✦ TRUSTFACTON ✦
INDIA TAX & COMPLIANCE BULLETIN
INCOME TAX | GST | MCA | RBI | LABOUR
✦ WEEK OF 12 MAY 2026 ✦
THIS WEEK: With the 20 May GSTR-3B deadline now eight days away, the GSTN portal has thrown up two practical filing hurdles that go beyond the IMS hard block. From the February 2026 tax period onwards, the Tax Liability Breakup tab must be opened and saved before "Proceed to File" is enabled, and the system-computed interest in Table 5.1 has moved to a non-editable downward formula aligned to Rule 88B. On direct tax, the CBDT has notified Form 164 under Section 507 of the Income Tax Act, 2025, creating a mandatory reporting trail for film, OTT, sports event, and performing-arts producers with payments above ₹50,000. The MCA has issued a fresh advisory for LLP Form 11 due 30 May 2026, with DIR-3 KYC compliance now acting as a hard interlock. At the RBI, Rohit Jain assumed charge as the new Deputy Governor on 3 May for a three-year term, replacing T. Rabi Sankar.
GST Updates
PORTAL VALIDATION | GSTN | ADVISORY 16 MAR + 3 APR 2026
"Proceed to File" Disabled Until You Save the Tax Liability Breakup Tab in GSTR-3B
From the February 2026 tax period onwards, a new portal-level validation in GSTR-3B is blocking many filings even after the tax has been offset and the cash and credit ledgers are properly debited. The GSTN advisory dated 16 March 2026 confirms that taxpayers must now open the "Tax Liability Breakup, As Applicable" tab on the payment page and click SAVE before the "Proceed to File" button is enabled. The tab itself is auto-populated based on the document dates of supplies reported in earlier GSTR-1, GSTR-1A, or IFF filings, where the related tax liability is being discharged in the current return. In substance, GSTN is asking the taxpayer to confirm the period-wise classification of tax liability as a separate step before the return can be filed.
The follow-up advisory dated 3 April 2026 acknowledges that the validation is being triggered even where there is no previous period liability, and clarifies that opening and saving the tab is mandatory regardless. The practical implication for the 20 May deadline is that returns prepared offline through software and then uploaded to the portal still need a manual portal-side confirmation step. Filers planning a same-day submission should not assume that an error-free offline JSON or software-generated return will go through end-to-end. The block has caused the most disruption for taxpayers who report supplies in a later month than the document date, where the breakup table accurately captures the period mismatch and demands explicit acknowledgement. Software vendors are updating their workflows to flag this checkpoint at the upload stage.
📋 GSTR-3B FILING CHECKLIST FOR 20 MAY 2026
✔ Reconcile IMS first: Accept, reject, or mark pending every B2B invoice, debit note, credit note, and Bill of Entry. Anything left unresolved is deemed accepted on the 20 May cut-off.
✔ Match GSTR-2B before filing: Excess ITC in 4(A) over GSTR-2B hard-blocks the return at submission.
✔ Open and save the Tax Liability Breakup tab: Even where there is no previous period liability, the tab needs explicit confirmation for "Proceed to File" to activate.
✔ Confirm RCM and ECRS balances: Unpaid RCM liability and negative ECRS closing balance are independent hard-block triggers.
INTEREST METHODOLOGY | GSTN | ADVISORY 647 OF 30 JAN 2026
Interest in Table 5.1 of GSTR-3B Now Auto-Computed and Non-Editable Downward: ECL Minimum Balance Brought into the Formula
GSTN Advisory 647 dated 30 January 2026 has rewritten the way interest on delayed GSTR-3B is calculated on the portal. With effect from the January 2026 tax period, the system computes interest only on the net cash liability after giving credit for the minimum balance available in the Electronic Cash Ledger (ECL) between the original due date and the actual date of payment. This aligns the portal logic with the proviso to Section 50 read with Rule 88B(1) of the CGST Rules. For a taxpayer who held adequate funds in the ECL through the delay period, interest will now compute on a substantially lower base than under the earlier methodology, which charged on the full delayed liability irrespective of cash ledger position. The new formula is: interest = (net tax liability minus minimum ECL balance from due date to debit date) × days delayed ÷ 365 × applicable rate.
