The week of September 22-28, 2025, saw significant regulatory updates across multiple domains. In Income Tax, the CBDT extended the Tax Audit Report filing deadline for A.Y. 2025-26 to October 31, 2025. The Supreme Court clarified that a violation of Section 269SS (cash loans above ) only attracts a penalty and does not render the underlying transaction unenforceable under the Negotiable Instruments Act. For GST, the Finance Ministry formally launched the GST Appellate Tribunal (GSTAT), introducing a staggered electronic filing schedule for appeals. The CBIC clarified that a third-party warehouse used for supplies functions as a ‘place of business’ requiring separate GST registration. Furthermore, the GSTN advised taxpayers that a statutory time limit of three years will soon be enforced, barring the filing of returns that are more than three years overdue. In Customs, the held that levy of export duty on goods supplied from the Domestic Tariff Area (DTA) to a Special Economic Zone (SEZ) is not justifiable. Finally, the RBI mandated that all domestic digital payment transactions must now use at least two factors of authentication, with one being dynamic, and streamlined the procedure for settling claims of deceased customers.
Notifications & Circulars issued during week (22nd- 28th Sep 2025)
(Income Tax, GST, Central Excise, Custom Duty, DGFT, SEBI, MCA, IBBI, RBI)
(Click the Link for Notification/ Circular as issued)
A. Income Tax
Exemptions to Real Estate Regulatory Authority of Rajasthan, Jaipur: Real Estate Regulatory Authority of Rajasthan, Jaipur, an Authority constituted by the Rajasthan State Government, has been notified under section 10(46) for exemption on its income arising from amount received as Grant in aid or loan/advance from Government, Fees / penalty, and interest on bank deposits.
(Link: Income Tax Notification 148/2025 Dated 22/09/2025)
Exemptions to High Court Legal Services Committee: High Court Legal Services Committee, an Authority constituted by the State Authority, Union Territory, Chandigarh in consultation with the Chief Justice of the High Court of Punjab and Haryana under the Legal Services Authority Act 1987, has been notified under section 10(46) for exemption on its income arising from amount received as Grant from Central Government, State Government for purpose of Legal Services, Costs imposed by P&H High Court, and interest on bank deposits.
(Link: Income Tax Notification 149/2025 Dated 22/09/2025)
Tax Audit Report filing deadline extended to 31st October 2025: CBDT has decided to extend the specified date for filing various audit reports for the Previous Year 2024–25 (Assessment Year 2025–26), from 30th September 2025 to 31st October 2025, for assessees referred to in Explanation 2(a) of section 139(1) of the Act.
(Link:Income Tax Circular 14/2025, Press Release Dated 25/09/2025)
SC, Cash Loans above Rs 20,000 Enforceable despite section 269SS Violation: Case of Sanjabij Tari vs Kishore S Barcor, SC Judgement Dated 25th September 2025. The court viewed that any breach of Section 269SS, is subject to a penalty only under Section 271D of the Income Tax Act. Further neither Section 269SS nor 271D state that any transaction in breach thereof will be illegal, invalid or statutorily void. Therefore, any violation of Section 269SS would not render the transaction unenforceable under Section 138 of the Negotiable Instruments Act.
HC, Material from internet is not Cogent Evidence: Case of CIT vs Hamdard Laboratories, HC Delhi Judgement Dated 10th September 2025. HC held that Assessing Officer is required to bring on record cogent evidence to justify the invocation of Section 13 of the Income Tax Act to deny exemption. Notably, material collected from the internet cannot be termed as corroborative piece of evidence. The writ of revenue is dismissed.
B. GST
Communication to taxpayer through eOffice- requirement of Document Identification Number (DIN): CBIC has clarified that a new online utility has been developed at https://verifydocument.cbic.gov.in, which allows for the online verification of the unique ‘Issue number’ ,generated by CBIC’s eOffice application. It is stated that for communications dispatched using the public option in the eOffice application, the verifiable ‘Issue number’ will now be considered as the DIN. It further specified that the DIN must still be used on all other communications that do not possess either an eOffice Issue number or a verifiable Reference Number (RFN) from the GST common portal.
