Analysis of Notifications and Circulars for Week ending 30th March 2025

The week ending 30th March 2025 saw several regulatory updates across income tax, GST, customs, SEBI, RBI, and other financial domains. The Central Board of Direct Taxes (CBDT) expanded Safe Harbour Rules, revised TDS return formats, and amended Form 3CD for tax audits. Income tax exemptions were granted to Karnataka Urban Water Supply & Drainage Board, while directives were issued for TDS/TCS interest waivers in technical failure cases. GST updates included rule modifications on refunds and appeals, clarifications on waiver eligibility under Section 128A, and tax treatment of input tax credit (ITC) for employee transport and damaged goods. Customs introduced anti-dumping duties on roller chains and acrylic solid surfaces from China, along with procedural guidelines for personal carriage imports. SEBI amended regulations on governance and disclosure requirements for listed entities, mutual funds, and investment trusts. The regulator also extended cybersecurity compliance deadlines and introduced voluntary ESG disclosures. RBI revised priority sector lending norms and capital adequacy requirements for Regional Rural Banks, alongside changes in ATM transaction fees. Additionally, the Supreme Court provided legal clarity on the differences between gift, settlement, and wills. These developments highlight evolving compliance requirements for businesses and taxpayers.

Notifications & Circulars issued during week (24^th– 30^th Mar 2025)

A. Income Tax

CBDT expands Safe Harbour Rules thresholds to INR 300 crores and other clarification: The scope of the safe harbour rules has been expanded by increasing the threshold for availing safe harbour from Rs 200 Crore to Rs 300 Crore, and including the ‘lithium ion batteries for use in electric or hybrid electric vehicles’ in the definition of core auto components. In order to provide tax certainty to the assessees opting for safe harbour, the amendments are applicable to two assessment years 2025-26 and 2026-27. (Income Tax Notification 21/2025 Dated 25/03/2025) (Press Release)

Changes in TDS Returns- section 194T added in Form 26Q and 27Q: The notification amends Income Tax Rules. In Form 26Q, Section 194T has been added to the heading, and a new entry in Note 16 clarifies that it applies to payments such as salary, remuneration, commission, bonus, or interest to firm partners. Similarly, in Form 27Q, Section 194T has been added, and modifications have been made in Note 13 to reflect payments to firm partners alongside existing provisions for non-resident payees under Section 195. (Income Tax Notification 22/2025 Dated 27/03/2025)

CBDT Amends Form 3CD- Adds Section 44BBC, Removes 32AC, 32AD, 35AC & 35CCB: The notification amends Income Tax Rules. The key changes include modifications to Form 3CD, used for tax audits, with the addition of Section 44BBC (Special provision for computing profits and gains of business of operation of cruise ships in case of non-residents) and removal of deductions under Sections 32AC (Investment in new plant or machinery), 32AD (Investment in new plant or machinery in notified backward areas in certain States), 35AC (Expenditure on eligible projects or schemes), and 35CCB (Expenditure by way of payment to associations and institutions for carrying out programmes of conservation of natural resources). New reporting requirements cover expenses related to legal settlements and buyback of shares. It also introduce detailed classifications for loans, deposits, and repayments. (Income Tax Notification 23/2025 Dated 28/03/2025)

Exemptions to Karnataka Urban Water Supply & Drainage Board, Bangalore: The Karnataka Urban Water Supply & Drainage Board, Bangalore,, a trust established by the State Government, has been notified under section 10(46) for exemption on its income arising from Establishment, administrative, supervision, water charges and rent, Forfeiture of EMD, Penalty, Sale of scrap, Storage charges, Survey charges, Issue of tender forms and interest on bank deposits. (Income Tax Notification 24/2025 Dated 28/03/2025)

Order under section 119 for waiver on levy of interest on TDS/ TCS: Section 20 I(IA) provides for levy of interest on account of failure to deduct or pay TDS to the credit of the Central Government by the deductor. Further, section 206C(7) provides for levy of interest on account of failure to collect or pay TCS to the credit of the Central Government by the collector. It has now been directed that CCIT/DGIT may reduce or waive interest charged in cases where the payment is initiated by the taxpayers/ deductors/ collectors and the amounts are debited from their bank accounts on or before the due date, and the tax could not be credited to the Central Government, before due date because of technical problems, beyond their control. (Income Tax Circular 5/2025 Dated 28/03/2025)

