During 20–26 October 2025, several regulatory updates were issued across multiple sectors. In Income Tax, the India–Qatar DTAA & Protocol was notified, and CBDT issued guidance on entertainment sector expenses, including pre-operative costs and Form 52A reporting. Delhi High Court rulings emphasized that blanket approvals of assessments under Section 153D are invalid and that AMP expenses do not constitute international transactions. Under GST, amendments clarified the definition of ‘Nominated Agency’ and rulings addressed ITC eligibility on capital goods outside the factory, share buyback expenses, product classifications for Tapioca Flour, cotton pyjamas, and cotton seed de-oiled cake, and commercial status of service apartments. The Supreme Court barred bank account attachments after pre-deposit in GST appeals. No Central Excise notifications were issued. Customs saw amendments in key notifications, revised duty rates, and Malur, Karnataka, designated as a new Customs Station. DGFT modified import policies for synthetic fabrics, pesticides, and chemicals, amended export obligations for Advance Authorizations, and reinstated SION C676 for galvanized rods. SEBI released guidance on PMS transfers, geo-tagging relaxation for NRI clients, KYC for MF folios, and timelines for unclaimed amounts under LODR. MCA issued no updates, while IBBI/NCLAT clarified that IBBI cannot issue general circulars recommending bans and is not required to create records under RTI. RBI updated UNSC sanctions compliance, issued draft directions for capital market exposures by banks and NBFCs, and proposed mandatory Unique Transaction Identifier for OTC derivatives. Miscellaneous updates include the Supreme Court ruling on repudiation of guardian sales by minors.
Notifications & Circulars issued during week (20th– 26th Oct 2025)
(Income Tax, GST, Central Excise, Custom Duty, DGFT, SEBI, MCA, IBBI, RBI)
(Click the Link for Notification/ Circular as issued)
A. Income Tax
Government notified the India–Qatar DTAA & Protocol: CBDT has notified the Agreement and Protocol between Republic of India and State of Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
(Link: Income Tax Notification 154/2025 Dated 24/10/2025)
CBDT Guidance on Entertainment Sector expenses following C&AG audit: The guidance relates to examining expenses in various segments of the entertainment sector, including television, radio, music, event management, films, animation and visual effects, broadcasting, sports, and amusement. A key focus area identified is the treatment of pre-operative expenses, incurred before the commencement of business. AOs are advised to examine such expenses in line with Section 35D for their eligibility for amortisation. Another area of guidance pertains to the declaration of expenses in feature film production. Assessees are required to submit Form No. 52A within thirty days from either the end of financial year or film completion date, whichever is earlier.
(Link: Income Tax CBDT Communication Dated 21/10/2025)
HC, Rubber-Stamp approval of 246 assessments struck down: Case of PCIT vs Ashutosh Developers Pvt Ltd, HC Delhi Judgement Dated 15th October 2025. The ITAT had found that the Additional CIT had accorded a blanket approval for 246 assessment orders by a single letter stating: “The above draft orders, as proposed, are hereby accorded approval with the direction to ensure that the orders are passed well before limitation period.” The Tribunal, relying on the legislative intent behind Section 153D and CBDT Circular held that such an approval defeats the object of ensuring supervisory application of mind by a higher authority in search-related assessments, thus invalid in law. The HC also dismissed the revenue appeal and held that approvals under Section 153D must be case-specific and demonstrate conscious satisfaction. Mass approvals covering dozens of assessments through one letter are invalid.
HC, AMP expenditure not an International Transaction: Case of PCIT vs Casio India Company Pvt Ltd, HC Delhi Judgement Dated 9th October 2025. The HC agreed with the Tribunal that the Advertisement, Marketing, and Promotion (AMP) expenses are not a separate international transaction in this context and therefore no upward adjustment to income was required.
