GSTPAM News Bulletin February 2026

GIST OF TRIBUNAL JUDGEMENTS (VAT)

Compiled by CA Rupa Gami

1. M/s Moonlight Electrical Contractors and Engineers Pvt. Ltd. in M.A. No. 76 and 78 of 2024 dated 06/01/2025

   Delay in filing second appeal by 170 days. After the order was received, the appellant had directed its accountant to handover the order to its Chartered accountant to take necessary action. During that time, the Chartered Accountant was on leave and thereafter the accountant was on leave. Later it skipped the attention of the accountant. On perusing the pending matters, it came to the notice of the accountant and immediate steps were taken to file the second appeal. The mistake was not deliberate or intentional. The Hon’ble Tribunal observed that in a plethora of judgements the Supreme Court has considered that the delay condonation should be considered liberally so as to serve the cause of justice. Delay was condoned after imposing cost of Rs.25000/- per appeal.

   (Petitioner represented by Adv. C.B.Thakar)

2. M/s Dattatray Enterprises in Vat S.A. No. 445 of 2019 dated 17/01/2025

   The appellant is in the business of undertaking works contracts. The first appellate authority had not allowed the credit of TDS on works contract which was erroneously deducted by M/s Hindustan Petroleum Corporation Ltd. on labour charges and the same was admitted by the company by way of clarification in the letter. Copies of TDS Certificates were produced during the hearing. Some of the Certificates for 2012-13 were issued by the party in the subsequent year 2013-14. The Hon’ble Tribunal directed the first appellate authority to verify if the TDS was considered in 2013-14 and if not the same be allowed in 2012-13. The matter was remanded for verification and the appellant was to submit the proof of submission of original certificates to the first appellate authority and if not to submit fresh certificates obtained from the party.

   (Petitioner represented by CA H.N.Swamy)

3. M/s Silent Enterprises in M.A. No. 24 of 2025 dated 29/01/2025

   Delay of 230 days in filing of second appeal. Delay caused due to the accountant of the appellant having

   filed the order in wrong file of completed file and on receipt of recovery reminder, filed the second appeal immediately. The Hon’ble Tribunal observed that the delay was caused due to negligence of the accountant and therefore the dealer should not suffer. Delay was condoned after imposing costs of Rs.5000/-.

   (petitioner represented by accountant of the applicant)

4. M/s Engineering Equipment Corporation in Vat S.A. No. 503 of 2019 dated 11/02/2026

   Against the Assessment Order passed under the CST Act demand was raised due to want of declaration forms. Thereafter, Rectification Application was filed and the original Forms were submitted. However, no Rectification Order was passed. The appellant had carried the matter in appeal. During the rectification proceedings all the original Forms were submitted. However, the file was lost by the Assessing authority. The first appellate authority confirmed the assessment order. After receipt of the appeal order, the file with original declaration forms was found. The matter was remanded to the first appellate authority to verify the forms and pass the order.

   (Petitioner represented by STP Dhaval Talati)

5. M/s Pehal Enterprises in Vat S.A. No. 206 of 2024 dated 11/02/2025

   The appellant was assessed and demand was raised on various grounds. In appeal, no one appeared and the order was passed ex parte. It was informed that the earlier consultant did not appear in the matter and when the documents were called for, the same were not produced. Only on receiving the appeal dismissal order. The appellant came to know that the notices were not attended to by the consultant. The Hon’ble Tribunal observed that the appellant was diligent in pursuing the matter but his consultant was not attending the matter. Now a new consultant was appointed and therefore one more opportunity should be given to the appellant to produce valid documents. Matter was remanded to first appellate authority.

   (Petitioner represented by Adv. A.B.Shah)

6. M/s Pinaki Projects in M.A. No. 65 of 2005 dated 24/02/2005

   Delay of 554 days in filing of second appeal. In first appeal nobody attended and dismissal order was passed. The applicant did not receive the dismissal appeal order as the appeal order was served upon the advocate of the appellant. The appellant obtained certified copy of the order and filed the second appeal. After getting the certified copy, the appeal was filed in time. The Hon’ble Tribunal observed that the applicant should not be a sufferer due to lapses on the part of the Advocate. However, as the applicant himself was not diligent, one more chance was to be given after imposing costs of Rs. 25000/-. (Petitioner represented by Adv C.B.Thakar)

INCOME TAX UPDATES

Compiled by By. Adv. Ajay Talreja

What to do When NRI recieved Income Tax Notice in India

An Income Tax notice in India creates stress for many NRIs, but it does not mean guilt. A notice means the Income Tax Department needs data, documents, or an explanation. If you act fast and present records in a structured way, you can close most matters at the assessment stage.

1) Why NRIs Are Receiving More Income Tax Notices

1. Data matching through AIS, TIS, Form 26AS, SFT reports

   The Department matches your return with third-party reports from banks, mutual funds, registrars, property registries, and brokers. If AIS shows a transaction but your return does not reflect it, the system flags the gap. This leads to emails, intimations, and then statutory notices in many cases.

2. High-value transactions in India without a return

   Property sale or purchase, large NRO credits, big mutual fund redemptions, and large bank deposits can trigger scrutiny when the return is missing or the income disclosure does not align with data feeds.

3. TDS form errors and mismatch for NRIs

   NRIs face TDS mismatch issues when the buyer or payer uses an incorrect TDS section or form. The mismatch blocks credit in Form 26AS/AIS and creates tax demand risk.

4. Cross-border reporting under CRS and FATCA

   Financial institutions report certain account and investor details under CRS and FATCA frameworks. This increases visibility of cross-border holdings and flows, and it raises compliance checks.

2) What Each Notice Means and What It Requires

1. Section 142(1): Inquiry and document call

   Section 142(1) notice asks you to file a return (if missing) or submit information and documents to support the return and income position. It can ask for bank statements, rent agreements, sale deeds, capital gain working, foreign tax proof, and source details.