Critically, the system-computed interest in Table 5.1 is now non-editable downward. The taxpayer can revise it upward where the actual liability is higher, but cannot reduce it below the portal figure. The auto-populated amount becomes the minimum mandatory interest at filing. This shifts interest planning to the pre-filing stage. The advisory also enables cross-utilisation flexibility: once IGST input tax credit is fully exhausted, CGST and SGST ITC can be used to discharge IGST liability in any sequence, useful for working-capital optimisation. GSTN clarified through Update ID 649 dated 19 February 2026 that the IGST utilisation flexibility is operational from the February 2026 return period, not January. For cancelled registrations, late filing of the final GSTR-3B will now route the interest recovery through Form GSTR-10.
Sources: TaxPower — GSTN Advisory 647: Interest Calculation and IGST ITC | TaxO — GSTN Advisory dated 30 Jan 2026 (Effective from Jan-2026)
Income Tax Updates
NEW FORM | CBDT | SEC 507, IT ACT 2025 | RULE 236
Form 164 Notified: Film, OTT, Sports Event and Performing-Arts Producers Now Have an Annual Reporting Obligation Under the Income Tax Act, 2025
The CBDT has operationalised Section 507 of the Income Tax Act, 2025 through Rule 236 of the Income Tax Rules, 2026, prescribing Form 164 as the annual statement to be furnished by any person carrying on the production of a cinematograph film or engaged in a specified activity. The definition of "specified activity" under Section 507(3) covers event management, documentary production, OTT and television programme production, sports event management, and other performing arts, with scope to add further activities by notification. The statement must be filed within 60 days from the end of the tax year, which means the first round under the new Act will be due on 30 May 2026 for Tax Year 2025-26. The form must report all aggregate payments exceeding ₹50,000 per payee, with corresponding TDS details where applicable.
The filing obligation applies to every individual, partnership firm, LLP, company, or other entity that produced a film or undertook a specified activity during the tax year, even where the film or activity was not completed in the year. Where multiple co-producers share a project, each co-producer files separately for their share of incurred expenses. The prescribed authority for receiving Form 164 is the Director General of Income-tax (Systems), who in turn forwards the statement to the jurisdictional Assessing Officer. The form replaces the earlier Form 52A regime that operated under Section 285B of the Income Tax Act, 1961, and is structurally similar but reflects the Tax Year (April to March) framework of the new Act rather than the legacy Financial Year terminology. Production houses, OTT platforms, sports event managers, and live-events organisers should reconcile their FY 2025-26 payment data against the ₹50,000 per-payee threshold ahead of the 30 May deadline.
Sources: CAclubindia — Form 164 Under IT Act 2025: Mandatory Reporting Rules | Income Tax Department — Form 164 FAQs (Official)
MCA Updates
ADVISORY | MCA | 5 MAY 2026 | DUE 30 MAY 2026
LLP Form 11 Annual Return for FY 2025-26 Due 30 May 2026: DIR-3 KYC Now Operates as a Hard Interlock
The Ministry of Corporate Affairs has issued a stakeholder advisory on 5 May 2026 reminding every registered LLP that Form 11, the Annual Return of Limited Liability Partnerships under Section 35 of the LLP Act, 2008, must be filed for FY 2025-26 by 30 May 2026. The form captures partner details, contributions, and any changes in the management of the LLP during the year. Filing is on the MCA V3 portal under MCA Services → LLP e-Filing → Form 11. The penalty for delay is ₹100 per day with no upper cap, which compounds quickly and significantly raises the cost of last-minute filing failure. The form must be digitally signed by two designated partners with active DSCs, and an active LLP status on the portal is a precondition.
A practical compliance trap this year is the DIR-3 KYC interlock. If a designated partner's DPIN has been deactivated for any reason, including a missed earlier KYC cycle, Form 11 validation will fail at the portal stage and the filing cannot be completed. Reactivation requires a separate DIR-3 KYC filing along with the non-refundable ₹5,000 reactivation fee per DIN under the Companies (Registration Offices and Fees) Rules, 2014. The triennial DIR-3 KYC Web filing window for DIN-holding partners closes on 30 June 2026 under Rule 12A(1), so partners whose KYC is current should still verify the active status before initiating Form 11. Two related due dates round out the LLP and company law calendar for the next six weeks: Form DPT-3 (Return of Deposits) for FY 2025-26 is due on 30 June 2026, and LLP Form 8 (Statement of Account and Solvency) is due on 30 October 2026. CCFS-2026, the amnesty scheme for catching up on overdue ROC filings at 10% of additional fee, remains open until 15 July 2026.