Income Tax Offices to Remain Open on March 29-31, 2025: CBDT has issued a directive under Section 119 stating that all Income Tax offices across India will remain open on March 29, 30, and 31, 2025. The order aims to facilitate the completion of pending departmental work before the financial year 2024-25 ends. (Income Tax Order Dated 26/03/2025)

B. GST

GST- Changes in Refund and Appeals Rules: The notification clarify refund eligibility and appeal procedures. Rule 164 has been revised to specify that no refund will be available for taxes, interest, or penalties already discharged before the commencement of these amended rules if a tax demand includes multiple periods. The changes in the appeal process allow taxpayers to partially withdraw their appeals related to tax periods from 1^st July 2017, to 31^st March 2020, without affecting other parts of the case. (CGST Notification 11/2025 Dated 27/03/2025)

GST- Clarifications on Waiver of interest and penalties under section 128A: Section 128A effective from 1^st November 2014, offers waivers on interest and penalties for demands under Section 73 for the period July 2017 to March 2020. It is clarified that taxpayers who paid tax via GSTR-3B before 1^st November 2024, are eligible for Section 128A benefits. Regarding demands covering periods both within and outside the scope of 128A, taxpayers can now pay only the tax for the eligible period and inform appellate authorities of their intent to withdraw appeals for that portion. The appellate authorities will then handle the remaining appeal separately. (CGST Circular 248/2025 Dated 27/03/2025)

AAAR, ITC denied on employee transport due to lack of statutory obligation: Case of Kirby Building Systems & Structures Pvt Ltd, AAAR Telangana Ruling Dated 20th February 2025. The AAAR emphasized that the proviso to Section 17(5) allows ITC only when the employer is legally obligated to provide such services. In this case, the employer’s provision of transportation was not a statutory requirement but rather a measure of convenience for employees working in remote locations. It upheld the AAR ruling and reject the appeal. (AAAR Telangana Ruling Dated 20/02/2025)

AAAR, upheld ITC reversal for goods destroyed in a fire: Case of Geekay Wires Limited, AAAR Telangana Ruling Dated 20th February 2025. The AAAR highlighted that the intent of Section 17(5)(h) is clear and unambiguous: ITC cannot be claimed on goods destroyed, regardless of whether they are inputs or finished goods. It upheld the AAR ruling and reject the appeal. (AAAR Telangana Ruling Dated 20/02/2025)

AAAR, Aluminium Composite Panel/Sheets classifiable under CTH 7606: Case of Aludecor Lamination Private Limited, AAAR Telangana Ruling Dated 20th February 2025. AAAR determined that HSN 7606, covering aluminium plates, sheets, and strip, was the correct classification. The decision was based on Rule 3(b) of the General Rules for the Interpretation of the Customs Import Tariff, which states that goods comprising composite materials are classified based on their essential character. The authority agreed that aluminium gave the ACP sheets their essential character. (AAAR Telangana Ruling Dated 20/02/2025)

AAAR, New Grounds Cannot Be Raised at Appellate Stage: Case of Maddi Seetha Devi, AAAR Telangana Ruling Dated 20th February 2025. AAAR clarified that new grounds not raised before the Advance Ruling Authority cannot be introduced at the appellate stage. It upheld the AAR ruling and reject the appeal. (AAAR Telangana Ruling Dated 20/02/2025)

AAAR, Electricity & Water Charges Bundled with Hotel Rent Taxable as Composite Supply: Case of Duet India Hotels Private Limited, AAAR Telangana Ruling Dated 20th February 2025. AAR noted that the provision of electricity and water was integral to the enjoyment of the rented premises. It determined that these charges formed part of a composite supply, with the principal supply being the renting of immovable property. The ruling clarified that the conditions for a pure agent, as defined in the CGST Rules, were not met, as the services were not independent of the principal supply, and the lessee did not authorize the lessor to make payments to the electricity department. It ruled that GST is applicable to the electricity and water charges as part of the composite supply of renting immovable property. (AAAR Telangana Ruling Dated 20/02/2025)

AAAR, E-Procurement transaction fee is taxable supply: Case of Telangana State Technology Services Limited (TSTSL), AAAR Telangana Ruling Dated 20th February 2025. The ruling clarifies that services provided by entities like TSTSL to the government, particularly in e-procurement, are subject to GST and do not fall under the government service exemptions. It upheld the AAR ruling and reject the appeal. (AAAR Telangana Ruling Dated 20/02/2025)

