Daily Intelligence Capsule — 17 August 2026

Latest EditionLatest Edition — Monday, 17 August 2026

Lead Briefing

Foreign Assets Disclosure Scheme 2026 — Complete Practitioner Guide to Eligibility, Fees & Forms

A practical, step-by-step guide to the Foreign Assets of Small Taxpayers – Disclosure Scheme Rules, 2026 — how to identify eligible clients, distinguish Category 1 from Category 2, and navigate the Form 1–4 sequence before the 31 December 2026 deadline.

Read the briefing

CBDT Notifies Foreign Assets of Small Taxpayers Disclosure Scheme Rules, 2026

Full Guide

CBDT notifies the Foreign Assets of Small Taxpayers – Disclosure Scheme Rules, 2026 (Notification No. 114/2026) — a fee-based disclosure window from 16 August to 31 December 2026 for previously undisclosed foreign income and assets, with protection from Black Money Act consequences on completion.

Section 107(6) 10% Pre-Deposit Not Applicable to Pre-Oct-2025 SCN Appeals

Delhi HC (Arun Kumar Jain)

Delhi High Court (Division Bench) reaffirms that the amended 10% pre-deposit under Section 107(6) of the CGST Act does not apply to appeals from Show Cause Notices issued before 1 October 2025, applying its Gaurav Jain principle to director-level personal penalty appeals. Arun Kumar Jain v. Additional Commissioner, CGST Delhi West Commissionerate & Ors., decided 13 August 2026.

Rule 86A ITC Blocking Needs a Hearing First

J&K & Ladakh HC Quashes ₹10.45 Cr Block (NCC Limited)

Jammu & Kashmir and Ladakh High Court reads audi alteram partem into Rule 86A of the CGST Rules, quashing a ₹10.45 crore Input Tax Credit blocking order for want of a hearing and reasons. NCC Limited v. Union Territory of J&K and Anr., decided 12 August 2026.

Lead Briefing

Rule 86A ITC Blocking — Natural Justice Checklist for Practitioners (2026)

A practical checklist for challenging Rule 86A ITC blocking orders — the natural justice safeguards the J&K and Ladakh High Court has now read into the provision, and the quantum argument every practitioner should also preserve.

Did You Know

Rule 86A Has No Express Hearing Requirement, But Natural Justice Still Applies

Rule 86A of the CGST Rules, which lets the department block a taxpayer's Input Tax Credit on suspicion alone, contains no express requirement for a hearing before the block is imposed — yet the Jammu & Kashmir and Ladakh High Court has now confirmed that the constitutional principle of audi alteram partem must still be read into the provision, because a power that can freeze crores of rupees in credit without warning is exactly the kind of adverse administrative action natural justice exists to constrain.

Quiz of the Day

₹10.45 Crore ITC Block Without a Hearing

The GST department blocks ₹10.45 crore of your client's Input Tax Credit under Rule 86A with no reasons and no prior hearing. Is the blocking order valid, and does Rule 86A require a hearing? Answer: The order is not valid as issued — per NCC Limited v. Union Territory of J&K, audi alteram partem must be read into Rule 86A despite no express hearing requirement; a communication with no reasons and no hearing is arbitrary. The separate argument that Rule 86A permits blocking only up to the amount actually available in the electronic credit ledger for Section 49/refund purposes remains an additional ground.