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✦ TRUSTFACTON ✦

INDIA TAX & COMPLIANCE BULLETIN

INCOME TAX  |  GST  |  MCA  |  RBI  |  LABOUR

✦ WEEK OF 29 JUNE 2026 ✦

CATCH-UP EDITION:   Three weeks of dense regulatory action condense into one bulletin. Tomorrow, 30 June 2026, is the absolute deadline for filing backlog GSTAT appeals against orders communicated before 1 April 2026, even though the GSTAT portal became fully operational only on 15 June. The relaxed scrutiny window has been extended to 31 December 2026, but the limitation date itself is not extendable, and the GSTAT Bar Association's representation seeking extension to 31 December has not been accepted as of this writing. On direct tax, the ITR-3 utility went live on 19 June for AY 2026-27 filers with business or professional income, and the Finance Act 2026 has extended the non-audit due date from 31 July to 31 August 2026. CBDT has also released FAQs on Form 27 under the IT Act 2025, the new mandatory reporting form for partnership and LLP reconstitution events. On the RBI side, the central bank has rationalised the Authorised Person framework under FEMA through the new Regulations 2026 and a follow-up circular dated 5 June 2026. The 30 June deadline cluster also includes DPT-3, DIR-3 KYC, and the Section 143(2) notice service window for FY 2025-26 returns.

INDIRECT TAX

GST Updates

URGENT  |  GSTAT  |  SEC 112 CGST ACT  |  DEADLINE 30 JUN 2026

GSTAT Backlog Appeal Deadline Is Tomorrow: Portal Operational Only Since 15 June, Scrutiny Relaxation Till 31 December, but the Limitation Date Itself Is Not Extendable

The statutory deadline for filing backlog appeals before the Goods and Services Tax Appellate Tribunal (GSTAT), in respect of orders communicated by First Appellate Authorities under Section 107 or Revisional Authorities under Section 108 of the CGST Act, 2017, before 1 April 2026, is 30 June 2026. The cut-off was notified by the Ministry of Finance through Notification S.O. 4220(E) dated 17 September 2025 under Section 112(1) of the CGST Act, and is a one-time relaxation arising from the recommendation of the 56th GST Council. Estimates from the GSTAT Bar Association place the pending backlog at approximately 4.8 lakh appeals across India. Operationally, the GSTAT e-filing portal has been live only since 15 June 2026, leaving a compressed two-week runway for the entire backlog. Appeals filed after 30 June require a separate condonation application under Section 112(6), which the Tribunal may admit only on sufficient cause and within a limited statutory condonable period. Beyond that, the right of appeal is permanently lost.

An important distinction has emerged in the past fortnight that practitioners should not misread. The GSTAT Principal Bench order dated 14 May 2026 extended the relaxed procedural scrutiny framework to 31 December 2026, in continuation of the earlier Office Order No. 16/2026 dated 20 January 2026. This extension applies only to the scrutiny of filed appeals and the manner in which defects of form are treated; it does not extend the limitation period for filing. The GSTAT Bar Association, Delhi has separately represented to the CBIC seeking extension of the 30 June statutory deadline to 31 December 2026, citing portal issues including payment gateway failures via Bharatkosh, Aadhaar authentication errors, DSC validation problems, and document upload restrictions. As of 29 June, no extension notification has been issued. Practitioners with pending pre-April 2026 appeals should treat 30 June as firm. The mandatory pre-deposit under Section 112(8) is 10% of disputed tax at the GSTAT stage (cumulative 20% across both appellate stages), capped at ₹20 crore each for CGST and SGST, and must be paid exclusively through the Electronic Cash Ledger via Bharatkosh, not through the Electronic Credit Ledger.

Sources: TaxGuru — GSTAT Appeal Deadline 30.06.2026 Should Not Be Missed  |  CAclubindia — GSTAT Filing Deadline vs Scrutiny Relaxation: The Distinction

DIRECT TAX

Income Tax Updates

FILING SEASON  |  CBDT  |  ITR-3 ENABLED 19 JUNE 2026  |  DUE 31 AUG 2026

ITR-3 Utility Goes Live for AY 2026-27; Finance Act 2026 Pushes Non-Audit Filing Deadline From 31 July to 31 August

The Income Tax Department enabled the ITR-3 utility and online filing for Assessment Year 2026-27 on 19 June 2026. ITR-3 is the form for individuals and Hindu Undivided Families with income from a proprietary business or profession (not eligible to use ITR-4 presumptive), and also captures income from house property, salary, capital gains, other sources, and remuneration from a partnership firm (other than from LLPs). Filers ineligible to use ITR-1, ITR-2, or ITR-4 default to ITR-3. The release closes the AY 2026-27 utility roll-out gap for individual filers, with ITR-5, ITR-6, and ITR-7 expected to follow in due course for firms, LLPs, companies, and trusts. As of this bulletin, the e-filing portal also reflects a corrigendum issued by CBDT to the original notification for Form ITR-3, alongside corresponding corrigenda for Form ITR-5 and the Income-tax Rules.