B. GST
Amendment in definition of ‘Nominated Agency’: The Notifications amends existing notifications i.e. CGST 26/2018 (Rate), IGST 27/2018 (Rate), UTGST 26/2018 (Rate), related to GST exemptions or concessional rates. The key change is the substitution of Clause (c), which defines ‘Nominated Agency’. The term ‘Nominated Agency’ will now mean entities listed in Lists 13, 14, and 15 appended to Table I of Customs Notification No. 45/2025 dated 24th October 2025. It will ensures consistency in the identification of these agencies across the indirect tax framework.
(Link: CGST Notification 18/2025 (Rate) Dated 24/10/2025, IGST Notification 18/2025 (Rate) Dated 24/10/2025, UTGST Notification 18/2025 (Rate) Dated 24/10/2025,)
AAAR upholds ITC eligibility for Power Line Capital Goods installed Outside Factory: Case of AC CGST & CE vs Elixir Industries, AAAR Gujarat Ruling Dated 22nd September 2025. AAAR held that Input Tax Credit (ITC) is admissible on capital goods such as wires, cables, and electrical equipment used for power transmission from the grid to the factory, even if installed outside factory premises and subsequently transferred to Gujarat Energy Transmission Corporation Ltd. (GETCO) for maintenance, provided the conditions under Section 16 of the CGST Act, 2017 are met. It upheld the prior Advance Ruling allowing ITC to the Respondent.
AAAR, GST ITC denied on expenses for company Share Buyback: Case of Gujarat Narmada Valley Fertilizers & Chemicals Ltd, AAAR Gujarat Ruling Dated 22nd September 2025. AAAR held that Input Tax Credit (ITC) is not admissible on expenses incurred for the buyback of shares, as shares being ‘securities’ do not qualify as goods or services under the GST law, and hence the transaction falls outside the ambit of GST. It dismissed the appeal and upheld AAR Ruling.
AAR, Tapioca Flour classifiable under HSN 23031000: Case of Perumal Vasudevan, AAR Tamil Nadu Ruling Dated 8th October 2025. AAR emphasized that the origin of the product as a residue of starch manufacture dictates its classification over its perceived commercial identity or historical tax treatment. It ruled that the applicant is required to classify its traded ‘Tapioca Flour’ or ‘Thippi’ under HSN 2303 1000 and discharge 5% GST on its supplies, mandating the company’s registration under the GST Act. As the said product is classified under 2303 1000, the exemption provided under Notification 02/2017 dated 28th June 2017 is not applicable to the applicant.
AAR, Mens Cotton Pyjama Sets classified under HSN 620721, 5% GST applicable for Packs Under Rs 1000: Case of Link Up Textiles Private Limited, AAR Tamil Nadu Ruling Dated 8th October 2025. AAR ruled that Men’s Pyjama Sets consisting of woven Shirt and woven Pant made of cotton is to be classified under HSN code 620721. GST rate of tax applicable for 2 Pyjama sets packed in a single pack and costing less than Rs.1,000 per piece or set will be 5% as per serial number 223 of Schedule I of Notification 01/2017 (Rate) dated 28th June 2017.
AAR, Cotton Seed De-oiled Cake (HSN 23061020) exempt from GST: Case of Gupta Feed Products Private Limited, AAR WB Ruling Dated 17th October 2025. AAR ruled that Cotton seed de-oiled cake (HSN 23061020) is exempt from tax irrespective of its use.
Service Apartments are Commercial for GST: Case of SRIPSK Developers LLP, AAR WB Ruling Dated 17th October 2025. AAR ruled that the Service Apartment being constructed by the applicant will fall under construction service of commercial buildings.
SC bars Bank Account attachments after 10% GST Pre-Deposit: Case of Deputy Commissioner vs Wingtech Mobile Communications (India) Limited, SC Judgement Dated 6th October 2025. The apex court held that the Revenue cannot continue to attach or restrain a taxpayer’s bank accounts under the GST Act once the appellate pre-deposit has been made. It upheld the AP High Court judgment granting relief to the assessee.
