For a fresh issue, the investment manager must file the initial offer document through a merchant banker with the regulator and recognised stock exchanges. The regulator endeavours to send comments within seven working days, and the exchanges must decide on in-principle approval within 15 working days of receiving the application and required documents. The final offer document must also be filed. Fresh issues generally require prior approval by at least 75% of votes cast, subject to exceptions for simultaneous initial offerings and subsequent offerings within an already approved overall limit.

The cooling-off period for offers for sale (OFS) involving illiquid units of private listed Infrastructure Investment Trusts (InvITs) is reduced to +/-8 weeks with immediate effect. The OFS framework for listed company equity shares also applies to units of Real Estate Investment Trusts (REITs) and InvITs, subject to specified conditions. For InvITs, the OFS trading lot must match the prescribed secondary-market trading lot. Retail investor provisions do not apply to OFS by private listed InvITs, and such offers remain open for one day only, on T day.

Clubbing of split consignments for customs classification depends on proof that apparently separate imports form one deliberately fragmented transaction, not merely on the possibility of assembly. Rule 2(a) extends a tariff heading to an incomplete article possessing the essential character of the complete article and also covers a complete article presented disassembled. A change of tariff heading alone does not establish that the transaction value is inaccurate; substantive misdescription of the goods requires separate evidentiary consideration. Replacement value must follow the prescribed sequence of methods.

GST on corporate guarantees requires separate consideration of whether a taxable supply exists and how that supply is valued. Section 7(1)(c) and Schedule I encompass qualifying supplies between related or distinct persons without consideration when made in the course or furtherance of business. Rule 28(2) deems the value of a guarantee furnished to a banking company or financial institution for a related recipient in India to be one per cent of the guaranteed amount per annum or actual consideration, whichever is higher. Where the recipient is eligible for full input tax credit, the proviso treats the value declared in the invoice as the value of the supply.

Coordination with the GST Council Secretariat for the Union Territory of Jammu and Kashmir is assigned to Ms. Deepali Kanna, Jr. JKAS, State Taxes Officer/P.A. (Technical), through her nomination as nodal officer. The Commissioner of State Taxes made the nomination on 7 March 2025 in supersession of Office Order No. 04/Adm of 2023, dated 5 July 2023.

Local operational control and a stated suspension of foreign employment do not, by themselves, resolve whether underlying foreign employment rights survive. Under Article 12(4)(b) of the India-USA DTAA, technical or consultancy services must make technical knowledge, experience, skill, know-how or processes available, or involve development and transfer of a technical plan or design. Under the knowledge-transfer limb, the recipient must acquire a capability it can use independently; the mere application of expertise or presence of qualified personnel is insufficient. Recovery at actual cost and absence of markup do not, by themselves, establish that a foreign enterprise's receipt is non-taxable.

The Central Government de-notifies 10.2050 hectares from the IT and IT-enabled services Special Economic Zone at Village Attipra, Thiruvananthapuram, Kerala, leaving a notified area of 7.3816 hectares. The action is taken under the second proviso to section 4(1) of the Special Economic Zones Act, 2005, in pursuance of rule 8 of the Special Economic Zones Rules, 2006. The Kerala Government approved the proposal, and the Development Commissioner of the Cochin Special Economic Zone recommended it. The Central Government recorded satisfaction that the requirements under section 3(8) of the Act and other related requirements had been fulfilled.

When the first appellate authority substantially reduces the disputed tax demand, an earlier deposit may be sufficient to satisfy the Tribunal-stage requirement, subject to verification. Sufficiency depends on the reduced liability, the applicable appellate requirements and the amount actually deposited; a first appellate payment does not automatically eliminate the additional obligation. Tribunal filing fees under Section 112(7) operate independently of pre-deposit. Where a fee shortfall and earlier deposit require verification, proof of fee payment and verification of the deposit precede consideration of admission.

Section 129A of the Customs Act bars Tribunal appeals against Commissioner (Appeals) orders relating to goods imported or exported as baggage. Revision lies to the Central Government under section 129DD and must be sought within three months of communication, subject to a further three months for sufficient cause. Articles carried on an international passenger's person may qualify as baggage; concealment, non-declaration, confiscation or denial of a concession do not ordinarily change the forum. Currency, proceedings based on an independent export prohibition and goods found after domestic arrival require separate jurisdictional assessment; physical association with a traveller is not conclusive.

GST departmental appeal monetary limits bind Central tax officers but do not automatically bar adjudication of appeals below the threshold. The limits are Rs. 20 lakh for the GST Appellate Tribunal, Rs. 1 crore for the High Court and Rs. 2 crore for the Supreme Court, subject to specified exclusions. The disputed amount is calculated according to the nature of the dispute; for a composite order, relevant amounts are aggregated across the appeals or demand notices it disposes of. Specified recurring or interpretative issues may be excluded, but the Department should identify and support the applicable exclusion. Exceeding a limit does not automatically justify an appeal: its merits and the objectives of reducing litigation and providing certainty must also be considered. Non-filing under the policy does not establish acquiescence or prevent an appeal on similar issues elsewhere.