(Link: CGST Circular 252/2025 Dated 23/09/2025)
CBIC clarifies Place of Supply Rules for Goods Stored in Third-Party Warehouses: The clarification confirms that if a business entity, whose principal place of business is in Delhi, uses a warehouse or cold storage in Haryana to make taxable supplies to recipients, that facility in Haryana functions as a ‘place of business’ and necessitates a separate GST registration in Haryana. The fact that the cold storage is operated by a third party does not alter this requirement if supplies originate from that location. Furthermore, establishments in different states under the same PAN are treated as ‘distinct persons’, meaning the movement of goods between the Delhi and Haryana locations constitutes a taxable supply requiring a tax invoice and appropriate GST payment. Supplies made from the Haryana warehouse to customers within Haryana are treated as intra-State supplies and subject to Haryana’s CGST and SGST.
(Link: CGST CBIC Letter Dated 25/09/2025)
GSTAT Issues Staggered Filing Schedule for Appeals: The GSTAT has issued directions that all appeals and applications under Sections 107 and 108 of the CGST Act, must be filed and processed electronically through the GSTAT portal developed by NIC. The order notes that a large number of appeals have already been disposed of by first appellate and revisional authorities, many of which are now appealable before GSTAT. Since the newly launched portal may face capacity constraints if a large number of appeals are filed simultaneously, GSTAT has introduced a staggered filing schedule to avoid system overload and ensure smooth functioning. For instance, cases where appeals or notices were filed on or before 31st January 2022 may be submitted between 24th September 2025 and 31st October 2025 or any date succeeding such date not being later than 30th June 2026, and specified timelines on similar pattern for other cases also.
(Link: GSTAT Order Dated 24/09/2025)
Advisory, New Changes in Invoice Management System (IMS): One significant update allows taxpayers to keep specific records pending for one tax period (either a month or a quarter, depending on their filing cycle). This applies to records such as credit notes and downward amendments of invoices/debit notes. Another change relates to rules for Input Tax Credit (ITC) reduction. The new system now allows taxpayers to declare the exact amount of ITC they’ve availed and need to reverse. This provides flexibility, enabling partial reversals or a declaration of no reversal if the ITC was never claimed. Additionally, taxpayers can now save remarks when rejecting or pending a record, which will be visible in their GSTR-2B and to their suppliers for future reference and corrective action.
(Link: GSTN Advisory Dated 23/09/2025)
Advisory to file pending returns before expiry of three years: The GSTN has advised taxpayers to file all pending GST returns immediately, as a new statutory time limit is set to be enforced on the GST portal starting with the October 2025 tax period. This restriction bars taxpayers from filing GST returns, including GSTR-1, GSTR-3B, GSTR-4, GSTR-9/9C, and others, after the expiry of three years from their respective due dates. Specifically, returns whose due date was three years ago or more, and which remain unfiled by the end of the October 2025 period, will be permanently barred from filing.
(Link: GSTN Advisory Dated 25/09/2025)
Advisory, Invoice-wise Reporting Functionality in Form GSTR-7 on portal: GSTN announced that the invoice-wise reporting functionality in Form GSTR-7 (Return for Tax Deducted at Source, or TDS) is now operational on the GST portal. The notification 09/2025, allow the capture of invoice level details for TDS. Thus, all TDS Deductors are required to furnish invoice level details for the tax deducted when filing Form GSTR-7 for the September 2025 tax period and onwards.
(Link:GSTN Advisory Dated 26/09/2025)
Finance Ministry Launches GST Appellate Tribunal: The Union Minister of Finance, Smt. Nirmala Sitharaman, formally launched the Goods and Services Tax Appellate Tribunal (GSTAT) in New Delhi on 24th September 2025. GSTAT has been established as a statutory appellate body under GST laws to provide an independent forum for taxpayers to appeal against orders of GST Appellate Authorities. The Tribunal will function through a Principal Bench in New Delhi and 31 State Benches across 45 locations. Each bench will include judicial and technical members from both Centre and States, reflecting cooperative federalism. A key feature is the GSTAT e-Courts Portal, developed by GSTN with NIC, enabling online filing of appeals, digital hearings, and case tracking.