CGST Offices to Remain Open on 29th to 31st March 2025: CBIC has issued a directive that all field formations of the Central Goods and Services Tax (CGST) will remain open and operational on 29th, 30th, and 31st March 2025. These dates, falling at the end of the financial year, will be treated as regular working days to facilitate seamless operations and timely compliance by taxpayers. (CBIC Directive Dated 28/03/2025)

SC, Charger not to be taxed separately when it is sold with cell phone: Case of Naresh Kumar Gupta vs State of Punjab, SC Judgement Dated 20th February 2025. The Apex Court held that when a cell phone is sold along with a charger, then, charger cannot be taxed separately under Uttar Pradesh Value Added Tax Act, since there is only one MRP. (SC Judgement Dated 20/02/2025)

SC, Right to correct clerical GST errors integral to business, software limits not justifiable: Case of CBIC vs Aberdare Technologies Pvt Ltd, SC Judgement Dated 21st March 2025. The apex court highlighted that denying input tax credit (ITC) due to clerical mistakes places an undue financial burden on the purchaser, who is forced to pay taxes twice despite having already fulfilled their tax obligations. The court observed that human errors are natural and occur on both taxpayers’ and the revenue’s side. Hence, allowing corrections in cases of genuine mistakes should be considered a fundamental business right, rather than being unreasonably restricted. SC rejected the justification of software limitations as a reason for denying correction rights. It pointed out that compliance software should be designed to facilitate rectifications, rather than becoming an obstacle. All pending applications in the matter were disposed of accordingly. (SC Judgement Dated 21/03/2025)

C. Central Excise

No Notification/ Circular during the week.

D. Custom Duty

Customs Duty on Import of Bengal Gram (Desi Chana) amended:  The Notification amend prior notifications 11/2028 and 11/2021 to impose a total import duty of 10% on Bengal gram (desi chana) under HS code 0713 20 20. The changes involve the inclusion of the HS code  in the former notification table and replacing the “Nil” duty rate with 10% in the latter notification. (Custom Notification 20/2025 (T) Dated 27/03/3025)

Amendment in Import Duty notification 22/2022: The Notification amend previous notification No. 22/2022 dated 30^th April 2022, which provide exemptions for certain goods imported from UAE. It substitute Table I of the principal notification. (Custom Notification 21/2025 (T) Dated 28/03/3025)

Amendments in Import Duty notification 25/2021: The notification amends previous Notification No. 25/2021 dated 31^st March 2021 which provide exemptions for certain goods imported from Mauritius. It substitute Table I of the principal notification. (Custom Notification 22/2025 (T) Dated 28/03/3025)

Customs notifies custom stations in Navi Mumbai & Noida: The notification designate Navi Mumbai in Maharashtra and Noida International Airport (Jewar) in Uttar Pradesh as additional customs stations. These locations are now authorized for the unloading of imported goods and the loading of export goods. (Custom Notification 15/2025 (NT) Dated 24/03/3025)

Adjudicating Authority Appointed for SVB Case of Delhi Metro: The notification appoints, Commissioner of Customs, MCH, Mundra, Gujarat, as the Common Adjudicating Authority for the finalization of provisional assessments in the Special Valuation Branch (SVB) case concerning M/s Delhi Airport Metro Express Private Ltd. This move centralizes the handling of multiple show cause notices issued between 2022 and 2024, aiming to streamline the adjudication process. (Custom Notification 16/2025 (NT) Dated 26/03/3025)

Fixation of Tariff Value of Edible Oils, Brass Scrap, Areca Nut, Gold and Silver: CBDT notified the Tariff Values of Edible Oils, Brass Scrap, Areca Nut, Gold and Silver, which shall come into force w.e.f. 29^th March 2025. The tariff value for crude palm oil is set at USD 1102 per metric ton, while gold and silver have tariff values of USD 984 per 10 grams and USD 1067 per kilogram, respectively. The tariff value for areca nuts is fixed at USD 8140 per metric ton. (Custom Notification 17/2025 (NT) Dated 28/03/3025)

Postal Imports Regulations for Foreign Post Offices: CBIC has introduced the Postal Imports Regulations for governing the assessment and clearance of goods imported via Foreign Post Offices. These regulations exclude certain items, such as live animals, perishables, gold, silver, and goods requiring sample testing. It defines key terms, outlines import procedures, and mandates electronic submission of customs forms. The regulations also specify risk-based assessments, clearance conditions, penalties, and provisions for re-export or disposal of undelivered goods. Postal authorities must ensure proper screening, duty collection, and record retention. The implementation date will be notified separately. (Custom Notification 18/2025 (NT) Dated 28/03/3025)

