Clarified
17stories
September 2026
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LabourEPFO answers employers’ questions on the ₹25,000 ceiling: one ECR for September 2026, contributions split at 17 September, no shift to 1 October
September ECR due 15 OctoberClarifiedEPFO’s FAQs on the revised wage ceiling tell employers to file a single ECR for September 2026, computing contributions separately for 1–16 September (₹15,000 ceiling) and 17–30 September (₹25,000 ceiling). The employee share that could not be deducted may be recovered in the next payroll, but the full remittance is still due by 15 October. The EDLI maximum stays at ₹7 lakh.
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Company LawMCA cautions public on Nidhi companies promising high returns; only 395 are declared Nidhis
395 NidhisClarifiedMCA says many companies working as Nidhis have not filed Form NDH-4 in time or are not complying fully. Deposits in Nidhi companies are not insured by DICGC.
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CustomsIndia–UK CETA: importers need not file Form-I with the Bill of Entry to claim preferential duty, CBIC clarifies
No Form-I at filingClarifiedCircular 43/2026-Customs says a valid Origin Declaration by the UK exporter is the proof of origin, Form-I under CAROTAR is not a precondition, and an earlier denial cannot be applied to later imports without hearing the importer.
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FEMA & RBIBanks must value unquoted InvIT and REIT units at disclosed NAV — and at ₹1 if NAV is not disclosed as SEBI requires or the units are infrequently traded
InvIT/REIT units: NAV or ₹1ClarifiedRBI has inserted paragraphs 84A and 84B in the Commercial Banks investment portfolio Directions, 2025 to bring uniformity in how banks value units of Infrastructure Investment Trusts and Real Estate Investment Trusts. Quoted units follow the rules for quoted securities; unquoted units are valued at the NAV disclosed by the trust, failing which at ₹1. In force from 22 September 2026.
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InsolvencyNo interim moratorium for personal guarantors from 26 May 2026, even where the application was already pending: IBBI Circular 106 cites Bombay and Delhi High Courts
No interim moratorium from 26 MayClarifiedIBBI has told insolvency professionals that the interim moratorium under section 96 (and section 124) of the Insolvency and Bankruptcy Code, in respect of a personal guarantor to a corporate debtor, ceased to operate from 26 May 2026 for applications pending before the Adjudicating Authority on that date. The circular rests on judgments of the Bombay High Court (24 July 2026) and the Delhi High Court (19 August 2026).
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CustomsSea cargo manifest: ICEGATE explains how to amend a CSN or Sea Arrival Manifest before and after Entry Inwards — Advisories 37/2026 and 38/2026
After SEI: officer approvalClarifiedTwo ICEGATE advisories on the Sea Cargo Manifest and Transhipment Regulations set out the filing sequence for amending a Cargo Summary Notification and a Sea Arrival Manifest. Before Sea Entry Inwards the system applies amendments directly; after it, a Customs officer must approve. The FAQs add that consolidators can now delete a CSN before the SAM is filed.
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CustomsAutomatic goods registration for e-sealed export containers: ICEGATE advisory warns that a wrong container count in the shipping bill breaks the process
Auto GR for e-sealed cargoClarifiedAn ICEGATE advisory dated 21 September 2026 sets out how goods registration happens automatically for factory-stuffed, e-sealed FCL export containers once the last container gates in. It is running at JNCH, Cochin and New Mangalore. Exporters must declare the exact number of containers, package details and marks and numbers in the shipping bill, and the correct destination port code in the e-seal data.
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CustomsScrip fraud cases under section 28AAA: Customs must first adjudicate the misdeclaration, then ask DGFT to cancel
Section 28AAAClarifiedInstruction 17/2026-Customs tells field formations how to decide show cause notices that were held up because DGFT had not cancelled the instrument — in three situations the wait is no longer the rule.
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FEMA & RBIIFSC distributors: IFSCA adds UAE, Singapore, Australia and the European Union as specified jurisdictions; “jurisdiction” means where the product is domiciled
4 jurisdictions addedClarifiedIFSCA has amended its Master Circular for Distributors in the IFSC. UAE, Singapore, Australia and the European Union are specified as jurisdictions for regulation 32(1)(a) and (c) of the Capital Market Intermediaries Regulations, 2025, provided they are not FATF-listed or notified as high risk. “Jurisdiction” refers to the domicile of the product, not the location of its manager.
