JOURNAL DECEMBER 2025

Ahmedabad Chartered Accountant Journal December, 2025 797TMcontrary]. Use of such expression is another wayof saying that the provision in which the nonobstante clause occurs usually would prevail overthe other provisions in the Act. Thus, the nonobstante clauses are not always to be regardedas repealing clauses nor as clauses whichexpressly or completely supersede any otherprovision of the law, but merely as clauses whichremove all obstructions which might arise out ofthe provisions of any other law in the way of theoperation of the principle enacting provision towhich the non-obstante clause is attached. [See:Bipathumma v. Mariam Bibi 1966 1 MYSLJ 162]48. A non obstante clause has two parts- the nonobstante clause and the enacting part. Thepurpose of enacting a non obstante clause is thatin case of a conflict between the two parts, theenacting part will have full sway in spite of thecontrary provisions contained in the non obstanteclause. Therefore, the object and purpose of theenacting part should be first ascertained and thenthe assistance of the non obstante clause shouldbe taken to nullify the effect of any contraryprovision contained in the clause.Judicial Analysisinclusion of the expression “for collection through anaccount” in Section 142(2)(a) is only to indicate theintention of the drawer to “make” the cheque in such amanner that it can only result in a transaction betweenthe bank accounts of the drawer and the payee.Presentment is the stage that immediately succeeds“delivery”. It stipulates that a cheque must bepresented for payment to the maker of such cheque(the drawer) or the person to whom directions are givento pay the amount specified in the cheque (thedrawee). Such presentment must be by or on behalfof the payee. Therefore, presentment creates arelationship between the drawee bank and the payee(in case of an account bearer cheque) or the payee’sbank (in case of an account payee cheque). The Courtclarified that presentment under Section 64 of the Act,Glimpses of Rulings1881 and presenting of cheque by the payee to hisbank are two distinct acts. The presentation of chequeby a payee to the payee’s bank is included in theconcept of “delivery” defined under Section 46 of theAct, 1881. It is nothing but an extension of delivery inthe case of non-transferable account payee cheques.The jurisdiction in such cases has been anchored bySection 142(2)(a) at the place where branch of the bankin which the payee maintains an account is situated....[Jai Balaji Industries Ltd. v. HEG Ltd., 2025 SCCOnLine SC 2581, decided on 28-11-2025]...Continued from page 779

798 Ahmedabad Chartered Accountant Journal December, 2025TMCross-Border M&A and Indirect Transfers: TheMumbai Tribunal Draws the Treaty Line1. Introduction1.1 India’s approach to taxing indirect transfers incross-border transactions has undergone amarked evolution over the past decade. TheSupreme Court’s decision in VodafoneInternational Holdings B.V. v. Union of India initiallyaffirmed that offshore share transfers could notbe taxed in India in the absence of clearlegislative authority, even where the underlyingvalue was derived from Indian assets. Parliamentresponded through the Finance Act, 2012 byretrospectively amending the Income-tax Act,1961 to deem gains from such indirect transfersas India-source income, significantly expandingIndia’s domestic taxing jurisdiction.1.2 However, the interaction of these domesticprovisions with India’s tax treaty network hasremained contentious. Many of India’s treatieswere not renegotiated to include express “lookthrough” clauses, raising the question whetherdomestic indirect transfer rules could overridetreaty-based allocations of taxing rights. Indiancourts have consistently held that, absent explicittreaty language, domestic deeming provisionscannot be read into treaties.1.3 It is in this context that a recent ruling of theMumbai Bench of the Income Tax AppellateTribunal, arising from Walmart’s 2018 acquisitionof Flipkart, assumes significance. The Tribunalheld that capital gains earned by a Singaporeresident company on the sale of shares ofanother Singapore-resident company weretaxable exclusively in Singapore under Article13(5) of the India–Singapore tax treaty. Thedecision reaffirms that treaty text, not domesticsource rules, defines the limits of India’s taxingrights over indirect transfers in foreign-to-foreigntransactions.2. Factual Background2.1 eBay Singapore Services Private Limited (“theTaxpayer”) is a Singapore-incorporated companythat forms part of the eBay group’s Asia-Pacificoperations. It performs a range of e-commercerelated functions for group entities, includingproduct management, business development,customer service support, and back-officefunctions such as legal, human resources, andfinance. The Taxpayer also operates an onlineplatform that facilitates export sales by Indiansellers to customers overseas. Throughout therelevant period, the Taxpayer remained a taxresident of Singapore and held valid tax residencycertificates for, inter alia, calendar years 2018 and2019.2.2 Beyond its operating role, the Taxpayer functionsas an investment holding vehicle for the eBaygroup in the Asia-Pacific region. Between 2014and 2019, it made several investments in Indiancompanies, alongside other global investments,reflecting its dual role as both a service providerand a regional investment platform.2.3 In April 2017, as part of a strategic realignment ofeBay’s Indian business, the Taxpayer transferredits shareholding in eBay India to FlipkartSingapore. The consideration for this transfer wasa minority equity stake in Flipkart Singapore,FEMA & InternationalTaxationCA. Dhinal A. [email protected]. Vibhu [email protected]

