Monthly Tax Bulletin: September 2026

Key highlights:

Direct taxes:

• The CBDT issues a guidance note on crypto-asset reporting obligations under Section 509 of the Income-Tax Act, 2025.
• The CBDT releases an updated Guidance Note on FATCA and CRS under Section 508 of the Act.
• The Taxation and Other Laws (Amendment) Act, 2026, has been passed by the Parliament.
• The Supreme Court dismisses the assessee’s SLP, upholds the disallowance of bogus share trading losses.

Transfer pricing:

• The ITAT permits separate benchmarking and Berry Ratio for high-seas distribution, along with aggregation under TNMM confined to closely linked transactions.
• The ITAT excludes acquisition-created goodwill amortisation from operating costs; prioritises economic function over accounting classification.

FEMA:

• The Reserve Bank of India proposes a revamped foreign investment framework.

Indirect taxes:

• The SC affirms that the omission of Rule 96(10) applies to all pending refund proceedings in the absence of a saving clause.
• The SC dismisses the Revenue’s review petition; the supplier’s ITC entitlement on telecom towers has been upheld.
• The SC holds that mere allegations of fraud cannot justify the invocation of Section 74.
• No GST on corporate guarantees before 26 October 2023; a deemed 1% valuation cannot override the actual consideration.
• The government of Maharashtra notifies the operational guidelines for the implementation of the Maharashtra Global Capability Centre (GCC) Policy, 2025.
• The Skoda Auto Volkswagen India classification dispute to be heard afresh by the Bombay HC after release from the reserved judgement.

Monthly Tax Bulletin: September 2026

The tax and regulatory environment continues to evolve rapidly, with significant developments on both judicial and legislative fronts. To keep you ahead of these developments, we present the September 2026 edition of the Grant Thornton Bharat Monthly Tax Bulletin. This edition provides a concise summary of key developments in direct taxes, FEMA, transfer pricing and indirect taxes for August 2026.

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