The CBIC has issued 8 Circulars dated 26.10.2026, related procedural guidance following the recommendations of the 57th GST Council Meeting, with a strong focus on simplifying compliance, reducing litigation, and improving cash flow for businesses. The key themes are smoother registration, fairer adjudication, and major relief in ITC and refund mechanisms. These are summarized as under –

Circular No.	Subject
257/03/2026-GST	Guidelines for GST registration applicants
258/04/2026-GST	Demand, adjudication and appeal proceedings
259/05/2026-GST	Pre-deposit under sections 107(6) and 112(8)
260/06/2026-GST	Input Service Distributor
261/07/2026-GST	Section 17(4) option for banks and NBFCs
262/08/2026-GST	ITC on demo vehicles, dealer-agency model
263/09/2026-GST	Receipt of export proceeds
264/10/2026-GST	Omission of rule 96(10)

A. Circular 257/03/2026-GST – Detailed Guidelines to Streamline Registration, Restrict Unwarranted Queries and Expedite Approval

The CBIC has turned its April 2025 officer instruction (Instruction 03/2025-GST) into an applicant-facing rulebook, with 51 FAQs, a constitution-wise checklist (Annexure II), a PPoB document list (Annexure III) and three formats (Annexures IV–VI). The Circular aims to facilitate the timely registration of genuine businesses, minimise avoidable queries and rejections, and ensure uniformity in the processing of registration applications by tax officers.

Key Highlights of the Circular

1. Restrictions on unwarranted queries and additional documents: The proper officer should adhere to the prescribed documentary requirements and should not seek unnecessary documents or raise presumptive queries unrelated to the registration application. Issues such as the applicant’s residential address being in a different city or State, non-submission of an Udyam certificate, the classification of electricity connections as domestic or commercial, the amount of electricity bills, or assumptions that residential premises are unsuitable for business should not, by themselves, become grounds for raising objections. Verification of utility bills and property tax receipts should principally be confined to confirming the applicant’s name and the address of the premises.

2. Mandatory use of FORM GST REG-03 for deficiencies: Where the application contains incomplete, incorrect, inconsistent or illegible information or documents, the proper officer should communicate the deficiency through FORM GST REG-03 and provide an opportunity to rectify it. Queries should be restricted to relevant deficiencies, such as illegible documents, discrepancies in the address of the principal place of business (PPoB), or incomplete address particulars. The applicant is required to furnish the clarification or documents in FORM GST REG-04 within seven working days of receiving the notice.

3. Prescribed timelines for processing registration applications: Applications involving successful Aadhaar authentication are generally required to be processed within seven working days. Where Aadhaar authentication has not been opted for or completed, or physical verification is required on risk-based grounds or with the prescribed approval, the applicable processing period is generally thirty days. Where a clarification is sought, the officer is required to decide the application within seven working days of receiving the applicant’s reply. If the officer fails to take action within the applicable statutory period, registration is deemed to have been approved in accordance with Rule 9 of the CGST Rules, 2017.

4. Simplified registration for small taxpayers: The Circular highlights the optional registration scheme under Rule 14A of the CGST Rules, 2017, available to eligible small taxpayers subject to the prescribed conditions, including the restriction on the monthly tax amount relating to outward taxable supplies to registered persons. Registration under this scheme is granted electronically within three working days, subject to the applicable provisions. An applicant wishing to withdraw from the scheme must file FORM GST REG-32 and comply with the prescribed procedure for regular registration.

5. Detailed documentary requirements for the principal place of business: The Circular prescribes documents according to the nature of possession of the premises. These include property tax receipts, municipal khata, property identification documents, or recent electricity or water bills for owned premises; rent or lease agreements for rented premises; consent letters for premises provided on a consent basis; and membership agreements and supporting ownership or lease documents for co-working spaces. Special provisions are also provided for inherited properties and premises situated in Special Economic Zones.

6. Complete and accurate particulars in FORM GST REG-01: Applicants are advised to ensure that their PAN, legal name, constitution of business, promoter or partner details, authorised signatory information, photographs, business address, jurisdiction, nature of business, and goods or services particulars are accurate and consistent with the supporting documents. The Circular also clarifies that bank account details are not mandatory at the time of applying for registration, although applicants are encouraged to furnish them if available. Under Rule 10A, the details must be furnished within thirty days of registration or before furnishing outward supply details in FORM GSTR-1 or the Invoice Furnishing Facility, whichever is earlier.