   What you must do:

   • Submit a point-by-point response with uploads through the e-filing portal.

   • Provide a clean reconciliation between AIS/26AS and your return.

   • Provide a written note on your residential status and income scope. 

2. Section 133(6): Information call to you or a third party

   Section 133(6) gives power to seek information from a person, bank, employer, payer, or other third party. In NRI matters, banks receive such notices for NRO credits, interest, or remittance details. Taxpayers can also receive a 133(6) notice for transaction confirmation.

   Key point: Non-response creates risk of adverse inference, but additions cannot rest on non-response alone when records exist and get filed at appeal stage.

3. Section 143(2): Scrutiny selection

   Section 143(2) means the Department has selected the return for scrutiny to verify correctness of income, loss or tax. This is the gateway to a detailed assessment.

   What you must do:

   • Treat this as a structured audit.

   • Submit evidence for each issue: capital gains, rent, interest, TDS, DTAA claims, foreign tax credit, and source trails.

4. Section 144: Best judgment assessment

   Section 144 applies when you do not file a return, do not furnish required details, or do not attend when required. The Assessing Officer (AO) can complete assessment on available material and make additions. This leads to high demands and penalties.

   Courts set aside Section 144 outcomes where the taxpayer later offers records and the case needs a fair hearing. In S. S. Traders 2025 (HC) 1651, Madras High Court set aside an order passed under Sections 147 read with 144/144B, gave another chance to submit documents and required a 15% deposit within 30 days. 

3) Step-by-Step Action Plan for NRIs After a Notice

Step 1: Verify notice authenticity and timeline

Log in to the Income Tax e-filing portal and check the notice in the e-Proceedings or “e-File” section. Note the DIN, section, assessment year, and due date.

Step 2: Identify the trigger issue

Common triggers for NRIs:

• Property sale: capital gains, TDS credit gap, section 195 or 194-IA mismatch
• NRO interest and TDS rate
• Mutual fund redemptions and capital gains
• Rent income with missing TDS certificates
• Cash deposit or large credits with source questions

Step 3: Build a document pack

Include:

• Passport pages and travel chart for the year (residential status)
• Bank statements for NRO/NRE for the relevant period
• Sale deed, purchase deed, cost proofs, improvement bills
• Rent agreement, rent ledger, municipal tax receipts
• Form 26AS, AIS/TIS download, reconciliation note
• TDS certificates (Form 16A), challans if any
• DTAA documents (see next section)

Step 4: File a structured response

Use a table format inside your submission note: “Notice point your response documents attached.” Keep each response tied to evidence.

Step 5: Use representation power if needed

If you cannot manage uploads and hearings from abroad, appoint an authorised representative in India and keep a signed authority letter ready.

4) Important DTAAs to Consider: Issues, Solutions, and Examples

India has DTAAs with many countries where NRIs live: USA, UK, UAE, Canada, Australia, Singapore, and others. DTAA relief works under Section 90 when you meet treaty conditions and provide documents.

A) Core DTAA documents NRIs must keep ready

• Tax Residency Certificate (TRC) from the country of residence
• Form 10F (for details not covered in TRC)
• Tax Identification Number of that country
• Proof of foreign tax paid or foreign tax return extract (when credit is claimed)

Tax authorities challenge treaty benefits when TRC or tax proof is missing.

B) Common DTAA issues and solutions

Issue 1: Bank deducts high TDS on NRO interest

Solution: Submit TRC and Form 10F to the bank and claim treaty rate where the DTAA allows a lower rate. If excess TDS has happened, claim refund through return with DTAA schedule support.

Example: NRI in UAE earns NRO interest. Bank cuts TDS at domestic rate. DTAA route can reduce the rate when documents are on file, and refund claim can recover excess deduction.

Issue 2: Salary earned outside India but credited to an Indian account Credit location does not control taxability. Service location and residential status control the outcome, subject to DTAA.

In Gautam Arora v DCIT, ITAT Kolkata held that an NRI who worked in Morocco and stayed outside India for over 182 days qualified for DTAA benefit under Article 15(1) of India–Morocco DTAA, even when salary came to India, subject to proof of tax in Morocco.

Issue 3: Capital gains disputes and treaty claimsCapital gains taxation depends on asset type and DTAA article. Real estate gains often remain taxable in India under many treaties. Some securities gains have treaty protection in some treaty versions, subject to limitation clauses and amendments.

5) Practical Safeguards and Case Law Support

1. Jurisdiction and service defects can void proceedings

   ITAT Chandigarh held reassessment invalid where the wrong officer issued notice to an NRI and proper service proof was absent. In Raman Pillai Sivasankara Pillai v DCIT, ITAT treated the notice as void and held that case transfer did not cure lack of jurisdiction without a fresh valid notice.

2. Mandatory procedure in scrutiny and reassessment

   In Shaily Juneja v ACIT, Delhi High Court quashed reassessment where notice under Section 143(2) was not issued, and it treated 143(2) compliance as mandatory in that context.

3. Best judgment exposure under Section 144

   Non-submission leads to Section 144 risk. Courts grant relief when records exist and the taxpayer seeks a fair hearing, as seen in S. S. Traders.

Conclusion: The NRI Notice Response Checklist

When you receive a notice under Sections 142(1), 133(6), 143(2), or face Section 144 risk, follow this checklist:

1. Download notice from the portal and record the due date.

2. Map the notice section to the action required.

3. Reconcile AIS/26AS with your return and transactions.

4. Prepare a single evidence set with clear labels.

5. Submit a point-wise response with document links.

6. For DTAA claims, submit TRC, Form 10F and foreign tax proof.

7. Raise jurisdiction and service issues where facts support it.

8. Avoid non-response, since Section 144 follows non-cooperation.

Only Final Stamp Valuation Determined by Collector Applies u/s 50C: ITAT allows Full Section 54F Exemption

n a recent ruling, Income Tax Appellate Tribunal (ITAT), Raipur, held that only the final stamp valuation fixed by the Collector applies under Section 50C of the Income Tax Act, 1961. It deleted a 74.5 lakh capital gains addition and held that Section 54F exemption must be based on actual sale proceeds reinvested, not deemed values.

