Finance Minister Nirmala Sitharaman presented Union Budget 2026 on 1 February, marking her ninth consecutive budget address. The Economic Survey 2026, presented on 29 January, projects that India's economy will grow by 7.4% in FY26 and between 6.8–7.2% in FY27. This growth is expected to be supported by regulatory reforms, a robust macroeconomic foundation, and a revitalised emphasis on private sector investment.
India currently stands at a crossroads, and Union Budget 2026 seeks to push the nation into its next phase of transformation, with Viksit Bharat as the overarching theme. PwC India’s Union Budget insights and analysis spotlight the priorities that can accelerate this growth. This Budget represents an opportunity to place India on the path towards financial stability while enabling businesses to be future ready—especially as they navigate the opportunities of AI adoption alongside challenges around talent, infrastructure, governance, and trust. PwC India’s subject matter experts outline the Union Budget reforms and sector-specific initiatives that can reinforce India’s economic foundation and unlock new engines of inclusive, sustainable growth.
This year’s budget marks a decisive shift in how India is shaping its growth story. It reflects a country thinking beyond consumption by strengthening its services engine while steadily emerging as a credible manufacturing destination.
What stands out is the clear long‑term view. The emphasis is on building physical, digital and human capability, enabling investments, boosting productivity, and supporting the sectors that will drive the next wave of global competitiveness.
Sanjeev Krishan, Chairperson, PwC in India, shares what this means for businesses. His message is focused and forward‑looking, to take the long view, invest in innovation and build the foundations that will power India’s next phase of growth.
The Economic Survey 2026 tells the story of an economy which is not just growing but is also steadily maturing with strong fundamentals and rising institutional capacity.
Growth remains broad-based, financial intermediation is deepening, banks and corporate balance sheets are healthy and public capital expenditure continues to bring down logistics costs. The emphasis is shifting from demand-led expansion to productivity-led growth, with focus on improving infrastructure, institutional capacity, and supply-side efficiency.
Strong bank credit growth, rising market-based funding and improving non-bank channels point to a more diversified and resilient financing structure. This, in turn, supports domestic investment while enhancing the confidence in the Indian currency.
The Survey signals the quiet strengthening of India’s economic buffers. Diversified funding sources, steady foreign investment and expanding export capabilities underline a long-term objective where competitiveness, not insulation, is the foundation of stability.
India’s path to economic development is framed around two key parameters: building strategic resilience and indispensability. The focus is on developing domestic capabilities that make India a reliable and credible participant in global value chains, supported by outcome-oriented institutions and regulatory credibility.
Swadeshi is inevitable for building scale, productivity and technological depth at home while competing globally. MSMEs are placed at the centre, along with targeted manufacturing in high-value, specialised segments.
The agriculture sector is diversifying its operations towards higher-value activities as allied sectors are gaining prominence, logistics capacity is expanding and physical and digital connectivity continues to improve.
The webcast provided an overview of the current macroeconomic environment and the direction set by Union Budget 2026–27, highlighting how policy priorities, fiscal choices, and structural reforms are shaping India’s growth trajectory. It also explored the evolving business and investment landscape across key sectors, along with important tax and regulatory developments and their implications for organisations.
Should you wish to discuss any aspect of the Budget in more detail or explore its implications for your business, please feel free to connect with your relationship contact at PwC.
Budget 2026-27 charts a path for India’s continued growth, reinforcing the government’s commitment to fiscal discipline and reform-led progress. Key focus areas include scaling up manufacturing across strategic and frontier sectors; supporting micro, small, and medium enterprises; enhancing infrastructure and energy security; deepening the services sector as an employment engine; investing in human capital; and promoting balanced regional development through city economic regions and targeted initiatives. From a tax perspective, the new Income-tax Act, 2025, is set to come into force from 1 April 2026 with select amendments proposed to both existing income-tax law and the new code.
Union Budget 2026 creates new pathways for a future ready economy that will fulfil the ‘Viksit Bharat’ dream. The financial services sector will be one of the key engines driving this change. The Budget’s focus has been on regulatory transformation and a new tax framework that is simple and easy to adopt. Details follow in our flyer on the financial services sector that helps you decode the evolving landscape.
