ACA JOURNAL APRIL 2026

Ahmedabad Chartered Accountant Journal April, 2026 49TM- From a practical standpoint, the decision providesconsiderable relief to capital-intensive industriessuch as pharmaceuticals, chemicals, and heavymanufacturing, where installation of sophisticatedmachinery necessarily involves substantialfoundational and structural work. At the same time,the ruling implicitly underscores the importanceof maintaining robust documentation, includingengineering certifications and clear costsegregation, to substantiate the nexus betweenthe structural work and the machinery installed.Overall, the ruling contributes to a more nuancedand industry-aligned interpretation of ITCrestrictions, balancing statutory provisions withoperational realities.Advance Ruling under GSTConclusion:The Gujarat AAR has held that Input Tax Credit isadmissible on input services used for construction offoundation and structural support for plant andmachinery, where such structures are essential andintegral to the functioning of the machinery. The rulingestablishes that such supports fall within the ambit of“plant and machinery” and are therefore not hit by theblocked credit provisions under Section 17(5), therebyproviding critical relief to manufacturing and processindustries undertaking capital-intensive installations.❉ ❉ ❉The focus has clearly shifted from legal form tocommercial substance and purpose. If an entitymerely holds assets, books income from grouptransactions, or operates without employees,decision making, or active involvement, it riskslosing eligibility for the 0% regime and may evenface reclassification.In practice, many businesses continue to operatewith minimal presence in the UAE while coreactivities and decisions remain outside thejurisdiction and this creates a weak andindefensible position. A sustainable structure,even for a holding company, must demonstrateactive management, strategic involvement andclear business rationale beyond tax benefits,supported by proper documentation andonground substance. In the evolving regime, it isnot passive ownership but active value creationin the UAE that will determine whether the structureholds or fails.Without genuine business activity, these structuresmay face Scrutiny or Disqualification9. Over Reliance on Outdated AdviceA major issue is that many businesses are stilloperating based on pre 2024 tax assumptions andOutdated consultant guidance But the UAE taxlandscape has fundamentally changed.10. No Integration with Indian Tax PlanningEven if UAE tax is optimized, ignoring India canbe costly:- POEM risk- Permanent Establishment exposure- Taxability in IndiaTrue planning must be cross border, notjurisdiction specific.NutshellThe Shift from “Tax Free” to “Tax Efficient”The UAE remains one of the most attractivebusiness destinations globally.But the game has changed.It is no longer about setting up a company but it isabout structuring a compliant, substancebacked, tax efficient business.Indian promoters who adapt to this shift will benefitand those who don’t may face:- Unexpected tax exposure- Compliance risks- Structural inefficienciesAs we move into 2026, the biggest risk is nottaxation it is misunderstanding taxation.❉ ❉ ❉Continued from page 43 GULF Insights

50 Ahmedabad Chartered Accountant Journal April, 2026TMIND AS InsightsCase Scenario :-Shrinath Ltd. is a company operating in the transportationsector and is engaged in running a fleet of busesacross multiple routes and customer categories. Thecompany has expanded its operations over the yearsand currently manages different transportation modelscatering to public authorities, retail passengers andinstitutional customers.For internal management reporting and performancemonitoring purposes, the management of the companyhas identified the following three operating segments:Segment Nature of OperationsSegment 1 Local Route OperationsSegment 2 Inter-city Passenger TransportSegment 3 Contract Hiring of BusesSegment 1 – Local Route OperationsUnder this segment, Shrinath Ltd. operates buses onroutes allotted by local transport authorities. Thecontracts are awarded through a competitive tenderprocess.Key features of this segment include:- Fare prices are regulated and controlled by thetransport authority.- The company does not independently determineticket pricing.- Revenue is earned on a per-kilometre contractualbasis and charged to the local transport authorities.- Passenger demand risk is substantially borne bythe transport authority rather than the company.- Margins are comparatively stable but dependentupon contract renewal and tendercompetitiveness.Recently, this segment has witnessed decliningprofitability due to:- increased fuel costs,- aggressive bidding by competitors, and- lower contract margins.Segment 2 – Inter-city Passenger TransportUnder this segment, the company independentlyoperates buses between cities.Key characteristics include:- Ticket prices are determined by the company.- Different service classes such as Deluxe, Luxuryand Superior are offered.- Revenue generation depends directly uponpassenger occupancy and customer demand.- The company bears pricing and market risk.- Profitability is linked to customer preferences, routepopularity, and competition.This segment has shown:- significant revenue growth,- improved occupancy ratios, and- enhanced operating margins.Segment 3 – Contract HiringUnder this segment, buses are leased to schools andinstitutions under long-term contractual arrangements.The segment generates:- relatively predictable cash flows,- stable margins, and- lower operational risk compared to passengertransportation services.CA. Niket Rasania [email protected]

Ahmedabad Chartered Accountant Journal April, 2026 51TMThe management of Shrinath Ltd. believes that usersof financial statements should primarily focus on thecompany’s overall profitability and consolidatedfinancial position rather than individual segmentperformance.Since Segment 1 and Segment 2 both involvepassenger transportation services through buses,management is considering aggregating these twosegments into a single reportable segment underOperating Segments.Management is of the view that:- both segments operate in the transport industry,- similar assets are used,- services involve passenger transportation, and- aggregation may simplify financial reporting.However, the Finance Manager has raised concernsthat combining these segments may conceal thedeteriorating performance of Segment 1.The following issues arise for analysis under Ind AS108:1. Whether Segment 1 and Segment 2 can beaggregated as a single reportable segment underInd AS 108.2. Whether disclosure of segment information isrelevant and useful for investors and otherstakeholders in evaluating the company’s financialperformance and future prospects.Solution :-As per para 12 of Ind AS 108 Operating Segments i.e.Aggregation criteria, Operating segments often exhibitsimilar long-term financial performance if they havesimilar economic characteristics. Two or moreoperating segments may be aggregated into a singleoperating segment if(i) aggregation is consistent with the core principleof this Ind AS,(ii) the segments have similar economiccharacteristics and(iii) the segments are similar in each of the followingrespects:Ind AS Insights(a) The nature of the products and services(b) The nature of the production process(c) The type or class of customer for theirproducts and services(d) The methods used to distribute their productsor provide their services(e) If applicable, the nature of the regulatoryenvironmentAs per para 1 of Ind AS 108 i.e. Core principle, anentity shall disclose information to enable users of itsfinancial statements to evaluate the nature and financialeffects of the business activities in which it engagesand the economic environments in which it operates.In this case scenario, although the segments havesimilar nature of services and the methods used toprovide their services, the customers for thoseservices are different.In Segment 1 – Local Route Operations, the decisionto award the contract is in the hands of the localauthority, which also sets prices and pays for theservices. The company is not exposed to passengerrevenue risk, since a contract is awarded bycompetitive tender.On the other hand, in Segment 2 – Inter City PassengerTransport, the customer determines whether a bus routeis economically viable by choosing whether or not tobuy tickets. Shrinath Ltd sets ticket prices but will beaffected by customer behaviour or feedback. ShrinathLtd is exposed to passenger revenue-risk, as it setsprices which customers may or may not choose topay.Operating Segment provides information that makesthe financial statements more useful to investors. Inmaking the investment decisions, investors andcreditors consider the returns they are likely to makeon their investment. This requires assessment of theamount, timing and uncertainty of the future cash flowsof Shrinath Ltd as well as management’s stewardshipof Shrinath Ltd.’s resources. How management derivesprofit is therefore relevant information to an investor.Continued to page 61

52 Ahmedabad Chartered Accountant Journal April, 2026TMMCA Updates:1. Advisory for Stakeholders for Name Reservationand Incorporation of Company and LLP:The MCA has issued a booklet dated 12.03.2026highlighting key considerations for Stakeholdersfor Name Reservation and Incorporation ofCompany and LLP.It is focused on ensuring adherence to MCAguidelines to avoid rejections of name(s) andregistration(s) of Companies/LLPs. It furtherprovides for keeping ready therequireddocumentation, certification thereof andconsidering trademark search before applying forname reservation.For detailed text of the circular, please refer to:h t t p s : / / w w w . m c a . g o v . i n / b i n / d m s /getdocument?mds=Yyau8%252FQveEEgOSo722nczw%253D%253D&type=openIFSC Updates:2. Fee structure for the entities undertaking orintending to undertake permissible activities inIFSC or persons seeking guidance under theInformal Guidance Scheme:The International Financial Services CentresAuthority (IFSCA) has clarified the fee structurefor entities undertaking permissible activities inIFSC and for persons seeking guidance underthe Informal Guidance Scheme. Key updatesinclude specific application, authorization andrecurring fees for Payment Service Providers(PSPs), Payment System Operators (PSOs),Fund Management Entities (FMEs) and otherregulated entities.Applicable fees/charges, may be remitted to thedesignated bank account of the Authority, underthe relevant categories mentioned below:a) Application fee;b) L i c e n c e / R e g i s t r a t i o n / R e c o g n i t i o n /Authorisation fee;c) Recurring fee;d) Activity based fee;e) Processing fee;f) Interest on delay in payment of applicablefees;g) Charges for delay in submission or nonsubmission of reports/returns; andh) Informal Guidance fee.For detailed text of the circular, please refer to:h t t p s : / / i f s c a . g o v . i n / C o m m o n D i r e c t /GetFileView?id=d575554ec59b09e7fde503d3a810d93a&fileName=02_03_2026_IFSCA_Fee_Circular_FY_2026_27_20260302_0641.pdf&TitleName=Legal[Circular No. IFSCA-DTFA/1/2026 dated02.03.2026]3. IFSCA FinTech Sandbox Framework:For supporting innovation by offering access todifferent kinds of sandboxes, viz., RegulatorySandbox, Innovation Sandbox, Inter-OperableRegulatory Sandbox, and Overseas RegulatoryReferral Mechanisms, across banking, capitalmarkets, insurance, fund management, and othersegments, the IFSCA has issued this Circular.This Framework shall apply to all entities desirousof obtaining Limited Use Authorisation as a FinTechSandbox Entity (FSE) from International FinancialServices Centres Authority (IFSCA).For detailed text of the circular, please refer to:CA. Naveen [email protected]

Ahmedabad Chartered Accountant Journal April, 2026 53TMCorporate Law Updateh t t p s : / / i f s c a . g o v . i n / C o m m o n D i r e c t /GetFileView?id=d575554ec59b09e7fde503d3a85390cf&fileName=IFSCA_FinTech_Sandbox_Framework_20260316_0338.pdf&TitleName=Legal[eF.No.: 505/IFSCA-FTec0FTEF/1/2023 dated16.03.2026]IBBI Updates:4. Filing of Forms to monitor insolvency resolutionprocesses for Personal Guarantors to CorporateDebtors under the Insolvency and BankruptcyCode, 2016 and the regulations madethereunder:- This circular sets out the filing requirements,timelines, and monitoring framework forinsolvency resolution processes initiated inrespect of Personal Guarantors (PGs) tocorporate debtors under the Insolvency andBankruptcy Code, 2016 and the regulationsmade thereunder.- To ease the compliance burden for InsolvencyProfessionals (IPs), a set of electronic formshas been developed by the Board (IBBI) tocapture the details of the insolvency resolutionprocess for personal guarantors.- These forms are crucial for the process underthe Insolvency and Bankruptcy Code (IBC),as they facilitate systematic and transparentrecord-keeping and seamless reporting. Thekey benefits of these forms include allowingresolution professionals to easily access andsubmit forms online, reducing delays andimproving efficiency and minimizing thelikelihood of errors and omissions, ensuringmore accurate and reliable information.For detailed text of the circular, please refer to:https://ibbi.gov.in//uploads/legalframwork/ea787956c30c57f52302ef56c10a13ea.pdf[Circular No. IBBI/II/92/2026 dated 06.03.2026]SEBI Updates:5. Regulatory Reporting by AIFs:- AIFs will submit a comprehensive AnnualActivity Report at the end of March of eachfinancial year. The Annual Activity Report shallbe submitted by all AIFs online on the SEBIIntermediary Portal (SI Portal) within 30calendar days from the end of March of everyfinancial year.- A limited Quarterly Activity Report shall besubmitted by all AIFs online on the SI Portalin a revised format within 15 calendar daysfrom the end of each such quarter.- This circular shall supersede the provisionsunder Clause 15.1 of Chapter 15 – “Reportingby AIFs” of the Master Circular for AlternativeInvestment Funds (AIFs) dated May 07, 2024and it shall come into force with immediateeffect.[Circular No. HO/19/28/(1)2026-AFD-SEC3/I/6176/2026 dated 04.03.2026]6. Relaxations in certain reporting requirementsfor certain Stock Brokers and doing away withthe requirement of reporting of demat account:The SEBI issued a circular easing compliance forstock brokers by removing the requirement toreport demat accounts to stock exchanges andrelaxing certain reporting obligations for brokersthat are also banks or primary dealers.Major relaxations are as under:- Demat account reporting to stock exchangesis no longer required and Depositories willnow directly share demat account details withexchanges; and- Brokers that are also banks or primarydealers must now report only those bankaccounts used for stock broking activities andAccounts used exclusively for non-brokingor banking activities are exempt fromreporting.[Circular No. HO/38/11/(1)2026-MIRSD-POD/I/7656/2026 dated 23.03.2026]❉ ❉ ❉