The appeal arises from an assessment order dated 29.03.2016, passed under section 147 read with section 143(3) for the assessment year 2008-09. The order had adopted the stamp duty valuation of 5.75 crore instead of the actual sale consideration of 1.30 crore for land situated at Labhandi, Raipur, resulting in the disputed addition.

The petitioner, Mahesh Shrivastava, argued that his th share of 21.75 lakh was fully reinvested in a residential house, entitling him to complete exemption under Section 54F.

Also, the Collector of Stamps, Raipur, after prolonged litigation and pursuant to directions of the Chhattisgarh High Court, had finally determined the property’s value at 1.60 crore on 30 September 2021. This valuation, the petitioner submitted, had attained finality and was already accepted in the identical case of his brother, where ITAT Raipur had granted relief 2024.

The revenue, argued the case vehemently and prayed for dismissal of the appeal.

The tribunal, after hearing both sides, noted that the deeming fiction under Section 50C could not be stretched to deny exemption under Section 54F. It alsoobserved that law cannot compel a taxpayer to invest more than the actual consideration received, citing the maxim “lex non cogit ad impossibilia” which means that the law cannot possibly compel a person to do something which is impossible to perform.

The tribunal also held that where the assessee claims exemption under section 54F of the Act, the net consideration when deployed in the acquisition or construction of a residential house, it should be eligible for exemption, and the provisions of section 50C should not be imported for such computation.

The Tribunal ruled that the stamp duty value adopted under Section 50C can only be used for computing capital gains, and cannot be treated as the actual net consideration of the property for purposes like Section 54F exemption.

The bench of Partha Sarathi Chaudhury ( judicial member), Avdhesh Kumar ( account member) directed the Assessing Officer to grant full exemption under Section 54F since the cost of the new residential asset was not less than the net sale consideration.

Accordingly, the assessee’s appeal was allowed in full.

Six Months Only Golden Opportunity Delay Today Means Zero Tension Tomorrow

FAST DS 2026 Introduction

FAST DS is a one time six month voluntary disclosure scheme announced in Budget 2026. It offers a second chance to resident individual taxpayers who hold small foreign income or assets but failed to report them correctly in earlier Income Tax Returns. This initiative has been introduced by the Ministry of Finance, Government of India. The core purpose is to legally correct foreign disclosure mistakes that happened due to lack of awareness.

Core Objective of the Scheme

FAST DS is not a punishment mechanism it is a correction opportunity. When taxpayers voluntarily disclose foreign income and foreign assets and pay the prescribed tax or fee they receive protection from harsh Black Money actions. This scheme has been designed to help genuine small taxpayers achieve peaceful compliance.

Who Can Use This Scheme

The scheme is meant exclusively for resident individual taxpayers. It applies to those who worked abroad those holding overseas investments foreign bank accounts ESOPs or foreign shares. Anyone who made genuine mistakes without intentional tax evasion can benefit from this relief.

Two Main Eligibility Categories

The first category includes taxpayers who failed to disclose both foreign income and foreign assets in earlier returns.

The second category includes taxpayers who already paid tax on foreign income but forgot to disclose the related foreign assets in Schedule FA.

FAST DS offers a practical solution for both groups.

Foreign Income That Can Be Disclosed

Foreign salary foreign interest foreign dividends and foreign capital gains can all be disclosed under this scheme. These incomes must be reported through Schedule FSI in the Income Tax Return.

Foreign Assets That Can Be Disclosed

Foreign bank accounts overseas properties foreign shares foreign mutual funds and ESOP holdings can be disclosed using Schedule FA. Even small assets that were previously missed can now be legally regularized through this scheme.

Monetary Limits Under the Scheme

Taxpayers who failed to disclose both foreign income and assets can generally regularize holdings up to one crore rupees through FAST DS.

Taxpayers who already disclosed foreign income and paid tax but missed asset reporting can regularize foreign assets up to five crore rupees by paying only a small flat fee.

This is why FAST DS is specifically called a small taxpayers scheme.

Tax or Fee Payable

If both foreign income and assets were fully undisclosed thirty percent tax on the asset value or income plus an

additional thirty percent levy must be paid. Once paid there will be no penalty or prosecution.

If foreign income was already taxed and only asset disclosure was missed a flat fee of about one lakh rupees is sufficient. This offers significant financial relief.

How to Avail This Opportunity

First collect complete details of foreign income and foreign assets. Then file the correct Income Tax Return by reporting foreign income in Schedule FSI and foreign assets in Schedule FA. Next calculate the applicable tax or fee under FAST DS and pay online. After payment an acknowledgement is generated which serves as legal protection proof. The declaration must be accurate. Once submitted and paid the amount is non refundable.

Who Is Excluded

Assets linked to crime are not eligible under this scheme. Cases already under prosecution are excluded. Taxpayers holding large scale undisclosed foreign wealth are also not covered. FAST DS is strictly meant for genuine small taxpayers.

Last Date for Declaration

The scheme is open only for six months from the date of notification. After this window FAST DS will no longer be available. Eligible taxpayers are strongly advised not to delay.

Key Benefits of FAST DS

Penalty and prosecution free closure is possible. Complex foreign disclosure issues receive a simple legal solution. Black Money risks are eliminated. Future assessments become stress free. Small overseas holdings can be regularized at low cost.

