 1, 2027 (effective) AQMM v2.0 mandatory for firms auditing entities with >₹50 Cr public/institutional funding ICAI
September 30, 2026 IFSC fund schemes must restructure fiduciary arrangements to eliminate conflicts of interest IFSCA
December 31, 2026 SEBI's net fund settlement for FPIs target implementation deadline SEBI/CDSSF
Half-year end (Sept 30 / Mar 31) MSME-1 filing trigger: dues to Micro/Small vendors unpaid beyond 45 days MCA

💡 Professional Takeaways

1. The ITR Form Corrigendum Cascade Demands Immediate Software Action
CBDT has issued seven corrigenda in a single day (Notifications 57–63/2026) correcting technical errors across ITR-1, ITR-2, ITR-4, ITR-5, ITR-6, ITR-7, and Form U. While none alter substantive tax positions, several corrections — particularly the Schedule CYLA cross-reference fix in ITR-7 and the new pass-through income sub-rows in ITR-6 and ITR-7 Schedule CG — directly affect total income computation and AIF income reporting. Tax professionals must treat these not as minor administrative updates but as urgent schema changes requiring immediate action from software vendors. Practices that rely on manual templates face the highest risk of filing errors in the AY 2026-27 season.

2. MSME Compliance Has Moved from Advisory to Enforcement Territory
The convergence of three detailed MSME compliance articles today — covering vendor verification, Form MSME-1 mechanics, and Section 405 obligations — reflects a broader regulatory pattern. The Samsung R&D Institute adjudication case signals active MCA monitoring and aggressive daily penalties. With no public government portal for third-party MSME status verification, companies that have not yet built their own Vendor MSME Register are already behind the compliance curve. Finance teams should treat the 45-day payment rule as a hard operational constraint rather than a soft guideline.

3. India's Regulatory Technology Infrastructure Is Transforming Compliance Obligations
Three separate developments today signal that "filing and forgetting" is no longer an option for regulated entities. SEBI's launch of SUPCOMS, e-Adjudication Portal, and C-SAC creates new registration and reporting obligations for market intermediaries. GSTN's editable pre-deposit field in APL-01 shifts computational burden squarely onto the assessee. IFSCA's digital-first mandatory prior approval process for PSPs in the RDA framework closes regulatory gaps with real enforcement teeth. Professionals who proactively engage with these new digital platforms will be better positioned than those who wait for enforcement action to prompt engagement.


This digest is prepared by TaxCorp India for informational purposes. All articles are original TaxCorp content. For detailed analysis, click the article links above. This digest does not constitute legal or tax advice.

© 2026 TaxCorp India | thetaxcorp.in

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