54 Ahmedabad Chartered Accountant Journal April, 2026TMWhen Does a Landowner Become a Promoter?Navigating RERA Liability in Joint DevelopmentAgreementsThe Real Estate (Regulation and Development) Act,2016 placed the homebuyer at the centre of India’sreal estate ecosystem. Promoters now registerprojects, declare timelines, park 70 per cent of buyercollections in escrow, and answer to a statutory authority.By and large, the discipline has worked. Yet one stretchof the canvas remains stubbornly grey: the legal statusof the landowner whose plot becomes the foundationof a joint development project.The question is deceptively simple. A landownercontributes land. A developer brings in capital andexecution capability. They share area or revenue undera joint development agreement (JDA). If the developerfalters, can a homebuyer reach across the table andpin liability on the landowner? Stated differently - isevery landowner in a JDA a “promoter” within themeaning of Section 2(zk) of the RERA Act?The answer, after nearly a decade of orders, circulars,and judicial pronouncements, turns squarely on whatthe JDA says and what role the landowner actually plays.The Statutory Hook: Section 2(zk)The definition of “promoter” is cast wide. It capturespersons who construct or cause to be constructedapartments for sale, develop and sell plotted layouts,act as builders, colonisers, contractors, or estatedevelopers, and government bodies undertaking suchprojects. The Explanation to Section 2(zk) carries adeeming fiction: where the person who constructs andthe person who sells are different persons, both aredeemed promoters and are jointly liable.The legislature has used the disjunctive “or” between“constructs” and “causes to be constructed” - a smalllinguistic choice with sweeping consequences. Bareownership of land is not the trigger. Promoter statusarises from the act of construction, or causingconstruction, with the intent to sell. A landowner whocontributes land and steps aside does not, by that actalone, become a promoter.State RERA CircularsFaced with the proliferation of JDA structures - areashare, revenue-share, hybrid arrangements, profitshare - state authorities issued circulars to bringpractical clarity. The threads that emerge areremarkably consistent.The Maharashtra Real Estate Regulatory Authority’scircular dated 4 December 2017 set the template: wherea landowner is entitled to a share of the revenuegenerated from the sale of apartments, the landowneris to be treated as a promoter. The Authorities of Goa(February 2018), Karnataka (October 2019), Gujarat(July 2020), and Rajasthan (June 2020) have followedbroadly the same logic.The Rajasthan order of 30 June 2020 is the mostinstructive for the practitioner because it lists, in plainterms, when a landowner should be treated as apromoter and when should not. A land owner becomesa promoter where: (a) the landowner himself plays abuilder, coloniser, or contractor role; (b) the landownerhas a share in the area developed for sale and intendsto market it; (c) the JDA does not vest the developerwith full power to sign agreements for sale and conveyunits; (d) the parties have agreed to share project profitor loss; or (e) the JDA expressly so provides. Wherethe landowner has executed an irrevocable power ofattorney empowering the developer to sign agreementsfor sale, has no role in development or marketing,and does not share in project profit or loss, thelandowner is not to be treated as a promoter.Liability follows control and economic interest, not thetitle deed.CA. Manan Doshi [email protected] Corner

Ahmedabad Chartered Accountant Journal April, 2026 55TMForm B: The Registration-Stage FilterForm B - the affidavit submitted at the time of projectregistration - distinguishes between two categories:the promoter who holds legal title, and the promoterwho develops land owned by another person, subjectto filing the landowner’s consent together with thedevelopment agreement and title documents. Had thelegislative intent been to compel landowners into thepromoter fold by default, Form B would have requiredboth signatures. It does not. The developer applies;the landowner consents.The Judicial TrailIndian courts have been called upon to resolve this issuein fact-specific contexts. Three threads can be identified.The L&T trail. In Larsen & Toubro Ltd v. State of UttarPradesh (Writ-C No. 16616 of 2024), the Allahabad HighCourt was confronted with UPRERA’s insistence thatJaiprakash Infratech Limited, the original landowner,be added as a co-promoter for L&T’s “Green Reserve”project at Wish Town, Noida. L&T had stepped in underan assignment agreement and held an irrevocablegeneral power of attorney; construction, sale, andmarketing were entirely its responsibility. The Courtheld that mere ownership of land does not pull theowner into the promoter definition. The Hon’bleSupreme Court, by its order dated 13 August 2025(UPRERA v. Larsen and Toubro Limited, 2025 SCCOnLine SC 1750), affirmed the High Court’s view.The Kerala perspective. In Pooja Constructions v. TheSecretary, Kerala Uranma Devaswom Board (2024 SCCOnLine Ker 4894), the Kerala High Court examinedthe deeming fiction under sub-clause (vi) of theExplanation to Section 2(zk) and held that it operatesonly when both persons - the one constructing andthe one selling - are involved in the project for sale.Where the landowner receives a fixed number ofapartments as consideration without any intention tosell, and the developer alone constructs, markets, andsells, the landowner is not a promoter for the purposesof registration under Sections 3 and 4. Certain dutiesunder the Act may still bind the landowner - for instance,the execution of the conveyance deed in favour of anallottee.The MOFA-RERA continuity. The Bombay High Court’sreasoning in Vaidehi Akash Housing Pvt Ltd v. NewDN Nagar Co-op Housing Society Union Ltd (2014 SCCOnLineBom 5068) - under the predecessor MOFA -was carried into the RERA era in Goregaon Pearl CHSLv. Seema Mahadev Paryekar (2019 SCC OnLineBom3274). Where a society or landowner has nooperational control over redevelopment and has notsigned agreements with flat purchasers as a confirmingparty, the obligations of the developer cannot bevisited upon the society or landowner.The contrarian view. The position is not, however, uniform.In Wadhwa Group Holdings Pvt Ltd v. Vijay Choksi(decided 26 February 2024), the Bombay High Courtdeclined to relieve a co-developer that had not receivedmoney directly from allottees but was registered as apromoter and had a share in saleable flats under theJDA. Joint liability under Section 18, the Court held, flowsfrom the status of being a promoter, not from receipt ofconsideration. The Hon’ble Supreme Court declined toentertain a special leave petition in April 2024. TheKarnataka RERA’s order of October 2025, holding alandowner who actively participated in development andmarketing as a promoter, carries the same message.Once a person voluntarily registers as a promoter andcommits to a share in sale proceeds, the protectivetheory of “I never received the money” does not work.The Synthesising PrincipleThe test is neither title-based nor purely contractual - itis functional.A landowner is not a promoter where: title is contributedin exchange for a fixed monetary consideration or afixed number of constructed units retained for self-use;the developer holds an irrevocable power of attorneyto execute agreements for sale and convey theundivided share of land; the landowner does not marketor sell units; and the landowner has no share in projectprofit or in revenue from sales.A landowner will be a promoter where: the landownerhas retained a saleable share, whether of revenue orarea, with intent to monetise; the landowner is namedin the registration; the landowner participates inmarketing, branding, or signing of allotment letters; orthe JDA expressly so provides.The RERA Act seeks to protect allottees from thecommercial hand behind the project. Where thelandowner is part of that commercial hand, theprotection extends; where the landowner is merely thesource of the title, it does not.GujRERA Corner

56 Ahmedabad Chartered Accountant Journal April, 2026TMPractical Implications for the ProfessionFor the chartered accountant advising landowners anddevelopers, this jurisprudence has severalconsequences worth flagging.First, the JDA must be drafted with post-RERA riskallocation in mind. A poorly worded JDA can convert apassive landowner into a promoter overnight. Crispclauses on the irrevocability and scope of the powerof attorney, the absence of any obligation on thelandowner to sign agreements for sale, the landowner’snon-participation in marketing and the structuring ofeconomic interest as fixed consideration rather thanrevenue-share, all materially shift the risk profile.Second, where the structure is genuinely a revenueshare or area-share-with-intent-to-sell arrangement, thelandowner cannot wish away promoter status. Thelandowner-promoter must be alive to the obligations:opening, or being a co-signatory on, the dedicatedbank account contemplated by Section 4(2)(l)(D);ensuring 70 per cent of project receipts are depositedthere; complying with the periodic engineer’s,architect’s, and chartered accountant’s certifications forwithdrawals; and contributing to the annual project auditprescribed under the applicable State Rules.Third, the income-tax implications run in parallel. Alandowner enjoying the deferral benefit under Section45(5A) of the Income-tax Act, 1961 must be cautiousthat converting the role into one of “active selling” -which can occur, sometimes inadvertently, when unitsretained as the landowner’s share are sold prior to theissue of the completion certificate - can disturb thedeferral and trigger an immediate liability. The interplayof RERA promoter status, Section 45(5A) and the GSTtreatment of construction services received by thelandowner under the rate notifications applicable toJDAs deserves an integrated review at the structuringstage rather than after the fact.Fourth, for chartered accountants functioning as projectauditors, certifying officers under RERA, or insolvencyprofessionals, the question of who the promoter isdetermines who must sign the audit report, who facespenalties under Sections 60 to 63 and who isimpleaded in allottee complaints. The L&T decisionprovides a defence against landowners beingmechanically dragged into promoter obligations; theWadhwa decision warns that voluntary registration isits own form of consent.Closing ReflectionsThe RERA framework distinguishes between personsby reference to the function they perform within aproject, not the asset they hold. A landowner whosimply parts with land is not in the same position asone who treats land as venture capital and shares inthe upside of sale. The Supreme Court’s affirmation ofthe L&T view in August 2025 has now anchored thedoctrinal position; the Wadhwa line of cases remindsus that the protection is shaped by what one does, notby what one is called.That said, the framework outlined in this article is doctrinal- it sets out the general principles. The actual answer inany given matter is intensely fact-sensitive and turns ona constellation of specifics: the precise wording of theJDA, the scope and irrevocability of the power of attorney,the structure of the area-share or revenue-share, whetherthe landowner has been named in the registration, theconduct of the parties during marketing and sale, theterms of any tripartite agreement with allottees, the stageat which units retained by the landowner are transferred,and the circular regime of the particular state. Two JDAsthat look similar on a one-page summary can producevery different outcomes once the underlying documentsare read together.The careful practitioner’s task, therefore, is to ensurethat the JDA, the powers of attorney, the registration form,and the conduct of the parties on the ground all line up.Because the liability that flows from RERA is functionalin nature, a paper construct that does not match the realityon the ground will, sooner or later, be set aside.For the landowner, the lesson is to negotiate the JDAbefore the project is registered, not after the disputebegins. For the developer, the lesson is that widerpromoter coverage is not always undesirable - in somestructures, it can lend funding credibility and sharedaccountability. And for the chartered accountantadvising both, the lesson is that the RERA Act, for allits complexity, is at heart a statute of substance overform. Where a JDA carries unusual features - staggeredconveyance, contingent revenue triggers, multi-phaseregistration, layered POAs, or co-development with alandowner-society - a tailored review of the documentsis the only safe course.❉ ❉ ❉GujRERA Corner