7. Physical verification and biometric authentication: The registration process is intended to remain online and faceless, except where physical verification of the business premises or biometric Aadhaar authentication and verification of original documents are required under the applicable rules. Where physical verification is undertaken, the officer must record specific findings regarding the existence of the premises and upload the verification report, photographs and relevant documents on the portal within the prescribed timeline.

8. Grievance redressal against delays and unwarranted queries: An applicant aggrieved by delays in processing a registration application or by unwarranted queries may lodge a complaint or grievance with the jurisdictional Chief Commissioner of Central Tax or Commissioner of State Tax through the special email address identified by the relevant Zone or State.

The Complete Circular can be accessed at https://cdn.taxo.online/wp-content/uploads/2026/10/Circular-No-257-03-2026.pdf

B. Circular 258/04/2026-GST – Comprehensive guidelines on GST demand, adjudication and appeal proceedings

A significant aspect of the Circular is its emphasis on the quality and specificity of the show cause notice. The CBIC’s central message is that a show cause notice is the whole case: what it does not say, the department cannot add later. That raises the bar for every SCN and arms taxpayers with a ready checklist for challenging defective ones.

Key Highlights of the Circular

1. Structured drafting of SCNs: Notices should clearly specify taxpayer particulars, relevant tax periods, factual allegations, applicable legal provisions, supporting evidence and quantified demand. Mere reproduction of statutory provisions is insufficient.

2. Evidence-based invocation of fraud or suppression: Section 74 and Section 74A(5)(ii) cannot be invoked merely because tax remains unpaid or a discrepancy is noticed. Specific material establishing fraud, wilful misstatement or suppression with intent to evade tax must be set out in the SCN.

3. Separate quantification of mixed demands: Where an SCN covers both fraudulent and non-fraudulent allegations, the respective grounds, legal basis and demand amounts should be separately identified.

4. Avoidance of parallel proceedings: CGST and SGST authorities should coordinate to prevent parallel proceedings on the same subject matter, in accordance with Section 6 of the CGST Act.

5. Compliance with natural justice: Personal hearings must be granted as required under Section 75(4). Virtual hearings may be encouraged, hearing records should be maintained, and adjournment requests must be considered judiciously.

6. Reasoned and speaking adjudication orders: Authorities must independently examine the taxpayer’s reply, evidence, additional submissions and cited judicial precedents. Generic observations such as “reply has been considered” should be avoided.

7. No demand beyond the SCN: Under Section 75(7), the order cannot confirm tax, interest or penalty beyond the amount specified in the notice or confirm a demand on grounds not stated therein.

8. Transparent quantification of liability: Tax, interest and penalty should be quantified clearly, preferably issue-wise and financial-year-wise, with separate identification of CGST, SGST, IGST and UTGST. Payments, appropriations, dropped demands and the final balance should be specified.

9. Penalty requires justification: Penalties should not be imposed mechanically; the order must record reasoned findings regarding the default and the applicable statutory provision, having regard to Section 126.

10. Limited scope of rectification under Section 161: Rectification is confined to errors apparent on the face of the record. It cannot be used to review the merits, reappreciate evidence or resolve debatable questions of law. Rectification must be undertaken by the issuing authority.

11. Preliminary scrutiny of appeals: Under Section 107, maintainability, limitation, prescribed forms, pre-deposit and supporting documents should be examined at the preliminary stage. Merits should ordinarily be considered during appellate adjudication.

12. Additional grounds and evidence in appeals: Additional grounds and evidence should be considered in accordance with the statutory conditions, with reasons recorded for acceptance or rejection and appropriate opportunity to the other side.

13. Timely and consistent appellate disposal: Cross-appeals against the same order should be processed together and disposed of through a common, composite order. Appeals should, as far as possible, be decided within the statutory one-year period, subject to applicable exclusions.

14. Mandatory electronic summaries: Demand notices and adjudication orders should be accompanied by the prescribed summaries in FORM GST DRC-01 and FORM GST DRC-07, respectively. Appellate order summaries should be uploaded in FORM GST APL-04.

15. Human oversight of AI tools: Information generated through AI or other technological tools must be independently verified before reliance is placed on it. Responsibility for the correctness of the order remains with the issuing authority.