(Link: Fin Min Press Release Dated 24/09/2025)
AAAR, Appeal on Solar Power ITC dismissed on grounds of Time Limitation: Case of Kanishka Steel Industries Limited, AAAR Tamil Nadu Ruling Dated 15th September 2025. Earlier AAR had ruled that the appellant is not eligible for input tax credit on the goods and services exclusively used for the provision of exempt supply namely ‘generation and supply of electricity’. Aggrieved by the said order, the Appellant filed the appeal against the Order. AAAR held that we are not satisfied with the reasons of delay advanced by the appellant as also we are not empowered to condone the delay beyond the statutory period in filing this appeal. Accordingly, we dismiss the appeal on the grounds of time limitation. without going into the merits of the case.
AAAR, Rent Received from Govt. Welfare Hostels taxable under GST: Case of Navya Nuchu, AAAR Telangana Ruling Dated 11th September 2025. The Appellate Authority ruled that renting a building to the Scheduled Castes Development Department for use as a social welfare college hostel is a taxable service under the Goods and Services Tax (GST) regime. It upheld AAR, dismissing the appellant’s claim that the service was exempt under the category of “pure services” provided to a governmental authority.
AAR, ITC on IGST for Imports allowed despite Deferred Payment beyond 180 Days: Case of Priya Holdings Private Limited, AAR Gujarat Ruling Dated 6th September 2025. AAR rules that ITC of IGST on imports remains admissible even if supplier payment is deferred beyond 180 days, provided payment is within FEMA/RBI timelines. No reversal under Sec 16(2) proviso or Rule 37 is required.
AAR, GST Exemption on Ancillary Electricity Transmission Services: Case of Gujarat Energy Transmission Corporation Limited, AAR Gujarat Ruling Dated 6th September 2025. The AAR has held that charges recovered for deposit work activities related to electricity transmission infrastructure, which include material and erection, pro-rata,
supervision, proportionate line charges, and registration fees, are exempt from GST under entry number. 25A of notification 12/2017 dated 28th June 2017.
AAR, 5% GST on Export of Pre-Packaged & Labelled Rice up to 25kg: Case of Olam Agri India Pvt Ltd, AAR Gujarat Ruling Dated 6th September 2025. AAR ruled that pre-packaged and labelled rice up to 25 kg, is taxable at 5% GST/IGST if the supplier opts to export on payment of tax.
AAR, Trading of Particulate Matter Permits Liable to GST at 12%: Case of Randhir Dyeing and Printing Mills, AAR Gujarat Ruling Dated 15th September 2025. AAR ruled that trading of Particulate Matter Permits are liable to tax under the GST Act. Particulate Matter Permits are goods under GST and fall under HSN 4907. The applicable rate of GST is 12%.
AAR, Renting Aircraft without crew falls under HSN 9973 subject to 5% GST: Case of Agneet Sky Aviation Private Limited, AAR Gujarat Ruling Dated 15th September 2025. AAR ruled that renting of aircraft without operator can be classified under HSN code 9973, ‘Leasing or rental services without operator’ serial number 17(iii) of Notification 11/2017 dated 28th June 2017. The GST rate applicable on the leasing of helicopter/aircraft services provided by the company is 5% IGST, as the applicant is an SEZ unit.
SC, Revenue could tax only if case fell within four corners of Statute, not on legislative intent or substance: Case of Shiv Steels vs State of Assam, SC Judgement Dated 11th September 2025. The apex court held that the Revenue authorities could not impose tax on the basis of legislative intent, substance, or analogy, unless the case strictly fell within the provisions of the statute.
HC, CCTV Footage of assessee’s family should not be used by GST Dept as it violated Right to Privacy: Case of Genesis Enterprises vs Principal Commissioner CGST, HC Delhi Judgement Dated 15th September 2025. HC directed that so far as the CCTV footage of the residence is concerned, the hard disk, or any memory cards, which contain the CCTV footage of the residential premises, would not be accessed by the officials of the GST Department, except, in the presence of at least one member of the family, and one authorised representative. After viewing the footage in their presence, if there is any relevant data that is required by the GST Department, only to that extent, the same would be copied. All the remaining footage would be returned to the Petitioners.
C. Central Excise
No Notification/ Circular during the Week.