Final Summary

FAST DS is not a punishment scheme it is a correction opportunity. Budget 2026 has provided this practical relief for foreign disclosure mistakes caused by lack of awareness. For anyone holding undisclosed foreign assets this is truly a golden window to regularize and move forward with confidence.

BUDGET HIGHLIGHTS

Compiled by By Mr. Tushar P. Joshi

The Union Budget 2026-27, presented by Finance Minister Ms. Nirmala Sitharaman, focuses on tax simplification, infrastructure growth, and self-reliance.

Taxation & Personal Finance.

New Income Tax Act: A completely redrafted tax law to replace the 1961 Act, effective April 1, 2026.

Zero Tax up to 12 Lakh: No income tax for earners up to 12 lakh under the New Tax Regime (effectively 12.75 lakh with standard deduction).

Standard Deduction Hiked: Increased from 50,000 to 75,000 for salaried individuals.

Tax Slabs Rationalized: The 30% tax rate now applies only to income above 24 lakh (up from 15 lakh).

Senior Citizen Relief: Tax deduction limit for medical insurance/expenses doubled to 1 lakh.

Stock Market Taxes: STT on Futures Raised to 0.05% and on Options to 0.15%.

Buyback Taxation: Share buyback proceeds will now be taxed as Capital Gains for shareholders.

Infrastructure & Industry.

Capex Outlay: Increased by 9% to a record 12.2 lakh Crore for FY27.

High-Speed Rail: Seven new high-speed passenger rail corridors announced.

Semiconductor Mission 2.0: Launched to build domestic chip equipment and supply chain ecosystem.

BioPharma Shakti: New scheme with 10,000 Crore to set up three biopharmaceutical institutes.

Rare Earth Corridors: Dedicated mining and processing zones in Odisha, Kerala, Andhra Pradesh, and Tamil Nadu.

Nuclear Energy: Amendments to the Atomic Energy Act to allow private sector partnership in nuclear power.

Agriculture, MSMEs & Social Sector.

Kisan Credit Card (KCC): Short-term loan limit for farmers, fishermen, and dairy farmers raised to 5 lakh.

PM Dhan-Dhaanya Krishi Yojana: Launched to uplift 1.7 Crore farmers in 100 low-productivity districts. MSME Growth Fund: A new 10,000 Crore fund established to help small businesses scale.

Education & Health: 75,000 new medical seats over 5 years and “IIT Creator Labs” for technical education.

Urban Challenge Fund: 1 lakh Crore allocated to transform cities into regional economic growth hubs. Macroeconomic Outlook.

Fiscal Deficit: Target set at 4.3% of GDP for 2026-27.

GDP Growth: Projected between 6.8% and 7.2% for the upcoming fiscal year.

Total Budget Size: Pegged at 53.5 lakh Crore.

CIRCULAR FOR RENEWAL OF MEMBERSHIP/SUBSCRIPTION CHARGES FOR THE F.Y. 2025-26

Dear Members,

RENEWAL OF MEMBERSHIP FOR F.Y. 2025-26

The Membership Fees for the year 2025-26 are due for renewal on 01.04.2025. We appreciate your Continuing support and participation in the activities of our Association.

The timely Renewal of Membership will enable the members to continuously receive the updates on various activities of GSTPAM along with the GSTReview, News Bulletin, Circulars, Messages, Webinars and online access to the website www.gstpam.org. The Life Members only need to renew the subscription charges for the GST Review. The members can also avail the benefit of discount by paying advance for subsequent two years membership fees /subscriptioncharges.

The Membership Renewal Fees received after 30thApril, 2025 will be subject to approval of the Managing Committee. If the Renewal fees for a particular year are not paid, then the member is liable to pay Admission Fees again for Renewal in the subsequent year.

Delayed Renewal Members will be provided Pre Renewal GST Review subject to availability upon payment of such additional courier charges.

The details of Membership/Subscription Fees are given below for your ready reference

Type of Membership	Membership Fees incl. GST	Admission Fees Incl.GST	Subscription Charges for GST Review	Total
New Membership Application
Donor Member	2,36,000.00		800.00	2,36,800.00
Patron Member	1,77000.00		800.00	1,77,800.00
Life Member	11,800.00	1180.00	800.00	13,780.00
Life Member (Conversion from Ordinary)	11,800.00	590.00	800.00	13,190.00
Ordinary Local Member	2,006.00	590.00		2,596.00
Ordinary Outstation Member	1,711.00	590.00		2,301.00
Student Member	590.00	590.00		1,180.00

New Membership Application (Firm/LLP)

Ordinary Local Member	2,006.00	944.00	0	2,950.00
Ordinary Outstation Member	1,711.00	944.00	0	2,655.00

Advance Membership/ Subscription charges for subsequent Three years 2026-27 & 2028-29 (Non-Refundable)

Ordinary Local Member	5,428.00			5,428.00
Ordinary Outstation Member	4,602.00			4,602.00
Life Member (Individual/Firm/LLP)	0		2,400.00	2,400.00
Patron Member	0		2,400.00	2,400.00
Donor Member	0		2,400.00	2,400.00

Advance Membership/ Subscription charges for subsequent Five years (Non-Refundable)

Ordinary Local Member	8,968.00			8,968.00
Ordinary Outstation Member	7,670.00			7,670.00

Subscription for GST Review for F.Y. 2025-26 by Non-Members (Non-Refundable)

Subscription fees for GSTR

1,200.00

1,200.00

Advance subscription charges for GST Review by non-members for subsequent two years (Non-Refundable)

Subscription Fees -GSTR

0

2,400.00 2,400.00

Advance subscription charges for GST Review by non-members for subsequent Three years (Non-Refundable)

