Marketing and technical support services supplied to an overseas group entity for consideration received in convertible foreign exchange are treated as exports of services rather than intermediary services. Consistent treatment of materially similar services supports export classification where the supplier provides the services directly to the overseas recipient. Consequently, denial of refund of accumulated CENVAT credit on the ground that the services are intermediary services is unsustainable.

Cash deposits during demonetisation require verification of bank statements, Form 26AS, the taxpayer's explanation and supporting business records before being treated as unexplained money. Telecom recharge-coupon resale activity reflected in available tax information may be relevant to establishing the source of deposits. Where the Assessing Officer has not obtained bank information through statutory information-gathering powers or reviewed departmental records and documentary material, the source explanation requires fresh examination. The deposit addition is consequently subject to fresh adjudication after consideration of the available evidence.

Bad-debt write-off is allowable where the debt was taken into account in computing the assessee's income in an earlier year, satisfying the requirement under section 36(2)(i) read with section 36(1)(vii) of the Income-tax Act. Ledger accounts, invoices, financial statements and prior income-tax returns established that the debt had been recognised as income. A contrary appellate finding, unsupported by the documentary record and by any remand objection on compliance with section 36(2)(i), could not sustain the addition. The bad-debt deduction was therefore allowable and the addition was deleted.

Penalties for non-compliance with information notices during scrutiny may be limited where later notices substantially duplicate information sought earlier. Failure to comply led to an ex parte assessment, but the explanation for non-compliance supported treating only the first notice as an independent default. The penalty was therefore restricted to the first non-compliance, and penalties imposed for the substantially repetitive later notices were deleted.

Declared agricultural income treated as unexplained money requires examination of relevant supporting material, including executed lease deeds, agreements for sale of rubber trees and teakwood, and bank records evidencing receipt of agricultural proceeds. Where this evidence was not adequately presented before the assessing authorities, verification of land ownership and the source and quantum of agricultural income remains necessary. The addition was restored for fresh examination after granting the taxpayer a reasonable opportunity to produce and substantiate the evidence.

Long-term capital gains from listed-share sales were not treated as unexplained cash credit after the taxpayer established allotment, banking, demat, broker and stock-exchange sale records, including securities transaction tax. A general investigation report, without evidence linking the taxpayer to manipulation or accommodation entries or enquiries disproving those records, did not support the addition. Acceptance of identical transactions in other years and deletion of a comparable same-scrip addition supported judicial consistency. The unexplained cash-credit addition and consequential unexplained-expenditure addition were deleted.

BRICS supports a rules-based multilateral trading system and seeks restoration of an accessible, effective, fully functioning two-tier binding dispute-settlement mechanism, including prompt appointment of Appellate Body members. It opposes unilateral tariff and non-tariff measures, trade restrictions, and economic or secondary sanctions not authorised by the UN Security Council. It also seeks reform of International Monetary Fund and World Bank governance through greater representation, quota and shareholding realignment, and increased voting power for emerging markets and developing economies.

Tax deduction at source on professional-service payments to a resident Chartered Accountant is governed by section 194J(1)(b) at 10%. The threshold is Rs. 50,000 per payee in a financial year. Once aggregate payments exceed that threshold, deduction applies to the entire amount. Tax must be deducted at the earlier of credit of the sum or payment.

Imported quality-testing equipment moved to customer locations for certification is treated as movement other than by way of supply. Transport documentation comprises a delivery challan and an e-way bill, with the customs bill of entry kept available for the imported consignment. Where equipment is imported directly to a customer location for testing and then returned, the same documents should accompany the consignment or remain readily available during transport.

E-way bill transaction-type selection turns on the actual dispatch location. Where a registered person invoices a customer but goods move directly from a farmer's premises, the suggested treatment is "Bill From-Dispatch From," with the registered person shown as Bill From and the farmer's address as Dispatch From. "Regular" treatment is suggested for dispatches from the registered person's own declared premises. An additional godown does not by itself require "Bill From-Dispatch From"; its actual address should be entered as the dispatch location where required.

A private discretionary trust with indeterminate beneficiary shares generally attracts the maximum marginal rate under section 164(1), while capital gains require separate examination under applicable special-rate provisions. A processing demand applying the maximum marginal rate to capital gains should be checked against the return, computation and section 143(1) intimation. An apparent rate error may be addressed through section 154 rectification supported by capital-gains details; an appeal and, where necessary, a separate stay request may also be considered.

Provisional attachment powers and recovery-related functions under the Delhi Goods and Services Tax Act, 2017 may be exercised by all Assistant Commissioners and Goods and Services Tax Officers only after obtaining prior case-specific approval from the Commissioner, State Tax. The arrangement partially modifies earlier delegation orders and takes effect immediately.

Timely issuance of show cause notices is required to preserve the statutory period available for GST adjudication. In non-fraud cases, notices must be issued at least three months before expiry of the three-year period for issuing an adjudication order. In fraud, wilful misstatement, or suppression cases, notices must be issued at least six months before expiry of the five-year order-making period. Ward and zonal in-charges should identify cases requiring action and ensure time-bound completion of proceedings.

Bullion exchanges and bullion clearing corporations must maintain regulatory compliance, due diligence, risk management, good governance, customer protection, fair treatment and prompt reporting of violations. Governing boards must oversee critical operations, independent regulatory and control functions, risk-appetite frameworks, three lines of defence, product reviews and conduct culture. Directors, committee members and key management personnel must act with integrity, preserve confidentiality, disclose beneficial interests, avoid conflicts and misuse of position, and support regulatory compliance. Director appointments require prescribed disclosures, fit-and-proper confirmation, approval processes, training and familiarisation.

Regulation 79 repeals the International Financial Services Centres Authority (Bullion Exchange) Regulations, 2020 and supersedes specified circulars. Savings and deeming provisions preserve actions, approvals, pending applications, accrued rights, liabilities, penalties, investigations and proceedings under the repealed framework. References to the repealed regulations are construed as references to corresponding provisions, while earlier circulars and guidelines continue unless specifically superseded or modified.

Regulation 78 authorises the Authority to issue circulars specifying norms, procedures, processes, manners and guidelines for implementing the International Financial Services Centres Authority (Bullion Market) Regulations, 2025 and addressing matters incidental to their implementation.

Relaxation of strict enforcement may be granted on the Authority's own motion or upon application by a covered entity, where written reasons are recorded and the relaxation serves the development and regulation of the financial services market in an International Financial Services Centre. Applications must state the relevant details and grounds, be accompanied by the prescribed non-refundable fee, and be processed within thirty days of receipt of a complete application. Reasons for acceptance or refusal must be recorded, and rejection reasons communicated to the applicant.

Power to remove difficulties permits the Authority to issue directions through guidance notes or circulars where difficulties arise in interpreting or applying the International Financial Services Centres Authority (Bullion Market) Regulations, 2025.

Bullion exchanges and bullion clearing corporations require prior approval to frame bye-laws governing bullion contracts, clearing and settlement. Amendments to relevant constitutional documents and bye-laws must be approved by the governing board, and by shareholders where applicable, before approval and required publication. Applications must include governing board minutes, shareholder resolutions and public consultation. Amendments pursuant to regulatory directions or circulars are exempt from shareholder approval and public criticism.

Regulatory fees are payable by bullion exchanges, bullion clearing corporations, bullion depositories and intermediaries as specified by the Authority. Each such entity must provide further information or clarification concerning the fee payable when required.