D. Custom Duty
Revision in sunset deadlines for certain custom duty exemptions: The notification amends the existing notification 50/2017 dated 30th June 2027, and thus extends the validity of key provisions and introduces phased timelines for cessation for certain custom duty exemptions. The amendments specifically modify the TABLE within the original notification, primarily by revising the sunset clauses for certain items.
(Link:Customs Notification 40/2025 (T) Dated 25/09/2025)
Communication to taxpayers through eOffice- requirement of document Identification Number (DIN): The circular clarifies the requirement of quoting the Document Identification Number (DIN) in communications sent via eOffice application. CBIC has introduced an online facility at https://verifydocument.cbic.gov.in that allows taxpayers and concerned persons to verify the authenticity of documents by entering the ‘Issue number’. With this utility in place, a separate DIN is no longer required on communications dispatched using the public option in eOffice, as the Issue number itself will be treated as the DIN. However, for all other communications outside the eOffice public option, the mandatory quoting of DIN remains unchanged.
(Link:Customs Circular 23/2025 Dated 23/09/2025)
SC, Levy of export duty on goods supplied from DTA to SEZ not justifiable: Case of Union of India vs Adani power Limited, SC Judgement Dated 28th September 2025. The apex court held that High Court has rightly arrived to the conclusion that the levy of export duty on goods supplied from the Domestic Tariff Area (DTA) to the Special Economic Zone (SEZ) is not justified.
E. Directorate General of Foreign Trade (DGFT)
Revision in SCOMET List in Line with Global Export Control Regimes: The notification revises the SCOMET (Special Chemicals, Organisms, Materials, Equipment and Technologies) List under Appendix-3 of Schedule-II of the ITC, in alignment with multilateral export control regimes. The revised Appendix-3 will be made available on the DGFT website under ‘Regulatory Updates’ → ‘Import, Export and SCOMET Policy’.
(DGFT Notification 31/2025 Dated 23/09/2025)
Export Policy of Second Generation (2G) Ethanol: The notification states that, the export of 2G Ethanol for both fuel and non-fuel purposes is now classified as ‘Restricted’. The key new requirement for exporting this type of ethanol is that a valid Export Authorisation from the DGFT is now mandatory. Further, the exporters must also provide a feedstock certification from a relevant competent authority to confirm that the ethanol meets the specified criteria, including its production from non-food sources and compliance with IS 15464 standards.
(DGFT Notification 32/2025 Dated 24/09/2025)
Non-Basmati Rice Export Now Requires APEDA Registration: The Notification relates to amendment in the export policy for Non-Basmati Rice. Although the export of Non-Basmati Rice remains classified as ‘Free’ under the relevant ITC codes of Chapter 10, exporters must now register all their contracts with the Agricultural and Food Products Export Development Authority (APEDA) prior to shipping the rice.
(DGFT Notification 33/2025 Dated 24/09/2025)
India restricts Import of Silver Jewellery until 31st March 2026: The notification amends the import policy, for specific ITC codes i.e. 71131141 and 71131149, which cover articles of jewellery and parts thereof, of silver (whether or not plated or clad with other precious metal), un-studded other Jewellery and other Jewellery. The existing import policy for these items, which was ‘Free’, has been revised to ‘Restricted’. The modified policy will be effective till 31st March 2026.
(DGFT Notification 34/2025 Dated 24/09/2025)
Clarification Regarding Ineligibility of Spices for Import under DFIA: The circular clarifies that the import of all spices, regardless of their intended use, is not permitted under the Duty Free Import Authorisation (DFIA) scheme. The circular explains that all spices are listed under Serial No. 1 of Appendix 4J, which mandates pre-import conditions, making them ineligible for import under DFIA.
(DGFT Circular 05/2025 Dated 22/09/2025)
Export of Second Generation (2G) Ethanol under Restricted Authorization: The Trade Notice has placed the export of Second Generation (2G) Ethanol under HS Code 22072000, under the Restricted Authorization category. 2G Ethanol refers to ethanol derived from non-food biomass sources such as agricultural residues, woody biomass, and algae, and must meet BIS 15464 standards. Exports are permitted for fuel, industrial, and other approved uses, provided exporters comply with conditions laid out in the notification, including securing authorization from DGFT, ensuring BIS compliance, obtaining certificates on feedstock origin and product quality from accredited agencies, and fulfilling destination country requirements.
