Goods sent or taken out of India for exhibition or export-promotion consignments are not supplies, and therefore not zero-rated supplies, at the time of removal where no consideration is received. They must move under a delivery challan and be recorded by the registered person. Goods must be sold abroad or returned within six months; supply arises on the date of sale for goods sold, or is deemed to arise on expiry of that period for goods neither sold nor returned. Tax invoices and eligible input tax credit refunds follow only after supply arises.

BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI AMARJIT SINGH, ACCOUNTANT MEMBER For the Appellant : Shekhar Gupta For the Respondent : Ms. Zeenia Handa ORDER Per Amarjit Singh (AM): This appeal filed by the assessee is directed against the order passed by the ld. CIT(A)-4, Mumbai, dated 30.03.2023 for A.Y. 2018-19. The assessee has raised the following grounds before us: "1. The learned Principal CIT has erred in law and on the facts of the case in reopening the assess... ... ...

International Financial Service Centre Insurance Offices conducting general, health or re-insurance business must file prescribed statements of admissible assets, liabilities and solvency margin, together with an annual actuarial report and certified valuations. Technical reserves must comprise premium and claims reserves, including UPR, PDR, OCR and IBNR components. Available Solvency Margin is determined from adjusted assets and liabilities, while Required Solvency Margin is the higher of premium-based and incurred-claims-based measures. The control level requires a minimum solvency ratio of 150%.

Customs demand relating to fulfilment of export obligations must be determined by reference to the Export Obligation Discharge Certificate issued by DGFT. Where a licence holder has applied for redemption with supporting documents but the certificate remains pending, Circular No. 16/2017-Cus. requires the demand to await and be decided based on the certificate when issued. The pending non-issuance of the certificate does not itself provide the stated basis for final determination of the customs demand.

US sanctions legislation authorises the President to impose tariffs, including up to 100 per cent, on countries purchasing Russian oil and gas. China rejects tariffs directed at its Russian energy purchases and opposes unilateral sanctions and long-arm jurisdiction absent an international-law basis or a UN Security Council mandate. Washington and Beijing are also negotiating a reciprocal tariff-reduction framework covering products from both sides.

Organised gold recycling, responsible sourcing, gold loans and financialised gold products are identified as ways to reduce reliance on fresh gold imports. Exchanging old jewellery can meet retail demand from existing domestic holdings, while gold loans unlock credit without requiring households to sell their gold. Gold ETFs and digital gold permit exposure to gold's value without physical possession and may reduce physical import demand. Transparency, trust and supporting infrastructure are necessary to integrate household gold into an organised formal economy.

Next Generation GST rate reductions effective from 22 September 2025 require trade and industry to ensure that reduced-tax benefits and savings are passed on to consumers, buyers and recipients. Tax authorities are to assist taxpayers with implementation, monitor retail outlets for transmission of GST savings, and initiate action under applicable legal provisions for non-compliance with GST law and rules.

Penalty for under-reporting or misreporting under section 270A was not attracted merely because an education-cess deduction, claimed on a bona fide belief as business expenditure, was voluntarily withdrawn during assessment before an addition. The penalty on that claim was deleted. For donations claimed as deductions, evidence reportedly submitted before the faceless appellate authority required consideration for the unresolved portion; the related penalty issue was remitted for fresh determination. Voluntary withdrawal of a bona fide expenditure claim, without further circumstances, does not establish penal under-reporting or misreporting.

Actions taken or purportedly taken under the superseded investment regulations and master circular before commencement are preserved and deemed taken under corresponding provisions of the 2022 Regulations. An International Financial Services Centre Insurance Office operating before commencement must meet the additional requirements within six months of commencement, unless the Authority permits an extended period.

The Authority may issue guidance notes or circulars to resolve difficulties in applying or interpreting requirements governing investments by International Financial Services Centre Insurance Offices. Upon an application accompanied by the specified non-refundable processing fee, it may relax strict enforcement of any requirement, provided written reasons are recorded in writing.

