Circular No. 212/6/2024-GST dated June 26, 2024, has been withdrawn

In order to ensure uniformity in the implementation of the provisions of the law across field formations, CBIC withdraws, circular No. 212/6/2024-GST dated 26th June, 2024.

Therefore, the procedure prescribed vide the aforesaid circular for providing evidence of compliance of conditions of Section 15(3)(b)(ii) shall not be required.

Consequently, it is no longer mandatory for post-sale discount to be established per an agreement executed on or before the date of supply.  

Consequently, it is no longer mandatory for post-sale discount to be established per an agreement executed on or before the date of supply.  

Circular No. 253/10/2025 – GST dated 1st October, 2025

Cheque Truncation System (CTS) – Continuous Clearing

As per the recent RBI announcement, Continuous Clearing of Cheques i.e., same-day cheque clearance, will be implemented across all Banks effective October 4, 2025, post which cheques issued by/to all customers will get debited/credited within a few hours
 Benefit of Continuous Clearing: Cheques deposited during the day will be credited on the same day, provided they are deposited within the stipulated cut-off time at the depositing branches.
 This directive is issued under Section 10 (2) read with Section 18 of Payment and Settlement Systems Act, 2007 (Act 51 of 2007).
 Time available for inward processing:
  1. During phase 1 (From October 4 to January 2, 2026), drawee banks shall be required to confirm (positively / negatively) cheques presented on them latest by end of confirmation session (i.e. 7:00 PM) else those will be deemed to have been approved and included for settlement. Item expiry time for all cheques shall be set as 7:00 PM in phase 1.
  2. In Phase 2 (from January 3, 2026), the item expiry time of cheques shall be changed to T+3 clear hours. For example, the cheques received by drawee banks between 10:00 AM and 11:00 AM will have to be confirmed positively or negatively by them by 2:00 PM (3 hours from 11:00 AM). Cheques for which confirmation is not provided by the drawee bank in the prescribed 3 hours shall be treated as deemed approved and included for settlement at 2:00 PM.

Pre-Deposit in case of Penalty order

With reference to Notification No. 16/2025- Central Tax dated September 17, 2025, in case of any Order demanding penalty without involving demand of any tax, no appeal shall be allowed to be filed unless a sum equal to 10% of the said penalty has been deposited by the appellant.This change will be implemented from 1st October, 2025. If any company has already receive such notices, it seems to be wise decision to file appeal by the end of September 2025 to avoid pre-deposit for filing appeal.

Implementation Timeline for GST Rate Changes

Timelines of GST rate changes recommended by 56th GST Council Meeting held on 03.09.2025:-

22nd September 2025

Implementation of GST rate changes on Services

22nd September 2025

Implementation of GST rate changes on all Goods except Tobacco products

To be decided

Pan Masala, gutkha, cigarettes, chewing tobacco products, unmanufactured tobacco and bidi will continue at existing rates until compensation cess obligations are discharged

1st November 2025

Operationalization of risk-based provisional refund system

End of September 2025

GST Appellate Tribunal to start accepting Appeals

End of December 2025

GST Appellate Tribunal to commence hearings

The Union Finance Minister and Chairperson of the GST Council will decide the actual date of transition to revised rates

As per the decisions taken, the GST rates of 12% and 28% have been removed by making changes in the GST rate structure of various items. Please note that these changes, along with other recommendations, will come into effect only upon issuance of the official notifications by CBIC.

Relief to Tax Deductors in respect of INOPERATIVE PAN

CBDT vide Circular No 9/2025, dated July 21, 2025, in partial modification of its earlier Circular No. 3 of 2023 w.r.t cases where PANs of deductees/collectees were inoperative, gives relief to deductors who committed default of ‘short deduction/ collection’, in these cases.

(i) Where the amount is paid or credited from 01.04.2024 to 31.07.2025 and the PAN is made operative (as a result of linkage with Aadhaar) on or before 30.09.2025,

(ii) Where the amount is paid or credited on or after 01.08.2025 and the PAN is made operative (as a result of linkage with Aadhaar) within two months from the end of the month in which the amount is paid or credited.

Amendments to Directions – Compounding of Contraventions under FEMA 1999

Reserve Bank of India’s (RBI) updated Master Directions on Compounding of Contraventions under the Foreign Exchange Management Act, 1999 (FEMA), issued on April 22, 2025, vide Notification No. RBI/FED/2025-26/135, FED Master Direction No.04/2025-26) and amended via RBI/FED/2025-26/32, A.P. (DIR Series) Circular No. 04/2025-26 dated April 24, 2025. The said guidelines aim to streamline the compounding process, promote voluntary compliance, and enhance transparency in handling FEMA violations.

Below is a summary of the key aspects in reference to the Master Directions:

1. What is Compounding?


Compounding is a process that allows individuals or entities to voluntarily admit breaches of FEMA provisions, plead guilty, and seek redressal by paying a penalty.

