SHRI GEORGE MATHAN, JUDICIAL MEMBER AND MANISH AGARWAL, ACCOUNTANT MEMBER For the Assessee : Shri S.K.Sarangi, CA For the Revenue : Shri Sanjay Kumar, CIT DR ORDER Per Bench This is an appeal filed by the revenue against the order of the Id Addl/JCIT(A)-1, Vadodara dated 19.1.2024 in Appeal No.NFAC/2021- 22/10235479 for the assessment year 2022-23. 2. Brief facts of the case are that the assessee has filed its return of income on 2.11.2022, which was pr... ... ...

FOURTH SCHEDULE [Refer Regulations 7] FORM - A INTERNATIONAL FINANCIAL SERVICES CENTRES AUTHORITY CERTIFICATE OF REGISTRATION Registration Number._________ In exercise of the powers conferred by section 12 and 13 of IFSCA Act, 2019 read with sub-section (2A) of section 3 of the Insurance Act, 1938 (4 of 1938), the Authority hereby grants a certificate of registration to (entity name and address) to transact the class(es) of business specified in the schedule below. This cert... ... ...

THIRD SCHEDULE [Refer Regulations 4] 1. Norms for establishing MGA in an IFSC: An MGA registered under Companies Act, 2013, desirous to transact insurance business in an IFSC, shall set up a company with the following norms: (1) The MGA may establish a private or a public company registered with Registrar of Companies in India, with a minimum paid up capital of INR five lakh; (2) The main objects of Memorandum of Association and Article of Association shall be to prov... ... ...

SECOND SCHEDULE [Refer Regulations 4] Provisions applicable for Lloyd's and Lloyd's IFSC: 1. Definitions applicable for Lloyd's and Lloyd's IFSC: (a) "administrator", for the purposes of these Regulations means Lloyd's IFSC, except "members of Lloyd's" (b) "binding authority" means an agreement between a Service Company and a cover-holder under which the Service Company authorises the cover-holder to enter into a contract of insurance on behalf of the members of a synd... ... ...

FIRST SCHEDULE [Refer Regulations 4 (2)] FORM - A APPLICATION BY AN INDIAN INSURER OR INDIAN RE-INSURER FOR GRANT OF CERTIFICATE OF REGISTRATION AS IIO Sr. No. Particulars Applicant's Response Remarks Section A : Company Profile 1 Name of the Applicant     2 Address of its registered office     3 Date of incorporation: [DD/MM/YYYY]     4 Registration No. and date of first registration [DD/MM/YYYY] ... ... ...

FORM GSTR-1 filing deadlines for reporting outward supplies are extended for specified Goa GST registered persons. Taxpayers required to furnish monthly returns for the December 2024 tax period may furnish FORM GSTR-1 up to 13 January 2025. Taxpayers required to furnish quarterly returns for the October-December 2024 tax period may furnish FORM GSTR-1 up to 15 January 2025. The extension is deemed effective from 10 January 2025.

Regulation 22 repeals the specified insurance business guideline governing International Financial Services Centres from publication of the Registration of Insurance Business Regulations, 2021 in the Official Gazette. Actions taken under the repealed guideline are preserved and deemed to have been taken under corresponding provisions. An Insurance Office operating in an International Financial Services Centre before notification must meet any additional requirements within three months, subject to an extension permitted by the Authority.

Surrender of Certificate of Registration for closure of an Insurance Intermediary Office (IIO) is permissible only with prior approval of the Authority and subject to conditions specified by the Authority.

Disciplinary action may be taken against an IIO whose operations fail to comply with applicable legal requirements or whose activities are adverse to the insurance market or public interest. Available measures include suspension or cancellation of the certificate of registration, after allowing the IIO an opportunity to make submissions. Other appropriate action may also be taken under applicable laws.

19. : The Authority shall have the power to inspect and/or investigate the affairs of the IIO including calling for the information from the IIO, its employees and the Applicant, so far as it relates to its activities as an IIO. =============... ... ...

CHAPTER VI MISCELLANEOUS 18. : For the purpose of implementation of these Regulations and matter incidental thereto, or in order to facilitate and regulate financial services related to insurance and re-insurance in an IFSC, the Authority may specify such norms, procedures, processes, manners or provide clarification and relaxations, by way of guidelines or circulars, as it may deem fit. =============... ... ...

CHAPTER V BASIC REGULATORY AND GOVERNANCE REQUIREMENTS 17. An IIO shall follow following basic regulatory requirements or such other requirements as may be specified by the Authority - (1) Net Owned Funds (NOF): (i) an Applicant, being a foreign company engaged in re-insurance business through a branch established in an IFSC shall comply with Net Owned Funds requirement prescribed under sub-section (3) of section 6 of the Insurance Act, 1938; (ii) an Applicant may demo... ... ...

Public charitable trusts whose trustees or members have no entitlement to a share of income are not subject to the maximum marginal rate merely because their shares are indeterminate or unknown. The rule for indeterminate member shares applies to associations of persons or bodies of individuals, but CBDT clarification treats charitable or religious trusts without beneficiary income rights as taxable at normal association-of-persons rates. Accordingly, a public charitable trust not registered under section 12A is assessable at normal rates rather than the maximum marginal rate; where its income remains below the basic exemption limit, no tax is payable.

16. An IIO may render such other insurance or re-insurance business related services as may be specified by the Authority; Provided that the applicant shall obtain prior approval of the Authority for rendering of such services, subject to such conditions as may be specified. =============... ... ...

15. In case of re-insurance business, the IIO - (1) may accept re-insurance business from the cedents based in the IFSC, in relation to risk emanating from other SEZs and re-insurance business from outside India; (2) may accept re-insurance business from the insurers operating in DTA in accordance with the order of preference for cession specified in the IRDAI (Re-insurance) Regulations, 2018. =============... ... ...

14. The IIO registered to transact direct insurance business shall not write direct insurance business from the DTA except in accordance with Section 2CB of the Insurance Act, 1938. =============... ... ...

13. An IIO registered to transact direct insurance business may be permitted to do so within the IFSC, from other SEZs and also from outside India. =============... ... ...

12. An IIO shall not engage itself in any business other than for which the registration has been granted by the Authority. =============... ... ...

11. An IIO shall conduct its business in any freely convertible foreign currencies other than INR, with such persons, whether resident in India or otherwise, as may be permitted by the Authority. =============... ... ...

CHAPTER IV PERMISSIBLE ACTIVITES 10. An IIO registered with the Authority may carry any of the following class of businesses as may be permitted by the Authority subject to such conditions as may be specified:- (a) Life Insurance Business; (b) General Insurance Business; (c) Health Insurance Business; or (d) Re-insurance Business. Provided that the IIO registered as place of business of Indian Insurer or Branch Office of Foreign Insurer or Re-insurer ... ... ...