Sources: CAclubindia — MCA Alerts Stakeholders to File LLP Form 11 by 30 May 2026 | Taxscan — LLP Form 11 Filing for FY 2025-26 (5 May 2026)
RBI & Financial Sector
LEADERSHIP | RBI | EFFECTIVE 3 MAY 2026
Rohit Jain Takes Charge as New RBI Deputy Governor for a Three-Year Term: Banking Supervision Portfolio Continuity Signalled
The Appointments Committee of the Cabinet has appointed Rohit Jain, Executive Director at the Reserve Bank of India, as Deputy Governor for a three-year term with effect from 3 May 2026. Jain replaces T. Rabi Sankar, whose extended tenure ended on 30 April 2026. With nearly three decades at the central bank, Jain has been Executive Director since December 2020, with a portfolio that has centred on banking supervision, risk assessment, and oversight of banks and non-banking financial companies. He is the latest in a series of internal elevations at the senior leadership level, following the appointment of S.C. Murmu in 2025. The four-member Deputy Governor panel now also includes Poonam Gupta and Swaminathan J, both appointed from outside the RBI.
The specific portfolio allocation for Jain has not been formally announced, but his background suggests continuity in the banking supervision domain that Rabi Sankar oversaw, particularly in the supervisory framework for banks and NBFCs. The change is significant in context: it comes shortly after the April 2026 MPC meeting at which the policy repo rate was held at 5.25% and a neutral stance was retained, with the Committee flagging West Asia supply-chain risk, El Niño concerns, and the first explicit core inflation projection of 4.4% for FY27. For regulated entities, the leadership transition does not change any ongoing compliance timeline, but it signals continuity of approach on financial stability, fintech regulation, and the evolving ECB and FEMA reporting frameworks that Rabi Sankar's department had been driving.
Sources: Free Press Journal — Govt Appoints Rohit Jain as RBI Deputy Governor | GK Now — Rohit Jain Appointed RBI Deputy Governor (May 2026)
KEY COMPLIANCE DEADLINES — MAY TO AUGUST 2026
|
15 MAY 2026 TDS certificate issuance for non-salary deductions (specified transactions) for Q4 FY 2025-26. Form 27EQ TCS Q4 FY 2025-26. |
20 MAY 2026 — NEXT WEEK GSTR-3B for April 2026 (monthly filers). Open the Tax Liability Breakup tab, confirm IMS reconciliation, verify RCM and ECRS before submission. |
|
22 MAY 2026 GSTR-3B for April 2026, Category 1 states (AATO up to ₹5 crore). GSTR-5 and GSTR-5A also due (NRTP and OIDAR). |
30 MAY 2026 LLP Form 11 (Annual Return) FY 2025-26. Form 164 under Sec 507 IT Act 2025 for film, OTT, and event producers (Tax Year 2025-26). |
|
31 MAY 2026 TDS Return Q4 FY 2025-26 (Forms 24Q, 26Q, 27Q, 27EQ) under IT Act, 1961. Form 15CC for authorised dealers (FEMA remittances Q4). |
30 JUN 2026 Form DPT-3 (Return of Deposits) for FY 2025-26. Triennial DIR-3 KYC Web filing under Rule 12A(1). DIN deactivation otherwise. |
|
15 JUL 2026 CCFS-2026 amnesty window closes. Last day to file pending ROC returns at 10% of additional fee. No extension expected. |
31 JUL 2026 ITR-1 and ITR-2 for AY 2026-27 (salaried individuals and HUFs, non-audit). DIR-3 KYC follow-up window. |
— ✦ —
TRUSTFACTON
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.
Investors are watching this fast growing tech company.
🚨 No, it's not the publicly traded tech giant you might expect… Meet $MODE, the disruptor turning phones into income generators.
📲 Mode’s 32,481% revenue growth ranked them #1 on Deloitte’s list of fastest-growing companies in software. They aim to pioneer "Privatized Universal Basic Income" powered by technology, not government, and their EarnPhone has already helped consumers earn & save $1B+.
Please read the offering circular and related risks at invest.modemobile.com. This is a paid advertisement for Mode Mobile’s Regulation A+ Offering.
Mode Mobile recently received their ticker reservation with Nasdaq ($MODE), indicating an intent to IPO in the next 24 months. An intent to IPO is no guarantee that an actual IPO will occur.
The Deloitte rankings are based on submitted applications and public company database research, with winners selected based on their fiscal-year revenue growth percentage over a three-year period.