Subscription Fees -GSTR

0

3,600.00 3,600.00

Notes: –

1. Membership Fees are inclusive of GST.
2. The Subscription Charges are payable by only those life members, who wish to subscribe to the “GST Review”.
3. No subscription charges are payable by Ordinary Local/Outstation Member

Modes of Payment:-

Cheque	A/c Payee Cheque drawn in favor of “The Goods & Services Tax Practitioners’ Association of Maharashtra”payable at Mumbai.
NEFT Details	The Goods & Services Tax Practitioners’ Association of Maharashtra Bank of India, Mazgaon Branch Current Account No. 007020100001816, IFSC Code – BKID0000070.Online generated transaction Acknowledgement should be sent by email on [email protected] along with membership and payment details Members are requested to send their physical form to the association for Approval, Issuance and Office record.
Cash	Renewal form along with requisite amount will be accepted between 10.30 a.m. and 5.30 p.m. on all working days except Saturday at our Office at Mazgaon Library – Mazgaon: 1stFloor, 104, GST Bhavan, Mazgaon, Mumbai – 400 010 Or Bandra Library – GST Bhavan, Ground Floor, A Wing, Bandra Kurla Complex, Bandra (East), Mumbai – 400 051. Or Mazgaon Tower-8 & 9, Mazgaon Tower, 21, Mhatar Pakhadi Road, Mazgaon, Mumbai – 400 010.
Identity (New Members)	New Members should provide the following as Identity Proof : PAN, Aadhar Card, Constitution Document. Address Proof(any one) : Electricity Bill / Passport/ Aadhar Card / Driving License/ Voter id/ Ration Card along with Membership Form
Identity Card (For Renewals)	Ordinary Local/Outstation Members should provide Two Photographs along with the Renewal Form for issue of I- cards.
Online Payment Link	Members can make online payment on our website www.gstpam.org. Members are requested to download Members Renewal form from website. Update the latest details in the form, scan it and mail at email [email protected] Payment Link: https://www.gstpam.org/online/renew-membership.php If you are login first time? Click here for create your password

We value your continuation of the membership and look forward to your renewal to this effect.

Dated:- 18.07.2025

Rahul Thakar

Sunil Joshi

Hon. Jt.Secretary

 

ORDER FORM FOR GSTPAM REFERENCER 2025-26

(Members are requested to take out the photocopy of the Order Form for booking)

Scan with QR Scanner

For Office use only

Date	Receipt No.	Coupon No.	Amount

To

The Convenor,

GSTPAM Referencer Committee

The Goods & Services Tax Practitioners’ Association of Maharashtra Room No. 8 & 9, Mazgaon Tower, Mhatar Pakhadi Road, Mazgaon, Mumbai – 400 010

Dear Sir,

Please book my/our order of GSTPAM Referencer for the year 2025-26 as given below.

Sr.	Particulars	Price per copy if booked prior to 05th August 2025	Price per copy if booked after to 05th August 2025	Qty	Total RS.
1	GSTPAM Referencer 2025-26 Part I & II (GST, VAT & Allied Law Referencer & Updated GST Rate schedules).	700	750
2	Courier Charges (For Outstation members only) (per set)	130	130
3	Courier Charges (For Local members only) (per set)	110	110

Note:

1. Referencer will be published in Part I & II (for GST, VAT & Allied Laws Referencer & Updated GST rate schedules).

2. Applicants requiring more than 5 copies of the Referencer are required to give a request on their letter head along with the order form. Tax Practitioner’s Associations can place order in bulk quantity by making request on their letterhead signed by the Association’s President and Secretary.

3. Applicants will be issued receipt at the time of placing of their order. Applicants are requested to bring receipt at the time of taking the delivery of the Referencer. No delivery of the Referencer shall be given, unless the receipt for payment is submitted at the counter. If the receipt for payment is lost, than no delivery of the Referencer shall be given.

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drawn on……………………………………………… Bank Branch, Mumbai.

Signature …………………………….

 

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Note:

• Please fill in all the details in the above form and send the same to the GSTPAM’s office at Tower or at Mazgaon library along with requisite payment.

• For Direct Deposit / NEFT payment – Bank of India, Mazgaon – Account No. 007020100001817, IFSC Code – BKID0000070. Acknowledgement of the same should be sent by email: [email protected] along with duly filled form.

• Online Payment Link : https://www.gstpam.org/online/purchase-publication.php

• Please mention your name and membership number on the reverse side of the Cheque / Demand Draft.

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• The Cheque / DD should be drawn in the name of “THE GOODS AND SERVICES TAX PRACTITIONERS’ ASSOCIATION OF MAHARASHTRA

 

THE GOODS & SERVICES TAX PRACTITIONERS’ ASSOCIATION OF MAHARASHTRA

INTENSIVE STUDY COURSE CIRCULAR FOR THE YEAR 2025-26

Dear Professional Colleagues,

In GST, change is the only constant. With frequent amendments, evolving jurisprudence, and continuous clarifications through Circulars and Notifications, professionals are constantly expected to update, relearn, and adapt. The rapid pace of legislative and procedural changes, coupled with practical implementation challenges, underscores the importance of staying updated and well-informed.

Recognising this need, our Association has been regularly organising Intensive Study Circle (ISC) meetings as a platform for members to engage in in-depth discussions on complex and evolving issues under GST. These sessions aim not only to keep members abreast of the latest legal developments but also to provide a space for sharing practical experiences and resolving interpretational challenges.

Each ISC session is led by a Group Leader – a member who initiates and steers the discussion on the chosen topic. The deliberation is further enriched under the guidance of a Senior Professional, who moderates the discussion and offers insights drawn from years of experience.

Sessions are held virtually, usually on Fridays between 4:30 p.m. to 7:00 p.m., making it accessible to members across locations. Around 12 ISC sessions are planned for the academic year 2025-26.

