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Circular No. Order No. F.3(377)/GST/POLICY/2021/2155-64 Dated:- 26-11-2024 Delhi SGST Dated:- 26-11-...
Powers under the first proviso to sub-rule (1) of Rule 23 of the Delhi Goods and Services Tax Rules, 2017 are delegated to every concerned Zonal Incharge. The delegation operates for all eligible cases governed by the amended provisions of Section 30(1) of the Delhi Goods and Services Tax Act, 2017, with effect from 1 October 2023.

Regulation 98 of the International Financial Services Centres Authority (Fund Management) Regulation...
Public-issue InvITs must invest at least 80% of asset value in completed and revenue-generating infrastructure projects, with only direct qualifying project investments through holdcos or SPVs counted toward that threshold. Up to 20% may be invested in specified ancillary assets, while under-construction infrastructure projects are separately capped at 10%. Market-driven breaches require trustee notification and restoration of compliance within the prescribed period. Privately placed InvITs must invest at least 80% in eligible infrastructure projects and may place uninvested funds in specified permitted securities and cash-equivalent instruments.

2020 (10) TMI 1408
Case Laws Income Tax
Transfer-pricing comparability adjustments require material functional and cost differences to be examined, with matching-period data where quarterly results exist.
Transfer-pricing comparability requires adjustments for material differences in import content, raw-material consumption, capacity utilisation and scrap sales; separate working-capital adjustment may be unnecessary where those differences are addressed. Safe Harbour Rules introduced prospectively cannot govern prior transfer-pricing documentation, and provision write-backs may be operating items. Companies with product, brand, significant research-and-development or functionally diverse operations may be unsuitable comparables, while different financial years may be reconciled through audited quarterly data. Warranty provisions require a present sales-related obligation, probable outflow and reliable estimation. Actual bad-debt write-offs and business-linked trade-advance write-offs may qualify for deduction, and depreciation must follow binding directions.

Investment Conditions
Act Rules Indian Laws
Regulation 97 of the International Financial Services Centres Authority (Fund Management) Regulation...
Investment Trusts may invest through SPVs or holdcos subject to non-interference with regulatory compliance, contractual dispute-resolution mechanisms, board-governance requirements, and exercise of voting rights. Holdco structures require an ultimate holding interest of at least 26 per cent in underlying SPVs. Foreign investments must comply with applicable local laws. Completed rent-generating property and infrastructure assets are generally subject to a minimum holding period, and significant sales require prior unitholder approval. Investment in other Investment Trust units is prohibited, while lending is limited to investee holdcos or SPVs.

Regulation 96 of the International Financial Services Centres Authority (Fund Management) Regulation...
Listed Investment Trusts must meet the continuous obligations and disclosure requirements of the recognised stock exchange. For unlisted Investment Trusts, the investment manager must provide annual, half-yearly and valuation reports to the trustee and unit holders. It must disclose material operational or performance-related information, including significant asset transactions, additional unit issues, credit-rating changes, unit-holder approval matters, significant legal proceedings, meeting notices and results, regulatory non-compliance, limit breaches, and other material matters requiring disclosure.

Regulation 95 of the International Financial Services Centres Authority (Fund Management) Regulation...
Offer documents and placement memoranda for Investment Trusts must provide material, true, correct and adequate disclosures for informed investment decisions. Required disclosures include details of relevant parties, assets, strategy, leverage, conflicts, valuation, financials, unit-holder rights, title matters, litigation, regulatory actions, risks and taxation. Specified valuation, project-management, due-diligence and stock exchange approval materials must be submitted to the Authority. Unlisted Investment Trusts must make applicable disclosures required for listed Investment Trusts.

Public Issues
Act Rules Indian Laws
Regulation 94 of the International Financial Services Centres Authority (Fund Management) Regulation...
Public fund raising by an Investment Trust requires advance filing and public availability of a draft offer document, supported by due diligence certification and incorporation of Authority comments before filing the offer document. Offers must comply with prescribed timing, subscription, allotment, dematerialisation and pricing requirements. Refund obligations apply where minimum subscription thresholds are not met or subscriptions exceed permitted limits. Retained oversubscription is capped, requires disclosure, and cannot fund general purposes. Offers for sale are subject to a minimum holding period, while general-purpose use of issue proceeds is restricted.

Regulation 93 of the International Financial Services Centres Authority (Fund Management) Regulation...
Private placement without listing by an Investment Trust requires advance filing of a draft placement memorandum with the Authority and payment of the applicable fee at least five working days before the issue opens. The issue must open within three months after the placement memorandum is taken on record. Fund raising is limited to investors committing at least USD 250,000 or accredited investors, with a maximum of fifty investors. A final placement memorandum must be filed within ten working days after unit allotment.

Private Placement With Listing
Act Rules Indian Laws
Regulation 92 of the International Financial Services Centres Authority (Fund Management) Regulation...
Private placement with listing by an Investment Trust requires in-principle approval from recognised stock exchange(s) and filing of a placement memorandum with the Authority at least five working days before opening the issue. Funds may be raised from accredited investors or investors committing at least USD 150,000, subject to a USD 1 million minimum where less than eighty per cent of asset value is invested in completed and revenue-generating assets. The offering must have between two and one thousand investors, and the final placement memorandum must be filed within ten working days after listing.

