Analysis of Notifications and Circulars for Week ending 27th April 2025
                     Analysis of Notifications and Circulars for Week ending 27th April 2025
Summary: 
During the week of April 21st to 27th, 2025, various tax and regulatory bodies issued significant notifications and circulars. In Income Tax, 
CBDT mandated TCS on ten new goods exceeding ₹10 lakh per transaction and updated Form 27EQ for reporting. Exemptions were 
granted to the National Mission for Clean Ganga and the Mysore Palace Board. Expenses for settling violations under SEBI, Competition, 
and Depositories Acts are now disallowed as business expenditure. The Supreme Court directed courts to report cash transactions above 
₹2 lakh to the Income Tax Department. For GST, the Goods and Services Tax Appellate Tribunal (Procedure) Rules 2025 were notified. 
The Supreme Court ruled against state rules inconsistent with central CST rules and disallowed ITC on exempt UP VAT sales. The Mumbai 
High Court clarified no GST on development agreements without TDR/FSI transfer. AAR Maharashtra issued rulings on GST applicability 
for a cancer test, a backward class girls’ hostel rent, a geometry compass box, and geomembrane. Central Excise saw no new 
notifications. In Customs, Rohini Yard Jetty was added as a custom port, and tariff values were fixed for edible oils, brass scrap, areca nut, 
gold, and silver. Authorities were appointed for SCN adjudication, and transhipment application fees were removed. Safeguard duty was 
imposed on certain steel imports from China and Vietnam. Guidelines for ‘Proof of Origin’ replaced ‘Certificate of Origin’, and procedures 
for air cargo movement and transhipment were simplified. NFFRL Kathmandu was recognized for food export analysis, and CITES permit 
exemptions for limited agarwood export were clarified. The Attari ICP was closed. The Supreme Court clarified the retroactive 
application of overruled NDPS judgments. DGFT extended MIP on certain synthetic knitted fabrics and introduced a ‘Mode of Export of 
Services’ field in eBRC. Inputs were sought for SCOMET export amendments for testing, and a new SION was issued for Doxycycline 
tablets. SEBI amended REITs and Credit Rating Agencies regulations, extended trading window closure to relatives of designated persons, 
changed NAV cut-off timings for overnight mutual funds, and issued draft circulars on LODR and ODR relaxations. MCA had no new 
releases. IBBI suspended two IPs for misconduct and NCLAT addressed insolvency initiation and liquidation. RBI issued guidelines on 
minor deposit accounts, reviewed LCR haircuts and run-off rates, mandated migration to the ‘.bank.in’ domain, amended FEMA 
compounding directions, relaxed norms for exports to ‘Bharat Mart’ UAE, extended the timeline for BIS note sorting machine standards, 
capped FEMA compounding amounts, and issued Master Directions on FEMA compounding and incentives for the Currency Distribution 
& Exchange Scheme. The Supreme Court clarified the distinction between copyright and design for industrial works and empowered 
courts to decide interest rates in the absence of agreement.
A. Income Tax TCS to be collected on 10 new items notified: CBDT has notified certain specified goods on which 
Tax Collection at Source (TCS) shall be applicable. It shall apply where the value of goods exceeds Rs 10 
Lakh per transaction. The rate of TCS is 1%. The obligation to collect TCS is on the seller of the specified 
goods. The newly notified Goods are 1. Wrist watches, 2. Art pieces (e.g., antiques, paintings, sculptures), 
3. Collectibles (e.g., coins, stamps), 4. Yachts, rowing boats, canoes, helicopters, 5. Sunglasses, 6. Bags 
(e.g., handbags, purses), 7. Shoes, 8. Sportswear and equipment (e.g., golf kits, ski-wear), 9. Home theatre 
systems, and 10. Horses for horse racing and polo. (Income Tax Notification 36/2025 Dated 22/04/2025) 
CBDT amends form No. 27EQ, added 10 new items for TCS Reporting: The return Form 27EQ has been 
updated to include collection at source on the sale of items such as wrist watches, art pieces (antiques, 
paintings, sculptures), collectibles (coins, stamps), yachts, rowing boats, canoes, helicopters, sunglasses, 
bags (handbags, purses), shoes, sportswear and equipment (golf kits, ski-wear), home theatre systems, 
and horses for racing and polo. (Income Tax Notification 35/2025 Dated 22/04/2025) Exemptions 
to National Mission for Clean Ganga: National Mission for Clean Ganga, an authority constituted under the 
Environment (Protection) Act, 1986 has been notified under section 10(46A) for exemption on its 
income, provided the authority continues to operate for the specified purposes under Section 10(46A) (a) 
of the Income-tax Act. (Income Tax Notification 37/2025 Dated 22/04/2025)
Expenses for settlement of SEBI, Competition, Depositories Act violations not allowable: The notification 
provides that expenses incurred to settle legal proceedings related to contraventions or defaults under 
certain laws will not be considered business or professional expenditures. Consequently, no deduction will 
be allowed for such expenses. The listed laws include the Securities and Exchange Board of India Act, 1992, 
the Securities Contracts (Regulation) Act, 1956, the Depositories Act, 1996, and the Competition Act, 2002. 
