Case law › Notifications › 2026 › Notification No. 56/2026 [F. No. 500/22/2022-FT&TR-V] / S.O. 1715(E)

Notification 2 April 2026

Notification No. 56/2026 [F. No. 500/22/2022-FT&TR-V] / S.O. 1715(E)

Ministry of Finance

What this is

Notification No. 56/2026 [F. No. 500/22/2022-FT&TR-V] / S.O. 1715(E) was published on 2 April 2026. Its subject is Ministry of Finance.

This one is about a tax treaty. India’s treaties enter Indian law by notification under section 90; where the instrument below is that notification, its date decides from when the treaty may be applied, and where it is a circular, it is the Board telling its officers how it reads the treaty — which is not the same thing.

What it does

Under sub-section (1) of section 90 of the Income-tax Act, 1961, the Central Government notifies that all the provisions of the Memorandum of Understanding for Assistance in Collection of Taxes, being the mode of application of Article 26A of the India-Japan Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, as set out in the Annexure, shall be given effect to in the Union of India. The Memorandum was signed at Tokyo on 30 June 2025 and at New Delhi on 8 July 2025. Paragraph 21 of the Memorandum provides that its provisions apply in respect of any request for collection of taxes made after the later of the two dates of signature by the competent authorities, and the notification records that the date of entry into force is 8 July 2025, being the date of signature in India, so the Memorandum has effect in India for any request for collection of taxes made after 8 July 2025.

Who it reaches

taxpayers with unpaid tax claims in India or Japan and assets in the other country
the competent authorities of India and Japan handling collection assistance
recovery officers pursuing cross-border collection
advisers on cross-border recovery and enforcement

The provisions it speaks to

Left, the provision of the Income-tax Act, 1961 as the instrument itself names it. Right, the section of the Income-tax Act, 2025 that the department’s own concordance maps it to — which is where the same ground is now covered.

Under the 1961 Act	Now
s.90	s.159

The instrument, as the Board published it

The department publishes this one only as a PDF, so the words below were read out of that PDF by machine. That reading can carry its own mistakes — a misread number, a broken line. Check the signed document before you rely on a figure in it.

MINISTRY OF FINANCE
(Department of Revenue)
NOTIFICATION
New Delhi, the 2nd April, 2026
(Income-Tax)
S.O. 1715(E).—Whereas, the Memorandum of Understanding for Assistance in Collection of taxes, as the Mode of Application of Article 26A of the Convention between the Government of the Republic of India and the Government of Japan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, was signed at Tokyo on the 30th June, 2025 and at New Delhi on the 8th July, 2025 as set out in the Annexure appended to this notification (hereinafter referred to as the said Memorandum);

And whereas, paragraph 21 of the said Memorandum provides that the provisions of the said Memorandum shall apply in respect of any request for collection of taxes made after the later of the dates of signature by two competent authorities;

And whereas, the date of entry into force of the said Memorandum being the date of signature in India, which is the later of the dates of signature of the two competent authorities, that is, the 8th day of July, 2025, the said Memorandum shall have effect in India in respect of any request for collection of taxes made after the 8th July, 2025;

Now, therefore, in exercise of the powers conferred by sub-section (1) of section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby notifies that all the provisions of the said Memorandum of Understanding as set out in the Annexure hereto, shall be given effect to in the Union of India.

[Notification No. 56/2026 F. No. 500/22/2022-FT&TR-V]
BHASKAR GOSWAMI, Jt. Secy.
Uploaded by Dte. of Printing at Government of India Press, Ring Road, Mayapuri, New Delhi-110064
and Published by the Controller of Publications, Delhi-110054.

From when

8 July 2025, the date of entry into force, for requests for collection made after that date.

What to watch

The Memorandum entered into force on 8 July 2025, the later of the two signature dates, though notified in India only on 2 April 2026.
It applies only to requests for collection of taxes made after 8 July 2025; requests made earlier are outside it.
The Memorandum is a mode of application of Article 26A of the Convention, so the scope of assistance is still governed by that Article.
The Annexure setting out the Memorandum is referred to but not reproduced in this extract, so its detailed paragraphs must be read from the gazetted annexure.

Where you meet it

In recovery proceedings where an Indian tax demand is sought to be collected in Japan or a Japanese demand in India under the assistance-in-collection article.

On the same provision

Other instruments in this library that name the same provision of the 1961 Act. They are not necessarily still operative, and a later one may have replaced an earlier one without saying so.

Notification No. 32/2025 [F. No. 370142/9/2025-TPL] / SO 1650(E) — Under the Direct Tax Vivad se Vishwas Scheme notified under section 89 8 April 2025
Circular No. 20/2024 — Extension of due date for determining amount payable as per column (3) of Table specified in section 90 of Direct Tax Vi 30 December 2024
Circular No. 19/024 — On provisions of the direct tax vivad se vishwas scheme 2024 16 December 2024
Notification No. 33/2024 [F.No. 503/2/1986-FTD-I] / SO 1484(E) — Ministry of Finance 19 March 2024
Notification No. 1/2024 — Specifying forms returns statements reports orders by whatever name called prescribed in appendix ii to be furnished ele 26 February 2024
Notification No. 135/2021 [F. No. 503/07/95-FTD-II] / SO 5094(E) — Ministry of Finance 8 December 2021

← Notification No. 57/2026 [F. No. 370142/5/2026-TPL] / GSR 262(E) · F. No. ADG(S)-1/PAN/M/3699/2026-AD-DD SYSTEMS 1-5 DELHI →

What a notification is. A notification is made under a power the Act itself gives, and within that power it is law — unlike a circular, which only binds the department. Its reach is the reach of the enabling provision and no wider, and the date it carries decides from when it works.

Source: the Income Tax Department’s own published text — its page for this instrument.