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Appellate enhancement is confined to income sources examined in assessment and cannot introduce sale consideration as a new taxable source where only related expenditure was scrutinised. Advance rental receipts already offered in later years are not taxable again absent accrual in the relevant year, preventing double taxation. Recorded bank credits, loans and advances supported by ledgers, confirmations and banking evidence cannot be treated as unexplained without adverse material. Likewise, no unexplained-investment addition arises for shareholdings acquired in earlier years, while documentary proof of disclosed cash sources and individual-to-HUF transfers shifts the evidentiary burden to the Revenue.
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Taxability of advance rental receipts - Appellate enhancement beyond the subject-matter of assessment - Onus to prove unexplained bank credits - Unexplained investments in prior-year shareholdings - Explained cash deposits - Transfers between individual and HUF accounts Advance rental receipts - Double taxation of income - Taxability of advance rental receipts and the alleged unexplained component of rental credits for A.Y.2015-16 - HELD THAT: - The bank records established that the actual re... ... ...
Notification No. F. No. IFSCA/GN/2026/2 Dated:- 5-1-2026 Indian Law
INTERNATIONAL FINANCIAL SERVICES CENTRES AUTHORITY NOTIFICATION Gandhinagar, the 5th January, 2026 F. No. IFSCA/GN/2026/002.-In exercise of the powers conferred by sub-section (1) of Section 28, read with sub-section (1) of Section 12 of the International Financial Services Centres Authority Act, 2019, the International Financial Services Centres Authority hereby makes the following regulations, further to amend the International Financial Services Centres Authority (Book-keeping, A... ... ...
Circular No. Circular No. 34/2019-20 - GST Dated:- 20-12-2019 Goa SGST Dated:- 20-12-2019 Goa SGST
Government of Goa Department of Commercial Taxes Vikrikar Bhavan, Panaji - Goa - 403001 CCT/ 26-4/2017-2018/D/2485 Dated: 20th December, 2019 CIRCULAR (No. 34 / 2019-20 - GST) Subject: Kind attention is invited to Circular No. 15/2019-20-GST dated 26/07/2019 wherein certain clarifications were given in relation to various doubts related to supply of Information Technology enabled Services (ITeS services) under GST. 2. Thereafter, numerous representations were received... ... ...
Notification No. F. No. IFSCA/GN/2026/3 Dated:- 5-1-2026 Indian Law
Service Companies of Lloyd's IFSC are redefined as service companies registered in India and promoted by Lloyd's Managing Agents, permitted group entities of Managing Agents or Members of Lloyd's, or Indian companies meeting applicable regulatory criteria. The revised definition applies to insurance-business registration in International Financial Services Centres and took effect upon Official Gazette publication on 8 January 2026.
Notification No. F. No. IFSCA/GN/2026/4 Dated:- 5-1-2026 Indian Law
Performance Review Committee composition is amended to require at least two independent experts from relevant fields, replacing the earlier provision permitting up to two such experts. The amendment modifies the International Financial Services Centres Authority (Performance Review Committee) Regulations, 2022 and takes effect upon Official Gazette publication.
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SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER For the Appellant : Shri H Guruswamy, I.T.P & Shri Ravi Kiran, C.A For the Respondent : Shri IC Prabhakar, JCIT(DR) ORDER Per Chandra Poojari, Accountant Member This Misc. Petition is filed by the assessee wherein assessee is seeking clarification on the finding given by the Tribunal in para 7 at page 15 of its order dated 16/4/2021. The assessee herein came in appeal before the Tribunal and raised the ... ... ...
Regulation 13 of the International Financial Services Centres Authority (Procedure for Making Regula...
On commencement, the earlier 2021 procedure-making regulations are repealed, but actions, purported actions, and commenced processes under that regime retain effect and are treated as arising under corresponding current provisions. Subsidiary instructions issued before commencement are similarly preserved. Regulations, subsidiary instructions, and related actions before or after commencement are not invalid merely because the prescribed procedure was not followed.
Regulation 12 of the International Financial Services Centres Authority (Procedure for Making Regula...
Regulation 12 excludes the prescribed regulatory procedure from internal organisational matters, procedural measures or subsidiary instructions not involving substantive policy changes, coordinated decisions, and specified market integrity or national security interventions. It also covers measures required to meet international agreements or similar arrangements where public consultation serves no meaningful purpose. The Authority must be informed whenever the prescribed procedure is not applied.
