Monthly Tax Bulletin: December 2025

Key highlights:

Direct taxes:

• The Ministry of Finance (MoF) notifies revised Double Taxation Avoidance Agreement (DTAA) and protocol between India and Qatar.
• The MoF notifies the enforcement of the amending protocol to the DTAA between India and Belgium.
• The Supreme Court (SC) dismisses the Revenue’s special leave petition (SLP) on the interpretation of the word ‘received’ under Section 153(2A) of the IT Act as ‘having knowledge’.

Transfer pricing:

• The ITAT adopts an ‘interest saving method’ to arrive at a fair corporate guarantee estimation; rejects the CIT(A)’s adoption of 1%.

FEMA:

• The RBI extends export realisation and shipment timelines.

Indirect taxes:

• The centre introduces twin bills to overhaul the excise duty and compensation cess structure for tobacco and specified goods.
• The J&K HC rules that cross-LoC trade constitutes intra-state supply under GST.
• The Cabinet approves the Export Promotion Mission and Credit Guarantee Scheme for exporters to strengthen India’s export competitiveness.
• The US Supreme Court hears a challenge to US President Donald Trump’s tariff powers under the IEEPA.

Monthly Tax Bulletin: December 2025

The December 2025 edition of the Grant Thornton Bharat Monthly Tax Bulletin captures key developments under the direct taxes, transfer pricing, indirect taxes, and FEMA, for November 2025.

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