Adjudicating Authorities Appointed for specific SCNs: CBIC has appointed adjudicating authorities for handling specific Show Cause Notices. These cases involve multiple noticees, including Shri Vikas Vilas Kadam and others, across different locations. It assigns adjudicating officers from Mumbai, Nagpur, and Lucknow ensuring that the adjudication process is centralized for efficiency. (Custom Notification 19/2025 (NT) Dated 28/03/3025)

Amendment to Sea Cargo Manifest and Transhipment Regulations: The key change pertains to the extension of the compliance deadline specified in the regulations. In the table after Form XII, against Sr No. 6, in column (3) the deadline has been updated to 31^st May 2025. (Custom Notification 20/2025 (NT) Dated 28/03/3025)

Anti-dumping Duty on Roller Chains originating  in or exported from China: Anti-dumping Duty has been imposed on imports of Roller Chains originating in or exported from China and imported into India. The anti-dumping duty shall be effective for a period of five years. (Custom Notification 06/2025 (ADD) Dated 24/03/3025)

Anti-dumping Duty on Acrylic Solid Surfaces originating  in or exported from China: Anti-dumping Duty has been imposed on imports of Acrylic Solid Surfaces originating in or exported from China and imported into India. The anti-dumping duty shall be effective for a period of five years. (Custom Notification 07/2025 (ADD) Dated 25/03/3025)

Clarification on scope of Camera Module of Cellular Mobile Phones: The circular clarifies the definition of “camera module” for mobile phone manufacturing. It defines a camera module as an assembly of essential components such as a lens, sensor, flexible printed circuit board (FPCB), brackets, connectors, and mechanical parts. It is clarified that if the imported camera module functions solely as a camera and does not include additional mobile phone components, it qualifies for the 10% concessional duty. However, if individual components are imported separately, they will be subject to standard Basic Customs Duty (BCD) rates. (Custom Circular 08/2025 Dated 24/03/3025)

Procedure for import/export through Personal Carriage: CBIC has issued guidelines for importing and exporting goods via personal carriage, particularly for gems, jewellery, and prototypes. It permits personal carriage of gems and jewellery by foreign-bound passengers from designated airports and allows re-import of duty-free rejected jewellery under specific conditions. The procedure also includes electronic filing of Bills of Entry and Shipping Bills. Jurisdictional commissioners will issue operational guidelines and ensure adequate infrastructure at airports. (Custom Circular 09/2025 Dated 28/03/3025)

Implementation of the Sea Cargo Manifest and Transhipment Regulations (SCMTR): CBIC has extended the transitional period for implementing the Sea Cargo Manifest and Transhipment Regulations (SCMTR) until 31^st May  2025. This extension addresses the insufficient testing and non-implementation of export and transhipment messages by carriers and transhippers. The circular urges stakeholders to utilize this extended period to file declarations electronically in the prescribed format, avoiding penalties under Regulation 13 of SCMTR. (Custom Circular 10/2025 Dated 28/03/3025)

E. Directorate General of Foreign Trade (DGFT)

Removal of Walnut from Appendix-4J of HBP: The Public Notice amend Appendix-4J (Export obligation period for specified inputs with pre-import condition) of the Handbook of Procedures (HBP) 2023. It involves the deletion of the entry for “Walnut in any form” listed at Serial No. 1 and 3 in Appendix-4J for ease of doing business. (DGFT Public Notice 52/2025 Dated 27/03/2025)

Amendment in ANF-4J for issuance of Diamond Imprest Authorisation (DIA): The amendment introduces four new declarations that applicants must provide. These include declarations confirming that the applicant holds a valid Two Star or higher status, has filed all required Income Tax Returns (ITR) and Goods and Services Tax (GST) returns, will abide by pre-import and actual user conditions, and that the application is their first for the current financial year. (DGFT Public Notice 53/2025 Dated 28/03/2025)