The inaugural session of Intensive Study Circle will be held on Saturday, 23-08-2025 between 10:00 a.m. & 01.00 p.m. via virtual mode on the subject “RCM on Government Services – Interpretations, Issues & Insights”. The discussion will be led by CA. Umang Talati and monitored by CA. Deepak Thakkar.

The Annual Fee for subscription to the ISC 2025-26 is as follows:

• Members: Rs. 1,650/- + Rs. 297 (GST) = Rs. 1,947/-

• Non-members: Rs. 2,100/- + Rs. 378 (GST) = Rs. 2,478/-

• Payment link: https://www.gstpam.org/online/event-registration.php

We invite all of you to subscribe to the ISC sessions and take full advantage of this initiative aimed at true knowledge sharing. Let’s build a community where thoughtful dialogue drives professionalgrowth!

Any member interested in leading any group discussion is requested to inform us through the Enrolment Form and

contact the Convenor’s on Cell No. 9833892635 /9821121433/ 9860231333.

Notes:

1. Every attempt will be made to share the case studies / study material with the participants in advance.

2. Participants are requested to study the case studies / study material / relevant provisions to be discussed on the day of the meeting, which will be helpful in better participation and a fruitful discussion.

Deepali Mehta/ Dilip Nathani/ Anvesh Vakharia Co-Convenors

Aditya Surte Chairman

 

Enrollment Form for Intensive Study Circle Meetings for the Year 2025-26

To, Convener,

Intensive Study Course The GSTPAM, Mazgaon, Mumbai – 400 010.

Dear Sir,

Please enroll me as a participant for the Intensive Study Course for the year 2025-26. The Registration fees of Rs.1,947/- (for members) / and Rs.2,478/- (for non-members) 18% Including GST is enclosed herewith by Cash /DD / Cheque No.                      dated                    drawn on                      

Particulars of Member/Participant :

Name:                                                                                          

Educational Qualification:                                                                      

Address for Communication:                                                                   

Telephone No. Office :                                   Res.                                  

Email ID :                                       Mob. No,                                       

GSTPAM Membership No:                                                                      

GSTIN (if Applicable):                                                                          

Which is your preferred mode of attending the ISC Meeting?

1. In-Person
2. Virtual Mode
3. Hybrid Mode

Which is your preferred day and time for attending the Meeting?

1. Friday, 4.30 pm to 7.00 pm
2. Saturday, 10.30 am to 1.00 pm

I also wish to be a group leader for the subject of                                                                          and

suitable available date will be :                                                                                               

Signature                

Note :-

• Please issue the Cheque in favour of ”The Goods & Services Tax Practitioners’ Association of Maharashtra” (FULL NAME IS REQUIRED TO BE STATED ON THE CHEQUE AS PER RBI DIRECTION).

• For NEFT payment – Bank of India, Mazgaon- Account No. 007020100001816, IFSC – BKID0000070. Acknowledgement generated through online transaction should be emailed on [email protected] along with Enrolment Form and payment details.

• Online Payment Link: https://www.gstpam.org/online/event-registration.php

• Outstation members are requested to make payment online payment.

• The enrollment form along with payment proof should be submitted at Room No. 104, Vikrikar Bhavan, Mazgaon, Mumbai – 400010.

• Kindly carry the receipt of payment to attend the Lecture.

• The Association reserves the right to change and alter the schedule if required.

 

The Goods & Services Tax Practitioners’ Association of Maharashtra

jointly with

The Malad Chamber of Tax Consultants All India Federation of Tax Practitioner’s (AIFTP)

ENROLMENT FORM FOR 3rd BATCH OF GST BEGINNERS CERTIFICATE COURSE IN

ગુજરાતી FOR THE YEAR 2025-26

Virtual : – Zoom Platform

Enrolment Fee :– Rs.1,540/-(Inclusive 18%GST) for all participants.

Date :– Monday, 23rd February, 2026 onward

Name of the participant

…………………………………………………………………………………………………..

GSTPAM Membership Number……………………..

GSTTIN of Member……………………………………

Professional/Student……………………….

Address

……………………………………………………………………………………………………………………

Telephone:(O)………………..……………..®………………………..

E-mail ……………………………………………Mobile No. ……………………….…………………

Amount: Rs. …………………………………….Cheque No. …………………………

Bank……………………………………………… Branch……..…………………..

Dated………………………

Participant Details:

E-mail ……………………………………………Mobile No.…………………………

WhatsApp No. …………………………………….

Signature…………………….

Note:

• Deserving Interested Candidate will get a chance to participate in a Mega Moot Court Competition organised by GSTPAM

• Please issue the Cheque in favour of ‘‘The Goods & Services Tax Practitioners’ Association of Maharashtra’’ (FULL NAME IS REQUIRED TO BE STATED ON THE CHEQUE AS PER RBI DIRECTION).

• For NEFT payment – Bank of India, Mazgaon- Account No. 007020100001816, IFSC – BKID0000070.

  Acknowledgement generated through online transaction should be emailed on [email protected] along with Enrolment Form and payment details.

• Online Payment Link: https://www.gstpam.org/online/event-registration.php

• Outstation members are requested to make payment online payment.

• The enrollment form along with payment proof should be submitted at Room No. 104, GST Bhavan, Mazgaon, Mumbai – 400010.

• The Association reserves the right to change and alter the schedule if required.

Our members have an option to subscribe to our monthly academic magazine, “GST Review”, which is one of the oldest monthly publications on indirect tax laws in the Country. You get access to indepth articles, analysis and updates on all aspects of indirect tax laws by veteran experts. Latest notifications and circulars are also printed in the same for the benefit of the subscribers.

For the benefit of our readers we are reproducing the index of the topics covered in the last month. Subscription form is available in this News bulletin. Please take this opportunity and become our member and subscribe to the GST Review.