Section 129 detention requires an identifiable contravention. Where re-use of invoices and e-way bills is alleged, the revenue authority must establish with cogent evidence that the intercepted goods were previously transported under those documents. Toll records, vehicle movements and photographs are relevant, but do not alone establish the identity of the consignment or a completed earlier journey. Valid documents do not rule out re-use, and an explanation that an earlier journey involved different goods requires verification. Absence of prescribed documents at interception or expiry of an e-way bill presents a distinct issue and may attract statutory consequences. Penalties require an opportunity to be heard.

Section 151 of the Jammu and Kashmir Goods and Services Tax Act, 2017 empowers the Commissioner of State Taxes or an officer authorised by the Commissioner to direct any person, by order, to furnish information relating to any matter dealt with in connection with the Act. The order specifies the time, form and manner for furnishing the information. The Deputy Commissioners of State Taxes (Recovery) for Jammu and for Kashmir are each authorised to seek information under Section 151 to support the recovery wing and safeguard the government exchequer in relation to recovery.

The power to call for information under section 151 of the Jammu and Kashmir GST Act, 2017 is exercisable by the Additional Commissioner, State Taxes (Tax Planning, Policy and Advance Ruling), Jammu and Kashmir, and the Additional Commissioners, State Taxes (Administration and Enforcement), Jammu and Kashmir. These officials are authorized to seek any information under that provision to safeguard the interests of the government exchequer.

Receipt of export-of-service consideration in convertible foreign exchange or through repatriable rupee accounts, including Special Non-Resident Rupee (SNRR), INR Nostro and comparable accounts, satisfies the payment condition for export of services under section 2(6)(iv) of the Integrated Goods and Services Tax Act, 2017. Export receivables set off against import payables satisfy the same payment condition when the set-off complies with RBI directions. For exported goods, non-realisation of sale proceeds within the period prescribed under the Foreign Exchange Management Act, including extensions, requires deposit or recovery of the refund attributable to the unrealised amount, with applicable interest, within 30 days of expiry. Recovery under rule 96B of the West Bengal Goods and Services Tax Rules does not apply to the extent the realisation requirement is written off by the RBI or an authorised dealer bank.

The omission of rule 96(10) is clarified as effective retrospectively from 23 October 2017. Field formations are advised to deal with pending proceedings concerning the restriction in accordance with the Supreme Court's decision in Goodluck India, and corresponding treatment applies, with necessary modifications, to the omission of rules 89(4A) and 89(4B). Section 6 of the General Clauses Act, 1897, does not apply to the omission of a rule; pending proceedings can continue only where an express provision or another legal device in the statute or rules preserves them.

Section 195 of the Income-tax Act requires tax deduction from payments to non-residents only when the income is chargeable to tax in India. Receipt, accrual or deemed accrual in India is relevant to chargeability. Where foreign agents provide services abroad, have no business connection or establishment in India, and receive commission abroad, the commission is not chargeable to tax in India. No tax deduction or consequential tax demand and interest arise.

Determination of tax not paid or short paid, tax erroneously refunded, and input tax credit wrongly availed or utilised for any reason relating to financial year 2024-25 onwards is assigned to specified proper officers under subsections (1) to (12) of section 74A of the Jammu and Kashmir Goods and Services Tax Act, 2017. The assignment is made under section 2(91), subject to section 5(2) read with section 5(3).

Sublimation paper falls under heading 4809 and attracts 18% GST. Registered seaweed-extract-based bio-stimulants fall under heading 3101, with past-period disputes recommended for regularisation on an "as is where is" basis. Toy entries cover all categories under heading 9503: non-electronic toys attract 5% GST and electronic toys attract 18%, including their parts and accessories. Under the used motor vehicle margin scheme, the input tax credit restriction applies only to tax paid on procured second-hand vehicles; credit on other inputs and input services remains subject to the applicable Act.

The nodal officer must compile details of the relevant cases and submit information on the entities to CEIB regularly and in a timely manner, on a monthly basis, in the prescribed format and supported by relevant documents. The information is intended for incorporation into the NEOR Fake ITC Module. Concerned GST formations must promptly furnish the required information to the nodal officer at [email protected] for onward transmission to CEIB.

Importers, customs brokers and the trade must use only empanelled chartered engineers to assist customs officers with valuation and related work. The importer, customs house agent or trade, as applicable, must bear the fees and service charges claimed by the engineers; the department is not responsible for non-payment or short payment. Inspection must be performed by the empanelled engineer, who must submit a duly signed report in the prescribed format. A firm employing an empanelled engineer cannot send another chartered engineer in that engineer's place. Selected engineers must submit half-yearly appraisal reports for April to September by the end of October and for October to March by the end of April.