This simplifies resolution, minimizes legal proceedings, and ensures compliance.

2. Key Updates in the Master Direction:

• Revised Compounding Rules: The Foreign Exchange (Compounding Proceedings) Rules, 2024, notified on September 12, 2024, have replaced the Foreign Exchange (Compounding Proceedings) Rules, 2000,

introducing higher monetary limits for compounding authorities and modernized payment methods.
• Application Process: Applications for compounding can be submitted physically or via the RBI’s PRAVAAH Portal with a fee of ₹10,000 plus GST. The application must include details such as foreign direct investment, external commercial borrowings, or branch/liaison office activities, along with an undertaking that the applicant is not under investigation by the Directorate of Enforcement (DoE).
• Compounding Authorities: The RBI’s Regional Offices and the Foreign Exchange Department (FED), CO Cell in New Delhi, are authorized to handle compounding applications.

• Non-Compoundable Cases: Contraventions involving unquantifiable amounts, serious offenses like money laundering, terror financing, or those already adjudicated by the DoE are not eligible for compounding.

Repeated contraventions within three years or cases under DoE investigation may also be ineligible.
• Payment of Penalty: The compounding amount, as specified in the order, must be paid within 15 days via demand draft or NEFT or RTGS or other permissible electronic modes in favor of the RBI. Failure to pay deems the application invalid, potentially leading to DoE referral.
• Compounding Matrix: A refined matrix provides transparency in calculating penalties, considering factors like undue gains, loss caused, and the contravener’s conduct. For non-reporting contraventions, the compounding authority may cap the penalty at ₹2,00,000 per contravention in exceptional cases, promoting a less punitive approach for technical lapses.
• Certificate of Compliance: Upon payment, the RBI issues a certificate confirming compliance with the compounding order.

It may be ensured that intimation of payment of application fee, to respective Regional Office, CO Cell, or Central Office, as the case may be. The compounding application must be accompanied by the payment details including the UTR number evidencing the payment of the application fee.

Please refer to the RBI’s official guidelines at https://www.rbi.org.in or contact the RBI’s Foreign Exchange Department for further details.

Disclaimer: This is for informational purposes only and does not constitute legal advice.

Madras High Court: Tax Officers Must Apply Mind Not Treat GST Notice Service as Formality

Tvl. Metro Computers, the applicant, contested the assessment order based on all the prior notices that have been uploaded only on the GST portal under the “View Additional Notices and Orders” section.

The applicant was not informed about these notices and, therefore, cannot submit a reply in time. They said that they desired to file 25% of the disputed tax and asked for the chance to show their case afresh.

The bench said that “No doubt, sending notice by uploading in portal is a sufficient service, but, the Officer who is sending the repeated reminders, inspite of the fact that no response from the petitioner to the show cause notices etc., the Officer should have applied his/her mind and explored the possibility of sending notices by way of other modes prescribed in Section 169 of the GST Act, which are also the valid mode of service under the Act, otherwise it will not be an effective service, rather, it would only fulfilling the empty formalities.”

Hon’ble Madras High Court overturned the original tax order and sent the case back to the GST officer, but with conditions: –

The petitioner must pay 25% of the disputed tax within four weeks

After that, they must submit a reply within three weeks

A personal hearing will be arranged

A new decision will be made based on the facts, not just formality

However, it is always advisable to tax payers to keep logging into GST portal periodically to avoid such incident.

Shares to be dematerialized by 30th June, 2025

Referring to the MCA notification dated October 27, 2023, and February 12, 2025, regarding the issuance of securities in dematerialized form by Private Companies and facilitating the dematerialization of all their Securities.

Following the amendment to the Companies (Prospectus and Allotment of Securities) Second Amendment Rules, 2023, a new rule has been inserted after rule 9A, known as “9B – Issue of Securities in Dematerialized Form by Private Companies.” This rule mandates that:

1. Every Private company, except for small companies, shall issue securities exclusively in dematerialized form and facilitate the dematerialization of its securities, in accordance with the provisions of the Depositories Act, 1996, and the accompanying regulations.

2. Private companies that are not considered small companies, as per audited financial statements ending on or after March 31, 2023, must comply with this rule by June 30, 2025

3. Private companies referred to in sub-rule (2), making any offer to issue securities, buyback securities, or issue bonus shares or rights offers after the compliance date must ensure that the entire holding of securities of its promoters, directors, and key managerial personnel is dematerialized in accordance with the Depositories Act, 1996, and related regulations.

4. Any holder of securities of a private company referred to in sub-rule (2) who intends to transfer such securities after the compliance date must dematerialize them before the transfer. Also, anyone subscribing to securities of the concerned private company after the compliance date, whether by private placement, bonus shares, or rights offers, must ensure that all their securities are held in dematerialized form before such subscription.