(DGFT Trade Notice 12/2025 Dated 24/09/2025)
F. Securities and Exchange Board of India (SEBI)
Amendments to SEBI Custodian Regulations: The key amendment raises the minimum net worth requirement for custodians from Rs. 50 crore to Rs..75 crore. Existing custodians have a period of three years to meet this new capital adequacy standard, which must be maintained separately from other business requirements. It further clarify that custodians can now offer a range of other financial services. It also introduces new section, outlining custodians responsibilities, including maintaining an appropriate governance structure, risk management policies, and operational infrastructure.
(Link: SEBI Notification Dated 18/09/2025)
SEBI Mandates Digital Accessibility Compliance for Market Intermediaries: The mandatory compliance guidelines enforces the Rights of Persons with Disabilities Act, for all Regulated Entities (REs). The directive sets out a phased schedule requiring REs to submit a list of digital platforms and appoint an IAAP- certified accessibility professional as an auditor. The critical deadlines are the completion of the initial Accessibility Audit by 30th April 2026, and the final submission of the remediation report, confirming compliance, by 31st July 2026.
(Link: SEBI Circular Dated 25/09/2025)
Consultation Paper to address the ‘technical glitches’ in Stock Brokers Electronic Trading Systems: Under the new framework, glitches occurring outside trading hours or beyond brokers’ control (such as issues at banks, cloud providers, or payment gateways) will not be classified as technical glitches. The framework will apply only to brokers with more than 10,000 registered clients. Reporting requirements are streamlined, with stock brokers required to notify exchanges and clients within two hours of a glitch, followed by a preliminary report within one trading day, submitted via a common reporting platform. The revised structure also rationalizes financial disincentives, excluding minor glitches or those affecting only one trading mode.
(Link: SEBI Consultation Paper Dated 22/09/2025)
G. Ministry of Corporate Affairs (MCA)
MCA Allows AGMs & EGMs via Video Conference but not change in Deadlines: The circular extends the permission for companies to hold Annual General Meetings (AGM) and Extraordinary General Meetings (EGM) via Video Conference (VC) or Other Audio Visual Means (OAVM) until further orders. Additionally, companies are still permitted to transact business for EGMs through postal ballots. However, the circular explicitly clarifies that this extension does not grant any additional time for holding AGMs beyond the statutory deadlines set by the Companies Act 2013.
(Link: MCA General Circular Dated 22/09/2025)
H. Insolvency and Bankruptcy Board of India (IBBI)
NCLAT, Termination of concession agreement not co-related with default in repayment of Dues: Case of Vikram Bhawanishankar Sharma vs Union Bank of India, NCLAT Delhi Judgement Dated 11th September 2025. The appellate tribunal held that termination of concession agreement has no relation with default in repayment of dues of the Financial creditor. The application under section 7 of IBC has been rightly admitted against Corporate Debtor, as debt and default established.
NCLAT, Demand by EPFO based on inspection report made after initiation of moratorium cannot be enforced: Case of Harry Dhaul vs RPFC, NCLAT Delhi Judgement Dated 15th September 2025. The appellate tribunal held that demand made by the EPFO on the basis of an inspection report made after initiation of moratorium is not enforceable as Section 14(1) of the IBC prohibits the initiation or continuation of assessment during the moratorium period.
NCLAT, Workmen not worked after layoff notice are not entitled for wages of that period: Case of Unitech Machines Karamchari Sangh vs Vivek Raheja, NCLAT Delhi Judgement Dated 16th September 2025. The appellate tribunal held that claim of wages and salaries after the issuance of the layoff notice rightly rejected since the appellant workmen due to issuance of the layoff notice has not worked after issuance of this layoff notice. Accordingly, appeal dismissed.
NCLAT, Written agreement not mandatory to prove existence of Financial Debt: Case of Bijendra Prasad Mishra vs HS Mercantile Pvt Ltd, NCLAT Delhi Judgement Dated 15th September 2025. The appellate tribunal held that a written agreement is not a condition precedent to prove the existence of a financial debt and the same very well be proved by other documentary evidence. Accordingly, CIRP application has been duly admitted, as debt and default proved.