Ahmedabad Chartered Accountant Journal December, 2025 799TMFEMA & International Taxationwhich was supplemented by a further minorityinvestment through a primary subscription laterin the same year. As a result, the Taxpayeremerged as a minority shareholder in FlipkartSingapore.2.4 The investment was monetised in August 2018,when Walmart acquired the Flipkart group.Pursuant to this transaction, the Taxpayer sold itsentire shareholding in Flipkart Singapore to aWalmart group affiliate for approximately INR7,440.79 crores, generating short-term capitalgains of around INR 2,257.91 crores. The Taxpayerretained part of the proceeds for working capitaland future investments, while the balance wasdistributed to its shareholder, eBay InternationalAG, by way of dividend.2.5 In its Indian income-tax return filed on 3 October2019, the Taxpayer reported nil taxable income,taking the position that the capital gains were nottaxable in India by virtue of Article 13(5) of theIndia–Singapore tax treaty. The return wasselected for scrutiny, and the Assessing Officerdenied treaty relief on the basis that the Taxpayerwas allegedly managed and controlled from theUnited States, contending that the India–US taxtreaty, rather than the India–Singapore treaty,governed the transaction. This view was affirmedby the Dispute Resolution Panel, culminating in afinal assessment order.2.6 Challenging the denial of treaty benefits and theresulting tax demand, the Taxpayer carried thematter in appeal before the Income Tax AppellateTribunal, setting the stage for a ruling ofconsiderable significance for cross-borderinvestors and offshore transaction structuringinvolving India.3. Issues Before the Tribunal3.1 The Tribunal was required to consider twoprincipal questions:i. Whether the Taxpayer was entitled to invokethe Singapore Treaty, or whether the India–US treaty applied on account of allegedmanagement and control from the UnitedStates; andii. Whether, assuming the Singapore Treatyapplied, India had taxing rights over the gainsunder Article 13, particularly Articles 13(4B)and 13(5).4. Tribunal’s Findings4.1 Treaty Residence and Place of ControlThe Tribunal rejected the Revenue’s contentionthat the Taxpayer was effectively managed andcontrolled from the United States and thereforenot entitled to claim benefits under the India–Singapore tax treaty. It noted that the Taxpayerhad furnished a valid Tax Residency Certificateissued by the Inland Revenue Authority ofSingapore for the relevant year, which remaineduncontroverted by the Revenue.On the issue of control and management, theTribunal accepted the Taxpayer’s evidence thattwo of its three directors were Singapore residentsand the third was based in Hong Kong, with noneholding any position in eBay Inc., USA during theyear under consideration. The Tribunal specificallyobserved that the Assessing Officer’s allegationregarding one director’s association with eBayInc., USA was factually incorrect, a positionconfirmed in a remand report dated 8 December2021, which the Dispute Resolution Panel failedto properly address.The Tribunal further noted that all board meetingswere held in Singapore and that key investmentand divestment decisions, including theacquisition and sale of Flipkart Singapore shares,were taken by the Taxpayer’s Board throughresolutions passed in Singapore. Theinvolvement of the global treasury team waslimited to execution of transactions under boardauthority, without any independent decisionmaking role.

800 Ahmedabad Chartered Accountant Journal December, 2025TMIn the absence of any contrary evidence from theRevenue, the Tribunal held that the Taxpayer’scontrol and management were clearly situated inSingapore. Accordingly, it concluded that theIndia–Singapore tax treaty applied to thetransaction and governed the allocation of taxingrights.4.2 Interpretation of Article 13 of the SingaporeTreatyThe Tribunal undertook a detailed textual andcontextual analysis of Article 13 and concludedas follows:· Articles 13(1) to 13(3) were inapplicable, as thetransaction did not involve immovable property,a permanent establishment in India, or ships oraircraft.· Article 13(4A), the grandfathering provision, didnot apply because the shares of FlipkartSingapore were acquired after 1 April 2017.· Article 13(4B), which allows source-based taxationfor shares acquired after 1 April 2017, applies onlywhere the alienator and the company whoseshares are sold are residents of differentcontracting states. In this case, both the seller(the Taxpayer) and the company whose shareswere sold (Flipkart Singapore) were residents ofSingapore. Consequently, Articles 13(4B) and13(4C) were inapplicable.· Since none of Articles 13(1) through 13(4C)applied, the residuary provision in Article 13(5)governed the transaction.· Article 13(5) provides that gains from thealienation of any property other than thosespecified in the preceding paragraphs shall betaxable only in the contracting state of which thealienator is a resident. As the Taxpayer was aSingapore resident, the Tribunal held thatSingapore had the exclusive right to tax thegains.FEMA & International Taxation4.3 No Treaty Override by Domestic LawThe Tribunal reaffirmed the settled legal positionunder section 90(2) of the Income-tax Act, 1961,that a taxpayer is entitled to be governed bythe provisions of domestic law or the applicabletax treaty, whichever is more beneficial. Whilesection 9(1)(i) of the ITA deems gains arisingfrom indirect transfers of Indian assets to be Indiasource income, the Tribunal held that suchdomestic deeming provisions cannot overridean express and contrary allocation of taxingrights under a Double Taxation AvoidanceAgreement.In reaching this conclusion, the Tribunal placedreliance on the consistent judicial principles laiddown by the Supreme Court in VodafoneInternational Holdings B.V. v. Union of India,Sanofi Pasteur Holding SA v. Department ofRevenue, and Engineering Analysis Centre ofExcellence (P.) Ltd. v. CIT. These decisionsunequivocally establish that where treatyprovisions are more beneficial to the taxpayer,they prevail over domestic tax fictionsintroduced under municipal law.Applying these principles, the Tribunal observedthat the India–Singapore tax treaty does notcontain any “look-through” or indirect transferprovision enabling India to tax gains arising fromthe transfer of shares of a foreign company merelybecause such shares derive value from assetslocated in India. In contrast to certain treaties thatexpressly permit source-based taxation of sharesderiving value from immovable property, theIndia–Singapore treaty contains no such enablinglanguage.Accordingly, in the absence of a specific treatyprovision permitting India to tax indirect transfers,the Tribunal held that the residuary provision inArticle 13(5) applied, conferring exclusive taxingrights on Singapore as the state of residence ofthe transferor.

Ahmedabad Chartered Accountant Journal December, 2025 801TM5. Analysis:5.1 The eBay Singapore ruling marks a careful andrestrained application of treaty interpretationprinciples and underscores the limits of India’ssource-based taxing rights in indirect transfercases. The Tribunal made it clear that theexpansive reach of India’s post-Vodafone indirecttransfer provisions under domestic law cannot,by themselves, alter the allocation of taxing rightsagreed under a tax treaty. Where a treaty has notbeen renegotiated to include an express indirecttransfer or “look-through” provision, its textcontinues to govern.5.2 A central aspect of the ruling is the Tribunal’sconstruction of Article 13(4B) of the India–Singapore tax treaty. By holding that the provisionapplies only where the transferor and thecompany whose shares are transferred areresidents of different contracting states, theTribunal rejected an interpretation that would haveenabled India to tax foreign-to-foreign sharetransfers solely because the underlying value waslinked to Indian assets. This reading is consistentwith the structure of the OECD and UN ModelConventions and avoids stretching treatylanguage to achieve outcomes not contemplatedat the time of negotiation. The decision also sitscomfortably alongside earlier judicialpronouncements such as Sanofi Pasteur andTiger Global, which declined to permit indirecttransfer taxation in the absence of an explicit treatymandate.5.3 The Tribunal also took a measured view onsubstance-based challenges. It declined toaccept allegations that the intermediary entitywas a façade or mere conduit in the absence ofsupporting evidence, reiterating that the burdenof establishing sham or tax avoidance lies withthe Revenue. The ruling reinforces that whileactive business operations are not aprecondition for treaty residence, the existenceof real governance, independent decisionmaking, and contemporaneous documentationremains critical, particularly in an environmentshaped by GAAR and the Principal PurposeTest.5.4 Taken together, the decision reinforces two wellsettled propositions. First, India’s taxing rightsunder a treaty are confined to what the treatyexpressly permits, and domestic deemingprovisions cannot be used to expand thoserights by interpretation. Second, treaty protectionis closely linked to substance: wherecommercial rationale and governance aredemonstrable, bona fide cross-borderinvestment structures will continue to berespected.FEMA & International Taxation

