Providers holding continuation letters may operate BATF services in their existing legal form during the three-year transition, but must obtain registration to continue BATF services from IFSC. BATF operations must be ring-fenced, prescribed fees paid, and specified requirements met. Transitional exclusions apply to pre-existing contracts, manpower and assets and to migration to a newly incorporated entity; further conditions must be met within six months.

Safeguarding conditions restrict employee relocation and asset transfers from Group Entities in India to a BATF Service Provider. Transferred or relocated employees must remain within the prescribed workforce limit, and only employees without recent Group Entity employment qualify as new employees. The conditions apply annually for the prescribed period. Existing contracts or work arrangements are treated as transferred where subsisting client arrangements are shifted, or prematurely terminated and replaced by a new arrangement with the same service recipient.

Repeal and savings remove references to Accounting, Book-keeping and Taxation Services from specified entries of the Ancillary Services Framework after a sixty-day commencement period. Ancillary Service Providers holding a letter of continuation remain governed by the prescribed conditions in the Second Schedule despite other provisions and must comply with those continuation conditions.

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 furnish operational information in the manner, intervals and form specified by the Authority. Financial reporting must be in US Dollar unless otherwise directed. Within ninety days after each financial year closes, each provider must submit an independent compliance certificate issued by a practising CA, CS or CMA, confirming compliance with applicable requirements, including 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.

BATF Service Providers in an IFSC must maintain minimum office accommodation measured by carpet area. Carpet area must be computed at 60 square feet for each employee, creating an employee-linked office-space compliance standard. The criterion applies to providers of book-keeping, accounting, taxation and financial crime compliance services and requires the prescribed minimum space within the IFSC as the minimum office-space threshold.

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 applies a safeguarding condition to BATF Service Providers: BATF Services must not be offered through the transfer or receipt of existing contracts or work arrangements from group entities in India. The scope of such transfers or receipts is determined in accordance with Part B of the First Schedule.

Regulation 8 requires an applicant to ensure that its IFSC business is not established by splitting up, reconstructing, or reorganising a business already in existence in India. The determination of whether an existing Indian business has been split up, reconstructed, or reorganised must follow the requirements in Part A of the First Schedule. The prohibition applies to each specified method of establishing the IFSC business.

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.

Registration may be granted to a BATF Service Provider subject to specified conditions. If deficiencies prevent grant, the applicant must be informed and given thirty days to rectify them, with a reasonable opportunity to make written submissions before rejection. A certificate remains valid unless cancelled or surrendered, and surrender requires approval. The BATF Service Provider must report material changes in previously furnished information.

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.

BATF Services in an IFSC require a certificate of registration, except for an Ancillary Service Provider. An Ancillary Service Provider intending to provide such services must communicate its willingness to operate within sixty days of commencement, in the specified form and manner. Until it receives a letter of continuation, the provider must comply with the requirements under regulations 8 and 9.

BATF Services comprise book-keeping, accounting, taxation and financial crime compliance services within the IFSC regulatory framework. A BATF Service Provider is an entity registered to undertake any or all of those service categories. Book-keeping excludes payroll and taxation services, while accounting includes non-assurance financial statement work and related valuation support but excludes auditing. Taxation services include consultation, planning, return preparation and filing, and financial crime compliance services cover AML/CFT measures and FATF-related activities.