GST liability on medicines, medical devices and consumables supplied to in-patients as part of hospital health services remains subject to adjudication. The adjudicating authority must examine invoices, procurement details, tax paid at procurement, and the manner in which supplies were billed to patients, including whether GST was separately collected. Notice has been issued and adjudication may continue; however, any final order cannot be given effect while the writ petition remains pending.

GST exemption extends to Maritime Training Institutes conducting Director General of Shipping-approved courses where education is part of a curriculum leading to a qualification recognised by law. Approved institutes and courses are recognised under the Merchant Shipping framework governing seafarer training, certification and watch-keeping. They are treated as educational institutions for GST purposes, subject to fulfilment of the applicable exemption-entry conditions.

Ancillary Service Providers holding a letter of continuation may provide BATF services in their existing legal form for three years from commencement, but must seek registration within that period; otherwise, they may not undertake BATF services from IFSC. Their BATF operations must be ring-fenced from other IFSC operations. They must meet applicable requirements, subject to exemptions for pre-existing contracts, manpower and assets and for migration to a newly incorporated entity, comply with regulation 11 within six months, and pay the prescribed fee.

Safeguarding conditions cap employees transferred or relocated from Group Entities in India at 20% of the BATF Service Provider's total workforce and prohibit asset transfers from those entities. The workforce condition applies annually for ten consecutive financial years from registration. Existing contracts or work arrangements are treated as transferred where they are shifted during their subsistence, or prematurely terminated and replaced with an arrangement involving the same non-resident service recipient, directly or indirectly.

References to Accounting, Book-keeping and Taxation Services in clause 1.C(ii) and item 2 of Annexure I to the Ancillary Services Framework are omitted sixty days after commencement. The omission is limited to those identified framework entries. Ancillary Service Providers holding letters of continuation must adhere to every condition in the Second Schedule notwithstanding other applicable provisions.

Contravention by a BATF Service Provider of applicable regulations, guidelines, circulars or directions may attract enforcement action under the Act, including suspension or cancellation of registration. Enforcement action cannot be taken unless the provider receives a reasonable opportunity to make submissions.

BATF Service Providers must pay the fees or charges specified by the Authority from time to time under the framework governing book-keeping, accounting, taxation and financial crime compliance services.

Authority powers include prescribing norms, procedures, processes and additional requirements through circulars, guidelines or directions. Directions may also be issued through guidance notes or circulars to address difficulties in interpretation or application, providing an administrative mechanism for supplementary requirements and interpretive clarification in matters incidental to implementation.

The Authority may relax strict enforcement of applicable requirements where this serves development of the financial market in an IFSC, with reasons recorded in writing. Applicants must file details and grounds with the specified non-refundable fee. A complete application, including clarification responses, must be processed within sixty days, and reasons recorded for acceptance or refusal.

BATF Service Providers must provide operational information in the manner, intervals, and form specified by the Authority, with financial reporting made in US Dollar unless otherwise directed. Within ninety days after each financial year closes, they must submit an independent compliance certificate from a practising Chartered Accountant, Company Secretary, or Cost and Management Accountant. The certificate must confirm compliance with applicable requirements, including those under regulations 8 and 9.

BATF Service Providers must conduct operations and maintain balance sheets in any Specified Foreign Currency. They may maintain an INR account only to defray administrative and statutory expenses and for other purposes permitted under applicable laws.

Regulation 12 governing minimum office space criteria for BATF Service Providers stands omitted from 8 January 2026. Before omission, each BATF Service Provider was required to ensure office space in an IFSC with a minimum carpet area computed at 60 square feet per employee. The applicable framework no longer prescribes that office-space criterion.

Pre-notice reversal of irregular CENVAT credit with interest resulted in appropriation of the amounts and removal of the related penalty under the statutory payment mechanism. Dry aircraft leases were not taxable under reverse charge as supply of tangible goods where the lessee received exclusive legal possession, operational control, and the right to use the aircraft, while overseas lessors retained no effective control. Non-scheduled passenger charter operations before 1 July 2010 were treated as passenger air transport rather than taxable supply of tangible goods. Aircraft repair and maintenance liability could not be imposed on an entity that did not render the service where the actual provider had already paid service tax, preventing double taxation.

BATF Service Providers must appoint IFSC-based Principal and Compliance Officers. The Principal Officer is responsible for overall IFSC activities, while the Compliance Officer reports to the Board of Directors or organisational head and oversees policies, procedures, record maintenance, and regulatory implementation. Both roles require prescribed professional qualifications or recognised degrees. Principal Officers require at least five years' relevant experience and Compliance Officers require at least three years. Principal Officers providing financial crime compliance services must also hold a relevant financial crime compliance qualification.

Service-recipient eligibility for BATF services requires the provider to ensure that each recipient is a non-resident. The provider must also ensure that the recipient is not from a jurisdiction identified in the Financial Action Task Force public statement as a high-risk jurisdiction subject to a call for action. These conditions restrict the permitted recipient base for book-keeping, accounting, taxation and financial crime compliance services.

Regulation 9 bars a BATF Service Provider from offering BATF Services through the transfer or receipt of pre-existing contracts or work arrangements from its Group Entities in India. This safeguarding condition applies to existing group-entity arrangements used to provide such services. The meaning and scope of such transfers or receipts are determined under Part B of the First Schedule.

IFSC business establishment requires each applicant to ensure that its business is not set up through the splitting up, reconstruction, or reorganisation of a business already in existence in India. Determination of whether an arrangement involves such splitting up, reconstruction, or reorganisation must follow the requirements prescribed in Part A of the First Schedule.

Fit and proper requirements require a BATF Service Provider to ensure that the entity and its principal officer, directors, partners, designated partners, key managerial personnel and controlling shareholders maintain fairness, integrity, financial integrity, good reputation, character and honesty. Disqualifications include relevant criminal convictions, pending recovery proceedings, winding-up for malfeasance, undischarged insolvency, regulatory restraints or orders within stipulated periods, unsoundness of mind, financial unsoundness, wilful default, fugitive economic offender status, and other specified disqualifications.

Certificate of registration for a BATF Service Provider may be granted after consideration of the application, subject to specified conditions. Where deficiencies prevent registration, the applicant must be given thirty days to rectify them and a reasonable opportunity to make written submissions before rejection. Registration remains valid unless cancelled or validly surrendered, with surrender taking effect only upon approval. BATF Service Providers must disclose material changes in previously furnished information or particulars.

Registration for BATF Services requires an application for a certificate of registration in the prescribed format and manner, accompanied by the specified non-refundable fee. Incomplete applications are liable to rejection. Applicants must be established in an IFSC as a company or limited liability partnership, and their promoters must be from jurisdictions not identified in the Financial Action Task Force public statement as high-risk jurisdictions subject to a call for action.