C. Central Excise
No Notification/ Circular during the Week.
D. Custom Duty
Amendments to Key Customs notifications: The notification amends specific entries across various prior notifications to ensure consistency and updated applicability. It affects the notifications governing customs exemptions and procedural frameworks, including notification 11/2018, 8/2020, 11/2021, 52/2017 and others.
(Link: Customs Notification 44/2025 (T) Dated 24/10/2025)
Revision of Customs Duty, IGST & Cess Rates: The notification seeks to supersede 31 customs exemption notifications and prescribes effective rates of customs duty, IGST and compensation cess for goods imported into India.
(Link: Customs Notification 45/2025 (T) Dated 24/10/2025)
Malur, Karnataka designated as a New Customs Station: The notification designates Malur in Kolar District, Karnataka, as a Customs Station. It permits the location to be used for the unloading of imported goods and the loading of export goods or any specified class of such goods.
(Link: Customs Notification 66/2025 (NT) Dated 23/10/2025)
E. Directorate General of Foreign Trade (DGFT)
Amendments in MIP on Synthetic Knitted Fabrics for Specific GSM: The notification amends the import policy for Synthetic Knitted Fabrics under ITC (HS) 60053600. The import policy for this specific code remains ‘Restricted’ but permits ‘Free’ import if the CIF value is as per existing Minimum Import Price (MIP) condition. It also introduces an exemption i.e. the MIP condition no longer applies to fabrics falling within the 28 to 48 grams per square meter (GSM) weight range.
(DGFT Notification 46/2025 Dated 21/10/2025)
Amendments to Import Policy for Pesticides, Chemicals: The notification amends the import policy conditions for specific items listed under Chapters 29 and 38 of the ITC (HS), Schedule I (Import Policy). The government modified import requirements for a range of chemicals and pesticides, including bifenthrin, glufosinate, glyphosate, emamectin benzoate, and others. The import of several pesticide-related products is now subject to registration and certification from the Central Insecticides Board and Registration Committee (CIB&RC). Also, the import of ‘Glufosinate and its salts’ with a CIF value below ₹1,289 per kg has been classified as ‘Restricted’, while imports with a CIF value of ₹1,289 or above per kg remain ‘Free’.
(DGFT Notification 45/2025 Dated 15/10/2025)
Amendments in Export Obligation Rules for Advance Authorisation: The Public Notice amends Para 4.84(b) of HBP, concerning the Export Obligation (EO) period under the Advance Authorisation (AA) Scheme. Under the amended procedure, the general EO period remains 120 days from the date of import for each consignment. However, for findings and mountings made of gold, platinum, or silver used for the export of jewellery, the EO period is extended to 180 days from the date of import.
(DGFT Public Notice 28/2025 Dated 23/10/2025)
DGFT reinstates and amends SION C676 for Galvanised Rods: The Public Notice reinstate and amend the suspended Standard Input Output Norms (SION) C676 for the export of ‘HOT DIPPED GALVANISED TENSION BAR/ GATE RODS/ TRUSS RODS/ DROP RODS’. It specifies the permissible inputs and wastage allowance for exporting 1000 Kgs of the finished product. The allowed imported inputs include RE-ROLLABLE SCRAP/BILLET CUTTINGS, MS BILLETS/BLOOMS, or NON- ALLOY STEEL WIRE RODS, with a wastage allowance of 1.10 per KG of the net weight of the ungalvanized steel content in the final product.
(DGFT Public Notice 27/2025 Dated 23/10/2025)
F. Securities and Exchange Board of India (SEBI)
Transfer of portfolios of clients (PMS business) by Portfolio Managers: The a circular simplifies the process for the transfer of Portfolio Management Service (PMS) business between Portfolio Managers (PMs). If the transfer is between PMs belonging to the same group, the transferor has the option to shift select Investment Approaches or the entire business, however a complete transfer necessitates surrendering the transferor’s registration within 45 working days. For transfers between PMs not belonging to the same group, a joint application for approval must be submitted, but only the complete PMS business can be transferred. The transferee must provide an undertaking accepting all future liabilities, pending actions, and obligations against the transferor.