“Budget 2026 is anchored in India’s potential and vision of becoming ‘Viksit Bharat’ by boosting employment, while combining technologies of the future with India’s legacy industries. This is a push for resilience to drive long-term, equitable, and sustainable growth backed by a ‘Kartavya’ approach.
Sanjeev Krishan, Chairperson, PwC in India
“A Union Budget focused on reform and increasing the speed of doing business. With a clear sector-first approach across manufacturing, technology, and pharma, it unlocks innovation, boosts competitiveness, and reinforces execution—paving the way for India to emerge as a global leader in industry and innovation, in line with the vision of Viksit Bharat.
Arnab Basu, Chief Industries Officer, PwC India
“Union Budget 2026 charts a decisive course for inclusive growth and enhanced global competitiveness, unlocking new opportunities for enterprises, boosting MSMEs, and empowering women entrepreneurs to scale and lead.
Vivek Prasad, Partner and Chief Commercial Officer, PwC India
“For the technology ecosystem, the standout move is India’s push to become a global cloud and data infrastructure hub through a tax holiday till 2047, supported by a more predictable tax and compliance regime that reduces uncertainty, boosts capital confidence and enables faster global scaling.
For telecom and connectivity‑led businesses, capital efficiency rises as regulation simplifies, supply chains strengthen, and domestic electronics capacity expands. ISM 2.0 and the expanded Electronics Components Manufacturing Scheme can reinforce the device‑to‑network stack and build a stronger backbone for next‑generation use cases.
For media and entertainment, the Orange Economy push, especially widespread AVGC creator labs, can build a strong talent pipeline for content, gaming and immersive storytelling. Together, these measures strengthen the TMT flywheel with better infrastructure, innovation, trust, and growth toward Viksit Bharat.
Manpreet Singh Ahuja, Partner, Chief Clients Officer and TMT Leader, PwC India
Income tax exemption limit raised to ₹12 lakh under the new regime.
Enhanced credit guarantee cover for MSMEs from ₹5 crore to ₹10 crore.
Launch of Prime Minister Dhan-Dhaanya Krishi Yojana to boost agricultural productivity.
Introduction of a 6-year Mission for Aatmanirbharta in Pulses focusing on Tur, Urad and Masoor.
Establishment of a Makhana Board in Bihar for improved production and marketing.
Enhanced loan limit under Kisan Credit Cards from ₹3 lakh to ₹5 lakh.
Significant increase in the number of Atal Tinkering Labs in government schools.
Broadband connectivity to be provided to all government secondary schools and primary health centres.
Launch of a comprehensive programme for vegetables and fruits in partnership with states.
Expansion of medical education with 10,000 additional seats in the next year.
Setting up of Day Care Cancer Centres in all district hospitals within three years.
Introduction of a new scheme for first-time entrepreneurs from women, SCs, and STs.
Launch of a National Manufacturing Mission to further "Make in India".
Extension of the Jal Jeevan Mission until 2028 to achieve 100% potable tap water coverage.
Establishment of a Maritime Development Fund with a corpus of ₹25,000 crore.
Modified UDAN scheme to enhance regional connectivity to 120 new destinations.
Launch of a Nuclear Energy Mission for research and development of Small Modular Reactors.
Introduction of a new income-tax bill to simplify and reduce litigation.
Increase in FDI limit for the insurance sector from 74% to 100%.
Setting up of an Urban Challenge Fund of ₹1 lakh crore for city redevelopment projects.
Reduction in customs duty on critical minerals to boost domestic manufacturing.
Full exemption of customs duty on 36 lifesaving drugs and medicines.
Launch of a Deep Tech Fund of Funds to support next-generation startups.
Extension of the period of incorporation for startups to avail benefits until 1.4.2030.
Introduction of a presumptive taxation regime for non-residents in electronics manufacturing.
Setting up of a National Digital Repository of Indian knowledge systems.
Tax holiday for foreign companies procuring services from Indian data centres
Any income accruing or arising in India or deemed to accrue or arise in India to a foreign company by way of procuring data centre services from a specified data centre in India would be eligible for a tax holiday up to 31 March 2047, subject to the condition that all sales by such foreign company to users located in India are made through an Indian reseller entity and that such foreign company does not own or operate any physical infrastructure or resources of the data centre.
Safe habour margin for data centre entities
A safe harbour margin of 15% on costs is proposed for companies providing data centre services to related entities.