Ahmedabad Chartered Accountant Journal April, 2026 57TMSummary:India’s economic momentum remains robust with realGDP growth estimated at 7.4% for FY26, yet thelandscape is increasingly defined by a sharp energyshock and geopolitical instability due to the 2026conflict between the US, Israel, and Iran. The closureof the Strait of Hormuz has pushed crude oil pricesover $100 per barrel, leading to a record rupee low of95.23/USD and a significant contraction in the BSESensex, which ended March at 71,947.55, down11.49%. Domestic industrial activity faces disruption,with commercial LPG supplies dropping to 20% andgas allocation to industries reduced, affecting over15,000 MSMEs. Despite this secondary market volatilityand massive FPI outflows of ` 1,23,025 crore, theprimary market active with nine main board IPOs inMarch, remained.Key M&A and PE activity highlights include Nova IVFacquiring a majority stake in Kerala-based CRAFTHospitals at a $40-million valuation to expand itsspecialist fertility footprint and Kochi-based SFOTechnologies securing ` 750 crore from a consortiumled by Trident and Amicus Capital to scale its electronicsmanufacturing and global EMS capabilities.Economic Update:The 2026 conflict between United States, Israel andIran under Operation Roaring Lion has emerged as aCA. Karan [email protected] geopolitical shock with deepeconomicconsequences. Within weeks, the war caused 1,300+deaths and over 3million displacement, whiledestabilising West Asia, one of the world’s mostcriticalenergy hubs. The disruption of the Strait of Hormuz,which handles nearly 20–25% of global oil trade, hasamplified risks to global energy security, trade flows,and inflation. At the time of writing this, there is anuneasy ceasefire between US and Iran as both sidesare trying to reach an agreement.Global Economy ImpactThe conflict has triggered a sharp energy shock, withcrude oil prices rising to over $120 per barrel, pushingglobal inflation upward. Disruptions in oil, LNG and LPGsupplies from the Gulf have strained energy-importingeconomies, while key maritime routes such as Hormuzand Bab el-Mandeb have faced interruptions, delayingshipments worldwide. Freight and insurance costs havesurged, increasing overall trade expenses andreducing competitiveness. These supply-sidepressures, combined with geopolitical uncertainty, areexpected to slow global economic growth anddestabilise financial markets.Indian Economy ImpactIndia faces disproportionate risks due to its heavydependence on Gulf energy imports, about 88% ofcrude oil and 90% of LPG imports, much of whichpasses through Hormuz. The immediate impact isvisible in rising fuel prices, with domestic LPG up by` 60 and commercial cylinders by ` 110–` 115,alongside broader petrol and diesel inflation.- Energy & supply shock: Commercial LPG supplyhas dropped to 20%, with delivery delays of 2–8days.- Industrial disruption: Gas allocation to industriesreduced to 65–80%, affecting 15,000+ MSMEs;170+ Morbi tile units shut.

58 Ahmedabad Chartered Accountant Journal April, 2026TMCapital Market- Agriculture impact: Fertilizer plants operating at70% capacity, raising food inflation concerns.At a macro level, the crisis risks widening India’s currentaccount deficit, increasing subsidy burdens, andexerting pressure on inflation and the rupee,highlighting structural vulnerabilities to external energyshocks.Secondary Market:- The BSE Sensex ended the month and financialyear at 71,947.55 (down 11.49% MoM) and theNifty 50 at 22,331.40 (down 11.31%), marking afourth consecutive monthly decline amid sharplate-week selling, driven by a weakening IndianRupee, elevated Brent Crude prices and sustainedFPI outflows linked to rising Middle East tensions.- Banking stocks fell after the Reserve Bank of Indiacapped banks’ forex exposure at $100 million,triggering unwinding of positions and pressuringsentiment.- The India VIX jumped to ~28, nearly 2x its normalrange of 12–15, indicating a steep rise in expectedmarket volatility over the next 30 days.- Foreign Portfolio Investors (FPIs) recorded netoutflows of ` 1,17,775 crore in March, while theirequity assets declined by $79 billion to $710 billionin just a fortnight marking the sharpest drop in over6 years.· The Indian Rupee depreciated by 0.5% in a singlesession to hit a record low of 95.23/USD,amplifying FPI outflows and increasing importedinflation risks.· The March F&O expiry triggered additionalvolatility, with sharp intraday swings of 1–2% astraders unwound positions and rolled overcontracts to the next series.Equity Markets Feb-26 Mar-26 % Change BSE Sensex 81,287.19 71,947.55 -11.49% Nifty 50 25,178.65 22,331.40 -11.31% BSE 500 36,332.56 32,182.38 -11.42% BSE Healthcare 43,917.47 41,778.38 -4.87% BSE IT 29,754.94 27,926.32 -6.15% BSE FMCG 18,739.32 16,774.27 -10.49% BSE Metal 40,424.48 36,815.93 -8.93%

Ahmedabad Chartered Accountant Journal April, 2026 59TMCapital MarketPrimary Market Update:There were 09 main board IPOs in March 2026 includingCleanmax Enviro Energy Solutions Limited, ShreeRam Twistex Limited, PNGS Reva Diamonds JewelleryLimited, Omnitech Engineering Limited, SEDEMACMechatronics Limited, Rajputana Stainless Limited,Innovision Limited, GSE Crop Science Limited andCentraL Mine Planning & Design Institute Limitedagainst 03 main board IPOs in February 2026. Therewere 05 SME IPOs in March 2026 as compared to 08SME IPOs in February 2026.SEDEMAC Mechatronics Limited:About the Founded in 2007, SEDEMACCompany Mechatronics Ltd is a technology-drivencompany specializing in control-intensiveelectronic solutions for automotive andindustrial applications. It designs andmanufactures critical electronic controlunits (ECUs), including ISG, EFI, andmotor control units, and is the first in Indiato develop sensor-less commutation(SLC)-based ISG ECUs for 2W/3W ICEvehicles. It holds 35% share in India’sISG ECU market and a dominant 75–77%share in genset controllers, with a growingglobal presence. The company reportedrevenue of Rs. 662.54 crore and profit ofRs. 47.05 crore in FY25, and has alreadysurpassed this performance with Rs.775.31 crore revenue and Rs. 71.50 croreprofit in 9M FY26.Funds The entire IPO proceeds will go directlyUtilization to the selling shareholders, including A91& Selling Emerging Fund, Xponentia Opportunities,Share- 360 One, HDFC Life Insurance, Capriholders Global, NRJN Family Trust, and otherinstitutional and individual investors.Anchor The company raised approximately Rs.Investors 326 crore from anchor investors prior tothe IPO. The anchor book sawparticipation from several institutionalinvestors including leading institutionalinvestors including HDFC Mutual Fund,SBI Mutual Fund, ICICI Prudential, AbuDhabi Investment Authority, GoldmanSachs, Nippon India, and Aditya Birla SunLife.IPO Per- The Rs. 1,087 crore IPO comprised offormance entirely offer for sale of around Rs. 1,087crore. The issue was priced in the bandof Rs. 1287– Rs. 1352 per share. TheIPO was subscribed approximately 2.7times, driven largely by strong demandfrom Qualified Institutional Buyers (QIBs)at 8.46 times. Shares of SEDEMACMechatronics Limited listed on theexchanges at around Rs. 1,535 on NSEand Rs. 1.510 on BSE, reflecting a13.54% premium and 11.69% premiumto the issue price.Funds Mobilization by Corporates (Rs. In Crore)Particulars Jan-26 Feb-26I. Equity Issues 40,833 10,201a. IPOs (i+ii) 5,533 4,650i. Main Board 4,765 4,009 ii. SME Platform 768 641b. FPOs – 0c. Equity Rights Issues 561 299d. QIPs/IPPs 4,150 5,222e. Preferential Allotments 30,589 30II. Debt Issues 55,304 65,519a. Debt Public Issues 1,601 896b. Private Placement of Debt 53,703 64,623III. REITs/ InvITs 1,900 696a. REITs 0 0b. InvITs 1,900 696Total Funds Mobilized (I+II+III) 98,037 74,416Mergers and Acquisitions (M&A) Key Deal:M&A: Nova IVF picks up majority stake in Kerala’sCRAFT Hospitals at $40-mn valuationTransaction:- Nova IVF Fertility, a leading fertility chain ownedby Asia Healthcare Holdings (AHH) and backedby global PE firm TPG Capital, has acquireda majority stake in Kerala-based CRAFT Hospital& Research Centre.- The transaction values CRAFT Hospitals atapproximately $40 million (around Rs. 368 crore)

60 Ahmedabad Chartered Accountant Journal April, 2026TMand marks Nova IVF’s formal entry into the highpotential Kerala market, expanding its footprint inSouth India.About CRAFT Hospital & Research Centre:- Founded in 1987 by Prof.Dr. C. Mohamed Ashraf,CRAFT (Centre for Research in AssistedReproduction and Fetal Therapy) is wellestablished fertility care provider with nearly fourdecades of clinical legacy in reproductivemedicine.- Headquartered in Kodungallur (Thrissur), itoperates a 250-bedded super-specialtyhospital offering services across infertility,gynecology, andrology, fetal medicine,neonatology, and medical genetics.About Nova IVF Fertility:- Founded in 2011 and acquired by Asia HealthcareHoldings in 2019, Nova IVF Fertility is amongIndia’s leading fertility service providers.- The company operates 120+ centres across 70cities, performing approximately 19,000 to 21,000IVF treatments annually with a team of 150+ fertilityspecialists and 200 embryologists.- It is led by healthcare veteran Vishal Bali andbacked by global private equity firm TPG Capital.Rationale:- The acquisition plugs a key geographic gap forNova in Kerala, where it previously had only1centre (Palakkad). proving immediate access toCRAFT’s established brand equity and massivepatient base in the region.- Following the acquisition, the combined entityplans to launch 10 new IVF centres across urbanand tier 2/3 cities in Kerala over the next 3 to 5years.- The deal combines CRAFT’s clinical excellenceand surgical expertise with Nova’s national networkand advanced technologies like AI-based embryoselection, PGT (Preimplantation Genetic Testing)and international-standard lab protocols.- Kerala remains a high-potential market with fertilityrates declining to 1.3 - 1.7 vs replacement levelCapital Marketof 2.1, driving demand for assisted reproductiveservices.- The deal reflects a broader trend in the Indian IVFsector valued at over Rs.3,000 crore wherescaled, PE-backed chains are acquiring reputableregional players to achieve rapid expansion andoperational synergies.Private Equity (PE) Key Deal:PE: SFO Technologies Secures $82 Mn (Rs 750Crores) from PE Investors; Trident and Amicus LeadRoundTransaction:- Kochi-based Electronics Manufacturing Services(EMS) provider SFO Technologies Pvt Ltd hasraised approximately Rs.750 crore ($82 million)in a fresh funding round led by Trident GrowthPartners and Amicus Capital Partners.- The round also saw participation from existinginvestors Anicut Continuum Equity Fund and HDFCAMC Select AIF FOF-1.About SFO Technologies:- Founded in 1990, SFO Technologies is theflagship company of the NeST Group and avertically integrated EMS provider- It operates 24 manufacturing facilities, acrossKochi, Bengaluru, and Pune, serving sectors suchas aerospace, healthcare, energy,communications, industrial and transportation, witha client base that includes several Fortune 500companies.About the Lead Investors:- Trident Growth Partners: A growth-stage PE firmled by former partners from Premji Invest and IFC.This transaction marks the third investment fromits Rs.2,000 crore maiden fund.- Amicus Capital Partners: A mid-market focusedPE firm that targets category-leading businessesin sectors such as specialty manufacturing,healthcare, and technology. Its portfolio includescompanies like Aequs and Eka Care.