DGFT Seeks Comments on Mandatory GST E-Invoices for Foreign Trade Policy (FTP): DGFT is considering making GST e- invoices received through the Goods and Services Tax Network (GSTN) mandatory for claiming deemed export benefits under the Foreign Trade Policy (FTP). This initiative is part of an ongoing integration between DGFT and GSTN to enhance data exchange, improve transparency, and streamline the verification of electronic Bank Realization Certificates (eBRCs) and deemed export transactions on the DGFT BO portal. The stakeholders comments/ suggestions are invited. (DGFT Trade Notice Dated 25/03/2025)

F. Securities and Exchange Board of India (SEBI)

Amendment to SEBI LODR Regulations: The changes primarily focus on governance and reporting requirements for listed entities, including High Value Debt Listed Entities (HVDLEs). It raises the threshold for HVDLEs to outstanding listed non-convertible debt securities of ₹1,000 crore, along with provisions ensuring compliance within six months of exceeding this threshold. Amendments also introduce new reporting standards for corporate governance, applicable to entities with listed specified securities on SME Exchanges, exceeding defined capital and net worth criteria. (SEBI Notification Dated 27/03/2025)

Extension of timelines for submission of offsite inspection data by Mutual Funds: As per existing provisions, mutual funds were required to submit daily data in a monthly file, formatted quarterly, within 10 calendar days of the quarter’s end. The new directive allows mutual funds 15 calendar days from the end of each quarter to submit this data. (SEBI Circular Dated 28/03/2025)

Extension of timelines for submission of offsite inspection data by Portfolio Managers: As per existing provisions, portfolio managers were required to submit data as per the specified formats for all its clients on quarterly basis within 10 calendar days. The new directive allows mutual funds 15 calendar days from the end of each quarter to submit this data. (SEBI Circular Dated 28/03/2025)

Framework for assurance or assessment, ESG disclosures for value chain, and introduction of voluntary disclosure on green credits: The changes include the introduction of voluntary green credit disclosures within the Business Responsibility and Sustainability Report (BRSR). Listed entities can now choose between “assessment” or “assurance” for BRSR Core and value chain ESG disclosures, with the “assessment” to be conducted as per Industry Standards Forum.  (ISF) guidelines. The timeline of mandatory BRSR Core assessment/assurance is phased, starting with the top 150 listed entities in FY 2023-24, and expanding to the top 1000 by FY 2026-27. Value chain ESG disclosures are deferred by one year, with voluntary disclosures beginning FY 2025-26, and assessment/assurance in FY 2026-27. The threshold for value chain partners is set at 2% or more of the entity’s purchases and sales. (SEBI Circular Dated 28/03/2025)

Intraday Monitoring of Position Limits for Index Derivatives: The stock exchanges are instructed to implement intraday monitoring by taking at least four position snapshots throughout the trading day, as stipulated in the original master circular. However, it has explicitly stated that no penalties will be levied for intraday breaches of existing position limits, and these breaches will not be considered violations. Exchanges are also required to develop a joint Standard Operating Procedure (SOP) to inform market participants about the modalities of intraday monitoring and to notify clients and trading members of any breaches for risk management purposes. (SEBI Circular Dated 28/03/2025)

Amendment to Master Circular for Real Estate Investment Trusts (REITs) dated 15^th May 2024: The lock-in period for units allotted to sponsors and sponsor groups is now aligned with initial offer regulations, with 15% locked-in for three years and the remainder for one year. Inter-se transfer of locked-in units within sponsor groups is permitted, provided the lock-in period continues for the transferee. SEBI has also introduced a framework for REIT follow-on offers, mirroring InvIT public issue guidelines. (SEBI Circular Dated 28/03/2025)

Amendment to Master Circular for Infrastructure Investment Trusts (InvITs) dated 15^th May 2024: The circular amends the lock-in requirements for preferential issues InvITs. The changes align lock-in provisions with existing regulations, ensuring that sponsor-held units are not subject to additional restrictions beyond their original lock-in period. It now permits inter-se transfers of locked-in units among sponsors and their group entities under specified conditions. The circular also introduces a regulatory framework for follow-on offers (FPOs) by publicly offered InvITs. (SEBI Circular Dated 28/03/2025)

Extension towards Adoption and Implementation of Cybersecurity and Cyber Resilience Framework (CSCRF) for SEBI Regulated Entities (REs): SEBI has extended the deadline to adopt and implement the Cybersecurity and Cyber Resilience Framework (CSCRF) to 30^th June 2025, for regulated entities (REs), excluding Market Infrastructure Institutions (MIIs), KYC Registration Agencies (KRAs), and Qualified Registrars to an Issue and Share Transfer Agents (QRTAs). (SEBI Circular Dated 28/03/2025)