Tax holiday for foreign companies providing capital equipment to Indian contract manufacturers
A foreign company earning income from providing capital goods, equipment, or tooling to an Indian contract manufacturer company located in a custom bonded area who produces electronic goods on behalf of such foreign company is exempt up to tax year 2030–31.
Extension of period of tax holiday for units in International Financial Services Centre (IFSC) and rationalisation of tax rate
The period of tax holiday available to units located in an IFSC shall be extended to 20 consecutive years, to be selected at the option of the taxpayer, out of a total span of 25 years. A concessional tax rate of 15% (plus surcharge and cess) shall apply during the non-tax holiday period.
Deemed dividend exemption for Global Treasury Centres is proposed to be restricted to cases where the counterparty group entity is located in a notified country or territory outside India.
Information Technology Services (ITS) safe harbour rules
Software development services, IT-enabled services, knowledge process outsourcing services, and Contract R&D services (related to software development) are proposed to be consolidated into a single safe harbour category of ‘Information Technology Services’ with a uniform safe harbour margin of 15.5%.
The eligibility threshold for availing safe harbour for ITS is proposed to be enhanced from INR300 crore to INR2,000 crore for value of international transactions.
It is proposed that safe harbour for IT services be granted through an automated, rule-based process and can be continued for a period of 5 years at the option of the taxpayer.
APA-related amendmentss
A unilateral APA process is proposed to be fast-tracked with a targeted conclusion within two years for IT services providers, which is further extendable by six months upon the taxpayer’s request. The facility of filing modified returns is proposed to be extended to the associated enterprises as well.
Rationalisation of buy-back provisions
The tax provisions with respect to buy-back of shares are proposed to be rationalised by taxing the consideration on buy-back of shares as capital gains. Promoters (including those holding more than 10% shares) are required to pay an additional income tax on gains arising from a buy-back as follows:
| Type of capital gains | Promoter being a domestic company | Other promoters |
| Short term | 2% | 10% |
| Long term | 9.5% | 17.5% |
Rationalisation of penalty provisions
The imposition of penalty for under-reporting and misreporting of income is now required to be made part of the assessment order itself. Furthermore, interest on the penalty will be kept in abeyance during the pendency of appeal by the first appellate authority.
Penalties for certain defaults, namely failure to get accounts audited, failure to furnish transfer pricing audit report, failure to furnish statement for financial transactions or reportable accounts, are converted into fees.
Immunity from penalty which was previously available only for under-reporting of income is now extended to cases of misreporting as well. However, in such cases, the taxpayer would be required to pay 100% of the tax amount as additional income tax over and above the tax and interest due, in addition to the previously applicable conditions.
Rationalisation of prosecution provisions
The nature of imprisonment for most offences is changed from ‘rigorous imprisonment’ to ‘simple imprisonment’, making the punishment less severe. The maximum punishment for most offences is reduced from seven years to two years (three years for repeated offences). Graded thresholds are introduced for offences based on the quantum of tax evaded. Certain offences (e.g., TDS on benefits and perquisites, failure to produce accounts and documents) are fully decriminalised and will now attract only a fine.
Retrospective amendment on time limit for passing of assessment order
The controversy regarding the time limit for passing assessment orders, specifically whether the period taken by the Dispute Resolution Panel (DRP) should be included in the computation of the time limit for passing the final assessment order, has now been clarified. A retrospective amendment has been proposed to section 144C, to clarify that the additional time provided under section 144C is available in cases where the DRP route is followed. This amendment ensures that the time taken by the DRP is not subsumed within the general time limits under sections 153 or 153B, but is instead in addition to those limits.
Removal of interest deduction against dividend income/mutual fund income
Deduction for interest expenses incurred in connection with earning dividend income or income from mutual fund units has been withdrawn.
The time limit for filing revised return of income has been extended to 12 months from the end of the tax year (i.e. March) from the existing time limit of nine months from the end of the tax year (i.e. December) along with an additional fee of INR1,000 (if income does not exceed INR5,00,000) and INR 5,000 (otherwise).
Updated tax return can be filed in cases where there is a reduction of the amount of loss as compared to the original return. Updated tax return can also be filed in cases where reassessment proceedings are initiated subject to payment of additional income tax of 10%.