Ahmedabad Chartered Accountant Journal April, 2026 61TMRationale:- SFO will deploy the capital over the next two yearsto expand capacity, pursue backward integrationthrough components manufacturing and strengthenits global presence.- A key strategic focus of this investment is todeepen backward integration, reducing relianceon external supply chains and improving margins- The funding will support SFO’s ambition to scalefrom a domestic player into a leading global EMSplatform, strengthening its international presence.- The deal under scores the “China Plus One”strategy and the structural shift in India’s EMSsector towards high-complexity, engineering-ledmanufacturing (“Develop in India”).Capital Market- Beyond capital, the investors bring strategicrelationships, operating expertise and globalnetworks to support SFO’s growth andgovernance.- For FY25, SFO reported a revenue of Rs. 2,865.5crore (up 7% YoY) and an EBITDA of Rs.265.34crore (up 16% YoY), reflecting steady growth andimproving operating performance.Acknowledgements: RBI Bulletin(www.bulletin.rbi.org.in), SEBI (www.sebi.gov.in), NSE(www.nseindia.com), BSE (www.bseindia.com), IBEF(https://www.ibef.org)❉ ❉ ❉Inappropriately aggregating segments reduces theusefulness of segment disclosures to investors. IndAS 108 requires information to be disclosed that is notreadily available elsewhere in the financial statements,therefore it provides additional information which aidsan investor’s understanding of how the businessoperates and is managed.In Shrinath Ltd.’s case, if the segments are aggregated,then the increased profits in segment 2 will hide thedecreased profits in segment 1. However, the fact thatprofits have sharply declined in segment 1 would beof interest to investors as it may suggest that futurecash flows from this segment are at risk.Hence, it will be prudent not to aggregate segment 1and 2. However, the aggregation of segments andreporting of segments will also be subject toparagraphs 13 to 19 of Ind AS 108 i.e. Quantitativethresholds.❉ ❉ ❉Ind AS Insights Continued from page 51

62 Ahmedabad Chartered Accountant Journal April, 2026TMAssented 6th April 2026Brief Summary of Regulatory AmendmentsBrief Points • Comparison with Pre-Amendment Position • Practice Impact1. Executive SnapshotThe Insolvency and Bankruptcy Code (Amendment) Act, 2026 represents the most consequential overhaul ofthe IBC since its enactment in 2016. The amendments respond to nine years of practitioner experience, NCLT/NCLAT jurisprudence and the BLRC and IBBI working group recommendations. Five themes run through theentire Act:• Time-Bound Adjudication -Every key stage now carries a statutory timeline (14 days for admission, 30 days for withdrawal/approvalorders, 3 months for NCLAT appeals).• Decongestion of the Adjudicating Authority -Introduction of the Creditor-Initiated IRP (Chapter IV-A) which commences without filing before NCLT, theIBBI-led liquidator and RP recommendation system, and the omission of Sections 38–42.• Stronger Creditor Protection -Expanded standing for avoidance applications, mandatory IU filing by operational creditors, surety actionscovered by moratorium, and the new Section 28A controlling guarantor-asset transfers.• Civil-Penalty Regime replacing Criminal Prosecution -Sections 74 and 76 omitted; revamped Section 235A and new Sections 64A, 67B, 67C and 183A bringmonetary penalties up to Rs 5 crore (or 3× loss/gain).• Modernisation -statutory enabling provisions for group insolvency (Chapter VA), cross-border insolvency (Section 240C)and an electronic portal (Section 240B).2. Definitions and CIRP Initiation (Sections 2-10)2.1 New / Amended Definitions - Section 3Three definitional changes have practical consequences for every engagement:Position under Old Act Position under 2026 Amendment Practice ImpactNo statutory definition of ‘Registered New Section 3(27A) - ‘Registered RV’s role formally embedded inValuer’ within IBC; reliance on Valuer’ means a person registered IBC. Engagement letters andCompanies (Registered Valuers) under Chapter XVII of the CIRP cost vouchers should nowRules 2017 and IBBI registration. Companies Act, 2013. cite Sec 3(27A) directly. Relevantfor our valuation practice.The Insolvency and BankruptcyCode (Amendment) Act, 2026Dr. CA IP RV Anjali [email protected] Services

Ahmedabad Chartered Accountant Journal April, 2026 63TMThe Insolvency and Bankruptcy Code (Amendment) Act, 2026Position under Old Act Position under 2026 Amendment Practice Impact‘Security interest’ under Sec 3(31) Explanation to Sec 3(31): security Direct legislative reversal of theincluded interests created by interest exists only by act of parties, Rainbow Papers position.operation of law (statutory dues, NOT by operation of law. Statutory dues will not enjoytax priority etc.) - leading to secured creditor status in CoC.disputes (Rainbow Papers Major impact on governmentcontroversy). dues claim review.‘Service Provider’ was not a defined Sec 3(31A) - ‘Service Provider’ = Single regulatory umbrella. Secterm; references scattered across IP, IPA, IU, Registered Valuer + 196 powers of IBBI now uniformlyIPs, IPAs and IUs. any other notified person registered extend to RVs. Expectwith IBBI. consolidated standards-ofconduct circulars.2.2 Admission Timelines - Sections 7, 9, 10This is one of the most operationally significant changes for ongoing matters at NCLT Ahmedabad, Chennaiand Mumbai.Position under Old Act Position under 2026 Amendment Practice ImpactSec 7 admission timeline of 14 days AA must admit/reject within 14 Effectively reverses Vidarbha.was directory (Vidarbha Industries days. 7-day defect notice NCLT discretion on ‘admit-orPower case held NCLT has discretion mandatory before rejection. reject’ is curtailed once IUto consider broader factors). Reasons for delay must be evidences default. Petitionsrecorded. IU record of default by backed by NeSL records will seeFI = sufficient proof. No rejection faster admission.ground beyond Sec 7(5)(a) ifconditions met.Sec 9 - additional information Phrase changed to ‘as may be Faster response loop - IBBI cansought ‘as may be prescribed’ specified’ (IBBI Regulations). AA amend forms without(CG Rules). must record reasons if order parliamentary delay. OCdelayed beyond 14 days. engagements must adapt torevised forms quickly.Sec 10 - disciplinary-proceedings Disciplinary condition omitted. For voluntary corporate-debtorcondition for proposed RP applied; AA refers to IBBI Board for RP filings, the proposed RP can noAA appointed RP directly. recommendation (new Sec 16(3A)). longer be hand-picked. IBBISec 10(3)(b) omitted. panel system extended to Sec 10- neutralising ‘friendly RP’concerns.3. Withdrawal, CoC, Moratorium and IRP Duties (Sections 11-26)3.1 Withdrawal - Section 12APosition under Old Act Position under 2026 Amendment Practice ImpactWithdrawal permitted at any stage No withdrawal before CoC Settlement window is nowwith 90% CoC vote (Brilliant Alloys, constitution OR after first invitation bounded. Promoters seekingSwiss Ribbons jurisprudence). for resolution plans. AA must pass OTS / settlement must moveorder within 30 days; reasons for BEFORE EoI invitation.delay to be recorded. Restructuring strategy timingbecomes critical.

64 Ahmedabad Chartered Accountant Journal April, 2026TMThe Insolvency and Bankruptcy Code (Amendment) Act, 20263.2 Moratorium - Section 14Position under Old Act Position under 2026 Amendment Practice ImpactSec 14 moratorium did not Sec 14 explicitly applies where a Closes the loophole - suretiesexpressly cover creditor’s surety initiates or continues action cannot bypass moratorium byenforcement against the corporate against corporate debtor under a suing the CD post-payment.debtor under a contract of guarantee contract. Sec 14(1) Major impact on bank guaranteeguarantee where surety was the updated to refer new sub-section enforcement and back-to-backthird party (limited Lalit Kumar (2A). guarantee chains.Jain coverage).3.3 IRP / RP Powers - Sections 18, 19, 22Position under Old Act Position under 2026 Amendment Practice ImpactIRP collated claims ‘in such manner Explanation to Sec 18 inserted: IRP Statutory grounding for valuationas may be specified’. Verification shall verify claims and, if required, by IRP/RP at claims stage -was implicit but not codified. determine value of verified claims. useful in disputes over admittedclaim values. Also strengthensRV’s role at this stage.Sec 19 cooperation duty was on Now extends to any person who Practical relief for IRP - non-‘personnel’; ambit unclear for has been personnel, promoter, cooperation applications underex-promoters and contractors. associated with management, or Sec 19(2) can now be filed againstengaged in contract for service. ex-CFO consultants, retainerHeading: ‘Persons.’ auditors, legacy IT vendors etc.RP appointment communication Communication now to IRP, CD, Eliminates the ‘RP appointmentunder Sec 22 went to AA. and the Board (replacing AA). RP confirmation’ bottleneck. Savesdeemed appointed from date of 10–20 days routinely lost in NCLTCoC resolution. cause lists.3.4 CoC Supervises Liquidation - Section 21(11)Brand-new sub-section: the CoC’s life is extended into the liquidation phase. The CoC shall supervise theliquidation process under Chapter III. IBBI may also notify additional creditors who can attend (without vote).• Old Position: Stakeholders’ Consultation Committee (SCC) under Liquidation Regulations served onlyan advisory role; CoC ceased to exist after liquidation order.• Practice Impact: Liquidator’s monthly progress meetings now have statutory force. CoC can directly holdliquidator accountable. Applies prospectively AND to ongoing liquidations where Sec 54 dissolutionapplication has not been moved.3.5 Avoidance Proceedings Survive - New Section 26Filing of avoidance / fraudulent or wrongful trading / Sec 47 applications does NOT affect the continuation ofCIRP or liquidation, and completion of CIRP / liquidation does NOT affect avoidance proceedings.• Old Position: Venus Recruiters and 63 Moons judgments created uncertainty whether avoidanceapplications survived Sec 31 plan approval or dissolution.• Practice Impact: Codifies what the Delhi High Court Division Bench held in Tata Steel BSL - survival ofavoidance proceedings independent of CIRP outcome. Resolution plans can now provide for assignmentof avoidance recoveries to a SPV / continuing trust.

Ahmedabad Chartered Accountant Journal April, 2026 65TMThe Insolvency and Bankruptcy Code (Amendment) Act, 20264. Resolution Professional, Resolution Plan and Liquidation (Sections 28-43)4.1 NEW Section 28A - Transfer of Guarantor AssetsThis is an entirely new provision with no pre-amendment equivalent. It directly impacts how guarantor securityis monetised.Position under Old Act Position under 2026 Amendment Practice ImpactNo statutory mechanism in IBC Corporate guarantor in CIRP: 66% MAJOR: SARFAESI/Section 13(4)dealing with creditor’s transfer of CoC vote needed for creditor to sales of guarantor security nowguarantor’s asset during ongoing transfer guarantor asset. During controlled by the IBC framework.CIRP/liquidation; conflicts between liquidation: only if creditor Banks cannot unilaterally enforceSARFAESI sale and CIRP arose relinquished asset to estate. against a CD-guarantor’s assetscase-by-case. Personal guarantor: 75%+ in value if the CD is in CIRP - they mustof personal guarantor’s creditors. seek CoC approval. ReshapesAll rights vest in transferee; surplus lender realisation strategyto guarantor. entirely.4.2 Resolution Plan Standards - Section 30Position under Old Act Position under 2026 Amendment Practice ImpactSec 30(2)(b) prescribed minimum New Sec 30(2)(ba): payment to Significantly upgrades dissentingpayment to dissenting / non-voting non-voting FCs = HIGHER of (i) creditor entitlement. EffectivelyFCs at liquidation value (Essar Steel). liquidation value, OR (ii) pro-rata of codifies a ‘fair-value floor’ linkedresolution plan distribution per to the plan’s actual distribution.Sec 53 priority. Lenders dissenting tactically gainleverage.Implementation committee Sec 30(2)(d): Implementation Standardises monitoringcomposition not statutorily defined. committee = RP/IP + creditor class committees post-approval. RPsrepresentatives + resolution should now insist on thisapplicant. composition in the plan itself.CoC approval reasons not required CoC must record reasons for Substantial mitigation againstto be recorded under Sec 30(4). decision under Sec 30(4). ‘commercial wisdom’ challenges.IPs must minute decisions withproper reasoning to insulate planapprovals.4.3 AA Approval of Resolution Plan - Section 31Position under Old Act Position under 2026 Amendment Practice ImpactAA approved or rejected the plan 2nd Proviso to Sec 31(1): AA may Game-changer for revival timing.as a single composite order. Long FIRST approve implementation, Implementation can begin whiledelays at NCLT level (often 12-18 THEN approve distribution within 30 distribution waterfall is finalised.months). days. Proviso to Sec 31(2): defect- Reduces ‘plan approval torectification notice to CoC handover’ lag.mandatory before rejection. Sec31(2A): AA must order within 30days, reasons for delay.