802 Ahmedabad Chartered Accountant Journal December, 2025TMInternational Trade Settlement in IndianRupees (INR)Attention is invited to Para 8(c) of A.P. (DIR Series)Circular No.10 dated July 11, 2022 wherein it has beenindicated that the balance in Special Rupee VostroAccounts can be used for: ‘Investment in GovernmentTreasury Bills, Government securities, etc. in terms ofextant guidelines and prescribed limits, subject toFEMA and similar statutory provision’.In the light of the directions issued through AP DIRCircular No.13 dated October 03, 2025, AD banks maypermit investment of surplus balances in the SpecialRupee Vostro Accounts also in non-convertibledebentures/bonds and commercial papers issued byan Indian company in terms of guidelines and limitsprescribed vide the referred circular dated October03, 2025.The above instruction is applicable with immediateeffect.Source: RBI/2025-26/91, A.P. (DIR Series) Circular No.14 dated October 03, 2025For full text refer:https://rbidocs.rbi.org.in/rdocs/notification/PDFs/NT918B6D8279B1CC41B8B6D664BF8019E434.PDFAmendments to Directions –Compounding of Contraventions underFEMA, 1999Attention is invited to Master Directions oncompounding of contraventions under FEMA, 1999,dated April 22, 2025.In order to streamline the receipt of compoundingapplication fee and ‘sum for which a contravention iscompounded’ (‘compounding amount’), it has beendecided to change the account details of accountwhere compounding application fee and compoundingamount will be received through National ElectronicFund Transfer (NEFT), Real Time Gross Settlement(RTGS). Accordingly, Annexure I of theaforesaid Master Directions has been modified toinclude the revised account details.Master Directions - Compounding of Contraventionsunder FEMA, 1999 No. 4/2025-26 updated on April 22,2025:The provisions of section 15 of Foreign ExchangeManagement Act, 1999 (42 of 1999) [hereinafter referredto as ‘FEMA, 1999’], enable compounding ofcontraventions and, empowers the Reserve Bank tocompound any contravention as defined under section13 of the FEMA, 1999, except the contraventions undersection 3 (a) of FEMA, 1999, on an application madeby the person committing such contravention.Government of India vide Notification G.S.R. 566 (E).dated September 12, 2024, has notified the ForeignExchange (Compounding Proceedings) Rules, 2024 insupersession of the Foreign Exchange (CompoundingProceedings) Rules, 2000.Instructions issued on ”Compounding of Contraventionsunder FEMA, 1999\" have been compiled in this MasterDirection. The list of underlying circulars/ notificationswhich form the basis of this Master Direction is furnishedin the Appendix attached to the Master Direction.Source: RBI/FED/2025-26/98, A.P. (DIR Series)Circular. No 15/2025-26 dated November 24, 2025For full text refer:https://rbidocs.rbi.org.in/rdocs/notification/PDFs/NT982EE0FA9FD61B49589A734579B17F1598.PDFCA. Dr. Savan R. [email protected] Updates19

Ahmedabad Chartered Accountant Journal December, 2025 803TMDubai International Financial Centre (DIFC): WhereGlobal Finance Meets OpportunityWhen we talk about global financial hubs, names likeLondon, New York, and Singapore usually come tomind. But over the last decade and especially in recentyears Dubai International Financial Centre (DIFC) hasquietly and confidently joined that league.During my recent visit to Dubai, I had the opportunityto experience DIFC closely - not just as a professional,but as someone walking its streets, meeting people,and understanding why the world increasingly truststhis ecosystem.This article is my attempt to demystify DIFC, explainwhy it is globally respected, and share first-handinsights on why startups, fintech founders, and highnet-worth individuals (HNIs) are increasingly choosingDubai as their base.What Exactly Is DIFC?In simple words, DIFC is a financial city within Dubai,created exclusively for finance-related businesses. Itis not just another free zone; it is a globally regulatedfinancial ecosystem.DIFC has:- Its own independent regulator (DFSA)- A separate legal system based on Englishcommon law- An independent court system (DIFC Courts)trusted worldwideThis structure gives international investors andinstitutions the confidence that disputes, contracts, andregulations are handled transparently andprofessionally.That is why global banks, asset managers, fintech firms,private equity funds, and wealth managers operatecomfortably from DIFC.Why Is DIFC Globally Recognised and Trusted?The trust in DIFC does not come from branding - itcomes from consistency and governance.Globally, DIFC is respected because:i. Regulations are clear, predictable, andinternationally alignedii. Compliance standards match UK, EU, and globalbest practicesiii. Investors know their capital is protected by a stronglegal frameworkiv. Businesses are encouraged, not harassedIn the finance world, trust is currency and DIFC hasbuilt that trust over time.This is why companies serving global clients - whetherfrom Europe, India, Africa, or the US feel comfortableoperating from DIFC.Why Fintech & Wealth tech Love DIFCDIFC has become a natural home for fintech, wealthtech, blockchain, and DeFi businesses.Some practical reasons:i. Access to global capital and investorsii. Pro-innovation regulatory approach (includingsandbox frameworks)iii. Strong banking, legal, and advisory ecosystemiv. Easy interaction with family offices and HNIsv. Credibility while dealing with international clientsCA. Sanskar [email protected]