Important clarification: The Circular states that these guidelines are illustrative and non-exhaustive and must not be cited by proper officers in show cause notices, final adjudication orders or appellate orders.

The Complete Circular can be accessed at https://cdn.taxo.online/wp-content/uploads/2026/10/Circular-No-258-04-2026.pdf

C. Circular 259/05/2026-GST – Clarification regarding GST appeal pre-deposit requirements and refund procedure

The circular ends the field-level confusion over what counts as “admitted” and when pre-deposit comes back. The taxpayer, not the officer, decides the split at the time of filing. It clarifies the computation, payment and refund of pre-deposit amounts required under Sections 107(6) and 112(8) of the CGST Act, 2017.

Key Highlights of the Circular

Issue	Board’s clarification
Admitted amount vs tax in dispute	Admitted = the portion of tax, interest, fine, fee and penalty the taxpayer accepts and will not challenge; paid in full. Tax in dispute = the contested portion; 10% of it is the pre-deposit. Declared in Table 14 of APL-01 / Table 20 of APL-05
Tribunal pre-deposit when liability is modified	10% of the tax confirmed by the Appellate Authority that is still disputed — payable in addition to the first-appeal deposit
Must the order direct refund?	No. File RFD-01 under S. No. 7 (“on account of order”) on receipt of a favourable order
Department plans a further appeal	Refund cannot be withheld on that ground; only a stay by the Tribunal or a Court stops it
Interest on refund (section 115)	Runs separately from each actual date of payment at each appellate level
Remand by Tribunal	Full remand: refund due within the normal time limit. Partial remand: the confirmed demand plus interest is adjusted first, the balance refunded

The Complete Circular can be accessed at https://cdn.taxo.online/wp-content/uploads/2026/10/Circular-No-259-05-2026.pdf

D. Circular No. 260/06/2026-GST – Clarifications on Input Service Distributor (ISD) Mechanism

The CBIC has issued clarification on seven important issues concerning the Input Service Distributor (ISD) mechanism under Sections 2(61), 20 and 21 of the CGST Act, 2017, read with Rules 39 and 54(1A) of the CGST Rules, 2017. The clarifications address multiple ISD registrations within a State, responsibility for ITC eligibility and reversals, the month of distribution of credit, and the treatment of credit-transfer documents for turnover and refund computations.

Key highlights of the Circular: 

1. Multiple ISD registrations within the same State or Union Territory: The Circular clarifies that there is no bar on obtaining more than one ISD registration for different business verticals or places of business within the same State or Union Territory. Each registrant receiving input service invoices for or on behalf of distinct persons, where the credit is required to be distributed under Section 20, must obtain ISD registration.

2. Responsibility for ITC eligibility and irregular distribution: The ISD is responsible for distributing credit in accordance with Section 20, whereas the recipient distinct persons must satisfy the conditions for ITC eligibility under Sections 16 and 17 and the relevant Rules. If the ISD distributes credit in contravention of Section 20, it may be liable to a penalty under Section 122(1)(ix). Where such contravention results in excess distribution, the excess credit is recoverable from the recipient(s), along with applicable interest, under Section 21.

3. Month in which ITC must be distributed: ITC is required to be distributed in the month in which the ISD ascertains, on the basis of the input service invoice details received in FORM GSTR-6A, that the credit is prima facie eligible for availment. The ISD must separately distribute eligible and ineligible credit in accordance with Rule 39(1)(g) and report the relevant details in FORM GSTR-6.

4. Responsibility for ITC reversals: The ISD must distribute the credit attributable to the respective recipients, while the recipients are responsible for making applicable reversals under Section 17(1) or Section 17(2), read with Rules 42 and 43, or under Section 17(4), read with Rule 38, as applicable. The ISD is not required to undertake these reversals merely because it distributes the credit.

5. Rule 54(1A) documents excluded from turnover: Invoices, credit notes and debit notes issued by a registered person having the same PAN and State code as the ISD under Rule 54(1A) are merely a mechanism for transferring ITC to the ISD. They do not represent outward supplies of the issuing person. Accordingly, the amounts reflected in these documents are excluded from the computation of “turnover in a State” or “turnover in a Union territory” under Section 2(112), including for the relevant computations under Section 20 read with Rule 39 and for determining “adjusted total turnover” under Section 54(3) read with Rule 89.