A second, equally significant change has crystallised. The Finance Act, 2026 has amended the due date for filing the return of income for taxpayers engaged in business or profession whose accounts are not required to be audited, as well as for partners of non-audit firms. The earlier 31 July deadline has been formally extended to 31 August 2026, and the ITR-3 form for AY 2026-27 incorporates the new date in its Part A General section. The deadline for audit cases remains 31 October 2026. For salaried filers, capital-gains filers, and presumptive filers using ITR-1 / ITR-2 / ITR-4, the original 31 July 2026 deadline continues to apply. A practical reminder on the regime: the AY 2026-27 return is for income earned in FY 2025-26 and is governed by the Income Tax Act, 1961. The new Income Tax Act, 2025 applies only to income earned from 1 April 2026 onwards (Tax Year 2026-27), with the first return under the new Act due in 2027. The portal runs both Acts in parallel, with the unified challan interface determining Act applicability based on the year selected.

Sources: ClearTax — ITR-3 AY 2026-27: Release Date, Who Can File, Last Date and How to File  |  Taxmann — ITR Forms AY 2026-27: Eligibility and Key Changes

OPERATIONAL GUIDANCE  |  CBDT  |  SEC 67(10) IT ACT 2025 + NOTIF 70/2026

CBDT Issues Form 27 FAQs on Partnership / LLP Reconstitution and Notifies Infrastructure Sub-Sectors as Specified Businesses Under Schedule V

The CBDT has released a comprehensive set of Frequently Asked Questions on Form No. 27, the new mandatory reporting form introduced under Rule 50 of the Income-tax Rules, 2026, which operationalises Section 67(10) of the Income Tax Act, 2025. Section 67(10) is the renumbered counterpart of Section 45(4) of the 1961 Act and governs the attribution of taxable income to capital assets that remain with a specified entity following dissolution or reconstitution. Specified entities include partnership firms, LLPs, and other arrangements covered under the section. The form requires reporting of income attributable to retained capital assets following a dissolution or reconstitution event, computed using the methodology laid down in Rule 50. The FAQs clarify that independent valuation of the capital asset is mandatory, and the form must be filed even where the entity continues under a reconstituted structure with one or more original partners remaining. Failure to file Form 27 or filing with incorrect particulars can trigger disputes in the computation of capital gains under Section 67(10), denial of deductions under Section 72(5), and proceedings under the Act.

Separately, the CBDT has issued Notification No. 70/2026 dated 1 June 2026, formally recognising businesses engaged in infrastructure sub-sectors listed in the Updated Harmonised Master List of Infrastructure Sub-Sectors (Department of Economic Affairs Notification F.No.13/1/2025-IPP dated 19 September 2025) as "specified businesses" under Schedule V of the Income Tax Act, 2025. The notification has been issued under Section 11(5) read with Note 5(d)(ii) of Schedule V [Table: Sl. No. 7]. The recognition operationalises the eligible-business framework that was previously governed under Section 35AD of the 1961 Act, and aligns the new Act's infrastructure tax framework with the policy directional list maintained by DEA. Companies engaged in airports, ports, urban transport, water supply, solid waste management, telecommunications, and other listed infrastructure sub-sectors should review the notification to confirm their classification before claiming deductions under the new Act framework for Tax Year 2026-27 onward.

Sources: CAclubindia — Form 27 Under IT Act 2025: CBDT Issues FAQs on Asset Attribution After Firm Reconstitution  |  CAclubindia — CBDT Notifies Infrastructure Sub-Sectors as Eligible Businesses (Notif 70/2026)

BANKING & FINANCE

RBI & Financial Sector

FEMA  |  RBI  |  FEMA 401/2026-RB  |  CIRCULAR 5 JUN 2026

RBI Rationalises the Authorised Persons Framework Under FEMA: Master Directions Amended, Legacy A.P. (DIR Series) Circulars Superseded

The Reserve Bank of India has issued a circular dated 5 June 2026 that gives effect to the Foreign Exchange Management (Authorised Persons) Regulations, 2026, notified through Notification No. FEMA 401/2026-RB dated 30 April 2026 and published in the Official Gazette on 6 May 2026. The Regulations rationalise the framework for authorisation of any person as an Authorised Person under the Foreign Exchange Management Act, 1999, with the stated objectives of improving the delivery of foreign exchange services and easing compliance for authorised persons. Authorised Persons include Authorised Dealer Category I banks, Authorised Dealer Category II entities, Full-Fledged Money Changers, and the newer category of online remittance partners that have come into scope following the May 2026 liberalisation of non-bank tie-ups for outward remittances.