804 Ahmedabad Chartered Accountant Journal December, 2025TMFor fintech founders, DIFC offers something rare:Innovation with regulation - not innovation despiteregulation.My Dubai Experience: A City Built for BusinessThis Dubai visits truly reinforced one thing for me -Dubai is not lucky; it is intentional.The infrastructure is world-class.Processes are digital.Government mindset is business-friendly.Decision-making is fast.What stood out most was the clarity of vision. Dubaiknows exactly what it wants to become - a globalbusiness and financial hub - and every policy supportsthat goal.It is no surprise that HNIs, startup founders, and globalprofessionals are increasingly relocating to Dubai. Notjust for tax reasons, but for:i) Safetyii) Quality of lifeiii) Ease of doing businessiv) Global connectivityv) Long-term stabilityA Personal DIFC Walkthrough: Seeing It from theInsideOne of the highlights of my visit was meeting SamyakJain, a close friend, classmate, and hostel-mate nowa Co-founder of @0xfluid, @Instadapp, and@avowallet, and a Forbes 30 Under 30 (India & Asia)honoree in the DeFi space.Samyak Jain shared insights about DIFC, and hearinghis journey gave me real clarity about whyprofessionals choose this ecosystem.He shared how:i. Dubai offers tremendous growth opportunitiesii. The city is extremely safe and structurediii. Work environments are professional and globallyorientediv. DIFC, in particular, is ideal for the finance andDeFi sectorHe chose DIFC because it provides:i. Global recognitionii. Regulatory comfort for finance businessesiii. Proximity to investors and institutionsiv. A serious, focused financial ecosystemHe even invited me to his home & DIFC, after whichhe walked me through the area and that’s when DIFCtruly made sense to me.DIFC: A Self-Sustainable Financial EcosystemWhat impressed me most was that DIFC is selfsustainable.Everything is within walking distance:i. Officesii. Residencesiii. Cafes and fine-diningiv. Gyms and wellness spacesv. Art galleriesvi. Financial institutionsvii. Professional service firmsFor someone working in finance, this environment isextremely productive. It saves time, improves worklife balance, and creates constant networkingopportunities.It feels less like a “free zone” and more like a financialcapital within a city.Why DIFC Makes Sense for Indian Founders &ProfessionalsFor Indian entrepreneurs, fintech founders, and financeprofessionals, DIFC offers a powerful combination:i. Global credibilityii. Access to international marketsiii. Favorable tax regimeiv. Regulatory certaintyv. Strong India-UAE business connectsGULF InsightsContinued to page 810

Ahmedabad Chartered Accountant Journal December, 2025 805TM[I] Important Case Laws :[1] Issue:Adjudication order quashed as no personalhearing was given before adverse decision underGST laws: HCCase Law :Jagjit Enterprises (P) Ltd. v. State of U.P. [2025]180taxmann.com 86 (All.)Facts :The petitioner, registered under GST, filed a writto challenge an adjudication order passed withoutaffording any personal hearing. It was contendedthat no date for a personal hearing had been fixedprior to passing the adverse adjudication order,and that the statutory appeal filed against the orderwas dismissed as time-barred. The petitionersubmitted that a personal hearing must be affordedbefore any adverse assessment or adjudicationis passed, unless it is expressly waived or notavailed. The matter was accordingly placed beforethe High Court.Held :The High Court held that the impugned adjudicationorder and the consequential appellate order couldnot be sustained as no date for a personal hearinghad been fixed, amounting to a denial of a statutoryopportunity. The Court observed that statutoryprovisions under Section 73, read with Section75 of the CGST Act, mandate a personal hearingprior to any adverse decision. Accordingly, bothorders were quashed, and the matter was remittedto the assessing authority to pass a freshadjudication order after providing the petitionerwith a proper opportunity for a personal hearing.CA. Vishrut R. [email protected]. Bihari B. [email protected] and VAT Judgmentsand Updates[2] Issue:HC quashes order rejecting rectificationapplication as no personal hearing was providedto assesseeCase Law :Aries Interior v. State Tax Officer [2025] 180taxmann.com 6 (Mad.)Facts :The petitioner, filed a rectification applicationagainst a demand order for the period 2020-2021.The jurisdictional officer under GST rejected therectification application, holding that there was noerror apparent on the face of the record to rectifyany defects in the demand order. It was contendedthat the rejection merely copied the statutoryprovision without giving a personal hearing orchecking for any error. It was submitted that thethird proviso to Section 161 of the CGST Act doesnot remove the need for a hearing in party-initiatedapplications. The matter was accordingly placedbefore the High Court.Held :The High Court held that the impugned order waslegally unsustainable as the existence of any errorapparent under Section 161 had to be determinedafter affording the petitioner a personal hearing.The Court clarified that rejection of the rectificationapplication without hearing contravened theprinciples of natural justice. Consequently, theimpugned order was set aside, and the petitionerwas directed to file a reply to be treated as anaddendum to the show cause notice, with de novoproceedings to be conducted by the jurisdictionalofficer under GST, requiring the petitioner’s full cooperation.

806 Ahmedabad Chartered Accountant Journal December, 2025TMGST and VAT - Judgements and Updates[3] Issue:Assessment order quashed as DRC-01 noticeuploaded only on portal went unnoticed; matterremanded for fresh adjudication: HCCase Law:VST and Sons v. Asst. Commissioner, Chennai[2025] 180 taxmann.com 167 (Mad.)Facts:The petitioner challenged the assessment orderissued under Form GST DRC-07 for the periodApril 2020 to March 2021, contending that thepreceding show cause notice in Form DRC-01 hadbeen uploaded solely on the GST portal and hadgone unnoticed. In support, an electronic creditledger (ECL) extract was submitted, indicatingrecovery of the disputed tax and it was arguedthat no proper personal service or opportunity ofhearing had been provided. The petitioner prayedfor the assessment order to be linked with DRC01 and an opportunity to submit a reply. The matterwas accordingly placed before the High Court.Held:The High Court held that uploading the DRC-01notice solely on the portal, without personalservice, amounted to a denial of a reasonableopportunity to be heard. The Court directed thatthe electronic credit ledger entries to be verifiedwhether they corresponded to the tax confirmedby the impugned order. If not, the petitioner wasrequired to deposit 25% of the disputed tax incash. The Court further directed that theassessment order be treated as an addendum tothe DRC-01 notice, and the petitioner be allowedto file a detailed reply. The matter was remitted tothe jurisdictional officer for fresh adjudication.[4] Issue:Interest liability u/s. 50 not attracted from tax depositdate to GSTR-3B filing s liability discharged bydeposit: HCCase Law:Symphony Ltd. v. Union of India [2025]180taxmann.com 298 (Guj.)Facts:Symphony Ltd., a GST-registered assessee withmultiple registrations, deposited tax amounts bygenerating DRC-03 (credited to its electronic cashledger) on 19.09.2017, but filed the correspondingGSTR-3B returns much later. The tax departmentnevertheless computed interest up to the date ofreturn filing and issued communicationsthreatening recovery under Section 79. Theassessee challenged demands for interest on theground that the tax had been paid (credited toGovernment account) on the deposit date and thatany subsequent debit from the cash ledger atreturn-filing was a mere accounting adjustment.Held:The Gujarat High Court allowed the writ petitionsand quashed the impugned recoverycommunications. The Court held that an undisputeddeposit credited to the Government/ exchequervia the electronic cash-ledger (DRC-03) constitutesan advance payment appropriated to theGovernment, and the assessee’s tax liabilitystands discharged from the date of such deposit.A later debit entry at the time of filing GSTR-3B isonly an accounting adjustment; interest underSection 50 cannot be charged for the intervalbetween deposit and return filing.The Court relied on the scheme of Sections 39, 49,50,79 and Rule 88B, and followed precedents(notably Arya Cotton Industries), concluding thatrecovery of interest for the period after deposit wasunsustainable. The communications were quashed.[5] Issue:Detention of goods quashed as penalty noticenot issued within statutory period under sec,129(3): HCCase Law:Khatu Enterprises v. State of Gujarat[2025] 180taxmann.com 247 (Guj.)Facts:The petitioner, a GST-registered trader of brassscrap, was transporting goods with all valid