Regulation 91 of the International Financial Services Centres Authority (Fund Management) Regulation...
Initial offers of Investment Trust units require registration, minimum asset value, and a minimum offer size. Where units are proposed to be listed on a recognised stock exchange, the minimum public offer and allotment is determined by post-issue capital through percentage-based or value-based thresholds. Units offered to the sponsor, investment manager, project manager, or their related parties or associates cannot be counted as units offered to the public.

Currency
Act Rules Indian Laws
Regulation 90 of the International Financial Services Centres Authority (Fund Management) Regulation...
Investment Trust units may be issued only in a freely convertible foreign currency. The currency-denomination requirement applies under Regulation 90 of the International Financial Services Centres Authority (Fund Management) Regulations, 2025.

Regulation 89 of the International Financial Services Centres Authority (Fund Management) Regulation...
Registration of an Investment Trust is conditional on the Investment Trust and its parties satisfying the fit and proper person criteria. Parties to the Investment Trust must perform their designated roles and discharge the responsibilities prescribed in the Fourth Schedule.

Trustee
Act Rules Indian Laws
Regulation 88 of the International Financial Services Centres Authority (Fund Management) Regulation...
Trustee eligibility for an Investment Trust requires authorisation or registration with the Authority or another securities market regulator. The trustee must be independent of the sponsor or sponsors and the investment manager, and must not be their associate. It must also maintain adequate infrastructure, personnel and other necessary wherewithal satisfactory to the Authority and recognised stock exchange or exchanges.

Investment Manager
Act Rules Indian Laws
Regulation 87 of the International Financial Services Centres Authority (Fund Management) Regulation...
Investment Manager appointments depend on the mode of issuance. Any Registered Fund Management Entity may be appointed for a private placement, whereas a public issue requires appointment of a Registered Fund Management Entity (Retail).

Sponsor
Act Rules Indian Laws
Regulation 86 of the International Financial Services Centres Authority (Fund Management) Regulation...
Sponsor eligibility for an Investment Trust requires each sponsor to maintain a minimum post-initial-offer unit holding, subject to restoration within one year if the holding declines. Corporate and limited liability partnership sponsors must meet prescribed financial strength requirements, with separate individual and collective net-worth thresholds for REIT sponsors. Sponsors or their associates must also demonstrate a sound track record in relevant real estate, infrastructure, or sectoral fund-management activities.

Trust
Act Rules Indian Laws
Regulation 85 of the International Financial Services Centres Authority (Fund Management) Regulation...
Investment Trust eligibility requires creation under Indian law, whether within or outside IFSC, or under a foreign jurisdiction. The trust deed must principally provide for REIT or InvIT activities and specify the trustee's regulatory responsibilities. Sponsor(s), an investment manager and a trustee must be designated as separate entities.

Registration
Act Rules Indian Laws
Regulation 84 of the International Financial Services Centres Authority (Fund Management) Regulation...
Investment Trust registration requires a sponsor-led application in the prescribed format, accompanied by the specified non-refundable fee. Additional information, clarification, or personal representation may be required for processing the application. Investor protection may warrant appointment of a person to take charge of the trust's records and documents on determined terms. Registration may be granted after receipt of required information, satisfaction with the application, and payment of the applicable fee.

Customs & Trade
Dated:- 11-9-2026
PTI
BRICS supports reform of international financial governance to increase emerging-market and developing-economy representation in the IMF and World Bank through quota and voting realignment. It opposes unilateral tariffs and non-tariff measures that distort trade and conflict with WTO rules, while supporting a rules-based multilateral trading system. BRICS also promotes local-currency trade and investment settlements and interoperable cross-border payment mechanisms, without creating a common currency or unified payment system. Development-finance cooperation includes expanded local-currency financing, project preparation, private-capital mobilisation and a phased, member-driven investment platform.

Definitions
Act Rules Indian Laws
Regulation 83 of the International Financial Services Centres Authority (Fund Management) Regulation...
Investment Trust definitions govern REITs, InvITs, their assets, participants and ownership structures. Eligible infrastructure projects include specified PPP projects, qualifying pre-COD projects and non-PPP projects holding requisite construction approvals. Holding companies and SPVs must meet prescribed control, ownership, asset-holding and permitted-activity conditions, subject to PPP restrictions. Trustees hold assets for investors, investment managers manage assets and investments, and project managers undertake project execution or management. Sponsor groups include sponsors, controlled entities, controlling persons and related controlled entities.

Investment Trust in IFSCs
Act Rules Indian Laws
Regulation 82 of the International Financial Services Centres Authority (Fund Management) Regulation...
Investment Trusts operating in IFSCs require registration with the Authority. They may raise funds through public issues or private placements, with units either listed on a recognised stock exchange or, in the case of private placement, unlisted. Recognised stock exchanges must prescribe requirements for listed or proposed-to-be-listed units, including offer-document disclosures, continuing obligations, trading, clearing and settlement. Investment Trusts must comply with the applicable exchange requirements.

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