66 Ahmedabad Chartered Accountant Journal April, 2026TMThe Insolvency and Bankruptcy Code (Amendment) Act, 2026Position under Old Act Position under 2026 Amendment Practice ImpactSec 31 silent on licences/permits Sec 31(5): licences/permits NOT Codifies Embassy Propertycontinuity post-approval (handled via suspended if CD complies with Developments and Lalit KumarSec 14 or NCLT directions case-by- conditions. Sec 31(6): all claims Jain. Promoter-guarantor liabilitycase). extinguished on approval; survives the plan - significant forguarantors/joint-liability persons personal guarantor proceedingsNOT protected. parallel to corporate CIRP.4.4 Liquidation Reforms - Sections 33, 34, 34A, 35Position under Old Act Position under 2026 Amendment Practice ImpactNo mechanism to reverse a Sec 33(1A)/(1B): AA must Allows fresh resolution attemptliquidation order once passed. consider CoC application (66% where a late prospectivevote) to RESTORE CIRP before resolution applicant emerges.liquidation order. Restore once Particularly useful where newonly, max 120 days. investor surfaces between Sec 33trigger and order.RP routinely became the liquidator Sec 34(1): liquidator appointed via Strict segregation. Hand-over(subject to CoC option). Continuity Board recommendation. Sec 34(4): from RP to liquidator becomes aargument used to justify same RP of same CIRP CANNOT be defined process. Will create aperson. appointed liquidator. Sec 34A: fresh stream of liquidationCoC may replace liquidator by appointments via the Board panel66% vote. - relevant for our IP empanelment.Sec 38-42 prescribed claim Sec 38-42 OMITTED. Process Liquidator’s claim handling nowinvitation, verification and admission now governed by Sec 35(1)(a) flexible to regulations - IBBI canprocess in liquidation in detailed and IBBI Liquidation Regulations. amend timelines withoutstatutory form. Transitional savings clause for pre- parliamentary action. Caution:amendment liquidations. ongoing liquidations commencedON or BEFORE the amendmentdate continue to be governed byold Sec 38-42.4.5 Look-Back Periods Clarified - Sections 43, 46, 50Pre-amendment ambiguity between ‘initiation date’ and ‘commencement date’ is resolved. The look-backperiod now uniformly runs from the relevant period (2 years for related-party / undervalued; 1 year for nonrelated party preferential) preceding the INITIATION DATE and ending on the INSOLVENCY COMMENCEMENTDATE.Practical effect: in cases where there is a long gap between filing and admission (which is common - sometimes6-18 months), the full pre-filing window is captured. Earlier interpretation often missed transactions in this gap.

Ahmedabad Chartered Accountant Journal April, 2026 67TMThe Insolvency and Bankruptcy Code (Amendment) Act, 20265. Avoidance Transactions (Sections 46-52)5.1 Expanded Creditor Rights - Section 47Position under Old Act Position under 2026 Amendment Practice ImpactOnly Sec 45 (undervalued) Creditors / members can apply for Major escalation in creditoravoidance was creditor-applicable; ALL FOUR - Sec 43, 45, 50 and activism. Fits situations where RPSecs 43, 50, 66 were RP/liquidator- 66. AA passes order as if filed by is perceived as soft on theonly. liquidator/RP. AA must direct IBBI to suspended Board. Creates realinitiate disciplinary action against risk of RP discipline - RP mustRP for non-reporting despite document avoidance reviewinformation. robustly in the InformationMemorandum.5.2 Related Party Transactions - Section 49Position under Old Act Position under 2026 Amendment Practice ImpactSec 49 applied to undervalued Scope extended to include ‘a Closes the ‘shell-companytransactions by the corporate debtor. related party of the corporate conduit’ route - transactionsdebtor’. where assets were diverted via arelated party to a third party arenow reachable.5.3 Secured Creditor Realisation - Section 52Position under Old Act Position under 2026 Amendment Practice ImpactOpt-out window: 30 days from Opt-out window: 14 days. Multiple Compresses lender decisionliquidation commencement. No secured creditors: 66% in value window from 30 to 14 days -threshold for multiple secured must agree. Liquidation/CIRP costs banks must act decisively. Thecreditors. No explicit liquidation cost + workmen dues deducted from 66% threshold prevents minoritydeduction. Shortfall treatment unclear. realisations. If security < debt: secured creditor from blockingsecured to value of security; collective realisation. Codifies theremainder is unsecured. M.K. Rajagopalan / DBS Bankapproach to shortfalls.5.4 Dissolution - Section 54Position under Old Act Position under 2026 Amendment Practice ImpactNo outer time limit for liquidator to Sec 54(1): Liquidator to apply within Mandatory closure timeline.apply for dissolution. 180 days (extendable by 90 Long-pending liquidations atdays). Sec 54(1A): CoC determines NCLT will face active monitoring.treatment of pending avoidance CoC’s role in deciding fate ofproceedings post-dissolution. Sec pending avoidance recoveries is54(2A): dissolution order does not a fresh strategic consideration.stop ongoing proceedings; AA toorder within 30 days.

68 Ahmedabad Chartered Accountant Journal April, 2026TMThe Insolvency and Bankruptcy Code (Amendment) Act, 20266. NEW Chapter IV-A - Creditor-Initiated Insolvency Resolution ProcessChapter IV (old Sections 55–57: Fast Track CIRP) is OMITTED and replaced with Chapter IV-A: CreditorInitiated Insolvency Resolution Process (CIRP-CI), Sections 58A-58K. This is arguably the single mostinnovative reform in the 2026 amendment.6.1 Conceptual ShiftUnlike a regular Sec 7 CIRP, CIRP-CI is initiated WITHOUT first approaching NCLT. Eligible financial creditors(with statutory voting threshold) directly appoint an RP and commence the process. Management remains withthe Board. NCLT is approached only for objections, conversion, withdrawal, or final plan approval.6.2 Key Provisions at a GlanceSection ProvisionSec 58A - Eligibility CD below notified asset/income levels OR with notified creditor/debt class.NOT available if CIRP/liquidation ongoing or if any insolvency processcompleted in past 3 years.Sec 58B - Initiation Step 1: 51% FC approval. Step 2: 30-day notice to CD. Step 3: Fresh 51%post-representation. Step 4: RP appointed; public announcement. NO courtfiling.Sec 58C - Objections CD may object to AA within 30 days. AA may declare void ab initio (no default+ procedural breach) or convert to regular CIRP under Ch. II. AA must decidewithin 30 days.Sec 58D - Timeline 150 days, extendable by 45 days (once, with 66% CoC). If no plan, AA convertsto regular CIRP.Sec 58E-F - Management Management REMAINS with Board (debtor-in-possession). RP attendsmeetings, may REJECT resolutions. Promoters liable for false IM info.Sec 58G - Moratorium OPTIONAL - RP applies post-CoC approval (or pre-CoC with 51% FI).Commences from application date.Sec 58H-J - Conversion / Conversion to CIRP if no plan / non-cooperation / 66% CoC vote. Withdrawal:Withdrawal / Plan 90% CoC. Plan: 66% CoC then AA approval under Sec 31.6.3 Practice Impact• Massively decongests NCLT -the entire admission stage is bypassed. We can expect Ahmedabad / Mumbai to see 30–40% reductionin admission-stage filings as eligible mid-market FCs move to CIRP-CI.• Debtor-in-possession model -Indian insolvency formally adopts a debtor-in-possession lite model alongside the practitioner-inpossession Chapter II CIRP. Management cooperation incentive shifts.• RP role re-engineered -The RP is more ‘monitor with veto’ than ‘manager’. New skill profile required: governance review, transactionsniff-test, IM accuracy. IPs should anticipate IBBI’s separate IP-CI registration norms under Sec 208(1)(cb).• Optional moratorium -creates strategic flexibility. Lenders may prefer a no-moratorium CIRP-CI to keep collateral enforceable.

Ahmedabad Chartered Accountant Journal April, 2026 69TMThe Insolvency and Bankruptcy Code (Amendment) Act, 20267. Pre-Pack, Voluntary Liquidation and Group Insolvency7.1 Pre-Pack - Sections 54A-54NPosition under Old Act Position under 2026 Amendment Practice ImpactSec 54A (2)(e) and (3): 66% FC Threshold reduced to 51%. Significantly increases pre-packapproval needed to initiate pre-pack viability for MSME corporatefor MSMEs. debtors. Expect material pickupat NCLT Ahmedabad givenGujarat’s MSME concentration.No bar on parallel CIRP-CI / pre-pack. CDs undergoing creditor-initiated Forum-shopping prevented.process cannot apply for pre-pack. Promoter cannot trigger pre-packto derail a CIRP-CI initiated byFCs.Sec 54L(2): AA could reject the plan AA must give CoC notice to rectify Aligns with the Sec 31(2) duewithout providing CoC opportunity to defects before rejection. process change. Reducesrectify defects. avoidable plan rejections.7.2 Voluntary Liquidation - Section 59Position under Old Act Position under 2026 Amendment Practice ImpactNo outer time limit for voluntary Maximum 1 year (as specified by Voluntary liquidations can noliquidation completion. Once initiated, IBBI). Termination possible if longer drift indefinitely. The newno statutory mechanism to terminate. members pass special resolution termination mechanism is a longAND creditors (2/3 in value) overdue safety valve whereapprove within 7 days. Liquidator business circumstances changeinforms Board + ROC within 7 days; post-initiation. Critical for ourtermination deemed from date of voluntary liquidationROC intimation. Claims now engagements.reference Sec 18(b) (post Sec38-42 omission).7.3 NEW - Group Insolvency Framework - Chapter VA (Section 59A)An entirely new framework with no prior IBC equivalent. The Central Government may prescribe rules forgroup insolvency of interconnected entities.• ‘Group’ definition: two or more corporate debtors interconnected by control or 26%+ significant ownership.• Enabling features: common NCLT Bench; coordination between CoCs/IPs of group entities; common IPfor coordination; group-level CoC; binding coordination agreements; treatment of group insolvency costs.• Parliamentary oversight: draft rules must be laid before Parliament for 30 days before notification.Practice impact: this codifies the procedural improvisations developed in Videocon Industries (NCLT Mumbai),Lavasa, Jaypee Group and Era Infra - substantive coordination between group CIRPs, common RP suggestions,and combined plans. Once notified, complex group resolutions will follow a clear statutory architecture.

70 Ahmedabad Chartered Accountant Journal April, 2026TMThe Insolvency and Bankruptcy Code (Amendment) Act, 20268. Appeals, Penalties and Enforcement8.1 NCLAT Disposal Timeline - Section 61Position under Old Act Position under 2026 Amendment Practice ImpactNo statutory timeline for NCLAT New Sec 61(6): NCLAT shall First-ever statutory appellatedisposal. Average pendency 9-14 dispose of appeal within 3 months timeline. Resolution applicantsmonths. from receipt. get certainty on plan finality. Willrequire capacity expansion atNCLAT.8.2 Frivolous Proceedings Penalty - New Sections 64A, 183AAA may impose Rs 1 lakh to Rs 2 crore penalty on any person initiating frivolous or vexatious proceedingsunder Part II (Sec 64A) or Part III (Sec 183A). This is a powerful deterrent against abuse - particularly the‘pressure tactic’ Sec 9 filings.8.3 Concealment of Pre-Existing Dispute - New Sec 67CRs 1 lakh to Rs 2 crore penalty on operational creditor who concealed dispute notification in a Sec 9 application.Mobilox Innovations principle now has teeth - the OC’s affidavit on ‘no dispute’ is not just a procedural formality.8.4 Decriminalisation - Sections 74 and 76 OmittedPosition under Old Act Position under 2026 Amendment Practice ImpactSec 74 - moratorium contravention Both sections OMITTED. Major shift in IBC enforcementby CD officer/creditor: 1-5 years Replaced by civil penalties under philosophy. Reduces criminalimprisonment + fine. Sec 76 - revised Sec 235A and new Secs court burden, speedswrongful concealment: criminal 67B / 67C. Ongoing prosecutions enforcement (penalty isprosecution. saved. administrative, not requiringproof beyond reasonable doubt).Civil penalty quantum issignificant - up to Rs 5 croreor 3× loss/gain.8.5 Civil Penalty Regime - Section 235ASubstantially revised. Penalty structure now codified:• Rs 1 lakh per day (minimum).• Maximum: 3× loss caused OR 3× unlawful gain (whichever is higher).• If loss/gain not quantifiable: maximum Rs 5 crore.• AA may reduce below Rs 1 lakh/day for sufficient cause (recorded in writing).• Savings clause: ongoing prosecutions under Secs 74/76 not affected.