Ahmedabad Chartered Accountant Journal December, 2025 807TMdocuments. The vehicle was stopped on 3 May2025 and physical verification showed nodiscrepancy. Despite this, the departmentdetained the goods on 6 May 2025.However, nopenalty notice and no penalty order were issuedwithin the mandatory time limit prescribed underSection 129(3). Nearly three months later, thedepartment initiated confiscation proceedings,explaining the delay by citing transfer of officers.The petitioner challenged the continued detentionas illegal.Held:The High Court held that the department’s failureto issue a notice and pass an order within thestrict timelines of Section 129(3) rendered thedetention itself illegal. The subsequent confiscationaction could not cure this defect. Therefore, thedetention was quashed and the authorities weredirected to immediately release the goods andvehicle.However, the Court clarified that freshconfiscation proceedings under Section 130 maycontinue independently, provided the petitionerfiles a reply and undertakes to pay the fine if anadverse order is eventually passed.[6] Issue:If the supplier’s registration was valid at the timeof purchase and transactions were duly supportedby e-way bills and bank payments, ITC cannot bedenied merely because the supplier’s registrationwas subsequently cancelled. Authorities mustverify the supplier’s existence and validity at thetime of the transaction, not retrospectively.Case Law:Singhal Iron Traders v. Additional Commissioner[2025] 180taxmann.com 163 (Allahabad)Facts:The petitioner is a proprietorship firm engaged inthe trading and supply of all kinds of iron scrap,etc. The petitioner purchased iron scrap from theregistered dealer against tax invoices and two eway bills, the said payment was made to thesupplier through banking channels. The supplier/seller also filed his GSTR-1 and GSTR-3B for therelevant period on time on the GST Portal.Proceedings against the petitioner were initiatedunder section 74 of the GST Act, 2017, and a showcause notice was issued to the petitionerdemanding ITC and a penalty, as the supplier’sregistration had been cancelled and no businessactivity had been undertaken. The petitioner filedhis detailed reply, annexing all the documentaryevidence, stating that he had validly claimed theITC, but that, without considering the same, theorder in GST DRC-07 was passed.Held:The Hon’ble Court noted that the registration ofthe supplier was cancelled after the transactionsin question. The Court observed that the supplierfiled its return in the forms of GSTR-01 and GSTR3B after payment of taxes. The Court held that oncethe supplier (sic) paid the tax in the forms of GSTR01 and GSTR-3B, no adverse inference can bedrawn against the petitioner on the premise thatthe dealer’s registration, from whom the purchaseswere shown to be made,was subsequentlycancelled. The Hon’ble Court also observed thatpurchases were made by the petitioner, for whichdue e-way bills were generated and the paymentswere shown to be made through bankingchannels, and that it is also not the case of therevenue that the vehicle used for transportationwas not found registered.The Hon’ble Court further held that it was the dutyof the authorities to verify the said information asto whether at the time of transactions, the firm wasin existence or not and therefore, without verifyingthe same, the authorities ought not to have initiatedthe proceedings against the petitioner only on theborrowed information as the petitioner dischargedits preliminary duty by making the payment of duetaxes through banking channels.Accordingly, the orders demanding ITC reversaland equal penalty were held unsustainable andquashed.(SOURCES: CORPORATE PROFESSIONAL TODAY)GST and VAT - Judgements and Updates

808 Ahmedabad Chartered Accountant Journal December, 2025TMSupply of Aerated Beverages in Hotel Restauranttreated as composite supply of Restaurant ServiceTaxable at 18%: West Bengal AAR - The Case of M/s.Summit Hotels & Resorts Private LimitedAdvance Ruling No. 20/WBAAR/2025–26 dated10.12.2025 In the case of M/s. Summit Hotels & ResortsPrivate LimitedBrief Facts: -- M/s. Summit Hotels & Resorts Private Limited (“theApplicant”) is engaged in the business of owningand operating hotels and resorts in the State of WestBengal and is registered under the Goods andServices Tax law bearing GSTIN19AAXCS7643D1ZP. The Applicant operates a 3-star rated hotel providing a wide range of hospitalityservices, including accommodation, banqueting,restaurant services, dining, spa facilities and roomservices.- The hotel restaurant caters to both resident guestsand walk-in customers and operates as a fullservice restaurant within the hotel premises. Therestaurant does not maintain any separate takeawaycounter or over-the-counter retail outlet for the saleof beverages. The menu of the restaurant includesvarious food items as well as aerated beveragesand soft drinks, which may be ordered either alongwith food or independently without ordering anyfood.- Historically, the Applicant treated aerated beveragesas independent supplies of goods and dischargedGST at the rate of 28% along with applicableCompensation Cess, as prescribed for aeratedwaters under Notification No. 01/2017–Central Tax(Rate). At the same time, restaurant services wereclassified under SAC 996331 and taxed at 18%.This differential tax treatment led to repeatedCA. Monish S. [email protected] from customers, who contended thataerated beverages supplied within a restaurantshould also be taxed at 18%, being an integral partof restaurant service.- The Applicant asserted that even where aeratedbeverages are supplied independently, thetransaction involves substantial service elementssuch as preparation, serving, ambience, use ofinfrastructure and staff involvement. On this basis,the Applicant contended that such supplies constitutea composite supply of restaurant service.Accordingly, an application was filed under Section97(1) of the CGST Act, 2017 before the West BengalAuthority for Advance Ruling seeking clarity on theapplicable rate of GST.Questions: -Based on the facts and circumstances submitted, theApplicant has sought advance ruling on the followingkey question;- The Applicant sought advance ruling on the followingquestions:- What is the applicable rate of GST on supply ofcarbonated drinks (aerated beverages) whensupplied independently in a restaurant and notalong with food?- What is the applicable rate of GST on supply ofcarbonated drinks (aerated beverages) whensupplied along with food as part of a compositesupply in a restaurant?Findings & Arguments: –- The Applicant contended that patrons visit arestaurant not merely for the purchase of food orbeverages, but to avail a comprehensive diningexperience comprising ambience, seatingarrangements, cutlery and glassware, waiter