STT on futures has been raised to 0.05% from 0.02%, and STT on options transactions has been raised to 0.15% from 0.1%/ 0.125%.
From a customs standpoint, the aim of Union Budget 2026 has been to simplify the tariff structure, support domestic manufacturing, and promote export competitiveness. Further focus has been on trade facilitation through a more digital, trust-based, and simplified regime, while selectively reducing duties to support priority sectors. Key changes proposed in the Union Budget are as under:
The budget provides a framework of transformative reforms across six key domains which will augment India’s growth potential and global competitiveness: (i) taxation; (ii) power sector; (iii) urban development; (iv) mining; (v) financial sector; and (vi) regulatory reforms. This webcast covered key budget announcements, economic indicators and industry experts’ perspectives to help you navigate the evolving business landscape.
Aligned with the vision of becoming Viksit Bharat by 2047, it is anticipated that the Government will take targeted measures to strengthen manufacturing capabilities, supporting the expansion of global capability centres (GCCs), simplifying tax regulations to facilitate ease of doing business and providing impetus to make India an attractive investment destination.
Join our panel of subject matter experts for a webinar as they decode Union Budget 2025 and provide a deep dive into the key policy announcements and implications for businesses.
Chairperson
PwC in India
Partner
Price Waterhouse
& Co LLP
Advisor
Price Waterhouse & Co LLP
and Former member of CBDT
Partner and Leader
Research and Insights Hub
PwC India
Day and date:
Monday, 3 February 2025
Time: 9:30am (India) | 3pm (Sydney) | Noon (Singapore/Hong Kong
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Day and date:
Monday, 3 February 2025
Time: 8:30pm (India) | 3pm (London) | 10am (New York)
Click here to register
Partner, PwC India
Partner, Price Waterhouse & Co LLP
Sanjeev Krishan, Chairperson, PwC in India, shares what this means for businesses. His message is focused and forward‑looking, to take the long view, invest in innovation and build the foundations that will power India’s next phase of growth.
Union Budget 2026 sets the stage for India’s full-stack AI economy, focusing on digital infrastructure, trust-centric governance and talent development to fuel tech-led growth. Manpreet Singh Ahuja, Chief Clients and Alliances Officer, PwC India, highlights how these moves position India as a global hub for cloud, data and emerging technologies.
This year’s Budget is all about disciplined growth and sharper execution. As Ranen Banerjee, Partner and Leader, Economic Advisory, PwC India, shares in this video, the focus has shifted from introducing new schemes to consolidating and strengthening existing ones—a strategic move in a fiscally tight environment.
Union Budget 2026 delivers historic reforms that simplify and strengthen safe harbour rules for the IT sector. In his latest video, Kunj Vaidya, Partner and Tax & Regulatory Services Markets Leader at PwC India, breaks down what these reforms mean for businesses.
Kunj Vaidya, Partner and Tax & Regulatory Services Markets Leader, PwC India, and Pratik Jain, Subject Matter Expert and Partner, Price Waterhouse & Co LLP, share their take on this year’s Budget, which they describe as historic for the balance it strikes between fiscal prudence and meaningful changes across tax policy.
This year’s Budget sets a clear direction for long‑term growth. As Mohammad Athar Saif, Partner and Leader, CP&I and Industrial Development, PwC India, notes in this video, four themes stand out.
Infrastructure investment remains robust. Cities emerge as powerful growth hubs. Manufacturing stays central to India’s Viksit Bharat vision, with momentum across semiconductors, electronics components and critical minerals. And digital infrastructure takes a strategic leap forward, positioning India as a global digital backbone.
Technology continues to play a defining role in India’s economic journey, and this year’s budget underscores that even more strongly. The push toward stronger digital foundations, from data platforms and cloud connectivity to cybersecurity and wider digital infrastructure, signals a long‑term approach to scale, interoperability and resilience.
Navnit Nakra, Partner and Leader, Technology Sector, PwC India, shares his perspective on what these shifts mean for businesses. His outlook highlights how the focus on skills, regulatory clarity and ease of doing business is helping reduce execution friction and positioning India as a trusted global technology and innovation hub.
Sambitosh Mohapatra, Partner and Leader, Climate and Energy, PwC India, outlines how key initiatives in decarbonisation, supply chain resilience, and fiscal reforms position India to lead the global clean-tech revolution.