Consultation Paper on the Final Settlement Day (Expiry Day) for Equity Derivatives: The proposal envisage that all equity derivatives contracts on an exchange will expire either on Tuesdays or Thursdays, preventing excessive trading activity on specific days. Exchanges will retain the flexibility to offer one weekly benchmark index options contract on their chosen day. All other contracts, including benchmark index futures, non-benchmark index futures/options, and single stock futures/options, will have a minimum tenure of one month and will expire on the last Tuesday or last Thursday of the month. Moreover, SEBI will require exchanges to seek prior approval before introducing or modifying contract expiry schedules. The stakeholders comments/ suggestions are invited. (SEBI Consultation Paper Dated 27/03/2025)

Consultation Paper on Draft Circular on ‘Rating of Municipal Bonds on Expected Loss (EL) based Rating Scale’: The draft circular relates to rating of municipal bonds using an Expected Loss (EL)-based rating scale. This proposed rating system, alongside the existing Probability of Default (PD) scale, aims to provide a more comprehensive assessment of municipal bond risks and recovery prospects. The stakeholders comments/ suggestions are invited. (SEBI Consultation Paper Dated 28/03/2025)

SEBI Board Meeting Highlights: SEBI held its 209^th board meeting on 24^th March 2025. The board approved raising the threshold for FPI additional disclosures from INR 25,000 crore to INR 50,000 crore equity AUM, aligning with increased market trading volumes. Category II AIFs were permitted to count investments in listed debt securities rated ‘A’ or below as equivalent to unlisted securities, easing compliance requirements. Governance of Market Infrastructure Institutions (MIIs) was strengthened, with changes to the appointment process for Public Interest Directors (PIDs) and Key Management Personnel (KMPs). The cooling-off period rules for PIDs transitioning between MIIs were clarified, and new appointment protocols for critical KMP roles were introduced. Investment Advisers (IAs) and Research Analysts (RAs) can now charge fees in advance for up to one year. (SEBI Press Release Dated 24/03/2025)

Extension of suspension in trading in seven key Commodities Derivatives:  The suspension in trading in derivative contracts has been extended till 31^st March 2026, for commodities i.e. Paddy (non-basmati), Wheat, Chana, Mustard seeds and its derivatives (its complex), Soya bean and its derivatives (its complex), Crude Palm Oil, and Moong. (SEBI Press Release Dated 24/03/2025)

G. Ministry of Corporate Affairs (MCA)

No Notification/ Circular during the week.

H. Insolvency and Bankruptcy Board of India (IBBI)

Mandatory Use of Baanknet (formerly eBKray) Auction Platform for Liquidation: IBBI has mandated the exclusive use of the Baanknet (formerly eBKray) auction platform for conducting auctions of assets during liquidation processes. Insolvency Professionals (IPs) are required to list unsold assets in ongoing cases by 31^st March 2025. Following recent amendments, liquidators are no longer required to perform due diligence on prospective bidders, instead, bidders must  submit necessary documentation, including a declaration of eligibility under Section 29A of IBC, through the Baanknet platform. Auction notices must also specify that Earnest Money Deposits (EMD) are to be made via the platform and will be forfeited if bidders are found ineligible. (IBBI Circular Dated 28/03/2025)

SC, Statutory dues not included in Resolution Plan stand extinguished post approval: Case of Vaibhav Goel vs DCIT, SC Judgement Dated 20th March 2025. The case involved tax demands raised after the approval of a Resolution Plan by the NCLT. The Income Tax Department issued fresh tax demands, despite these liabilities not being part of the approved Resolution Plan. SC noted that, under Section 31 of IBC, once a Resolution Plan is approved, all claims not included in the plan stand extinguished. Citing The court set aside the orders of the NCLT and NCLAT and ruled that the tax demands were unenforceable. (SC Judgement Dated 20/03/2025)

NCLAT, Beneficiary under personal guarantee entitled to file application under section 95 of IBC: Case of Krishan Kumar Jajoo vs Piramal Enterprises Limited, NCLAT Delhi Judgement Dated 21st February 2025. The appellant tribunal held that beneficiary under the personal guarantee is fully entitled to initiate Personal Insolvency Resolution Process against personal guarantor under section 95 of the Insolvency and Bankruptcy Code. (NCLAT Delhi Judgement Dated 21/02/2025)