Ahmedabad Chartered Accountant Journal April, 2026 71TMThe Insolvency and Bankruptcy Code (Amendment) Act, 20268.6 IBBI Disciplinary Mechanism - Sections 219-220Position under Old Act Position under 2026 Amendment Practice ImpactIBBI directly issued show-cause; SCN on prima facie opinion from For IPs: doubling of monetaryDisciplinary Committee was Board- inspection; multiple committees exposure under disciplinaryconstituted; penalty ceiling Rs 1 from Chairperson/WTM/officers (ED action. NCLAT appeal route iscrore; no appeal to NCLAT. level); penalty ceiling Rs 2 crore; welcome - earlier only writappeal to NCLAT within 30 days remedy was available.(extendable by 15). Insurance review is advisable.9. Cross-Border IRP, Electronic Portal and Information Utilities9.1 NEW Sections 240B and 240CSection 240B enables the Central Government to notify an Electronic Portal for IBC processes - a single digitalwindow for filings, public announcements, claim submissions, voting and orders. This builds on the IBBI’sexisting pilot platforms.Section 240C empowers the Central Government to prescribe rules for cross-border insolvency: recognitionof foreign proceedings, relief, judicial cooperation, coordination, and designation of special NCLT Benches.The definition of ‘corporate debtor’ is extended to include limited liability entities incorporated outside India.• Old Position:Sections 234 and 235 contemplated bilateral arrangements that were never operationalised. UNCITRALModel Law adoption was repeatedly recommended (Insolvency Law Committee 2018, 2020, 2021) butnot legislated.• Practice Impact:Once rules are notified, foreign-incorporated subsidiaries / parents of Indian groups can be broughtunder coordinated proceedings. Especially relevant for groups with Mauritius / Singapore / DIFC layers- common in Gujarat-based diamond, pharma and chemical groups.9.2 Information Utilities — Section 215Position under Old Act Position under 2026 Amendment Practice ImpactIU filing was permissive - Sec 215 Operational creditor SHALL NeSL filings will become asaid FCs / OCs ‘may’ file financial (mandatory) file financial info with precondition to Sec 9. Affectsinformation. IU before filing Sec 9 application. engagement timing - OC clientsSec 215(4): CD shall authenticate IU should be advised to commenceinformation; deemed authenticated IU filing at least 30-45 days beforeif no response within specified contemplated demand notice.period.❉ ❉ ❉

72 Ahmedabad Chartered Accountant Journal April, 2026TMAccounting for Government Grants - [IND-AS 20] -Annual Report - 2024-25Indian Oil Corporation Ltd.A. Revenue Grants1 Subsidies on sales of SKO (PDS) and LPG(Domestic)Subsidies on sales of SKO (PDS) in Indiaamounting to H 33.03 crore (2024: H 93.80 crore)and subsidies on sales of LPG (Domestic) tocustomers in Bhutan amounting to H 15.39 crore(2024: H 5.80 crore) have been reckoned as perthe schemes notified by Governments.2 Export of Notified Goods under MEIS Claims/RoDTEP/Duty Drawback schemeThe Company has recognised H 31.01 crore (2024:H 37.62 crore) on export of notified goods underMerchandise Exports from India Scheme (MEIS)/Remission of Duties and Taxes on ExportedProducts (RoDTEP)/Duty Drawback scheme in theStatement of Profit and Loss as Revenue Grant.3 Stipend to apprentices under NATS/NAPSschemeAs per Ministry of HRD & Skill development andEntrepreneurship, a portion of stipend and basictraining cost for apprentices will be reimbursed toemployer by Government under NationalApprenticeship Training Scheme (NATS) andNational Apprenticeship Promotion Scheme(NAPS), subject to prescribed threshold limit. TheCompany has recognised grant in respect ofstipend paid to apprentices & Basic training costunder NATS & NAPS amounting to H 0.31 crore(2024: H 7.93 crore) as Revenue Grant.4 Grant in respect of revenue expenditure forresearch projectsDuring the year, the Company has receivedrevenue grant of NIL (2024: H 0.47 crore) in respectof meeting out revenue expenditure such asManpower, Consumables, Travel & Contingencyetc. for research projects undertaken with variousagencies.5 Incentive on sale of powerThe Company is getting incentive from Departmentof Renewable Energy, GOI for wind powergeneration of Electricity at the rate of H 0.50 paisefor per unit of power generated. The Companyhas received grant of H 0.01 crore during the currentyear (2024: H 1.46 crore).6 Excise duty benefit in North EastExcise duty exemption of 50% of goodsmanufactured and cleared from north eastrefineries has been reckoned at full value inrevenue and on net basis in expenses under‘Excise Duty’ (to the extent of duty paid). Financialimpact for the current year is H 3,885.58 crore(2024: H 3,816.73 crore).7 Viability Gap Funding (VGF)The Company has received grant in the form ofinterest free loans from Odisha Government for aperiod of 15 years.The unamortized grant amountas at March 31, 2025 is H 3,100.61 crore (2024: H2,901.21 crore). During the year, the Company hasrecognised H 273.26 crore (2024: H 241.15 crore)in the Statement of Profit and Loss as amortisationof grants.CA. Pamil H. [email protected] PublishedAccounts

Ahmedabad Chartered Accountant Journal April, 2026 73TM8 Post Export EPCG GrantPost Export EPCG grants are received in respectof Import duties paid on procurement of capitalgoods under Post Export EPCG Scheme of CentralGovt. which allows refund of Basic custom duty inthe form of duty scripts upon fulfilment of an exportobligation. During the year, the Company hasrecognized H 1.84 crore (2024: Nil) as RevenueGrant in the Statement of Profit & Loss.B. Capital Grants1 OIDB Government Grant for strengtheningdistribution of SKO (PDS)The Company has received government grant fromOIDB (Oil Industry Development Board) forstrengthening distribution of PDS Kerosene as perthe directions of MoP&NG to be used inconstruction of 20KL underground Tank,Mechanical Dispensing Units and Barrel Shed. Theunamortized capital grant amount as at March 31,2025 is H 0.20 crore (2024: H 0.31 crore). Duringthe year, the Company has recognised H 0.11 crore(2024: H 0.15 crore) in Statement of Profit and Lossas amortisation of capital grants.2 Capital Grant in respect of Excise duty, Customduty and GST waiverThe Company has received grant in respect ofCustom duty waiver on import on capital goods,Excise duty waiver and GST waiver on purchaseof goods from local manufacturer in India underthe certificate issued by Department of Scientificand Industrial Research (DSIR). The unamortizedcapital grant amount as at March 31, 2025 is H38.81 crore (2024: H 49.48 crore). The goods soimported or procured from local manufacturer shallnot be transferred or sold for a period of five yearsfrom date of installation.TATA Motors LimitedOther income includes export and other recurring andnon-recurring incentives from Government (referredas”incentives”). Government grants are recognisedwhen there is a reasonable assurance that the Companywill complywith the relevant conditions and the grantwill be received. Government grants are recognisedin the statement of profit and loss, either on a systematicbasis when the Company recognises, as expenses,the related costs that the grants are intended tocompensate or, immediately if the costs have alreadybeen incurred. Government grants related to assetsare deferred and amortised over the useful life of theasset. Government grants related to income arepresented as an offset against the related expenditure,and government grants that are awarded as incentiveswith no ongoing performance obligations to theCompany are recognised as income in the period inwhich the grant is received.Uttam Sugar Mills LimitedGovernment grants are recognized at fair value whenthere is reasonable assurance that the grant would bereceived and the Company would comply with all theconditions attached with them.Government grantsrelated to property, plant and equipment are treatedas deferred revenue (included under non-currentliabilities with current portion considered under currentliabilities) and are recognized and creditedin thestatement of profit and loss on systematic and rationalbasis and included under other income.Governmentgrants related to revenue nature are recognized on asystematic basis in the Statement of profit and Lossover the periods necessary to match them with therelated costs which they are intended to compensateand are adjusted with the related expenditure. (If notrelated to a specific expenditure, it is taken as incomeand presented under: other Income)Welspun Specialty Solutions LimitedOther income includes export and other recurring andnon-recurring incentives from Government (referred as“incentives”). Government grants are recognised whenthere is reasonable assurance that the Company willcomply with the relevant conditions and the grant willbe received. Government grants are recognised inthe consolidated statement of profit and loss, eitheron a systematic basis when the Company recognises,as expenses, the related costs that the grants areintended to compensate or, immediately if the costshave already been incurred. Government grantsrelated to assets are deferred and amortised over theFrom Published AccountsContinued to page 80

74 Ahmedabad Chartered Accountant Journal April, 2026TMCA. Kunal A. [email protected] the Government CA. Ashwin H. [email protected] on invoices uploaded by their suppliersthrough GSTR-1, GSTR-1A, or IFF, includingaccepting, rejecting, or keeping such recordspending in the system.To continuously enhance the taxpayerconvenience and facilitate ease of compliance,an IMS Offline Tool has now been introduced inthe GST system. The said offline tool is basedon MS excel making it easy to use by thetaxpayers and it enables them to undertakeactions on both individual as well as bulkinvoices in an efficient manner. Detailed advisoryon the IMS offline tool is available on the GSTINportal.INCOME TAX1) Navigator of forms as per ITA 2025/1961With the implementation of the Income Tax Act,2025 (ITA 2025), effective 1st April 2026, formsprescribed under the Income Tax Act, 1961 (ITA1961) have been renumbered and restructuredunder the new legislative framework.For ease of reference, a mapping of the ITA 2025forms available for filing on the e-Filing portal from1 April 2026 to their corresponding ITA 1961 formsis provided below. This table facilitates easyidentification of the equivalent forms under theIncome-tax Act, 2025GOODS AND SERVICE TAX1) Pre-deposit Percentage in the GST Portal (GSTupdates April 10th, 2026)While filing an appeal in Form APL-01 on the GSTportal, the pre-deposit percentage is autopopulated as 10% in accordance with Section107(6) of the CGST Act, 2017, and was previouslynon-editable. Due to this restriction, taxpayersfaced difficulties in cases where the pre-deposithad already been made through other means orwhere the demand amount was incorrectlyreflected under the appropriate head.To address these issues, GSTN has now madethe pre-deposit field editable at the time of filingthe appeal, from April 6th, 2026. This allowstaxpayers to modify the pre-deposit percentageas applicable to their specific case and calculateand pay the required amount accordingly whilesubmitting the appeal. The appellate authority willsubsequently verify the correctness of the predeposit amount and the mode of payment duringthe adjudication of the appeal.2) Introduction of IMS Offline Tool (GST updatesApril 21st, 2026)The Invoice Management System (IMS) wasintroduced on the GST portal from the October2024 tax period enabling the taxpayers to takeForm No. Form No. Form Description(ITA,2025) (ITA,1961)1 3BB Monthlystatementtobefurnishedbyastock exchangein respect of transactionsin which client codes have been modified after registering in the system forthe month of…….2 5B Application for notification of a zero coupon bond undersection 2(112) of theAct

Ahmedabad Chartered Accountant Journal April, 2026 75TMForm No. Form No. Form Description(ITA,2025) (ITA,1961)17 3CF Application for approval of a company under section 45(3)(b) and of a researchassociation, university, college or other institution under section 45(4)(b) ofthe Income-tax Act, 202518 3CN Application for notification of affordable housing projectas specified businessunder section 46 of the Act19 3CS Application for notification of a semiconductor wafer fabrication manufacturingunit as specified business undersection 46 of the Act20 3C-O Application for approval of agricultural extension project under section 47(1)(a)of the Act41 10F Information to be provided under section 159(8)42 10FA Application for Certificate of residence for the purposes of an agreement undersection 159(1) and 159(2)50 3CEC Application for a pre-filing consultation51 3CED, 3CEDA Application for an Advance Pricing Agreement (APA)52 3CEF Annual Compliance Report on Advance Pricing Agreement54 New Form Application for Renewal of an Advance Pricing Agreement (APA)55 34F Form of application for an assessee, resident in India, seeking to invokemutual agreement procedure providedfor in agreements with other countriesor specified territories80 65 Application for *exercising/renewing option for the tonnage tax scheme under* section 231(1) or 231(10) ofthe Act104 10A Application for provisional registration or provisional approval105 10AB Application for registration of non-profit organisation under section 332 orapproval for deduction under section 133(1)(b)(ii)106 10AC Order for provisional registration u/s 332 or provisional approval u/s 354Rejection of application113 10BD Statement or Correction Statement to be filed by Donee under section 354(1)114 10BE Certificate of donation under section- 354(1)(g)121 15G, 15H Declaration under section 393(6) for receipt of certain in comes withoutdeduction of tax127 27C Declaration under section 394(2) of the Act to be made by a buyer for obtaininggoods without collection of tax141 26QB, 26QC, Challan-cum-statement of deduction of tax under section 393(1) [Table Sl. No.26QD,26QE 2(i), 3(i), 6(ii) & 8(vi)]145 15CA. Information to be furnished for payments to a non-resident not being a company,or to a foreign company146 15CB. Certificate of an accountant for payments to a non-resident, not being a companyor to a foreign companyFrom the Government