Union Budget 2026 sets clear boundaries on the tax front with four key announcements aimed at enhancing ease of doing business and fostering growth in Global Capability Centres (GCCs). Vikram Doshi, Partner and Leader, GCC, Tax, PwC India, highlights the introduction of a 15.5% transfer pricing safe harbour covering over a thousand existing GCCs and all new units.
As India deepens its focus on strategic industries and future‑ready growth, this year’s Budget delivers a clear signal of intent. Anshul Jain, Partner, PwC India, highlights how the Budget balances support for manufacturing, semiconductors and rare earth magnets while also driving growth for startups, small businesses, and MSMEs.
Sujay Shetty, Managing Director, ESDM and Semiconductor, PwC India, shares insights on this transformative Budget. He highlights the launch of ISM 2.0—a bold step to boost domestic production, advance full-stack design, develop Indian IP, and strengthen the supply chain with focused R&D and skilled workforce development.
By sharing risk more intelligently rather than simply pushing it onto contractors or banks, these tools can draw in both domestic and international capital at scale.
Cities occupy barely 3% of the land surface but generate close to 60% of GDP. For a rapidly urbanising country like India, this makes large-scale, well-planned investment in cities a simple economic imperative. The challenge is to do this while grappling with pollution, congestion, hygiene, safety, ageing populations, and rising expectations of convenience.
By 2030, India is expected to have at least seven megacities with populations above 10 million and over 60 cities with more than 1 million residents. All of them will demand affordable, fast, clean, and reliable public transport—just as fiscal space remains tight. Urban development is constitutionally a state subject, but the Union Government plays a critical role in enabling metro systems, electric buses, and other mass transit investments.
The question, therefore, is not whether the Centre should support urban transport, but what more it can do to accelerate sustainable, citizen-centric mobility. Five priorities stand out:
Complementing this, MoHUA should support regional skilling centres focused on installation, operation, and maintenance of urban transport technologies. This will help cities manage systems in-house or as informed clients, rather than being fully dependent on vendors.
This budget presents an opportunity to transform the maritime sector by focusing on three key areas:
Align investments to support the long-term Maritime Amrit Kaal Vision by scaling up the Sagarmala Programme. Develop trunk infrastructure in ports, establishing alternate fuel hubs, and promoting port-led industries to attract private participation. Additionally, prioritise next-generation initiatives such as greening, smart port technologies, and broader coastal community development.
Drive self-reliance through an outcome-oriented programme for container manufacturing, supported by incentives linked to large-scale capacity creation. Establish an indigenous container shipping line to strengthen India’s global trade competitiveness.
Implement measures to enable EXIM growth and enhance digitisation, including improvements in port processes and expansion of the Maritime Single Window for seamless documentation and compliance.
India’s path towards technology sovereignty-building a resilient electronics and semiconductor manufacturing ecosystem Expectations from Union Budget
To support supply chain resilience and India’s participation in GVCs, the country is required to achieve readiness and maturity across critical supporting industries. A continued policy push towards electronic components and semiconductor manufacturing is critical to ensure supply chain ecosystem development, reducing lead times and improve reliability.
The incentive outlay for the MSME sector in India for electronic components remains limited. With MSMEs contributing approximately 25–35% of the industry, capital support along with continued access to advanced technology and skilled talent is critical to ensure the development of a robust component ecosystem moving forward. To sustain chip production in India, it is imperative to extend the focus from fabs towards development of critical input materials such as gases, chemicals, and substrates. Incentive support, infrastructure readiness. and promotion of long-term strategic partnerships will be essential to attract players who have the potential to supply domestically to Indian manufacturers, thereby enabling investors to save costs on logistics.
In line with the Government of India’s vision of building self-reliance in semiconductor manufacturing, in addition to critical utilities such as power supply and ultra-pure water supply, establishment of industry benchmarks across road infrastructure, cold-chain logistics for high-precision equipment, and transportation systems to handle high-purity gases is essential.
Incentives to raise R&D expenditure, IP development, and retention are required to increase technological advancement and industrial competitiveness, thereby enhancing industry–academia collaboration.
To support skilling and workforce development, a focused approach towards the development of a robust talent pipeline with establishment of dedicated training fabs, cleanroom simulation facilities, etc., is critical.