Ahmedabad Chartered Accountant Journal December, 2025 809TMservice, preparation and presentation of items, andpost-consumption services such as cleaning.According to the Applicant, the true essence of thetransaction lies in the provision of restaurant service,and not in the standalone sale of goods.- With specific reference to aerated beverages, theApplicant submitted that such beverages are neversold over the counter in sealed bottles or cans.Instead, they are invariably opened by restaurantstaff, poured into glassware, and frequentlycustomised with ice, lemon, masala, or sugar syrup.In several instances, aerated beverages serve asinputs for value-added drinks such as Masala Cokeor Fresh Lime Soda. These prepared beveragesare then served at the table by wait staff or deliveredthrough room service. The Applicant emphasizedthat such supplies are inseparably linked withservice elements including preparation,customisation, use of restaurant infrastructure andambience, presentation, waiter service, and postservice activities, thereby negating anycharacterization as an independent supply ofgoods.- In support of its submissions, the Applicant reliedupon Section 2(30) of the CGST Act definingcomposite supply, Section 8 governing tax liabilityon composite supplies, and Clause 6(b) ofSchedule II, which deems the supply of food ordrinks by way of or as part of any service to be asupply of service. Reliance was also placed onNotification No. 11/2017–Central Tax (Rate), CircularNo. 164/20/2021-GST, and various judicialprecedents including MFAR Hotels & Resorts Pvt.Ltd. (Tamil Nadu AAR), Kundan Misthan Bhandar(Uttarakhand AAAR), and Gangaur Sweets(Rajasthan AAR). On this basis, the Applicant arguedthat aerated beverages supplied within a restaurantconstitute part of restaurant service and are taxableat 18% GST.- The Authority observed that the Applicant’s hotelqualifies as a “specified premises” for the relevantfinancial year and that, accordingly, restaurantservices are taxable at 18% with input tax creditunder Serial No. 7(vi) of Notification No. 11/2017–Central Tax (Rate). The Authority examined thecommonly understood meaning of a restaurant, thestatutory definition of restaurant service, and thenature of aerated beverages as carbonated drinks.- It was noted that the Applicant operates a fullservice restaurant within the hotel premises, whereaerated beverages are listed on the menu andprepared by restaurant staff. These beverages arenot sold in sealed condition as retail goods but areprepared through mixing, garnishing, and servingusing restaurant infrastructure, with consumptionrestricted to the restaurant premises or through roomservice.- Placing significant reliance on Clause 6(b) ofSchedule II to the CGST Act, the Authority held thatthe supply of food or drinks (other than alcoholicliquor for human consumption), when provided byway of or as part of any service, is to be treated asa supply of service. The Authority concluded thatthe supply of aerated beverages, whether alongwith food or independently, is naturally bundled withrestaurant service, with the restaurant service beingthe principal supply. Accordingly, such transactionsqualify as a composite supply of service.- The Authority further clarified that the manner of billingor the fact that aerated beverages may be orderedseparately does not alter the essential nature ofthe supply, as the service element remainsdominant and inseparable in all cases.Ruling: -- Supply of Aerated Beverages Independently inRestaurant Where aerated beverages are suppliedindependently (without food) within the restaurantpremises, under the factual matrix presented, thesupply constitutes a composite supply of service,with restaurant service as the principal supply.Accordingly, GST shall be levied at 9% CGST +9% SGST under Serial No. 7(vi) of Notification No.11/2017–CT (Rate).- Supply of Aerated Beverages Along with Foodwhere aerated beverages are supplied along withfood, the transaction equally constitutes a compositesupply of restaurant service, taxable at 9% CGST+ 9% SGST.Advance Ruling under GST

810 Ahmedabad Chartered Accountant Journal December, 2025TMComments: –- This ruling provides much-needed clarity on thelong-debated issue relating to the taxability ofaerated beverages supplied in hotel restaurants.The Authority has rightly adopted a substance-overform approach by focusing on the true nature of thetransaction rather than the manner of billing orsegregation in invoices.- A key takeaway from this ruling is that the absenceof over-the-counter sales and the involvement ofpreparation and service are decisive factors indetermining whether a supply qualifies as acomposite supply of restaurant service. The rulingaligns with earlier advance rulings and appellaterulings, including MFAR Hotels, Kundan MisthanBhandar and Gangaur Sweets, thereby reinforcinga consistent interpretational trend.- For hotels and restaurants operating from specifiedpremises, this ruling confirms that aeratedAdvance Ruling under GSTbeverages served within dining facilities should betaxed as restaurant services rather than asindependent supplies of goods. Businesses areadvised to review their billing systems, taxpositions, and rate applications, as charging GSTat 28% on aerated beverages in similar factualsituations may lead to excess tax collection andpotential customer disputes.- Overall, the ruling strengthens the jurisprudence thatrestaurant dining is an experience-driven service,in which food and beverages are integral andinseparable components of a composite supply ofservice.Continued from page 804From a Chartered Accountant’s perspective, DIFC alsoallows structured growth, clean compliance, and longterm scalability - something serious businesses valuedeeply.DIFC now among world’s top five hedge funds hubsaccording to the GULF News of December 16, 2025 &joined ranks of the world’s leading hedge funddestinations after surpassing 100 registered managers.“Becoming a leading hedge funds centre reflects thematurity of the DIFC Platform as well as the confidenceof its participants,” said Arif Amiri, Chief ExecutiveOfficer of DIFC AuthorityClosing ThoughtsDIFC is not just about tax benefits or location, it is abouttrust, structure, and vision.Dubai’s leadership has created an ecosystem wherebusinesses feel welcomed, protected, andencouraged to grow. And DIFC stands as one of thestrongest symbols of that mindset.After visiting Dubai and DIFC personally, interactingwith professionals on the ground, and seeing theecosystem up close, I can confidently say:DIFC is not the future of global finance - it is alreadythe present.GULF Insights