Regulation 11 of the International Financial Services Centres Authority (Procedure for Making Regula...
Periodic review is mandated for each regulation made under regulation 3 every five years, unless an earlier review is warranted. The review assesses objectives, outcomes, implementation, enforcement, related litigation, global best practices, relevance in a changed environment, redundancy reduction, and ease of doing business. Where amendment is warranted, it must be made under the procedure in Chapter III.
Regulation 10 of the International Financial Services Centres Authority (Procedure for Making Regula...
Amendments to existing regulations and subsidiary instructions made under regulation 4(2) must comply with the procedural requirements prescribed in Chapter III, subject to regulations 6 and 9. The amendment process therefore applies to both regulations and subsidiary instructions.
Regulation 9 of the International Financial Services Centres Authority (Procedure for Making Regulat...
Regulation 9 authorises dispensation of public consultation where the Authority considers it expedient in the interest of developing and regulating the financial services market. The power may be used where the time required for consultation would defeat the purpose of proposed regulations or result in undue delay in redressing a problem or market failure.
Regulation 8 of the International Financial Services Centres Authority (Procedure for Making Regulat...
The Authority may engage stakeholders through additional mechanisms considered appropriate, establish and consult expert or advisory committees for recommendations on drafting or reviewing regulations and subsidiary instructions, and constitute Independent Thematic Review Committees. Independent Thematic Review Committees may conduct focused, independent evaluations of high-priority regulatory themes, including for Regulatory Impact Assessment, on terms considered fit.
Regulation 7 of the International Financial Services Centres Authority (Procedure for Making Regulat...
Public consultation for proposed subsidiary instructions ordinarily requires a minimum period for public comments. The Chairperson may dispense with consultation or reduce that period by recording reasons in writing, with the decision placed before the Authority for information. Comments must be reviewed, and necessary modifications proposed. The modified proposal and comments must be placed before the Authority or its delegated officer for approval. Before issuance, a summary of comments and a general response must be uploaded on the Authority's website.
Regulation 6 of the International Financial Services Centres Authority (Procedure for Making Regulat...
Public comments on proposed regulations must ordinarily be invited for at least 21 calendar days. The Chairperson may, for recorded reasons, reduce or dispense with consultation, subject to placing that decision before the Authority. Proposed regulations and public comments must be considered by the Authority, with written reasons for substantial deviations in an approved revised draft. Comment summaries, responses, and justified substantial changes must be published before notification, and substantive changes differing materially from the consultation paper may require repeated consultation.
Regulation 5 of the International Financial Services Centres Authority (Procedure for Making Regulat...
Public comments must be sought before specified regulations or subsidiary instructions are made. Publication of a consultation paper on the Authority's website is required. The paper must state relevant international norms and regulatory best practices, the problem addressed, regulatory intent and objectives, enabling enactment or regulation, draft measures, and the manner, process, and timelines for public comments.
Regulation 4 of the International Financial Services Centres Authority (Procedure for Making Regulat...
Subsidiary instructions may implement the Act and regulations made under it by prescribing requirements for financial products, services or institutions, explaining or clarifying provisions, establishing procedures, and addressing implementation needs. Public consultation under the prescribed process is mandatory before issuing instructions that impose requirements for financial products, services or institutions or outline the meaning, scope or intent of a provision.
Regulation 3 of the International Financial Services Centres Authority (Procedure for Making Regulat...
Regulation-making power is conferred on the Authority to carry out the purposes of the Act. Exercise of that power is subject to compliance with the requirements prescribed under regulations 5 and 6. The framework requires adherence to the stipulated procedure before regulations are made.
Regulation 2 of the International Financial Services Centres Authority (Procedure for Making Regulat...
Defined terms govern the procedure for making regulations and subsidiary instructions. Public comments include consultation responses on proposed regulations, subsidiary instructions, and amendments from persons and market participants. Subsidiary instructions include circulars, guidelines, frameworks, and other instruments approved by the Authority or an authorised delegate. Expressions not defined carry the meanings assigned under the International Financial Services Centres Authority Act, 2019, including statutory modifications or re-enactments.
Regulation 1 of the International Financial Services Centres Authority (Procedure for Making Regulat...
Commencement occurs on publication in the Official Gazette unless a different provision expressly applies. Gazette publication operates as the default trigger for legal effect while allowing a specific provision to prescribe alternative commencement. Regulation 1 addresses the formal short title and commencement, without prescribing detailed procedures for making regulations or subsidiary instructions.