Incremental incentives for exporting electronics and semiconductor products, such as tax and duty rationalisation, export subsidies, access to low-cost capital, or other support mechanisms can cumulatively help boost exports for Indian electronics. With 46 applicants approved under the ECMS scheme, component manufacturing is expected to scale up. However, effective integration of tier-2 and tier-3 suppliers will be critical to ensure high domestic value addition. Incentives for exporting electronics and semiconductor products, such as duty drawbacks, export subsidies, or other support mechanisms and similarly for rationalisation of import duties on essential components, raw materials, and equipment to reduce costs can cumulatively help boost exports for Indian electronics.
Backward integration of finished goods manufacturers in consumer electronics should be encouraged by continuing and increasing benefits–such as Production Linked Incentive (PLI) for white goods—that focus on manufacturing of compressors, copper tubes, and assembling of controller units. It would create value chain localisation and in-house design capabilities, thereby harnessing additional savings through efficiency gains and encouraging Indian manufacturers to overcome the learning curve.
Technology clients expect Budget 2026 to reinforce India’s positioning as a global hub for AI-led services, product engineering, digital exports, and tech manufacturing—shifting from just digitisation to productivity, competitiveness, and value creation.
AI enablement: Compute access, cloud, and resources (energy, water, utility infrastructure)
Clients expect more emphasis on AI enablers (compute access, AI-as-a-service marketplaces, and support for scalable AI adoption). AI growth in India is constrained by a lack of data centres and utility resources, so any budget allocations that ease infrastructural bottlenecks will allow organisations to fill this gap.
GCCs as strategic tech engines instead of back offices
For Global Capability Centre (GCC)-heavy clients, the expectation is policy signaling that India is the destination for high-end engineering, R&D, and AI work, not just cost arbitrage—an evolution of GCCs into strategic capability hubs. While GCCs are expanding in number and scale, there is significant friction around compliance policies (state-level variations in policies and regulations) and access to talent (while engineering talent is abundant, product ownership and super specialised skillsets such as AI engineering are still concentrated in limited pockets). These aspects slow the transition from support roles to greater strategic ownership. The technology sector will benefit from a policy that reinforces India’s intent to move GCCs up the value chain through clarity and execution support.
Manufacturing and PLI: Continuity and ease of execution
Technology manufacturing clients expect continuity and predictability in Production Linked Incentive (PLI) schemes, particularly electronics manufacturing, semiconductors, and hardware-led technology value chains. Key pain points include lack of clarity in eligibility, delay in approvals, and slow disbursements of incentives. Budget signals that improve ease of access to the scheme, faster disbursal, and long-term visibility of PLI frameworks would support sustained manufacturing investments.
Policy and compliance clarity, including responsible AI
Technology clients are looking for clear interpretation and consistent execution of policy that impacts technology operations. This includes clarity around cloud compliance, responsible AI usage, cross-border delivery models, and data protection. Clients expect clear and practical guidance on responsible AI, focused on how AI systems can be deployed safely and at scale by providing guardrails that offer clarity on data usage, accountability, and risk management that is aligned with emerging global norms. Such clarity helps enterprises deploy AI with confidence while continuing to innovate.
Enterprise adoption: AI-led modernisation
Enterprise tech firms expect the budget to continue supporting AI-led modernisation of enterprise tech systems—such as leveraging AI to drive automation of operations, better information and cybersecurity, and adoption of digital platforms. The expectation is of policy continuity and ecosystem support that encourage enterprises to move AI into scaled deployments. This will drive higher demand for technology services, expanded GCC mandates, and deeper technology capabilities, which together will reinforce India’s broader AI capacity-building agenda.
Export competitiveness: Technology manufacturing
Technology clients in hardware-linked segments would benefit from policies that continue improving export competitiveness through stable tariff regimes, export facilitation, and alignment with global supply chains. Reducing uncertainty around duties and improving export infrastructure would strengthen India’s position as a reliable technology manufacturing and export base.
Technology clients will look to the budget to send an execution-oriented signal that India is scaling from a services powerhouse to a value-creation hub—supported by infrastructure readiness, manufacturing continuity, and policy clarity.