6. Rule 54(1A) credit excluded from Net ITC for refunds: Credit transferred through the mechanism prescribed under Rule 54(1A), pertaining to input services attributable to one or more distinct persons, does not constitute ITC in respect of an inward supply of the transferring registrant. Consequently, such credit cannot be included in “Net ITC” for calculating refunds under Rule 89(4) or Rule 89(5).

7. ITC reversals by the transferring registrant under Rule 54(1A): The registered person having the same PAN and State code as the ISD is not required to reverse the credit transferred under Rule 54(1A) under Sections 17(1), 17(2) or 17(4). It must transfer the entire relevant credit arising from tax paid by it under reverse charge to the ISD for further distribution. The applicable reversals are to be made by the recipient distinct persons, which may also include the transferring registrant where it receives the credit in its capacity as a recipient.

The Complete Circular can be accessed at https://cdn.taxo.online/wp-content/uploads/2026/10/Circular-No-260-06-2026.pdf

E. Circular No. 261/07/2026-GST – Clarifications on ITC Availment by Banks and Financial Institutions under Section 17(4)

The CBIC has issued clarification on the applicability and implementation of the special ITC availment mechanism under Section 17(4) of the CGST Act, 2017, for banking companies, financial institutions, including non-banking financial companies (NBFCs), engaged in accepting deposits or extending loans and advances. The Circular addresses the scope of the 50% ITC availment option, the conditions for the benefit under the second proviso to Section 17(4), and the appropriate procedure for reporting ITC availment and reversals in FORM GSTR-3B.

Key highlights of the Circular

1. Applicability of the 50% ITC mechanism across registrations: The Circular clarifies that a registration of a banking company or financial institution that is not engaged in accepting deposits or extending loans and advances—for example, a registration engaged exclusively in bullion trading—neither has the option nor is required to follow Section 17(4). A registration engaged in the specified banking or financial services, even if it also provides other services, may opt for the special mechanism. However, once one eligible registration opts for Section 17(4), all other registrations of the same banking company or financial institution that are engaged in the specified activities and may also supply other services must necessarily follow that mechanism.

2. Restriction on the benefit under the second proviso to Section 17(4): The relaxation under the second proviso, concerning the restriction on availment of only 50% of eligible ITC, is available only in respect of supplies received from another registered person having the same PAN who has also opted to comply with Section 17(4). The benefit is therefore linked to the application of the special mechanism by both relevant registrations.

3. Procedure for reporting ITC in FORM GSTR-3B: The Circular prescribes the manner of availment and reversal of ITC by registered persons opting for Section 17(4), read with Rule 38 of the CGST Rules, 2017. The procedure differs depending on whether the Invoice Management System (IMS) is used, including cases where IMS has been used before the relevant amendments to the CGST Rules are notified.

Where IMS is not used, the taxpayer must first ascertain the eligibility of ITC reflected in FORM GSTR-2B, together with ITC claimed on inward supplies liable to reverse charge. Credit attributable to non-business purposes and supplies covered by Section 17(5) must be permanently reversed in Table 4(B)(1) of FORM GSTR-3B. Eligible credit covered by the second proviso to Section 17(4) is to be availed, and 50% of the remaining eligible ITC is admissible under Section 17(4), with the balance permanently reversed in Table 4(B)(1).

4. Temporary reversal and subsequent reclaim of ineligible-at-present ITC: ITC that cannot presently be established as eligible because conditions under Section 16 have not been fulfilled, but which may become eligible later, must be temporarily reversed in Table 4(B)(2) of FORM GSTR-3B. Upon fulfilment of the requisite conditions, the credit may be reclaimed in Table 4(A)(5) of a subsequent return, subject to the time limit under Section 16(4). The reclaimed credit must also be reported in Table 4(D)(1), and its availment and reversal must follow the prescribed Section 17(4) procedure.

5. Treatment of invoices under IMS: Taxpayers may accept, reject or keep invoices and other inward-supply documents pending on IMS. Where ITC is not presently eligible because the conditions under Section 16 have not been met, but may become eligible subsequently, the relevant documents are required to be kept pending on IMS. Such ITC will not be made available in FORM GSTR-2B and, consequently, will not be auto-populated in FORM GSTR-3B. Once invoices accepted or deemed accepted on IMS become available in FORM GSTR-2B, the taxpayer must follow the prescribed availment and reversal procedure under Section 17(4).