(Income Tax Notification 38/2025 Dated 23/04/2025) Exemptions to Mysore Palace Board: The Mysore 
Palace Board, a Board established under the Mysore Palace (Acquisition and Transfer) Act, 1998, has been 
notified under section 10(46) for exemption on its income arising from Income from Palace or proceeds of 
any property vested in the Board, fees and charges, rent and interest on bank deposits. (Income Tax 
Notification 39/2025 Dated 24/04/2025) SC, Report & probe cash transactions exceeding ₹2 Lakh under 
section 269ST: Case of The Correspondence RBANMS Education Institution vs B Gunashekhar, SC 
Judgement Dated 16th April 2025. The apex court held that whenever, a suit is filed with a claim that Rs. 
2,00,000/- and above is paid by cash towards any transaction, the courts must intimate the same to the 
jurisdictional Income Tax Department to verify the transaction and the violation of Section 269ST of the 
Income Tax Act, if any the courts must intimate the same to the jurisdictional Income Tax Department to 
verify the transaction. (SC Judgement Dated 16/04/2025)
B. GST Goods and Services Tax Appellate Tribunal (Procedure) Rules 2025: The rules have been notified to establish a 
structured and efficient framework for the functioning of the Goods and Services Tax Appellate Tribunal. The rules are 
effective from 24th  April 2025. The procedural framework is divided into 11 chapters, encompassing 70 distinct rules 
and four designated forms, with the objective of promoting uniformity, procedural clarity, and digital efficiency in the 
functioning of the Tribunal. (Fin Min Notification Dated 24/04/2025) SC, State Government cannot frame rules 
inconsistent with Central Rules under CST Act: Case of State of Rajasthan vs Combined Traders, SC Judgement Dated 
16th April 2025. The apex court held that State Government cannot frame rules in exercise of power under Section 
13(3) of the Central Sales Tax Act (CST Act), which will be inconsistent with the rules framed by the Central Government 
in exercise of powers under Section 13(1) of the CST Act. (SC Judgement Dated 16/04/2025)  SC, ITC Disallowed on 
exempt sales under section 7(c) of UP VAT Act: Case of Neha Enterprises vs Commissioner Commercial Taxes, SC 
Judgement Dated 9th April 2025. The apex court held that as per section 13(7) of the Uttar Pradesh Value Added Tax 
Act, 2008 (UP VAT Act), input tax credit will not be allowed to a dealer with respect to the purchase of any goods where 
the sale of such goods by the dealer is exempt from tax under Section 7(c) of the Act. (SC Judgement Dated 
09/04/2025)  HC, No GST on Development Agreements Without TDR/FSI Transfer: Case of Srinivasa Realcon Private Ltd 
vs DC Anti-evasion CGST, Mumbai HC Judgement Dated 08th April 2025. HC has provided an significant ruling for 
homeowners and landowners involved in redevelopment projects. The court clarified that GST is not applicable in 
specific Joint Development Agreement (JDA) scenarios where development rights are not sold. The court held that in 
situations where the landowner does not sell development rights but merely appoints a developer to construct on their 
land, GST is not applicable under Entry 5B. This is because there is no supply of service in the form of TDR (Transfer of 
Development Rights) or FSI (Floor Space Index) transfer. (HC Mumbai Judgement Dated 08/04/2025)
AAR, Biotech’s Cancer Test not exempt from GST: Case of Epigeneres Biotech Private Limited, AAR Maharashtra Ruling Dated 27th 
March 2025. AAR ruled that the provision of diagnostic services by the applicant would not qualify for exemption from GST 
under Entry, No.74 of notification No.12/2017 dated 28th June 2017. The Service Tax Accounting Code (SAC) 9981 would 
become relevant in this case. (AAR MH Ruling Dated 27/03/2025) AAR, Renting Residential Building for Backward Class Girls 
Hostel is GST Exempt: Case of Ravindra Navnath Satpute (Dewoo Engineers), AAR Maharashtra Ruling Dated 27th March 
2025. AAR ruled that service provided by the applicant to the Social Justice and Special Assistance Department, Govt of 
Maharashtra qualifies to be an exempted supply of pure services vide serial no 3 of notification 12/2017. As the subject 
transaction has been held to be exempt from the levy of GST, TDS under Section 51 of the CGST Act, 2017, will not be 
applicable. (AAR MH Ruling Dated 27/03/2025)  AAR, Geometry Compass Box is a Mixed Supply, Taxable at 18%: Case of 
Amardeep Udyog, AAR Maharashtra Ruling Dated 26th March 2025. AAR ruled that the Geometry Compass Box supplied by 
the applicant to BMC amounts to mixed supply under section 2 (74) and is appropriately classifiable under Chapter Sub 
Heading 90178010, being HSN of the goods that attracts highest rate of tax. The rate of GST applicable would be 18% (9% 
CGST + 9% SGST). (AAR MH Ruling Dated 26/03/2025) AAR, Geomembrane for Waterproof Lining Under Textile Chapter 59, 
Attracts 12% GST: Case of Lamifab and papers Private Limited, AAR Maharashtra Ruling Dated 26th March 2025. AAR ruled 
that Geo Membrane for Water Proof Lining is classifiable under Tariff item 59111000.  GEO Membrane laminated HDPE 
woven polymer lining attract (4) 12% GST. (AAR MH Ruling Dated 26/03/2025)  C. Central Excise No Notifications/ Circular 
during the week.