Regulation 18 empowers the Authority to specify norms, procedures, processes and compliance manners for International Financial Service Centre Insurance Offices (IIOs). The power applies to implementation, facilitation and regulation of IIO investments, including matters incidental to those investments, and permits operational compliance requirements governing IIO investment-related compliance.

Every International Financial Service Centre Insurance Office (IIO) must furnish investment-related information to the Authority in specified or requested manners, intervals and forms. The obligation covers information concerning its investments. Financial reporting to the Authority must be in USD unless otherwise specified, creating a default reporting currency subject to regulatory variation.

Investment management by an International Financial Service Centre Insurance Office requires Board-authorised oversight through an Investment Management Committee with financial, actuarial and insurance or reinsurance risk expertise. Unincorporated offices must invest through Parent Entity-authorised persons subject to reporting and review protocols. Internal controls and investment audits are mandatory. Offshore investments must be transferable to the International Financial Services Centre when directed, while investments must generally use freely convertible foreign currencies and minimise liquidity risk.

Governance requirements applicable to an International Financial Service Centre Insurance Office require its Board to maintain prudential mechanisms for evaluating, monitoring, measuring, reporting, controlling and limiting investment exposure. The IIO must independently conduct due diligence on proposed investments. Additional capital must be infused if exposure exceeds applicable limits or an invested asset is downgraded below investment grade.

Investment exposure limits apply to an International Financial Service Centre Insurance Office's total investment assets across specified fixed-income, debt, equity, fund, property, and infrastructure investments. Caps are 10 per cent for a single investee entity, 5 per cent within the IIO's own group, and 15 per cent for any other group or industrial sector. Separate limits restrict aggregate equity-related investments to 10 per cent of an investee's paid-up equity share capital and debt investments to 10 per cent of specified investee capital, reserves, and debt securities.

Sovereign credit rating-based limits govern IIO exposure to immovable property and infrastructure assets. SCR-RC 1 allows 100 per cent exposure without a buffer; SCR-RC 2 and 3 allow 50 per cent with a 10 per cent buffer; SCR-RC 4, 5 and 6 allow 30 per cent with a 5 per cent buffer; and SCR-RC 7 and lower within investment grade allow 10 per cent without a buffer.

Equity exposures of an International Financial Service Centre Insurance Office (IIO) in listed equities and equity-type instruments, including equity mutual funds, preference shares, Category I and II alternative investment funds, and derivatives, are subject to sovereign-credit-rating-based limits. SCR-RC 1 permits maximum exposure of 100 per cent with no buffer, while lower investment-grade rating categories carry progressively reduced exposure limits and specified buffers. Equity exposures in India, including IFSC, carry a 100 per cent maximum and no buffer.

IIO exposure to bonds, debts and deposits is limited according to the sovereign credit rating of the country from which the instruments are offered. The framework covers fixed-income instruments, debt mutual funds, loans, corporate and bank deposits, and similar rights. Maximum exposure is 100 per cent for SCR-RC 1 and India including IFSC, 50 per cent with a 10 per cent buffer for SCR-RC 2 and 3, 20 per cent for SCR-RC 4 to 6, and 10 per cent for SCR-RC 7 and lower within the investible grade.

The Supreme Court required the Central Government urgently to identify, in consultation with the Tribunal President, infrastructural amenities needed by tribunal benches. The Principal Bench Bar Association was required to compile tabulated infrastructure data for every regional bench. At least 18 benches were asserted to conduct half-day sittings because of member shortages, against a sanctioned complement that remained unchanged despite expanded insolvency jurisdiction.

Exposure limits for an International Financial Service Centre Insurance Office investing in bonds, debt and deposits are determined by Insurance Capital Standards rating categories and apply to total investment assets. ICS-RC 1 permits 100 per cent exposure without a buffer; ICS-RC 2 and 3 permit 50 per cent exposure with a 10 per cent buffer; and ICS-RC 4 permits 20 per cent exposure without a buffer. Exposure in India, including IFSC, is permitted up to 100 per cent without a buffer.