IBBI Suspends Valuer over violations in valuation reports: The valuation report by Mr. Vipan Kumar, revealed discrepancies in market rate calculations, inadequate disclosure of valuation sources, and unclear justifications for discounting factors. The investigation found that he relied on informal market sources without providing sufficient supporting evidence, violating Valuation Rules. Moreover, significant discounting was applied without detailed reasoning, further reducing the fair and liquidation values of properties. DC suspended his registration for three months. (IBBI Order Dated 26/03/2025)

I. Reserve Bank of India (RBI)

Currency Chest operations on 31^st March 2025: RBI has directed all banks holding Currency Chests (CCs) to keep them operational on March 31, 2025 (public holiday). Since government transactions require access to CCs, banks must keep them open as on a normal working day. (RBI Notification 129/2025 Dated 24/03/2025)

Review of Priority Sector Lending (PSL) Targets- Urban Co-operative Banks (UCBs): As per existing directives, UCBs are required to achieve an overall PSL target of 75 per cent of Adjusted Net Bank Credit (ANBC) or Credit Equivalent Amount of Off-balance Sheet Exposure (CEOBSE), whichever is higher, by FY2025-26, with interim targets of 60 per cent (FY2023-24) and 65 per cent (FY2024-25). On a review, it has been decided that the overall PSL target for UCBs shall stand revised, FY2024-25 onwards, to 60 per cent of ANBC or CEOBSE, whichever is higher. (RBI Notification 130/2025 Dated 24/03/2025)

Priority Sector Lending Certificates (PSLC): RBI clarified the classification of PSLCs under the category ‘PSLC – SF/MF’. This category now includes all eligible loans to small and marginal farmers (SF/MF) and will count toward multiple sub-targets, including the SF/MF sub- target, Weaker Sections sub-target, Non- Corporate Farmers (NCF) sub-target, agriculture target, and overall Priority Sector Lending (PSL) target. (RBI Notification 131/2025 Dated 24/03/2025)

Amendment to Gold Monetization Scheme (GMS): RBI has amended the Gold Monetization Scheme (GMS), 2015. The Medium and Long Term Government Deposit (MLTGD) components will no longer be available. Gold deposits under MLTGD will not be accepted beyond 25^th March 2025, at Collection and Purity Testing Centres (CPTCs), Gold Monetization Scheme Mobilization, Collection & Testing Agents (GMCTAs), or designated bank branches. Existing MLTGD deposits will continue until maturity, adhering to previous guidelines. However, banks may continue to offer Short Term Bank Deposits (STBD) under GMS at their discretion. (RBI Notification 132/2025 Dated 25/03/2025)

General Notification for Sale and Issue of Government Securities (including Treasury Bills and Cash Management Bills): RBI has issued a new notification regarding the sale and issuance of Government of India Securities, including Treasury Bills and Cash Management Bills. It aims to streamline the issuance process and ensure alignment with current financial regulations. (RBI Notification 133/2025 Dated 27/03/2025)

Special Clearing Operations on 31^st March 2025: RBI has provided for Special Clearing Operations for government cheques on 31^st March 2025. The normal clearing timings under the Cheque Truncation System (CTS) will apply on that day. However, a special clearing session for government cheques will take place from 17:00 to 17:30 hours for the presentation session and from 19:00 to 19:30 hours for the return session. All scheduled commercial banks, including regional and urban co-operative banks, and other relevant financial institutions, are required to participate. (RBI Notification 134/2025 Dated 28/03/2025)

Revised Valuation Norms for Government-Guaranteed Security Receipts (SRs): The new guidelines provide a differentiated approach to valuing SRs backed by the Government of India. If a loan is transferred to an Asset Reconstruction Company (ARC) for a value exceeding its net book value, the excess provision may be reversed to the Profit and Loss Account, provided the sale consideration includes only cash and government-guaranteed SRs. However, the non-cash component in SRs must be deducted from Common Equity Tier 1 (CET 1) capital, and no dividends can be paid from it. The periodic valuation of these SRs will be based on the Net Asset Value (NAV) determined by ARCs. (RBI Notification 135/2025 Dated 29/03/2025)