(Link: SEBI Circular Dated 24/10/2025)
Draft Circular on Relaxation of India geo-tagging for NRI client re-KYC/KYC modification: The proposals intend to relax the India geo-tagging requirement for Non- Resident Indian (NRI) clients undergoing digital re-KYC or KYC modification processes through the Video Client Identification Process (V-CIP). The current Master Circular on KYC mandates geo-location tagging to ensure the physical location of the client is in India during digital on-boarding. The proposed modification allows existing NRI clients to complete their re-KYC/KYC modification digitally even when they are outside India. However, V-CIP application must still capture the GPS location (latitude and longitude) of the client and verify that it matches the country provided in client Proof of Address.
(Link: SEBI Draft Circular Dated 23/10/2025)
Consultation Paper on standardization of process for opening new Mutual Fund (MF) folios and execution of first investment: Currently, Asset Management Companies (AMCs) process an investment and open a folio after their internal checks, even as the formal Know Your Client (KYC) verification by the KYC Registration Agency (KRA) is pending. This sequential method has led to instances where folios are later marked as KYC non-compliant due to KRA-identified discrepancies, preventing investors from executing future transactions or receiving redemptions/dividends accurately. The proposed change mandates that the first investment in a new folio will only be permitted after the KRA has successfully completed the KYC verification and the folio is officially marked as KYC compliant in the KRA system.
(Link: SEBI Consultation Paper Dated 23/10/2025)
Consultation paper for review of LODR Regulations regarding the timeline for transfer of unclaimed amount by entity having listed non-convertible securities: Currently, the LODR Regulations require any unclaimed amount held in an escrow account for seven years to be transferred. However, Section 125(2) of the Companies Act mandates that unclaimed debentures and interest be transferred to IEPF only after seven years from the debenture’s maturity date. SEBI proposes an amendment stating that the transfer to the IEPF or IPEF will occur in the manner prescribed under Section 125 of the Companies Act, i.e. effectively after seven years from the maturity date.
(Link: SEBI Consultation Paper Dated 24/10/2025)
G. Ministry of Corporate Affairs (MCA)
No Notification/ Circular during the Week.
H. Insolvency and Bankruptcy Board of India (IBBI)
NCLAT, IBBI not empowered to issue general circular recommending ban of Resolution Professional: Case of Manish Jaju Erstwhile Resolution Professional of Rajesh Landmark Projects Private Limited vs Committee of Creditors of Rajesh Landmark Projects Private Limited, NCLAT Delhi Judgement Dated 18th September 2025. The appellant tribunal held that Insolvency and Bankruptcy Board of India (IBBI) is not empowered to issue a general circular referring power conferred under section 34(4)(b) recommending that IP other than IRP/RP may be appointed as liquidator.
IBBI not required to interpret or clarify records: The appellant sought details regarding the corporate insolvency resolution process (CIRP) of Micro Dynamics Pvt. Ltd, including the receipt and upload dates of the admission order and constitution of the Committee of Creditors (CoC). The CPIO stated that this information was not held by the Board. The Appellate Authority noted that under Section 2(f) of the RTI Act, a public authority is not required to create new information, and the requested data was not in the possession or control of the IBBI. It observed that communications between the resolution professional and the Board contain commercial information whose disclosure could harm competitive positions. Consequently, such information is exempt under Section 8(1)(d) of RTI Act. The appeals were disposed of without ordering additional disclosure.
