Notification No. S.O. 5053(E) [No. 157/2025/F. No. 500/1/2014-APA-II] | Dated: 6th November 2025

The Central Government, in exercise of its powers under the third proviso to Section 92C(2) of the Income-tax Act, 1961, has notified the tolerance limits for determining the Arm’s Length Price (ALP) for Assessment Year 2025-26.

Prescribed Tolerance Range:

• In cases of wholesale trading, the variation between the actual transaction price and the ALP shall not exceed 1% of the transaction price.

• In all other cases, the permissible variation is capped at 3% of the transaction price.

Where the variation falls within the above limits, the price at which the international transaction or specified domestic transaction has been undertaken shall be deemed to be the arm’s length price.

For the purposes of this notification, “wholesale trading” refers to transactions in goods where:

• The purchase cost of finished goods is 80% or more of the total cost of trading activities, and

• The average monthly closing inventory of such goods is 10% or less of sales.

Notification S.O. 5074(E) [No. 160/2025/F. No. 505/2/1989-FTD-I] | Dated: 10th November 2025

The Central Government has notified the Protocol amending the Agreement and Protocol between the Government of the Republic of India and the Government of the Kingdom of Belgium for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

• The original agreement, signed at Brussels on 26th April 1993, has been amended by a Protocol signed at New Delhi on 9th March 2017.

• The Amending Protocol entered into force on 26th June 2025, upon completion of legal formalities by both countries, in accordance with paragraph 2 of Article 4 of the said Protocol.

• The provisions of the Protocol shall now be given effect in the Union of India, pursuant to section 90(1) of the Income-tax Act, 1961.

Note:

While the text of the Amending Protocol has been annexed to the official notification, readers are advised to refer directly to the complete annexure for specific provisions and implications relevant to cross-border taxation under the amended treaty.

Central Board of Direct Taxes (CBDT) — Notification S.O. 5293(E) [No. 161/2025/F. No. 370142/23/2024 TPL] | Dated: 19th November 2025

The Government of India has issued significant amendments to the Capital Gains Account Scheme, 1988 — aimed at updating definitions, widening eligible investment sections, and facilitating electronic mode deposits and compliance procedures. The amendments come into force from the date of publication and apply to investments made under relevant sections of the Income tax Act, 1961 (Sections 54, 54B, 54D, 54F, 54G, 54GA, 54GB).

• Inclusion of Section 54GA: The scheme’s ambit is expanded by inserting “54GA” alongside “54G” wherever relevant — now allowing capital gains reinvested under section 54GA to be covered.

• Deposit Office Definition Expanded: Any authorized branch of a bank as defined under relevant banking laws can now serve as a “Deposit Office.”

• Electronic Mode of Deposit Allowed: Deposits may now be made via electronic modes such as net banking, UPI, RTGS/NEFT, IMPS, BHIM Aadhaar Pay, credit/debit cards. In such cases, the effective date of deposit is the date of successful electronic payment receipt.

• Revised Documentation Norms: Instead of passbook copies, electronic account statements are now acceptable for verification.

• Flexible Closure Procedure (from FY 2027 28): Form based closure of account (Form G/ H) can be submitted electronically under digital signature or electronic verification code (EVC). Systems authorities (DGIT Systems) will frame the procedural standards, including data security and archival protocols.

• Updated Forms:

  • In Form A: The reference “*54G/” is expanded to “*54G/54GA/”, and fields are updated to allow “electronic mode” besides demand drafts.

  • In Form C: Similar changes are made to reference sections and to provide space for electronic transfer transaction details (RTGS/NEFT/IMPS) by deposit offices.

Note: For complete eligibility, conditions, and procedural details, readers should refer to the full text of the notification and amended Scheme.