IBBI suspends RP Shivkumar Madanlal Baser, over delays in CIRP and Liquidation: The Disciplinary Committee (DC) found two major contraventions. First, Mr. Baser failed to seek timely extension of CIRP beyond the statutory 180-day limit and continued proceedings for over 300 days without CoC approval or an application to the NCLT, contrary to Section 12 of the Code. Second, he delayed filing the liquidation application despite the Committee of Creditors (CoC) expressing intent to liquidate. DC has suspended his registration for one year.
(Link: IBBI DC Order Dated 23/09/2025)
I. Reserve Bank of India (RBI)
Participation of Standalone Primary Dealers in Non-deliverable Rupee Derivative Markets: Presently, only Authorised Dealer Category-I (AD Cat-I) banks with International Financial Services Centre (IFSC) Banking Units (IBUs) were permitted to transact in Non-deliverable Rupee Derivative Contracts (NDDCs). RBI has now decided that Standalone Primary Dealers (SPDs) that are authorised as Authorised Dealer Category-III (AD Cat-III) will also be eligible to transact in these Rupee NDDCs.
(RBI Notification 78/2025 Dated 22/09/2025)
RBI Authentication mechanisms for digital payment transactions Directions 2025: These directions mandate that all domestic digital payment transactions must have at least two factors of authentication, with one factor being dynamic and robust to prevent compromise. While SMS-based OTP will continue as an accepted method, the framework encourages adoption of advanced technologies such as biometrics and tokens, ensuring interoperability and open access. Responsibilities of issuers include ensuring the security of authentication systems and compensating customers for losses arising from non- compliance. The directions also cover cross-border card-not-present (CNP) transactions, requiring card issuers to validate additional factors of authentication.
(RBI Notification 79/2025 Dated 25/09/2025)
Investment by Co-operative Banks in Shared Service Entity (SSE) established by NABARD: RBI has issued revised directions on investments in non- SLR instruments by State Co-operative Banks (StCBs) and Central Co-operative Banks (CCBs) following the regulatory approval granted to NABARD for setting up a Shared Service Entity (SSE). Under the updated framework, StCBs and CCBs are permitted to invest voluntarily in the share capital of the SSE, subject to a cap of five percent of their owned funds, which includes paid-up share capital and reserves. These investments will not be counted under the overall prudential limit on non-SLR investments, nor will they be subject to the restrictions on unlisted non- SLR securities.
(RBI Notification 80/2025 Dated 26/09/2025)
Special Clearing in Cheque Truncation System on 3rd October 2025: This measure is designed to facilitate the shift to the new continuous clearing and settlement on realization process, the first phase of which is set to begin on 4th October 2025. On 3rd October the regular CTS clearing sessions will be suspended after the morning return session for instruments presented on 1st October concludes. The special clearing session will be the only one accepting all types of instruments that day. The settlement will be processed for both the presentation and return sessions of this special clearing, and banks must maintain adequate balances in their settlement accounts.
(RBI Notification 81/2025 Dated 26/09/2025)
Standardisation of Deceased Customer Claim Settlement for Banks: RBI (Settlement of Claims in respect of Deceased Customers of Banks) Directions, have been issued to standardize and streamline the procedure for settling claims on deceased customers’ deposit accounts, safe deposit lockers, and articles in safe custody. It replaces diverse existing practices with a harmonized framework and standard documentation (Annex I-A to I-H) to minimize hardship for families. It provides a simplified procedure for accounts without a nominee for claims below a defined threshold limit (Rs 5 lakh for cooperative banks and Rs 15 lakh for others).
(RBI Notification 82/2025 Dated 26/09/2025)
J. Miscellaneous
SC, Demand notice under section 138 of Negotiable Instruents Act invalid as amount in notice different from cheque amount: Case of Kaveri Plastics vs Mahdoom Bawa Behruddin Noorul, SC Judgement Dated 19th September 2025. The apex court held that demand notice stands invalid in the eye of law when amount mentioned and demanded in notice send under Proviso (b) to section 138 of the Negotiable Instrument Act is different from actual cheque amount.
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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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