76 Ahmedabad Chartered Accountant Journal April, 2026TMForm No. Form No. Form Description(ITA,2025) (ITA,1961)152 28A Intimation to the Assessing Officer under section 407(8) regarding the noticeof demand under section 289 of the Income -tax Act, 2025 for payment ofadvance tax under section 407(2)/407(5) of the Act174 10BBA Application for notification under Schedule V [Table: Sl.No.7. Note 5(a)(iii)(D)](Pension Fund)180 9 Application for grant of approval to a fund referred to in Schedule VII [Table:Sl. No. 2]186 40C Application for recognition of a Recognised provident fund187 42, 43, 44 Appeal against refusal to grant recognition/approval orwithdrawal of recognition/approval from a Provident Fund, Superannuation Fund, or Gratuity Fund.188 New Form Application for Approval for Superannuation Fund/Gratuity Fund189 59 Guidelines for approval under Schedule XV (1)(z)(i) and(1)(z)(ii) of the Act190 59A Application for approval of mutual funds investing in the eligible issue of publiccompanies under section Schedule XV: Paragraph 1(z)(ii) of the ActForm I Form I Application for notification under Schedule V [Table: Sl.No.7.Note 5(a)(ii)(G)](Sovereign (SWF) (Sovereign Wealth Fund)Wealth Fund)Form 1 Form 1-New Statement-cum-Declaration to be furnished by a Unit engaged in the business(Ship leasing (Ship Leasing of leasing of a ship of an International Financial Services Centre (payee) to thebusiness) business) Lessee (payer)(NotificationNo.57/2023)Form 1 Form 1-New Statement-cum-declaration to be furnished by a Unit ofInternational Financial(Declaration (Declaration Services Centre (‘payee’) to the‘payer’by Unit by Unitof IFSC) of IFSC)(NotificationNo.28/2024)Form 1 Form 1 Statement-cum-Declaration to be furnished by a Unitengaged in the business(Dividend {Dividend of leasing of aircraft (payee) located in International Financial Services Centreexempt exempt u/s to a Unit of International Financial Services Centre (payer)under 10(34B)}Schedule VI (Notification(Table: S. No.52/2023)No. 11))Form 1 Form 1 Statement-cum-Declaration to be furnished by a unitengaged in the business(Aircraft (Aircraft of leasing of aircraft located inInternational Financial Services Centre to theLeasing Leasing LesseeBusiness) Business)(NotificationNo.65/2022)❉ ❉ ❉From the Government

Ahmedabad Chartered Accountant Journal April, 2026 77TMIRDAI Information & Cyber Security Framework 2026A Practice-Oriented Guide for Chartered AccountantsReference: IRDAI/GA&HR/CIR/MISC/51/4/2026,Notified 6th April 2026 (Version 2.0)The release of the IRDAI Information & Cyber SecurityGuidelines 2026 (Version 2.0) Dated 6th April, 2026,represents a decisive shift in India’s insuranceregulatory landscape, moving decisively fromcompliance based IT controls to governance-drivencyber resilience. For Chartered Accountants engagedin system audits, Cyber Governance certifications andadvisory mandates, this framework materially expandsboth the scope of professional responsibility and therange of value-added services CAs are positioned todeliver.1. From IT Controls to Governance FrameworkThe 2026 framework is not just a technical checklist,but it is a Governance Mandate. Every IRDAIregulated entity is required to develop and maintaina Board approved Information & Cyber SecurityPolicy (ICSP) that encompasses:• The Confidentiality, Integrity and Availability(CIA) triad• Risk-based protection of information assetsacross the enterprise• Cyber resilience strategies and BusinessContinuity Planning (BCP)• Regulatory alignment, including compliancewith the DPDP ActKey Implication for CAs: The audit lens must shiftfrom verifying system controls to evaluatinggovernance maturity. Cyber security is now aboardroom responsibility, not an IT departmentfunction.2. Structured Governance Framework: ACompulsory RequirementThe guidelines mandate a formal, multi-tieredgovernance structure, including:• Board of Directors, carrying ultimateaccountability for cyber security posture• Chief Information Security Officer (CISO), withfull operational independence• Chief Risk Officer (CRO), integrated within thegovernance hierarchy• Information Security Risk ManagementCommittee (ISRMC), mandated to convenequarterlyThe ISRMC carries responsibility for policyupdates, incident oversight and continuous riskposture monitoring. This marks a fundamentaldeparture from earlier guidelines, which were ITcentric and lacked formal committee governance.Audit Focus Areas: Verify whether the ISRMCfunctions substantively or exists merely on paper;review board-level reporting and decision trails;and assess whether cyber risk budgets areappropriately calibrated.3. CISO Independence: A Non-Negotiable MandateThe framework prescribes strict conditions for theCISO role:• Senior executive appointment, not a mid-levelIT designation• Direct reporting line to the CEO or CRO,independent of the IT head• No business performance targets that couldcompromise security objectivityCA. Zalak [email protected]

78 Ahmedabad Chartered Accountant Journal April, 2026TM• Clear segregation between securitygovernance and technology operationsCA Focus: Validate the CISO’s reporting hierarchy,identify any conflicts of interest and assess theadequacy of security staffing and expertise relativeto the entity’s risk profile.4. Risk-Based Approach to Cyber SecurityEntities are required to implement a formal,documented risk management lifecycle. Atminimum, risk assessments must be conductedannually and mandatorily triggered by:• Adoption of new technologies, digitalplatforms, APIs, mobile applications,customer-facing portals or major changes toexisting information systems requiringTechnology Risk Assessment (TRA) andsecurity evaluation prior to implementation.• Migration to or expansion of cloudenvironments, including evaluation of hostingarrangements and use of CSPs empanelledor certified in line with applicable MeitYrequirements, wherever applicable to theRegulated Entity’s operating model andregulatory obligations.• On boarding of third-party vendors,outsourced service providers, cloud serviceproviders (CSPs), SaaS platforms, or externalentities having access to organizationalinformation assets, customer data, or criticalsystems, requiring formal securityassessment and risk evaluation prior toengagement.• Risk treatment plans must be formallydocumented, with residual risk acceptancerequiring explicit written approval. Theframework also introduces a “comply orexplain” approach for certain provisions,particularly for complex entities.CA Role: Scrutinise the risk assessmentmethodology, verify that identified risks have beengenuinely mitigated rather than merelydocumented and review approvals for any residualrisk acceptance.IT Corner5. Structured Security Domain Controls: Over 20Prescribed AreasThe framework introduces a comprehensive setof structured security domains. Those mostdirectly relevant to audit and assuranceengagements include:• Data Classification (Confidential, Restricted,Internal, Public)• Access Control, Role-Based Access Control(RBAC) and least-privilege principles• Asset Management, full lifecycle tracking ofinformation assets• Network Security and Segmentation• Cryptographic Controls• Incident Detection and Management• Logging, Monitoring and Audit Trails• Cloud Security Governance• Multi Factor Authentication (MFAs)• End to end Encryption of Data in transit andat rest• Web Application Layer Firewall• Industry acceptable Recovery Time Objective(RTO) and Recovery Point Objective (RPO)CA Perspective: Shift from checklist verificationto control design testing, effectiveness validationand evidence-based assurance. The standardrequires unique user identification and strictlyauthorised access tied to documented businessneed.6. Cyber Resilience and Business ContinuityA significant enhancement in the 2026 guidelinesis the shift from breach prevention to holisticresilience. Entities are required to establish andmaintain:• Disaster Recovery (DR) plans with definedRecovery Time Objectives (RTO) andRecovery Point Objectives (RPO)• Business Continuity Planning (BCP) alignedwith the entity’s risk exposure

Ahmedabad Chartered Accountant Journal April, 2026 79TM• Scenario-based incident responseprocedures• Regular cyber drills and simulated attackexercises• Security Operations Centre (SOC) monitoringcapabilitiesCA Focus: Validate documented RTO/RPOcommitments against actual DR test results; reviewevidence of completed drills; and assess incidentresponse readiness against defined scenarios.7. Third-Party and Cloud Risk GovernanceThe guidelines impose strict and unambiguousaccountability for all outsourced functions andcloud arrangements. Regulated entities mustensure:• Security standards equivalent to internalcontrols are maintained by all vendors• Formal vendor risk assessments areconducted prior to and during engagement• Service Level Agreements (SLAs) are alignedwith regulatory security requirements• Cloud Service Providers (CSPs) are subjectto the same governance rigour as internalsystemsCritical Principle: Outsourcing an IT function doesnot transfer regulatory responsibility. The regulatedentity remains fully accountable for the securityposture of its service providers.8. Integration with the DPDP Act and LegalComplianceThe framework explicitly mandates alignment withthe broader legal and regulatory environment,including:• Digital Personal Data Protection Act (DPDPAct)• Information Technology Act and associatedrules• CERT-In directions and circularsImplication for CAs: Cyber security audits nowintersect directly with data privacy compliance.Engagements must address consentmechanisms, data processing obligations andmandatory breach notification timelines under theDPDP framework.9. Mandatory Annual Cyber Security AuditThe framework prescribes a compulsory annualcyber security audit by an eligible audit firm /auditor with:• 30 days reporting timeline for intermediariessubmitting audit reports to insurers• 90 days reporting timeline for insurerssubmitting audit reports to IRDAI• Mandatory coverage of Annexure III auditchecklist• Cyber risk rating and reporting of identifiednon-compliancesEarlier IRDAI guidelines specifically mandatesannual review of ISNP controls by:• CISA auditor• DISA-qualified Chartered Accountant• CERT-In expertThe audit must incorporate the prescribed checklist(Annexure III), a formal risk rating and reporting ofall identified non-compliances.Opportunity for CAs: The framework significantlystrengthens opportunities for CharteredAccountants possessing Information SystemsAudit expertise in Cyber security assurance audits,ISNP certifications, Technology risk reviews,Governance assessments, Regulatory cybercompliance advisory engagements ExpandedRole of the Chartered Accountant. The IRDAI 2026framework repositions the CA’s role across threedistinct dimensions:Assurance• Conduct of the mandatory annual cybersecurity audit• Control design and operating effectivenesstestingIT Corner

80 Ahmedabad Chartered Accountant Journal April, 2026TM• Certification reporting to IRDAI and regulatedentitiesAdvisory• Drafting and reviewing the Information & CyberSecurity Policy (ICSP)• Designing governance structures andcommittee charters• Implementing risk assessment frameworksand treatment plansStrategic• Board-level cyber risk reporting andcommunication• Integration of cyber risk into enterprise riskmanagement frameworks• Aligning IRDAI cyber security obligations withDPDP Act complianceClosing PerspectiveThe IRDAI Cyber Security Framework 2026 elevatescyber security from a backend IT function to aboardroom governance imperative. For CharteredAccountants, this is not merely a compliance evolution,it is a strategic expansion of professional practice intogovernance, risk and cyber assurance.Those who develop fluency in both financial risk andcyber risk will be uniquely positioned to lead thistransition, serving not only as auditors, but as trustedadvisors at the intersection of governance, technologyand regulatory compliance.❉ ❉ ❉useful life of the asset. Government grants related toincome are presented as an offset againstthe relatedexpenditure and government grants that are awardedas incentives with no ongoing performance obligationsto the Company are recognised as income in theperiod in which the grant is received. In case of SGSTincentive, the Company is following the gross basis ofaccounting of government grants. As per this method,the balance sheet would reflect the cumulative netamount of grant that has been amortised to date andthe cash that has been received / reasonably assuredto be received under the terms of the grant andcorresponding government grant is recognised in thestatement of profit and loss.Export BenefitsFrom Published AccountsIn case of sale made by the Company as SupportManufacturer, export benefits arising from DutyEntitlement Pass Book (DEPB), Remission of Dutiesand Taxes on Export Products (“RoDTEP”) and DutyDrawback scheme are recognised on export of suchgoods in accordance with the agreed terms andconditions with customers. In case of direct exportsmade by the Company, export benefits arising fromDEPB, Duty Drawback scheme and RoDTEP arerecognised on shipment of direct exports.❉ ❉ ❉Continued from page 73IT Corner

Ahmedabad Chartered Accountant Journal April, 2026 81TMIn the heart of North Gujarat, far from the towering glassbuildings of metro cities, a quiet revolution began. onethat would change how India thinks about innovation.This is not a story of billion dollar unicorns born inBengaluru or Gurgaon. This is the story of a districtthat chose to believe in itself.It begins in Mehsana, a place better known for its dairylegacy than for startups. For decades, ambition herefollowed a familiar path: education, a stable job,perhaps a family business. Innovation felt distant,something that belonged to big cities. But in 2023,something shifted.Under the leadership of M. Nagarajan, the districtadministration asked a simple yet powerful question:What if talent already exists here and all it needs isopportunity?That question gave birth to the AmritMehsanaStartup&Innovation Mission (AMSIM). And with it, a bold idea:that a districtnot a metrocould become the center of athriving startup ecosystem.CA. Siddharth Bhatt CSR Stories [email protected] Spark That Became a MovementAt first, it looked like a series of small stepsworkshopsin schools, innovation clubs, exposure visits. Studentswho had never heard the word “startup” began buildingprototypes. Teachers became mentors. Governmentofficers became enablers.But something deeper was happening.For the first time, a 16yearold in a small town couldimagine building a product. A college student couldpitch an idea. A local entrepreneur could accessinvestors without leaving their district.

