HON'BLE MR. P.A. AUGUSTIAN, MEMBER (JUDICIAL) AND HON'BLE MR. PULLELA NAGESWARA RAO, MEMBER (TECHNICAL) For the Appellant : Ms. Radhika Shriranjani, Advocate For the Respondent : Mr. Neeraj Kumar, Authorized Representative ORDER Per: P.A. Augustian The issue in the present appeal is whether the demand of Service Tax against the amount received for conducting package tours abroad is liable to service tax under the category of tour operators service and further whether the e... ... ...

Trust and Company Services Providers may support permitted leasing activities by establishing trusts, companies, limited liability partnerships, and other bodies corporate; performing or arranging fiduciary, management, and nominee functions; and providing registered, business, correspondence, or administrative addresses where applicable law permits. They may act as trustees, directors, company secretaries, nominee shareholders, partners, designated partners, or equivalent persons. Additional services may be undertaken where permitted by the Authority.

Regulation 10L requires every Trust and Company Services Provider to identify conflicts of interest arising in the course of its business and, wherever appropriate, disclose them. Each provider must also maintain a documented conflict management policy, establishing a formal framework for identifying, disclosing and managing business-related conflicts.

Every Trust and Company Services Provider must maintain professional indemnity insurance cover commensurate with the scale and risk profile of its business. The cover must protect against claims arising from negligence, errors, omissions, or breach of duty. Compliance requires insurance protection calibrated to the provider's business scale and risk profile.

^1[10J. (1) The Trust and Company Services Provider who contravenes any of the provisions of these regulations, guidelines, circulars or direction made thereunder, shall be liable for enforcement action under the Act, including but not limited to suspension or cancellation of registration. (2) No enforcement action as referred to in sub-regulation (1) shall be taken without giving the Trust and Company Services Provider a reasonable opportunity of being heard by way of written submissions... ... ...

HON'BLE MR. RAMESH NAIR, MEMBER (JUDICIAL) AND HON'BLE MR. C. L. MAHAR, MEMBER (TECHNICAL) For the Appellant : Shri Dhaval K Shah, Advocate For the Respondent : Shri A R Kanani, Superintendent (AR) ORDER RAMESH NAIR The issue involved in the present case is the demand of service tax is renting of Hydrogen Cylinder Skids vehicle under the head of supply of tangible goods for use service under section 65(105) (zzzj) of Finance Act, 1999. 2. Shri Dhaval Shah learned counse... ... ...

^1[10I. (1) The Trust and Company Services Provider shall furnish information relating to its operations to the Authority, in such manner, interval and form, as may be specified by the Authority. (2) Any financial reporting by the Trust and Company Services Provider to the Authority shall be in US Dollar, unless otherwise specified by the Authority]     *************** NOTES:- 1. Inserted vide F. No. IFSCA/GN/2026/ 008 dated 05-05-2026 =============... ... ...

^1[10H. The Trust and Company Services Provider may provide the services to a Service Recipient, who is a Non-resident and from a jurisdiction which has not been identified in the public statement of Financial Action Task Force (FATF) as "High-Risk Jurisdiction subject to call for action". Provided that a Trust and Company Services Provider may provide services enlisted under Fifth Schedule to a special purpose vehicle in the IFSC, where such special purpose vehicle is the primary service... ... ...

^1[10G. . (1) Every Trust and Company Services Provider shall appoint a Principal officer and Compliance officer in accordance with regulation 9 of these regulations. (2) The Principal Officer and Compliance Officer shall be based out of IFSC and shall be a full-time employee of the Trust and Company Services Provider. (3) The Principal Officer and Compliance Officer shall possess minimum educational qualifications and experience as specified below: (a) A professional or post-g... ... ...

^1[10F. (1) Every Trust and Company Services Provider shall have a Governing Body in place, which shall, inter-alia, formulate a governance framework commensurate with the scale, nature, complexity and risk profile of its activities. (2) The Trust and Company Services Provider shall establish an internal audit or independent review mechanism, commensurate with the scale, nature, complexity and risk profile of its operations, to inter-alia assess: (a) adequacy of governance and co... ... ...

Regulation 10E requires Trust and Company Services Providers to ensure, at all times, that the provider entity and its principal officer, compliance officer, directors, partners, designated partners, and controlling shareholders are fit and proper persons. The applicable fit and proper standard is governed by Regulation 7.

Regulation 10D provides that the permissible services which may be undertaken by a Trust and Company Services Provider in an International Financial Services Centre are those specified in the Fifth Schedule to the International Financial Services Centres Authority (Techfin and Ancillary Services) Regulations, 2025.

Regulation 10C requires an applicant for trust and company services provider activities to be incorporated in the IFSC as a company or limited liability partnership, unless another legal form is permitted by the Authority. Every promoter or partner must also be from a jurisdiction not identified in the Financial Action Task Force public statement as a high-risk jurisdiction subject to a call for action.

Prior registration is required before an entity may commence Trust and Company Services Provider services in an IFSC. An applicant must apply in the prescribed form and manner, obtain a certificate of registration, and declare that its Trust and Company Services Provider activities will remain at arm's length from other services. The certificate remains valid unless suspended, cancelled, or voluntarily surrendered, with surrender taking effect only upon acceptance. Existing TechFin and Ancillary Service Providers require separate approval to undertake these services.

Regulation 10A defines a Trust and Company Services Provider as an entity granted registration as a Tech Fin and Ancillary Services Provider under the applicable Regulations. Registration qualifies the entity to undertake Trust and Company Services Provider services for leasing activities permitted by the Authority, limiting the service category to registered entities operating within the permitted leasing scope.

Merit in a civil review petition concerning Central Excise was not found after consideration of the petition and connected papers, resulting in dismissal. No underlying Central Excise issue, review ground, statutory provision, or broader legal principle is identified. The dismissal records only the absence of merit in the particular review petition.

HON'BLE MR. S.N. VARIAVA AND HON'BLE MR. H.K. SEMA, JJ. ORDER We see no reason to interfere. The Civil Appeal is dismissed. =============... ... ...

Customs clearance operates on a 24x7 basis through import facilitation centres, export parking plazas, extended Assessment Group working and continuous preventive staffing at port-terminal gates, container freight stations and the boarding office. Assessment, examination, Out of Charge and laboratory operations may be extended to address congestion, delays or operational surges, with implementation treated as a Standing Order for officers.

Each Pension Fund must maintain a formal risk management framework integrated with Scheme governance. It must identify, assess, mitigate, monitor and report risks throughout the investment lifecycle, with oversight by the Compliance Officer and reporting to senior management or the Board. Controls must address market, credit, liquidity, operational and compliance risks through diversification, hedging, liquidity buffers, internal controls, audits and legal compliance reviews. Regular stress testing and scenario analysis must assess resilience under adverse conditions and support corrective measures, including portfolio rebalancing, additional hedging, increased liquidity and contingency planning.