(Link: IBBI FAA Order Dated 23/10/2025)
I. Reserve Bank of India (RBI)
Updates on UNSC Sanctions List Under UAPA Compliance: MEA has informed about the UNSC amendments on its ISIL (Da’esh) and Al-Qaida Sanctions List of individuals and entities, which are subject to the assets freeze, travel ban and arms embargo. Regulated Entities (REs) are advised to take note for necessary compliance in terms of Master Directions on KYC.
(Link: RBI Notification 93/2025 Dated 23/10/2025)
Updates on UNSC Sanctions List Under UAPA Compliance: MEA has informed about the UNSC amendments on its ISIL (Da’esh) and Al-Qaida Sanctions List of individuals and entities, which are subject to the assets freeze, travel ban and arms embargo. Regulated Entities (REs) are advised to take note for necessary compliance in terms of Master Directions on KYC.
(Link: RBI Notification 94/2025 Dated 24/10/2025)
Draft RBI Commercial Banks- Capital Market Exposure Directions: Capital market exposures (CME) by regulated entities (REs) carry higher risk and are therefore subject to sectoral exposure limits, purpose-specific lending caps, and loan-to-value (LTV) ratios. CME includes both direct exposures (investments in securities) and indirect exposures (lending against securities, financing to capital market intermediaries like stockbrokers and custodians). The existing guidelines have been reviewed to align with evolving market practices and provide a more enabling framework for bank financing of CME. The feedback and comments from stakeholders are invited.
(Link: Draft Directions Dated 24/10/2025, Press Release)
Draft RBI Small Finance Banks- Capital Market Exposure Directions: Capital market exposures (CME) by regulated entities (REs) carry higher risk and are therefore subject to sectoral exposure limits, purpose-specific lending caps, and loan-to-value (LTV) ratios. CME includes both direct exposures (investments in securities) and indirect exposures (lending against securities, financing to capital market intermediaries like stockbrokers and custodians). The existing guidelines have been reviewed to align with evolving market practices and provide a more enabling framework for bank financing of CME. The feedback and comments from stakeholders are invited.
(Link: Draft Directions Dated 24/10/2025, Press Release)
Draft RBI Non-Banking Financial Company- Scale Based Regulation Directions: The Reserve Bank had issued RBI Non-Banking Financial Company- Scale Based Regulation Master Directions in 2023. Based on a review, it is proposed to amend certain provisions relating to the applicable risk weights for infrastructure exposures of NBFCs. The feedback and comments from stakeholders are invited.
(Link: Draft Directions Dated 24/10/2025, Press Release)
Draft Circular on Unique Transaction Identifier for OTC Derivative Transactions in India: Unique Transaction Identifier (UTI) is one of the key data elements identified globally for reporting of OTC derivative transactions, along with the Legal Entity Identifier (LEI). While the LEI uniquely identifies the counterparties to an OTC derivative transaction, the UTI serves as a single unique reference number for a transaction. In India, LEI has already been implemented. It is now proposed to mandate UTI for all OTC derivative transactions. The feedback and comments from stakeholders are invited.
(Link: Draft Directions Dated 23/10/2025 and Press Release)
J. Miscellaneous
SC, Minor can repudiate Guardian’s unauthorized sale by conduct: Case of KS Shivappa vs Smt K Neelama, SC Judgement Dated 7th October 2025. A minor, on attaining majority, need not necessarily file a suit to cancel a voidable sale executed by his guardian without court permission. Such sale can be validly repudiated by unequivocal conduct within limitation, such as by executing a fresh sale. The Court clarified that earlier decisions did not lay down that a suit is the only way to repudiate a voidable transaction. The apex court held minors subsequent sale to KS Shivappa constituted valid repudiation of the guardian’s earlier voidable sale.
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Compiled by: CMA Yash Paul Bhola, MBA, FCMA, Former Director (Finance), National Fertilizers Limited.
Disclaimer: The contents of this article are for informational purposes only. The user may refer to the relevant notification/ circular/ decisions issued by the respective authorities for specific interpretation and compliances related to a particular subject matter)
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