Two operational changes flow from the circular. First, instructions contained in the Master Directions on Money Changing Activities and the Master Direction on Other Remittance Facilities have been amended to align with the new Regulations, with specific changes set out in Annex I to the circular. Second, a list of legacy A.P. (DIR Series) Circulars has been superseded through Annex II to the circular, removing duplications and contradictions that had accumulated across the FEMA instruction set. Compliance functions at AD banks, FFMCs, and online remittance entities should reconcile their internal FEMA instruction manuals against the new circular, retire the superseded A.P. circulars from internal reference, and update standard operating procedures for customer due diligence, transaction monitoring, and Liberalised Remittance Scheme reporting. The cumulative effect is a cleaner, leaner regulatory baseline that is also aligned with the RBI's mid-May 2026 decision to remove prior approval for non-bank outward remittance tie-ups with AD-Cat-I banks, the broader direction being to move from ex-ante approval to ex-post supervision.

Source: Banking Finance — RBI Circulars for June 2026: FEMA (Authorised Persons) Regulations 2026

AT A GLANCE

Importance & Applicability

Who each update applies to, why it matters, and the action it triggers.

INDIRECT TAX

GSTAT backlog appeal deadline 30 June 2026

APPLIES TO

Every taxpayer with a Sec 107 (First Appeal) or Sec 108 (Revision) order communicated before 1 April 2026 where the second appeal to GSTAT is pending. ~4.8 lakh affected appeals across India.

WHY IT MATTERS

Tomorrow is firm. Limitation period is not extended despite scrutiny-relaxation extension to 31 Dec. 10% pre-deposit via Electronic Cash Ledger only. Missing the date can permanently extinguish the appeal right.

DIRECT TAX

ITR-3 live for AY 2026-27; non-audit deadline pushed to 31 Aug

APPLIES TO

Individuals and HUFs with proprietary business or professional income (non-presumptive), partners of non-audit firms (other than LLPs), and any filer not eligible for ITR-1 / ITR-2 / ITR-4.

WHY IT MATTERS

Filing window now open. 31 Aug 2026 deadline gives one extra month for non-audit business/profession filers. ITR-1 / ITR-2 / ITR-4 deadline still 31 July. Audit cases remain 31 October.

DIRECT TAX

Form 27 FAQs + Infrastructure businesses recognised under Schedule V

APPLIES TO

Form 27: partnership firms and LLPs undergoing dissolution or reconstitution. Schedule V notification: companies in airports, ports, urban transport, water supply, solid waste, telecom, and other DEA-listed infrastructure sub-sectors.

WHY IT MATTERS

Form 27 valuation must be independent; non-compliance can deny Sec 72(5) deductions. Notif 70/2026 effective 1 Jun 2026 enables infrastructure deduction claims under Schedule V for TY 2026-27 onward.

BANKING & FINANCE

FEMA Authorised Persons framework rationalised

APPLIES TO

AD Category I banks, AD Category II entities, Full-Fledged Money Changers, online remittance partners, and any other Authorised Person under FEMA. Compliance and treasury functions in AD entities.

WHY IT MATTERS

Master Directions on Money Changing and Other Remittance Facilities amended. Legacy A.P. (DIR Series) circulars superseded. Retire old internal references; update SOPs for CDD, transaction monitoring, LRS reporting.

KEY COMPLIANCE DEADLINES — JUNE TO OCTOBER 2026

30 JUN 2026 — TOMORROW

GSTAT backlog appeal filing deadline. Form DPT-3 (Return of Deposits) FY 2025-26. Triennial DIR-3 KYC Web filing. Sec 143(2) notice service deadline for FY 2025-26 returns.

1 JUL 2026 — THIS WEDNESDAY

Unregistered Type I NBFC framework live. PRAVAAH portal deregistration window opens (closes 31 Dec 2026). Window for eligible entities to exit NBFC registration.

7 JUL 2026

TDS / TCS deposit for June 2026 (transactions governed by IT Act 2025). Use unified challan interface; verify correct Act selection at entry.

11 JUL 2026

GSTR-1 for June 2026 (monthly filers). GSTR-1 IFF for QRMP taxpayers. Confirm IMS reconciliation before filing.

15 JUL 2026

CCFS-2026 amnesty window closes. Last day to file pending ROC returns at 10% of additional fee. No extension expected.

20 JUL 2026

GSTR-3B for June 2026 (monthly filers). Q1 FY 2026-27 closes; first full quarter under new triple-layer regime.

31 JUL 2026

ITR-1, ITR-2, ITR-4 for AY 2026-27 (non-audit individual / HUF filers). DIR-3 KYC late window. TDS Return Q1 FY 2026-27.

31 AUG 2026 — NEW

ITR-3 for AY 2026-27 (non-audit business / professional filers, partners of non-audit firms). Deadline extended from 31 July under Finance Act 2026.

— ✦ —

TRUSTFACTON

www.evensetconsultancy.com

This bulletin is for general information only and does not constitute legal, tax, or financial advice.
Please verify with primary sources and consult your CA or advisor before acting.

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