B. Custom Duty Customs added Rohini Yard Jetty, Rohini Village, Raigad as custom port: The notification add Rohini Yard Jetty, Rohini Village, Raigad in 
Maharashtra as new custom port. (Custom Notification 27/2025 (NT) Dated 22/04/2025) 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. 24th April 2025. The tariff value for crude palm oil is set at USD 1153 per metric ton, while gold and silver have tariff values of 
USD 1106 per 10 grams and USD 1045 per kilogram, respectively. The tariff value for areca nuts is fixed at USD 6970 per metric ton. (Custom 
Notification 28/2025 (NT) Dated 23/04/2025) SCN Adjudication Authorities appointed: The notification appoints officers to handle the 
adjudication of show-cause notices (SCNs) as detailed in Annexures I to VII. It specifies the officers who will exercise the powers and duties of the 
Commissioner of Customs, Nhava Sheva–V, Mumbai Customs Zone–II, for adjudicating the notices listed in the annexures. (Custom Notification 
29/2025 (NT) Dated 24/04/2025) No fees for transhipment applications at customs stations: The notification amends the Goods Imported 
(Conditions of Transhipment) Regulations, 1995. It provides that no fees will be applicable for applications concerning the transhipment of 
imported goods across all customs stations. (Custom Notification 30/2025 (NT) Dated 24/04/2025) Safeguard duty imposed on Non-Alloy and 
Alloy Steel Flat Products: The notification imposes safeguard duty on Non-Alloy and Alloy Steel Flat Products namely (a) Hot Rolled coils, sheets 
and plates, (b) Hot Rolled Plate Mill Plates, (c) Cold Rolled coils and sheets, (d) Metallic Coated Steel coils and sheets, whether or not profiled, 
including Galvanneal, Coated with Zinc or Aluminium-Zinc or Zinc-Aluminium-Magnesium, and (e) Colour Coated coils and sheets, whether or not 
profiled, imported from China and Vietnam. It shall be effective for a period of two hundred days. (Custom Notification 01/2025 (SG) Dated 
21/04/2025) Guidelines replacing ‘Certificate of Origin’ with ‘Proof of Origin’: The circular amend guidelines related to the Customs 
(Administration of Rules of Origin under Trade Agreements) Rules. The notification 14/2025 which replaced ‘Certificate of Origin’ with ‘Proof of 
Origin’ to align with the amended Section 28DA of the Customs Act, reflecting a global shift towards self-certification. Proof of Origin now 
encompasses both certificates issued by designated authorities and self-declarations by eligible exporters. The type of proof of origin required will 
depend on the specific trade agreement. (Custom Circular 14/2025 Dated 21/04/2025) Simplification of procedures related to Air Cargo 
Movement & Transhipment: The key changes include the removal of the Rs. 20 Transhipment Permit fee to reduce compliance burdens and the 
introduction of a more standardized procedure for the movement of Unit Load Devices (ULDs) outside Customs areas. ULDs can now be 
temporarily imported with tracking devices, subject to compliance with security regulations. It also highlights the use of a National Transhipment 
Bond to simplify transhipment procedures and the activation of an ICEGATE facility to facilitate transhipment requests, eliminating the need for 
physical visits to service centres. (Custom Circular 15/2025 Dated 25/04/2025)
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