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FEMA & RBIUPI stays free for person-to-person transfers and merchant payments up to ₹2,000; 0.4% MDR on specified merchant payments above ₹2,000, says Finance Ministry
UPI: 0.4% MDR above ₹2,000ClarifiedThe Ministry of Finance says the new UPI framework under the Payment and Settlement Systems Act, 2007 does not touch person-to-person transfers. Merchant payments up to ₹2,000 and small merchants receiving up to ₹1 lakh a month stay at zero MDR. A 0.4% MDR applies to merchant payments above ₹2,000, capped at ₹300 for ₹75,000 and above; customers are not to be charged.
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InsolvencyIBBI lists six red flags of IBC misuse; insolvency professionals must apply to the Adjudicating Authority where the process serves a fraudulent purpose — Circular 105
Six red flags for IPsClarifiedIBBI says it has information from law enforcement and regulatory agencies that the IBC framework is, in certain cases, being misused for purposes other than insolvency resolution or liquidation. Circular No. IBBI/CIRP/105/2026 dated 9 September 2026 gives insolvency professionals six illustrative indicators to watch for and requires an application to the Adjudicating Authority where, on reasonable grounds, the process appears to serve a fraudulent or malicious purpose.
August 2026
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CustomsRaw sugar imported under Advance Authorisation and moved to TRQ: IGST to be paid on a reassessed Bill of Entry, interest waived
Interest waivedClarifiedCircular 37/2026-Customs lays down how an Advance Authorisation holder pays the earlier-exempted IGST at the port of import after the one-time conversion to the Tariff Rate Quota scheme, so that input tax credit can flow to GSTN.
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Company LawMCA FAQs on foreign companies and Indian subsidiaries: FC-1 within 30 days, FC-2 for every RBI extension, apostille rule turns on the place of signing
FC-1 within 30 daysClarifiedThe Ministry of Corporate Affairs has put out FAQs on registration of foreign companies and on Indian subsidiaries of foreign body corporates. They cover Forms FC-1 to FC-4, name reservation under rules 8 and 8A, the documents ROC-CRC expects, and when notarisation, apostille or consularisation is needed.
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Income TaxForeign assets disclosure scheme: CBDT FAQs explain who can declare, the 30% tax plus equal amount, the ₹1 lakh fee and payment through Challan ITNS 289
30% tax + equal amountClarifiedCBDT’s FAQs on the Foreign Assets of Small Taxpayers Disclosure Scheme, 2026 explain that even a person who is now non-resident can declare, that undisclosed foreign assets and income up to ₹1 crore cost 30% tax plus an equal amount, and that foreign assets up to ₹5 crore already taxed but not reported cost a flat ₹1 lakh. Payment is through Challan No. ITNS 289.
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Foreign TradeDGFT advisory asks exporters, banks and ECGC to exercise heightened vigilance with two Thimphu-based firms: Trade Notice 19/2026-27 under para 8.07(d) of FTP 2023
Advisory: 2 Bhutanese firmsClarifiedDGFT has issued a precautionary advisory under para 8.07(d) of the Foreign Trade Policy 2023 against two Bhutanese entities — M/s Legoy Powersports and M/s Druk A-Z Store, both of Thimphu — after a complaint could not be resolved for want of response. EPCs, Regional Authorities, ECGC and AD banks are advised to exercise enhanced caution and due diligence.
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FSSAIFSSAI asks importers and customs brokers to declare the “NFG” qualifier in ICEGATE for non-food-grade items, so the Bill of Entry is not routed to FSSAI
Declare “NFG” in ICEGATEClarifiedFSSAI says a large number of Bills of Entry for non-food-grade items — especially goods with both food and non-food use under the same HSN code — are being routed to it for clearance. By a public notice dated 10 August 2026, it advises importers and customs brokers to declare the qualifier “NFG” while filing Bills of Entry under Single Window, so that the SWIFT system routes the entry correctly.
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Income TaxCBDT FAQs on the Taxation and Other Laws (Amendment) Bill, 2026: electronics contract-manufacturing exemption to 2040-41, data centre conditions eased, new exemptions for rough diamonds
Six changes to the IT Act, 2025ClarifiedCBDT’s FAQs explain six proposals of the Taxation and Other Laws (Amendment) Bill, 2026 on the Income-tax Act, 2025: a ten-year extension of the exemption for foreign companies supplying capital goods to electronics contract manufacturers, easier data centre conditions, two new exemptions, dividend relief for unit holders of business trusts and five conditions instead of thirteen for offshore funds.
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