As India readies Budget 2026, we expect continuity with acceleration in customs reforms anchored towards:
Policymakers should pursue a time-bound Customs amnesty to:
Together, these measures should lower friction, enhance certainty, and improve the cost competitiveness of Indian trade and manufacturing.
The following proposals reflect key reforms that the industry expects from Budget 2026 which would materially advance these objectives.
As we wait for Budget 2026, the direction is clear: a pragmatic approach to faster and more digital trade flows, tariff rationalisation to fix inversions and cushion external shocks, and a targeted extension of time-bound exemptions where justified. Taken together, these moves would lower friction and costs, improve certainty, and strengthen ‘Make in India’.
1. Presence of employees of foreign entities in India
In a globalised world, travel of employees to India from overseas jurisdictions is inevitable. In addition, given the pole position that India occupies as a hub for global capability centres (GCCs), travel to India by senior executives for setting up of business or process operations is a frequent occurrence. However, uncertainty over potential tax costs and compliance obligations poses a challenge from an ease of doing business perspective. Given the current uncertainty surrounding the H-1B visa regime in the US, the Government should look at measures that facilitate the set-up and expansion of GCCs in India, which will also enable expatriates of Indian origin or otherwise to stay in and work from India. The deemed income regime provided through section 44BBD for the electronic manufacturing sector may be made broad-based so as to cover any category of non-resident providing services in India, irrespective of industry or sector. This measure will facilitate tax collections while avoiding litigation and reducing the compliance burden on companies.
2. Tax neutrality for fast-track demergers
It is recommended to extend the benefit of tax neutrality to fast-track demergers. The tax authorities have a concern that fast-track demergers do not involve any court or tribunal supervision and that the valuations involved may result in tax avoidance. However, the authorities already possess wide powers—including under General Anti-Avoidance Rules (GAAR)—to address tax avoidance in specific cases. By withholding tax neutrality, companies are effectively forced to use the longer National Company Law Tribunal (NCLT) route, making the fast-track mechanism practically redundant and undermining its intended efficiency benefits.
3. Clarity and certainty on data centres (DCs) not constituting a permanent establishment (PE) in India
Setting up DCs requires substantial long-term investment, and multinational digital players are keen on tax certainty because of these significant financial commitments. To avoid PE disputes for foreign enterprises, specific safe harbour rules could be introduced that prescribe an operating profit margin on a cost-plus basis, aligned with the arm’s length principle. Once the Indian DC functions are fully remunerated at arm’s length, any further attribution of profits to a PE in India should be unnecessary, effectively rendering the PE question infructuous and allowing corresponding relief to non-residents.
4. Keeping assessments in abeyance till the outcome of the advance pricing agreement (APA) is achieved
Given that APAs often take 4–6 years to finalise, assessment proceedings for covered years should be kept in abeyance, similar to the advance ruling regime. This would prevent unnecessary litigation on interim assessments that would anyway be realigned once the APA is concluded. Thereafter, final assessments can be framed in line with the agreed terms, along with payment of applicable taxes and interest.
5. Streamlining of buy-back provisions
The tax provisions with respect to buy-back of shares may be rationalised by treating the buy-back proceeds as dividends only to the extent of the company’s accumulated profits, consistent with other deemed dividend provisions, and taxing the balance as capital gains, similar to a capital reduction.
1. Time-bound customs amnesty with a focus on pre- Goods and Services Tax (GST) Countervailing Duty (CVD)/Special Additional Duty (SAD)
Introduce a one-time settlement scheme to close legacy disputes, especially those tied to additional duties of customs (CVD/SAD) subsumed into GST. A graded relief on core duty, coupled with full waiver of interest and penalty, would catalyse resolution of large backlogs and free up cash and management bandwidth. Such a scheme would align with prior successful settlement models, permit resource reallocation to forward-looking enforcement, and materially reduce pendency in adjudication and litigation.
2. Implement a true single window system by fully operationalising section 11(3)
Section 11(3), inserted in 2018, allows Customs to enforce import/export prohibitions or conditions from other laws only if they are formally notified under the Customs Act, thereby centralising all EXIM obligations. Implementing this would reduce uncertainty, prevent enforcement of unnotified conditions, ensure consistent compliance, and advance a true single window. The recommendation is to issue a comprehensive section 11(3) notification mandating that all cross-sectoral trade requirements be routed through Customs notifications and published in a unified, digitally assessable database.