RBI (Priority Sector Lending– Targets and Classification) Directions, 2025:  The framework outlines lending targets across key sectors such as agriculture, micro, small, and medium enterprises (MSMEs), export credit, education, housing, social infrastructure, renewable energy, and weaker sections. The guidelines specify computation methods for Adjusted Net Bank Credit (ANBC) and Credit Equivalent of Off-Balance Sheet Exposures (CEOBSE) to determine PSL targets. A new weight-based system has been introduced to address regional disparities in PSL credit flow. The directions also provide details on on-lending norms, investment in securitization notes, inter-bank participation certificates, and co-lending arrangements between banks and Non-Banking Financial Companies (NBFCs). (RBI Master Directions 128/2025 Dated 24/03/2025)

RBI (Prudential Norms on Capital Adequacy for Regional Rural Banks) Directions, 2025: The guidelines requires that RRBs must maintain a minimum Capital to Risk Weighted Assets Ratio (CRAR) of 9%, with at least 7% in Tier 1 capital. Tier 1 capital includes paid-up share capital, reserves, and perpetual debt instruments (PDIs), while Tier 2 capital comprises general provisions and investment fluctuation reserves. These also detail risk- weight calculations, regulatory deductions, and conditions for PDIs. Reporting requirements mandate RRBs to submit annual capital adequacy returns to NABARD. It also requires prior RBI approval for certain capital instruments and call options. (RBI Master Directions 129/2025 Dated 25/03/2025)

Usage of Automated Teller Machines/ Cash Recycler Machines– Review of Interchange Fee and Customer Charges: Based on a review, it has been decided that ATM interchange fee will be as decided by the ATM network. Customers are eligible for five free transactions (inclusive of financial and non-financial transactions) every month from their own bank ATMs. They are also eligible for free transactions (inclusive of financial and non-financial transactions) from other bank ATMs viz. three transactions in metro centres and five transactions in non-metro centres. Beyond the free transactions, a customer may be charged a maximum fee of ₹23 per transaction. (RBI Notification 52/2025 Dated 28/03/2025)

J. Miscellaneous

SC, explains legal distinctions between Gift, Settlement and Will: Case of NP Saseendran vs NP Panammma, SC Judgement Dated 24th March 2025. The ruling emphasized that the nomenclature of a legal document is immaterial, its legal nature is derived from its contents. A gift or settlement involves a transfer of interest during the lifetime of the executor (in praesenti), while a will postpones such transfer until after the testator’s death. Importantly, delivery of possession is not mandatory for validating a gift or settlement as long as it is proven to have been acted upon during the executor’s lifetime.

— Under Section 122 of the Transfer of Property Act, 1882, a gift entails the voluntary transfer of property without consideration, requiring acceptance by the donee during the donor’s lifetime. Registration is mandatory for gifts involving immovable property, aligning with Section 17 of the Registration Act, 1908. Gifts are irrevocable unless a conditional clause explicitly allows for revocation.

— A settlement deed, as per Section 2(b) of the Specific Relief Act, 1963, involves the non-testamentary disposition of property, often executed out of moral obligation or affection toward family members. Settlements frequently include life interest provisions or successive devolution of rights, allowing the settlor to impose certain conditions. However, Section 11 of the Transfer of Property Act restricts conditions that limit the transferee’s absolute rights. Like gifts, settlements require registration under the Registration Act for immovable property to be valid.

— A will, governed by the Indian Succession Act, 1925, is a testamentary instrument effective posthumously. The testator retains the right to alter or revoke the will multiple times during their lifetime. The execution of a will requires attestation by two witnesses, as per Section 63 of the Act. While similar to gifts in its voluntary nature, a will differs in deferring the transfer of property until the testator’s death.

— The interplay of these instruments lies in their shared voluntary disposition, with nuanced distinctions based on timing, acceptance, and revocability. (SC Judgement Dated 24/03/2025)

SC, No Stamp Duty on flat transferred as per divorce settlement: Case of Arun Rameshchand Arya vs Parul Singh, SC Judgement Dated 28th February 2025. The primary issue in divorce dispute was a jointly owned flat in Kalyan (West), Maharashtra. The husband ultimately agreed to relinquish his rights. In return, the wife agreed not to seek alimony. Since both parties are well-established in their respective careers, financial support was not deemed necessary. The court directed the absolute transfer of the flat to the wife without encumbrances and ruled that no stamp duty was required for registration, as the property was part of the legal proceedings. The court then dissolved the marriage by mutual consent. (SC Judgement Dated 28/02/2025)

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Compiled by: CMA Yash Paul Bhola, MBA, ICWAI, 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)