Contents Vol. 8 No. 5 | Mumbai | January, 2026 | GST REVIEW JOIN GSTPAM A MEMBER

Topic	Writer	Page No.
Part – I
Editorial	Mayur R. Parekh	05
From the President	Parth Badheka	08
Roving Eye	D. H. Joshi	10
GST Updates	Deepali Mehta	18
Ink that outlived its Era: Specially curated legacy articles		23
Celebrating 75th Year
My Journey with STPAM: A Grateful Reflection	Nitin Shah	41
The Xiaomi Customs Case: Unpacking IP Royalties in Valuation	Abhishek  Mitishkumar  Modi	43
Classification of Jelly Products under GST	Ratan Samal & Manohar Samal	49
Fresh recovery proceedings on same grounds for refund granted and affirmed in appeal on merits is unsustainable and without jurisdiction	Pranav Mehta	53
फिक्स डिपॉझिट वरील व्याज – जीएसटी	Amit Lulla	60
जीएसटी – तांत्रिक चुकांमुळे वाहन अडवणूक	Kishor Lulla	62
देशी-विदेशी सहलींवर जीएसटी कायदेशीर वास्तव	Kishor Lulla	65
जीएसटी पोस्ट सेल डिस्काऊंट बाबत शासनाकडून स्पष्टीकरण	Vinayak Agashe	69
Updates on Real Estate (Regulations & Development) Act, 2016	Ashwin Shah & Maitri Shah	71
Service Tax Updates	Vasudev Mehta	78
Income Tax Update – Highlights on Recent Amendments	SonakshiJhunjhunwala & Sunil Jhunjhunwala	81
Do You Know?	Moti B. Totlani	86
Replies to Queries	C. B. Thakar	88
Speaker’s Forum	D. J. Ruparelia Ashish Ruparelia	90
Representation & Response		99
Important Judgments		106
Association News	Rahul Thakar & Sunil Joshi	111
Part – II
From the Courts	Dhaval Talati	116
Gist of Advance Rulings	Ashit Shah	120
Part – II
Recent Amendments – Notifications/Trade Circulars
Notification No. 19/2025- Central Tax (Rate) New Delhi, the 31st December,2025		128
Notification No. 20/2025–Central Tax New Delhi, the 31st day of December,2025		129
CORRIGENDUM No. MGST-2025/C.R.-36/Taxation-1. dated the 19th December, 2025.		130
CORRIGENDUM No. MGST-2025/C.R.-36(1)/Taxation-1. dated the 19th December, 2025.		130
Advisory on Filing Opt-In Declaration for Specified Premises, 2025		130
Advisory & FAQ on Electronic Credit Reversal and Re-claimed Statement & RCM Liability/ITC Statement		132
Announcements
Announcement For New Membership, Renewal of Membership & Subscription For Year 2025-26		Page 115

“Wishing our members a very HAPPY BIRTHDAY!!”

Members Name	Date of Birth
Visharia Pankaj Goshar	11- February
Joshi Tushar Praful	11- February
Chavanke Sandeep Chandrakant	11- February
Jadhav Mahesh Bhagwan	11- February
Kokane Mahesh Eknath	11- February
Soni Mahendrakumar Murarilal	11- February
Dedhia Hasmukh K.	12- February
Hindivali Prakash Shivappa	12- February
Shah Hemal Pravinchandra	12- February
Hussain Mazhar Musharraf	12- February
Dedaniya Jigar Ratilal	12- February
Shah Rajesh Chimanlal	13- February
Bhatt Rameshkumar Shashivadan	13- February
Kulkarni Atul Vasant	13- February
Ruparelia Ashish Damodardas	13- February
Doshi Praful J.	14- February
Menon Subhash	14- February
Mundada Pravinkumar S.	14- February
Parihar Jayant Bastimal	14- February
Tripathy Satyabrata S	14- February
Surte Pramod Prabhakar	15- February
Shaikh Shakeel Ahmed	15- February
Vaishampayan Mukund Manohar	15- February
Gangaramani Mukesh Vasdev	15- February
Bajaj Harsh Nandlal	15- February
Chandak Piyush Premsukh	15- February
Savani A G	16- February
Arif Shafakat Sajjad	16- February
Nakade Manoj Ramnath	16- February
Suryavanshi Arjun Pandurang	16- February
Jaitapkar Yogesh Dipak	16- February
Porania Mansi Bharat	16- February
Chouhan Govind K	17- February
Desai Neelesh M.	17- February

Members Name	Date of Birth
Agrawal Ravi	17- February
Poojari Poojashree Gopal	17- February
Arkal Sagar Nagesh	17- February
Chaudhary Avachal Ganeshbhai	17- February
Agrawal Pankaj Shyamsunder	18- February
Agrawal Pankaj Shyamsunder	18- February
Dedhia Manisha K	18- February
Taparia Jitendra Shankarlal	18- February
Jadhav Suhas Sukadev	18- February
Deodhar Arya Pushkar	18- February
Rahane Dilipkumar Mrigendra	19- February
Gadhia Vijay Chandulal	19- February
Thakarar Deepak Gordhandas	19- February
Jain Vijaykumar Sarupchand	19- February
Mundada Vijay Badrinarayan	19- February
Doshi Biren Himatlal	19- February
Shah Vipul Jitendra	19- February
Dungarwal Rahul P	19- February
Gandhi Jasmit Hiralal	21- February
Shah Vipul Manaharlal	21- February
Joshi Kiran Kantilal	21- February
Patel Geeta Hemant	22- February
Vasa Ketan Manharlal	22- February
Acharekar Rupesh Laxman	22- February
Chande Ankit Kishor	22- February
Bapat Sanket Deepak	22- February
Dixit Dilip Shriniwas	23- February
Varde Vishwas Jaywant	23- February
Kothadiya Sanjeev Sharao	23- February
Desai Vimal Dolatrai	23- February
Chitre Kiritkumar Vasant	23- February
Thakkar Pradip Kalidas	23- February
Darji Mittal Ramesh	23- February
Beriwala Neha	23- February