Ahmedabad Chartered Accountant Journal December, 2025 811TMAI And Automation as The New Frontier forChartered AccountantsArtificial intelligence and automation are changing thefield of accountancy. Tedious tasks are now managedby machines. Data is processed and sorted instantly.Clients increasingly expect faster, more accurateresults. Chartered Accountants need to keep pace orrisk falling behind.AI is no longer a distant concept. Firms use such toolsfor audits, tax filings, and compliance reviews. Smalland large practices report fewer errors and reducedhours. Professional bodies promote adoption ofresponsible AI. The market for AI in accounting growsat more than 30 percent annually and growth remainsstrong.Every Chartered Accountant needs a workingunderstanding of these technologies. This articlepresents practical guidance. The focus is on where AIworks best, which risks require attention, and howprofessionals add value as experts leading theprofession.Key Areas Where AI and Automation Deliver ValueThere is no need to guess where AI helps most. Valueflows through clear channels. Priority areas include:1. Audit and Assurance- AI agents scan large sets of transactionsinstantly. No sample-based testing needed.- Errors and anomalies appear as clear alerts.- Manual effort reduces, time shifts toward riskassessment and insights for clients improve.- Internal and external audits move from periodicspot-checks to ongoing, real-time monitoring.2. Compliance and Regulation- Rules and laws change fast and often withoutlong transition periods.CA. Hency [email protected] Avenues forChartered Accountants- Automation tools scan client ledgers and crosscheck with regulatory updates.- Gaps or discrepancies surface quickly.- Compliance reports are filed with less effortand higher accuracy.- Penalty risks drop sharply due to quickerresponse.3. Fraud Detection- Algorithms analyse all entries, not samples.- Unusual patterns trigger further review.- Fraud is found sooner.- Client protection improves and confidence infinancial reporting grows.4. Document Processing- OCR and natural language tools extract datafrom invoices and contracts.- Files are indexed and searchable for futurereviews.- Time spent tracking documents reducessignificantly.5. Predictive Analytics- AI tools forecast cash flows and identify riskfactors.- Decision-makers receive real-time, data-basedrecommendations.6. Tax and Statutory Workflows- Automated systems prepare returns byextracting and sorting data from multiplesources.- Tax research tools retrieve regulatory guidanceinstantly.- Accuracy in filings and research is higher,freeing up for advising clients directly.

812 Ahmedabad Chartered Accountant Journal December, 2025TMPractical Case ExamplesPractical effects are visible across typical services:Area Example in PracticeAudit AI engine checks full data sets forsuspicious entries in minutes, notweeks.Tax Preparation AI systems extract totals frominvoices, classify as per GST/Income Tax and attach to returns.Compliance Automated platform scans newTracking government updates, flags clientnon-compliance, generates alertsand draft emails.Fraud Detection Machine learning tool flagsduplicate payments and off-trendentries for manual review.Document NLP-based solution creates auditManagement ready summaries from leaseagreements and board minutesinstantly.Workflow: How Automation Streamlines theAccounting CycleAutomation turns the accounting cycle into a structured,repeatable flow. Manual touch points reduce andprofessional focus shifts to review and judgment.1. Data ImportBank feeds and invoice data flow directly into thesystem through integrations and standardizedformats. This removes most manual data entry andreduces input errors.2. ClassificationMachine learning models tag each transaction withaccounts, tax codes, and cost centers based onhistorical entries and defined rules. Humanintervention is needed only when the system isuncertain.3. ReconciliationSoftware automatically matches ledger entries withbank statements and subledgers. Only mismatchesand exceptions appear in the review queue.4. AnalyticsDashboards show trends in revenue, costs, cashflow, and ageing. Outliers and anomalies arehighlighted so attention moves to material issues.5. Compliance ChecksRules engines and updated regulatory content testdata against statutory requirements. Potentialbreaches and missed filings are flagged beforedeadlines.6. Review And Sign-OffExceptions are reviewed, judgments refined, andcommentary added. Once satisfied, professionalsapprove outputs such as financial statements, auditworking papers or returns.Leading Tools in Current UseTool selection depends on client base, transactionvolume and compliance needs. Key platforms include:- QuickBooksStrong for SMEs, with automated bank feeds,transaction categorization and basic forecasting.Well suited for outsourced bookkeeping and VCbacked startups.- SageUseful for firms handling complex entities and multilocation operations. Automation supports tax,reporting, and consolidation workflows.- Zoho BooksGood fit for digital-first firms and Indian CAs.Supports GST, recurring billing, client portals, andintegrations with the broader Zoho suite.AI And Automation as The New Frontier for Chartered Accountants