6. Relief for past reporting practices: Recognising that different methodologies for reporting ITC availment and reversals may have been followed in earlier tax periods, the Circular directs field formations not to take an adverse view of a different past reporting methodology, provided the amount of ITC availed under Section 17(4) is consistent with the principles set out in the Circular.

The Complete Circular can be accessed at https://cdn.taxo.online/wp-content/uploads/2026/10/Circular-No-261-07-2026.pdf

F. Circular No. 262/08/2026-GST – ITC on Demo Vehicles Allowed to Authorised Agents under the Dealer-Agency Model

The CBIC withdraws the clarification contained in paragraph 4.6 of Circular No. 231/25/2024-GST dated 10 September 2024, which had denied input tax credit (ITC) on demo vehicles purchased by authorised dealers operating under the dealer-agency model. The CBIC has clarified that ITC on such demo vehicles is not blocked under Section 17(5)(a) of the CGST Act, 2017, thereby aligning the ITC treatment of demo vehicles across the dealer-agency and traditional dealership-based models.

The CBIC observed that demo vehicles serve the same commercial purpose under both business models: enabling prospective customers to experience a vehicle before purchasing a similar motor vehicle. In both cases, the authorised dealer purchases the demo vehicles from the manufacturer against tax invoices, generally records them as capital assets, holds them for a prescribed mandatory period and subsequently sells them at their written-down value, discharging the applicable GST. The Circular also notes that the vehicles are treated at par under the Central Motor Vehicles Rules, 1989.

The Board further relied on the expression “further supply of such motor vehicles” in Section 17(5)(a)(A) of the CGST Act. It observed that the expression permits ITC not merely on the specific motor vehicle subsequently sold, but also on vehicles used to facilitate the further supply of similar motor vehicles. Since demo vehicles promote the supply of similar vehicles under both business models, the Board concluded that denying ITC solely because the OEM, rather than the dealer, makes the final sale would create an unjustified difference in ITC treatment.

Accordingly, the clarification contained in paragraph 4.6 of Circular No. 231/25/2024-GST dated 10 September 2024 has been withdrawn. ITC on demo vehicles purchased by authorised dealers under the dealer-agency model is not blocked under Section 17(5)(a) of the CGST Act, 2017.

The Circular removes the differential ITC treatment between traditional dealerships and dealer-agency arrangements. Authorised dealers operating under the dealer-agency model can claim ITC on demo vehicles, notwithstanding that the OEM directly supplies the vehicles to customers, because the demo vehicles facilitate the further supply of similar motor vehicles. The clarification specifically addresses the blockage under Section 17(5)(a); it should not be read as dispensing with other applicable statutory conditions governing ITC.

The Complete Circular can be accessed at https://cdn.taxo.online/wp-content/uploads/2026/10/Circular-No-262-08-2026.pdf

G. Circular No. 263/09/2026-GST – Export Proceeds through Repatriable INR Accounts and Set-off of Export Receivables

The CBIC has issued clarification on the conditions for treating consideration as received for export of services under Section 2(6)(iv) of the IGST Act, 2017, where payments are received through repatriable Indian rupee (INR) accounts, export receivables are set off against import payables, or reinsurance brokerage commissions are settled through a net retention mechanism. It also clarifies the applicable realisation period for export proceeds from goods and recovery of refund under Rule 96B of the CGST Rules, 2017.

Key clarifications of the Circular 

1. Export of services—receipt through repatriable INR accounts: The Circular clarifies that where Indian exporters receive payment for export of services in convertible foreign exchange or through repatriable INR accounts, such as Special Non-Resident Rupee (SNRR) accounts or INR Nostro accounts, the condition under Section 2(6)(iv) of the IGST Act is considered fulfilled. This clarification is consistent with the permitted modes of settlement under the Foreign Exchange Management (Manner of Receipt and Payment) Regulations, 2023, subject to applicable RBI directions and other legal requirements.

2. Payments to stockbrokers serving overseas clients: Payments received by Indian stockbrokers from overseas clients, including Foreign Portfolio Investors (FPIs), Non-Resident Indians (NRIs) and Overseas Citizens of India (OCIs), through repatriable INR accounts such as SNRR and NRE accounts may be treated as satisfying the receipt-of-consideration condition for export of services. Where payment is received through an NRO account, it must be routed through a repatriable INR account, such as an SNRR or NRE account, to satisfy the said condition.