Members Name	Date of Birth
Bhutada Ramratan Kashiram	24- February
Parikh Rajesh Chimanlal	24- February
Wagh Sunilkumar Madhukar	24- February
Joseph Jeberson Samuel	24- February
Mir Jawedali Yaqubali	24- February
Baldi Pawan Satynarayan	24- February
Kasare Atesh Ashok	24- February
Khan Gulam Mujtaba Muslim	24- February
Jhaveri Sanjiv Piyush	25- February
Mahaldar Arun Hardeo	25- February
Kharat Anil Dhondiram	25- February
Dudani Sanjeev Anand	25- February
Panchal Umang Vasantlal	25- February
Salvi Kunal Vithal	25- February
Nagla Pawankumar Madhusudan	25- February
Bardia Saket	25- February
Solanki Jagdish Ratanlal	25- February
Khandelwal Sanket Sunil	25- February
Daga Rajendra K	26- February
Vora Mahendra K.	26- February
Desai Rajesh N	26- February
More Sanjay Govind	26- February
Magar Subodh J	26- February
Chandidas Ajaykumar Avinash	26- February
Jain Popatalal Seshmal	27- February
Darji Bharat Kasturbhai	27- February
Chachra Gulab Inderlal	27- February
Prajapat Dharmendra Bhooraram	27- February
Nachanekar Mahesh Suryakant	27- February
Siddiqui Mohammed Ali	27- February
Adavadkar Milind P	28- February
Assawa Shiwbhagwan Chaturbhuj	28- February
Lingsur Ramakrishna Raghavendra	28- February
Manek Nilesh Bharat	28- February
Gaikwad Anand Murlidhar	28- February

Members Name	Date of Birth
Palan Bhavesh S.	28- February
Makani Adeeb Ayaz	28- February
Upadhye Z. J.	01- March
Bodake M. B.	01- March
Parte Shobhana Bhalchandra	01- March
Sheth Chetan Narendrakumar	01- March
Pednekar Rajesh Kashinath	01- March
Pawar Samir Vishnu	01- March
Chauhan Somesh H	01- March
Apoorav G. Mohanlal	01- March
Karangutkar Siddhesh Anil	01- March
Shaha Vrindavan G	02- March
Nachankar Ritesh Ravindra	02- March
Jain Vijay Mangilal	03- March
Patel Bharat Ranchhod	03- March
Bhagwat M P	03- March
Srivastav Vinod C	03- March
Kanapade Sudesh Vishnu	03- March
Pawar Jyoti Sanjay	03- March
Jadhav Nilesh Rajendra	03- March
Mehta Sujoy Pankaj	03- March
Gupta Manisha	03- March
Shetty M D	04- March
Bapatla Venkata Raja	04- March
Kolpe Raosaheb Dhondiba	04- March
Khandwala Mihir H.	04- March
Parmar Vishal Parasmal	04- March
Doshi Bijal Rajesh	04- March
Jambhekar Shweta Vinayak	04- March
Bhuptani Bhavesh Chandrakant	05- March
Matekar Dadasaheb B	05- March
Kale Subhash Laxman	05- March
Mistry Sandeep Bhagwanji	05- March
Hinduja Ajeet Singh Ranjeet Singh	05- March
Chhajed Kamlesh Sayarchand	05- March

Members Name	Date of Birth
Shukla Satish Devnarayan	05- March
Patil Virendrakumar K	05- March
Tonge Pratik Dilip	05- March
Vatnani Jai Moti	06- March
Nagal Lata Leeladhar	06- March
Eriya Ilsha P. Joseph	06- March
Udani Roopa	06- March
Surte Shirish P	07- March
Patil Subhash Daga	07- March
Deshpande Atul Vishwanath	07- March
Jadhav Sachin Vitthal	07- March
Magar Nishikant Bapusaheb	07- March
Ransinga Amol Vitthal	07- March
Sheth Dinesh N	08- March

Members Name	Date of Birth
Jhunjhunwala Prakash G.	08- March
Mundada Gopal Ramvilas	09- March
Bhanushali Rajendra N.	09- March
Gurav Pramod Anant	09- March
Bhanushali Mahendra B.	09- March
Patil Komal Kailas	09- March
Rathi Dilip Narayandas	10- March
Karpe Venayack Baburao	10- March
Chulawala Manish Bhupendra	10- March
Balkawade Santosh R.	10- March
Parsewar Laxmikant Bhalchandra	10- March
Patil Rhushikesh Chandrakant	10- March
Jain Sachin Mahendrakumar	10- March

OUR PUBLICATIONS AVAILABLE FOR SALE

Sr. No.	Name	Price
1	FMCG & Pharmaceutical Industry – GST Issues & Challenges	150/-
2	Mega Full Day Seminar Booklet 6.5.2023	120/-
3	Short Publication GST practical guides (5 Book Series)	555/-
4	47th RRC Lucknow Booklet	250/-
5	Mega Full Day Seminar Booklet 9.2.2024	150/-
6	48th RRC Book	250/-
7	Mega Full Day Seminar Booklet 6. 7.2024	130/-
8	Half Day Seminar Booklet 22.11.2024	100/-
9	Writ Remedies Under Indian Constitution	150/-
10	Referencer 2025-26	750/-
11	GST Beginners Book 2025	350/-
12	50th RRC Book	250/-

Payment Link for Publication on Sales : https://www.gstpam.org/online/purchase-publication.php

GSTPAM News Bulletin Committee for Year 2025-26

Parth Badheka President

Jatin Chheda Chairman

Pratik Satyuga Co. Convenor

Aloke R. Singh Co. Convenor