3. Strengthening Manufacture and Other Operations in Warehouse Regulations (MOOWR) for export competitiveness
The MOOWR regime can be fully leveraged by aligning its treatment with comparable customs and foreign trade policy facilitation schemes. Two calibrated steps in this direction are recommended. First, extend remission of duties and taxes on exported goods (benefits to exports manufactured in MOOWR premises), recognising prevalent domestic input use and the capex-driven nature of many MOOWR operations. Second, clarify eligibility for brand rate drawback where raw materials are imported with duty paid (without deferment benefit) through a uniform circular specifying documentation and field implementation. These changes will remove structural disadvantages, improve liquidity, and support export competitiveness without revenue leakage.
4. Enhancement of deferment and facilitation for Authorised Economic Operator (AEO) entities
This budget is expected to prioritise a clear differentiation between Tier-II and Tier-III by extending duty-deferment and facilitation benefits for Tier-III. This is to create a select low-risk pool with fewer ad hoc interventions, alongside simplified, bright-line eligibility (including legal compliance norms) to deepen trade integration and reduce field-level variance.
5. Tariff rationalisation to support Make in India
Further pruning of Customs duty slabs is expected to be paired with targeted cuts on raw materials or intermediates to remove inversions. Further, sunset-anchored review of exemptions with impact checks is expected, with time-bound, entry-specific relief to cushion external tariff shocks focused on priority sectors such as electronics, semiconductors, renewable energy, EVs, specialty chemicals, and defence/aerospace.
Pursuant to the recommendations of the 56th GST Council meeting, the following legislative amendments are likely to be introduced in the upcoming Union Budget.
1. Amendment in place of supply provisions for intermediary services under section 13(8) of the Integrated Goods and Services Tax (IGST) Act
At its 56th meeting, the GST Council proposed deleting clause (b) of section 13(8) of the IGST Act, 2017. Following this amendment, the place of supply for ‘intermediary services’ will be determined in accordance with the default provision under section 13(2) of the IGST Act, 2017—that is, the location of the recipient of the services. This change will enable Indian providers of such intermediary services to avail export benefits.
2. Amendment to section 15 and 34 of the Central Goods and Services tax (CGST) Act
Omission of section 15(3)(b)(i) of the CGST Act, 2017, does away with the requirement to demonstrate that post-sale discounts are in accordance with an agreement executed before or at the time of supply and are specifically linked to the relevant invoices.
Further, section 15(3)(b) of the CGST Act, 2017, is being amended to mandate that such discounts must be passed on through a credit note issued under section 34 of the CGST Act, with a corresponding amendment to section 34 to refer to section 15(3)(b), thereby requiring the recipient to reverse input tax credit where a post-sale discount is granted and the value of supply is reduced by way of a GST credit note.
3. Amendment to section 54(14) of the CGST Act to provide for GST refunds in respect of low-value export consignments
The 56th GST Council meeting recommended an amendment to section 54(14) of the CGST Act, 2017, to abolish the minimum threshold for refund claims arising from exports made on payment of tax. This move will be especially beneficial for small exporters, including those exporting through courier and postal modes.
1. Tax certainty: Considering the recent ruling of the Apex Court in the context of tax treaty benefits applicable to non-residents and foreign companies, Union Budget 2026–27 should clarify or elaborate on the requirements for allowing tax treaty benefits beyond the availability of tax residency certificates from the foreign jurisdiction.
2. No tax withholding on transactions in securities: Under the existing income tax laws, transactions in securities outside of the Indian stock exchanges are subject to withholding tax provisions intended for sale of goods. To ease the compliance burden, the relaxation provided for sale of listed securities on stock exchanges should be extended to all transaction in securities.
3. Timing of taxability of deferred contingent consideration: Amend capital gains tax computation provisions to allow for contingent deferred consideration arising from transfer of shares or securities to be deemed to be the income of the seller of the previous year in which such money or other asset is received.
4. Taxation for investment fund on actual receipts: With respect to income of debt securities which is accrued but not due to be received by an alternative investment fund (AIF), a specific provision may be inserted providing for deferral of taxability of income in the hands of unitholders till it becomes due. Where income is past due but not received by the AIF, it is recommended that interest income received by the AIFs may be chargeable to tax in the year of actual receipt.
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