3. Set-off of export receivables against import payables: The Circular recognises set-off as a valid mode of settlement under FEMA regulations. Accordingly, where export receivables are set off against import payables in accordance with RBI directions, the condition under Section 2(6)(iv) of the IGST Act is considered fulfilled. The Circular notes that the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, effective from 1 October 2026, have changed the earlier position regarding the conditions applicable to such set-offs.

4. Reinsurance brokers—net retention mechanism: Where an Indian reinsurance broker’s commission for services supplied to foreign reinsurers is settled by retaining the commission from funds before remitting the net premium abroad, a separate inward remittance of the commission may not take place. The Circular clarifies that, since the obligation to realise and repatriate export proceeds is extinguished through this net retention mechanism under FEMA regulations, the receipt condition under Section 2(6)(iv) of the IGST Act is considered satisfied.

5. Export of goods—period for realisation of export proceeds: Rule 96B of the CGST Rules provides for recovery of refund, to the extent export sale proceeds remain unrealised within the period prescribed under FEMA, including any extension granted, along with applicable interest. The Circular clarifies that the applicable realisation period for export of goods under the GST law is the period, including any extended period, prescribed under RBI’s FED Master Direction No. 16/2015-16 dated 1 January 2016, as amended from time to time.

6. Write-off of unrealised export proceeds: No recovery of refund under Rule 96B is to be made where the requirement to realise export proceeds has been written off, wholly or partly, by the authorised dealer (AD) bank. The Circular thus clarifies the treatment of such write-offs for GST refund recovery purposes.

The Complete Circular can be accessed at https://cdn.taxo.online/wp-content/uploads/2026/10/Circular-No-263-09-2026.pdf

H. Circular No. 264/10/2026-GST – Retrospective Omission of Rule 96(10) and Relief in Pending Export Refund Proceedings

The CBIC clarifies that the omission of Rule 96(10) of the CGST Rules, 2017, with effect from 8 October 2024, is to be given retrospective effect from 23 October 2017. The clarification follows the judgment of the Hon’ble Supreme Court dated 6 August 2026 in M/s Goodluck India Limited & Anr. v. Union of India & Ors., which held that, in the absence of a saving clause or sunset clause, the omission applies to proceedings pending on the date of omission. The Circular also extends the same treatment, mutatis mutandis, to the omission of Rules 89(4A) and 89(4B) of the CGST Rules.

Issue

Whether the omission of Rule 96(10) of the CGST Rules, 2017, with effect from 8 October 2024, applies retrospectively from 23 October 2017, particularly in respect of proceedings pending on the date of omission, and whether the same principle applies to Rules 89(4A) and 89(4B).

Clarification and legal position

The Supreme Court, in its judgment dated 6 August 2026 in Goodluck India Limited, relied on the Constitution Bench judgment in Kolhapur Canesugar Works Ltd. v. Union of India [(2000) 2 SCC 536]. The Court reiterated that Section 6 of the General Clauses Act, 1897, does not apply to the omission of a rule. In the absence of an express provision preserving pending proceedings, or another legal mechanism incorporated into the statute or rules to preserve them, such proceedings cannot continue merely because the omitted rule was previously in force.

Following this ruling, CBIC has clarified that the omission of Rule 96(10) is effective retrospectively from 23 October 2017, the date on which the rule was originally introduced. Accordingly, field formations have been directed to deal with pending proceedings concerning Rule 96(10) in accordance with the Supreme Court’s judgment. The Circular further clarifies that the same treatment applies, mutatis mutandis, to the omission of Rules 89(4A) and 89(4B).

The Circular recognises the retrospective effect of the omission of Rule 96(10), providing an important basis for resolving pending proceedings concerning export refunds previously restricted under that provision. The clarification is particularly relevant to exporters whose refund claims or related proceedings remained pending after the rule’s omission. Field formations must apply the Supreme Court’s ruling while dealing with such matters, including proceedings concerning Rules 89(4A) and 89(4B). The Circular addresses the effect of the omission on pending proceedings; the outcome of any individual matter will depend on its facts and procedural status.

The Complete Circular can be accessed at https://cdn.taxo.online/wp-content/uploads/2026/10/Circular-No-264-10-2026.pdf