82 Ahmedabad Chartered Accountant Journal April, 2026TMThen came the turning point: the creation of NAMOiHUB India’s first district level startup and innovationhub.It wasn’t just a building. It was a symbol.Inside its walls were coworking spaces, mentors,investors, and ideas waiting to take shape. For theyouth of Mehsana, it meant one thing: you don’t haveto leave your hometown to build your future.When Systems Come Together, Magic HappensWhat makes this story truly powerful is not just theinfrastructureit’s the collaboration behind it.Government didn’t act alone. Industry leaders,educational institutions, investors, and professionalscame together with a shared vision. Partnerships werebuilt with universities, organizations local giants likeDudhsagar Dairy.Imagine this: a student with an idea meets a mentor,gets support from a government program, and pitchesto an investorall within their own district.That is not just coordination. That is ecosystembuilding.And the results speak for themselves. Over thousandsof students have been introduced to entrepreneurship.Thousands have actively participated. Startups havereceived funding. Ideas have turned into ventures.At one event alone, crore in investment commitmentswere madenot in Mumbai or Delhi, but in a district town.Stories Hidden Behind NumbersBut numbers only tell part of the story.The real story lies in moments.- A young girl attending her first innovationworkshop, realizing she can build something ofher own.- A farmer’s son creating a solution for agriculturalchallenges he has seen all his life.- A nursing student inspired to explore healthcarestartups after a session on innovation.These are not just participants. They are the architectsof a new India.Through initiatives like the BharatNext Accelerator,exposure visits to organizations like ISRO andgrassroots entrepreneurship camps, the mission hascreated pathways where none existed before.A New Definition of OpportunityFor decades, success in India often meantmigrationfrom small towns to big cities. But Mehsanais quietly rewriting that narrative.It is proving that opportunity doesn’t have to beimportedit can be created locally.This model challenges a longstanding belief: thatinnovation requires urban ecosystems. Instead, itshows that with the right intent, even a district canbecome a hub of ideas, investment, and impact.And perhaps more importantly, it shows thatgovernance can go beyond administrationit can inspiretransformation.Final ThoughtWhen government vision meets industry &Professional support and youthful energy, somethingextraordinary happens.It creates not just start-ups but belief.Belief that innovation belongs to everyone.Belief that geography does not define destiny.Belief that India’s future will not only be built in itsmetrosbut in its districts, villages, and classrooms.And that is the real revolution.❉ ❉ ❉CSR Stories

Ahmedabad Chartered Accountant Journal April, 2026 83TMProfessionalOpportunitiesNETWORKING ZONE“Connect • Collaborate • Grow – Invitation to CA Firms & CAs”The Vision: Cultivating Professional SynergyIn an increasingly dynamic professional landscape, the true strength of a practitioner is often amplified by thepower of their connections. While individual expertise remains our greatest asset, the ability to tap into a widernetwork of collective wisdom is what allows us to truly excel in a complex environment.The Networking Zone is a dedicated initiative by the Journal Committee to serve as a bridge for professionalsynergy. This platform is designed for those who believe in the power of collaboration-whether you are looking toexpand your reach, explore new avenues, or partner on specialized assignments. Our goal is to ensure that everymember has a gateway to find the right partner for mutual growth and success. In today’s fast changing world wherethe law has become so extensive that practicing in a niche has become paramount. Synergy is now not merely anoption but a path to grow and survive. Hence, we come up with this column where our peers can seek referencesto merge and collaborate.How to ParticipateTo ensure a professional and uniform aesthetic in the Journal a few examples are given categorially.CA FIRM/ CA SEEKING FOR NAME OF CATEGORY LOCATION POSITION CONTACTTHE FIRM/CAPracticing partnership firm with___ years of experience, speciallyin _____, ________ ,and____________. Lookingforward to collaborate withexisting firms and looking foropportunities and networking .I am a CA with ___years of postqualification experience. Haveworked for _____ years with__________. Open for any kindof work or any collaboration.

84 Ahmedabad Chartered Accountant Journal April, 2026TMCA FIRM/ CA SEEKING FOR NAME OF CATEGORY LOCATION POSITION CONTACTTHE FIRM/CAI am excited to collaborate, I amworking in the TDS, Income taxreturns tax compliance and GSTcompliance. DM for anyopportunities or referenceswhere my expertise can beutilized.We are pleased to invite entries from Chartered Accountant Firms and Practicing Chartered Accountants interestedin expanding their professional network and collaborating with fellow professionals across various domains.This initiative aims to create a platform for:● Professional networking among CA firms and CAs● Knowledge sharing and exchange of expertise● Collaboration opportunities for assignments and specialized services● Building strong professional associations across locations and practice areasInterested firms/professionals are requested to share their profile/details to participate in this networking initiative.We invite all members and firms to utilize this platform to connect and build lasting professional bonds.● Email your details to: [email protected]● Deadline: Please send your entries by the 20th of each month.● Details required: Name of Firm/CA, Category, Location and Contact Detailsin the format provided above.Let us transition from individual excellence to collective strength. Together, let’s build a legacy of shared growth.❉ ❉ ❉Professional Opportunities

Ahmedabad Chartered Accountant Journal April, 2026 85TMCA. Parth H. DesaiHon. SecretaryAssociation NewsCA. Sulabh PadshahHon. Secretary75th Annual General Meeting1 At the 75th Annual General Meeting of the members of the Chartered Accountants Association, Ahmedabadheld on Saturday, 2nd May, 2026 at H. T Parekh Convection Centre AMA, Ahmedabad, the following OfficeBearers and Executive Committee Members have been declared elected for the year 2026-27. Office Bearers1 Dr. CA. Anjali N. Choksi President2 CA. Mayur H. Modha Vice - President3 CA. Sulabh U. Padshah Hon. Secretary4 CA. Parth H. Desai Hon. SecretaryExecutive Committee Members1 CA. Atul R. Shah 2 CA. Bishan R. Shah 3 CA. Devang A. Doctor4 CA. Dharmesh A. Parikh 5 CA. Hiten M. Parikh 6 CA. Jignesh J. Shah7 CA. Karim S. Lakhani 8 CA. Kshitij M. Patel 9 CA. Umesh M. Jintanwala2. The following prizes and Medals were declared:Best Article in Ahmedabad Chartered Accountant Journal Name of the Trophy Name of the Recipient Name of the Article published in theACA Journal Shri Gatorbhai Patel Shiva Pharma Eshaan Singal Income Tax Implications in Case of a Foundation Trophy for Best Article Deceased Assessee - Journal June, 2025 on Direct Taxes (Taxation) Champaben Chandulal Shah Memorial CA. Dhruv Bhavsar Impact of GST on online gaming in India” Trophy for Best Article on GST (Indirect Tax) Journal October, 2025 Shri U. R. Shah Memorial Funds Trophy CA. Dipen Shah Opportunities for Chartered Accountants in for Best Article on Corporate and Other Law Succession Planning - Journal October, 2025 Shri U. R. Shah Memorial Funds Trophy Daksh M. Kasundra Start-up Archetypes: Way Ahmedabad for Best Article on Corporate and Other Law Chooses Camels Over Unicorns - JournalAugust, 2025

86 Ahmedabad Chartered Accountant Journal April, 2026TMBest Study Circle Meeting Leader Sr. Name of the Trophy Name of the Recipient Topic Date of the Study Circle Meeting 1 Shri Dwarkadas B. Shah CA. Dhaval Patanvadia Income Tax Reading Series “Basic of NewMemorial Trophy for the Best Lead Income Tax Act Scope of Total Income,Study Circle Meeting Residential status, Exempt Income“2025-263. CA. Riken Patel & Co., Chartered Accountants is appointed as Hon. Auditor of the Association for the financial year2026-2027.4. The 1st Executive Committee Meeting:At the 1st Executive Committee meeting held on 02nd May, 2026 three senior members of the association namely (a) CA.Ajit C. Shah (b) CA. Gautam K. Choksi and (c) CA. Mukesh M. Khandwala have been co-opted as the members of theExecutive Committee for the year 2026-27. Immediate Past President CA. Rushabh Shah shall also be a part of theExecutive Committee for the year 2026-27.The following Sub-Committees were formed:Name Position Committee NameCA. Jianah Tulsija Chairperson Journal CommitteeCA. Shivang Choksi Chairman Residential Refresher Course CommitteeCA. Sulabh Padshah Chairman Brain Trust Cum Workshop CommitteeCA. Karan Shah Chairman Legal And Representation (Direct Taxes) CommitteeCA. Monish Shah Chairman Legal And Representation (Indirect Taxes) CommitteeCA. Zalak Parikh Chairperson Information Technology CommitteeCA. Dhaval Raval Chairman Cultural and Entertainment CommitteeCA. Hirak Shah Chairman Membership Development CommitteeCA. Jay Parekh Chairman Sports CommitteeCA. Abhinav Malavia Chairman Study Circle (Indirect Tax) CommitteeCA. Ashish Sharma Chairman Study Circle (Direct tax) CommitteeCA. Riddhi Sheth Chairperson Professional Development CommitteeCA. Prakash Sheth Chairman Mutual Benefit CommitteeCA. Vedant Parikh Chairman Corporate & Allied Laws CommitteeCA. Silva Padshah Chairperson Women CommitteeCA. Devang Doctor Chairman 75th Year Celebration CommitteeCA. Priyanka Sharma Chairperson Placement CommitteeCA. Swati Panchal Chairperson Public Relation CommitteeAssociation News

Ahmedabad Chartered Accountant Journal April, 2026 87TM5. Glimpses of Past Events.Day & Date Program Speaker Venue02nd May, 2026 Annual General Meeting - H. T ParekhSaturday Management Convection CentreAMA, Ahmedabad6. Forthcoming Events.Day & Date Program Speaker Venue05th to 07th 58th Residential Refresher Course 1. Sr. Adv. Tushar Hemani AmartaraJune, 2026 2. CA. Manthan Khokhani The Resort,3. CA. Jignesh Shah Mt.Abu Road,4. CA. Harshal Bhuta Rajasthan5. Bhavin Goklani25th May, 29th May, Executive Presence Dr. Ruchi Sharma CA Association ,1st June, 5th June, Excellence Programme Navrangpura,8th June Ahmedabad11th July Smart Strategies for Adopting DPDPA Anandaday Misshra Yet to bein an organisation announced❉ ❉ ❉Association News

88 Ahmedabad Chartered Accountant Journal April, 2026TMAcross1. CA Association Ahmedabad’s theme for theseventy fifth year is – “Celebrating the____________ & Shaping the Future.2. India recently signed a Free Trade Agreement(FTA) with ___________________ on 27-04-2026.3. Meaningful change is possible only whensupported by a strong and __________ foundation.ACAJ Crossword Contest - 58❉ ❉ ❉Notes:1. The Crossword puzzle is based on this issue ofACA Journal.2. Two lucky winners on the basis of a draw will beawarded prizes.3. The contest is open only for the members ofChartered Accountants Association and nomember is allowed to submit more than one entry.4. Members may submit their reply either physicallyat the office of the Association or by emailat [email protected] on or before31-05-20265. The decision of Journal Committee shall be finaland binding.Prize CourtesyWinners of ACAJ Crossword Contest – 571. CA. Virang Mehta2. CA. Alpa PanchalACAJ Crossword Contest 57 - SolutionAcross: Down:1. Four 4. Hormuz2. Implement 5. Live3. Wadhwani 6. TransparencyDown4. Under RERA promoters have to park ________percent of buyer collections in escrow account.5. As per section 2(50) of the CGST Act, _________establishment means a place (other than theregistered place of business) which is characterizedby a sufficient degree of permanence and suitablestructure in terms of human and technical resourcesto supply services, or to receive and use servicesfor its own needs.6. Prior to 1997, India followed the system of dividendtaxation where dividends were taxed in the handsof _________________.