Registration, regulation and supervision of Pension Funds in the IFSC require a certificate of registration from the Authority and are directed to long-term retirement savings, subscriber protection, transparency, and pension-system integrity. Applicants must be IFSC-incorporated companies or qualifying foreign-company branches, permitted only where the Pension Fund is already regulated for comparable activities in India or another jurisdiction. They must have a board of at least four directors with at least half independent, demonstrate at least ten years' relevant institutional experience, and maintain minimum net worth of USD 1 million. At least two qualified Key Managerial Personnel and a Board-reporting Compliance Officer are required.

The framework substitutes electronic signatures for specified references to digital signatures and permits reliable electronic authentication under conditions of exclusive control, integrity and prescribed safeguards. Electronic contracts cannot be treated as unenforceable merely because proposals, acceptances or revocations use electronic form. A body corporate that negligently fails to implement reasonable security practices for sensitive personal data or information and causes wrongful loss or gain must pay compensation. Conditional intermediary safe harbour depends on limited transmission functions, due diligence and expeditious removal or disabling of unlawful material upon actual knowledge or appropriate-government notification.

NCLT approval of a corporate insolvency resolution plan, coupled with the resulting moratorium, prevents pending Revenue appellate proceedings from continuing. Where financial creditors have initiated insolvency resolution proceedings and the resolution plan receives approval, further prosecution of Revenue appeals serves no purpose. The operative effect is that such tax appeals cannot continue after plan approval.

Classification of ductless split-system air conditioners with two-ton capacity remains disputed between the tariff item for ductless split systems and the specific entry for split air conditioners of two tonnes and above. Harmonized System Explanatory Notes describe split systems as ductless installations using a separate evaporator for each area. Conflicting coordinate-bench views classified such systems respectively under the ductless-system entry and the capacity-based entry. The classification issue was referred to a Larger Bench for resolution of the conflicting interpretations.

Appellate enhancement is confined to income sources examined in assessment and cannot introduce sale consideration as a new taxable source where only related expenditure was scrutinised. Advance rental receipts already offered in later years are not taxable again absent accrual in the relevant year, preventing double taxation. Recorded bank credits, loans and advances supported by ledgers, confirmations and banking evidence cannot be treated as unexplained without adverse material. Likewise, no unexplained-investment addition arises for shareholdings acquired in earlier years, while documentary proof of disclosed cash sources and individual-to-HUF transfers shifts the evidentiary burden to the Revenue.

Rental advances already offered to tax in subsequent years should not be taxed again in an earlier year where bank reconciliation establishes lower actual receipts, applying accrual, real-income and anti-double-taxation principles. Appellate enhancement may address an issue or source considered in assessment but cannot introduce a new source of income, such as sale consideration not examined during assessment. Money recorded in books and supported by confirmations, ledgers, PAN details and banking records cannot be treated as unexplained under Section 69A once identity, genuineness and creditworthiness are established. Carried-forward loans, advances, investments, cash deposits and bank transfers remain explained where financial records establish their source and no contrary material is produced.

Regulation 12 is omitted from the International Financial Services Centres Authority (Book-keeping, Accounting, Taxation and Financial Crime Compliance Services) Regulations, 2024. Item 5 of the Second Schedule is correspondingly revised by deleting its reference to regulation 12, leaving only the reference to regulation 11. The amendments take effect upon publication in the Official Gazette.

The Commissioner of State Tax, Goa, withdraws ab initio the GST clarification concerning doubts relating to the supply of Information Technology enabled Services (ITeS). Representations had expressed apprehensions about its implications. The withdrawal is exercised under the power to issue directions for uniform implementation and seeks consistent application of GST provisions across field formations.

Service Companies of Lloyd's IFSC are redefined as service companies registered in India and promoted by Lloyd's Managing Agents, permitted group entities of Managing Agents or Members of Lloyd's, or Indian companies meeting applicable regulatory criteria. The revised definition applies to insurance-business registration in International Financial Services Centres and took effect upon Official Gazette publication on 8 January 2026.

Performance Review Committee composition is amended to require at least two independent experts from relevant fields, replacing the earlier provision permitting up to two such experts. The amendment modifies the International Financial Services Centres Authority (Performance Review Committee) Regulations, 2022 and takes effect upon Official Gazette publication.

Setting aside an assessment without an express remand or direction to make a fresh assessment wipes out the original assessment rather than merely reopening it. Appellate power to require fresh adjudication must be exercised through a clear direction authorising reassessment. Where an assessment was set aside on the basis of Form 26AS but no fresh-assessment direction accompanied the order, the assessment stood annulled, and the Assessing Officer had no jurisdiction to issue a fresh assessment order on that issue.

Actions done, taken, or commenced under the repealed procedure, including purported actions, are preserved and treated as undertaken or commenced under corresponding provisions of the revised framework. Subsidiary instructions issued before commencement are deemed to have been issued under the revised framework. Regulations, subsidiary instructions, and actions taken under them cannot be invalidated merely because the prescribed procedure was not followed.

Regulation 12 excludes the prescribed regulatory procedure from internal organisational matters, procedural measures or subsidiary instructions not involving substantive policy changes, coordinated decisions, and specified market integrity or national security interventions. It also covers measures required to meet international agreements or similar arrangements where public consultation serves no meaningful purpose. The Authority must be informed whenever the prescribed procedure is not applied.

Regulations made under regulation 3 must be reviewed every five years or earlier where warranted. Review considers objectives, outcomes, implementation and enforcement experience including related litigation, global best practices, relevance in a changed environment, redundancies, ease of doing business, and other relevant factors. Any amendment warranted by review must follow the Chapter III procedure.

Amendments to existing regulations or subsidiary instructions made under regulation 4(2) are subject to regulations 6 and 9 and require compliance with Chapter III. Every such modification must therefore follow the Chapter III procedure, while the applicability of regulations 6 and 9 remains preserved in relation to those amendments.

Regulation 9 authorises dispensation of public consultation where the Authority considers it expedient in the interest of developing and regulating the financial services market. The power may be used where the time required for consultation would defeat the purpose of proposed regulations or result in undue delay in redressing a problem or market failure.

The Authority may engage stakeholders through additional mechanisms considered appropriate, establish and consult expert or advisory committees for recommendations on drafting or reviewing regulations and subsidiary instructions, and constitute Independent Thematic Review Committees. Independent Thematic Review Committees may conduct focused, independent evaluations of high-priority regulatory themes, including for Regulatory Impact Assessment, on terms considered fit.

Public consultation for proposed subsidiary instructions ordinarily requires a minimum period for public comments. The Chairperson may dispense with consultation or reduce that period by recording reasons in writing, with the decision placed before the Authority for information. Comments must be reviewed, and necessary modifications proposed. The modified proposal and comments must be placed before the Authority or its delegated officer for approval. Before issuance, a summary of comments and a general response must be uploaded on the Authority's website.

Public consultation for proposed regulations ordinarily requires a minimum period of 21 calendar days for comments, subject to the Chairperson's recorded power to reduce or dispense with consultation. Proposed regulations, public comments or their summary, and remarks must be placed before the Authority. Material deviations in approved revised drafts require written reasons. Comment summaries, general responses, substantial changes, and justifications must be published before Gazette notification. Substantive modifications materially differing from the consultation paper may require repeat consultation.

Prior public consultation is required before the Authority makes specified regulations or subsidiary instructions. Public comments must be invited by publishing a consultation paper on the Authority's website. The paper must identify the problem to be addressed, state regulatory intent and objectives, specify the enabling legal provision, include the draft proposed regulations or subsidiary instruction, and state the method, process, and timelines for submitting public comments.