Ahmedabad Chartered Accountant Journal December, 2025 813TM- Advisory ServicesAnalytics are translated into decisions on pricing,funding, tax positions, and restructuring. Trade-offsare explained and rationale documented.- Strategic PlanningDecisions are taken on which processes toautomate first, which tools to adopt, and whichcontrols to implement. Workflows are aligned withstandards and engagement terms.- Risk ManagementFlagged entries and exceptions are reviewed,thresholds set, and rules refined. Decisions aretaken on when to override systems or escalateissues.- Client RelationshipDashboards are interpreted for boards and owners,and communication is tailored to theirunderstanding. Coordination occurs across finance,tax, legal, and operations.- Continuous LearningPractitioners stay current on tools, data regulations,and standards. Teams are trained on new workflows,with emphasis on documentation and review culture.Risks and ChallengesAutomation reduces some risks while introducing newones. Structured governance is essential.- Data QualityPoor source data creates incorrect outputs at scale.Controls at points of data capture and regular reviewof key assumptions remain essential.- SecurityCloud tools and integrations increase exposure tocyber risks. Collaboration with IT is required foraccess controls, encryption, monitoring, andincident response.- Regulatory ChangeFrequent changes in tax and regulatory normsrequire updated logic in tools. Engagementplanning and documentation must reflect currentrequirements.- FreshBooksWorks well for service businesses with time trackingand project billing. Automation covers expensecoding and recurring invoices.- BlackLineDesigned for medium and large entities that needcontinuous reconciliation and strong controls. Helpsshorten closing cycles and supports audit readiness.- KPMG ClaraAudit platform that ingests client data, runs analytics,and structures evidence. Enhances samplingstrategies, risk assessment and documentationquality.- Deloitte AI SuiteFocuses on anomaly detection, fraud patterns, andadvanced analytics across large datasets.- Trullion and Ask Blue JTrullion automates document reading, leaseaccounting, and audit tie-ups. Ask Blue J supportstax research and scenario analysis with generativeAI.Changing Client ExpectationsClients no longer ask how books are processed. Theywant to know to prevent errors, avoid penalties, anddeliver insights that lead to improved outcomes.Automation tools provide:- Faster closes and quicker reports are viewed asstandard practice. Turnaround time has become acompetitive differentiator.- Early warnings on compliance and tax issues areexpected, instead of last-minute corrections.- Recommendations are expected to connectnumbers with clear business decisions.- Stakeholders prefer a single version of financial data,shared across management, lenders, and investors.Automation supports these expectations. Role shiftstoward explaining scenarios, guiding plans andcoordinating with other advisers.Skills: What Chartered Accountants Add in the Ageof AIProfessional expertise remains central. The mix of taskschanges more than the overall importance of the role.AI And Automation as The New Frontier for Chartered Accountants

814 Ahmedabad Chartered Accountant Journal December, 2025TM- Human OversightFalse positives, missed anomalies, or biasedmodels can occur. High-risk areas need review andprofessional skepticism remains essential.- Ethical UseClients should know where AI is used, who hasaccess to data, and retention practices.Responsibility for opinions and reports continuesto rest with professional signatories.Building an Automation Strategy for a FirmA structured roadmap reduces waste and failed pilots.1. Identify repetitive and manual tasksPrepare a simple inventory of tasks that involvedata entry, matching and routine checks. Includereconciliation, bank posting, invoice capture, andstandard reporting.2. Assess current tool adoptionReview the use of Tally, Zoho, QuickBooks, Excel,and practice management tools. Note featuresalready available but unused.3. Prioritize upgradesSelect two or three workflows with high volumeand low judgment for the first wave. For example,bank reconciliation, GST return preparation, orvendor invoice posting.4. Train staffOffer short, focused sessions: new workflow,controls, escalation paths, and documentationstandards. Assign champions for each tool.5. Monitor resultsTrack metrics such as hours spent, rework,exceptions, filing timeliness, and client feedback.Compare results before and after automation.6. IterateExpand automation to more complex areas oncethe first set stabilizes. Adjust policies andtemplates based on lessons from early projects.Real-World Impact in Indian Firmspeers have begun the transformation. Leadingexamples include:- Audit teams using tools like Trullion cut manualdocument review time by about half. Compliancechecks that took days now finish in hours.- Platforms designed for SMEs, such as Bharat PlusAI, support regional languages and common Indianworkflows. This reduces onboarding friction forsmaller clients and improves data consistency.- ICAI initiatives such as CA GPT signal institutionalsupport for AI adoption. These initiatives givemembers structured exposure to tools and usecases.ICAI Embraces Artificial Intelligence with Launch of CAGPT The Path Forward for Chartered AccountantsAI and automation offer substantial opportunity for theprofession. Repetitive tasks are automated, manual errorreduces, and more time becomes available for strategicanalysis. Clients receive faster, more reliable, and moresecure services, and the advisory role expands.Key actions include:- Automate repetitive tasks wherever tool quality, dataquality, and controls are acceptable.- Learn how to configure rules, train relevant models,and review outputs in a disciplined way.- Focus on tailored insights rather than generic reports.- Stay informed about new products, data rules,security requirements and professional guidance.- Position the Chartered Accountant as designer,supervisor and explainer of automated financesystems.With disciplined adoption and clear professionaljudgment, control of the process rests with the CharteredAccountant and value delivered to clients increases.AI And Automation as The New Frontier for Chartered Accountants

Ahmedabad Chartered Accountant Journal December, 2025 815TMIND AS InsightsCase ScenarioA Ltd. became a listed entity and required to prepareits financial statements as per the Companies (IndianAccounting Standards) Rules, 2015 from 01st April, 2025.It has various subsidiaries, associates and jointventures.(a) During the financial year 2024-25, A Ltd. had soldoff its entire investment in X Ltd. (subsidiary) on31st December 2024. Therefore, X Ltd. is no longera subsidiary of A Ltd. for the purposes ofpreparation of financial statements as on 31st March2025. Should X Ltd. prepare its financialstatements as per the Companies (AccountingStandards) Rules, 2006 or the Companies (IndianAccounting Standards) Rules, 2015?(b) During the financial year 2025-26, A Ltd. had soldoff its investment in Z Ltd. (subsidiary) on 31stDecember 2025.Therefore Z Ltd. is no longer asubsidiary of A Ltd. for the purposes of preparationof financial statements as on 31st March 2026.Should Z Ltd. prepare its financial statements asper the Companies (Accounting Standards) Rules,2006 or the Companies (Indian AccountingStandards) Rules, 2015?(c) During the financial year 2025-26, A Ltd.incorporated an LLP with B Ltd. namely, A&B LLP.Should A&B LLP prepare its financial statementsas per the Accounting Standards issued by ICAIor the Companies (Indian Accounting Standards)Rules, 2015?(d) During the financial year 2025-26, A Ltd.incorporated a Real Estate Investment Trust (REIT)with C Ltd. namely, A&CREIT. Should A&CREITprepare its financial statements as per theAccounting Standards issued by ICAI or theCompanies (Indian Accounting Standards) Rules,2015?(e) For CSR obligations, A Ltd. has invested inCompany D, an associate company of A Ltd.Company D is a charitable organization andregistered under Section 8 of the Companies Act,2013.Should Company D prepare its financialstatements as per the Companies (AccountingStandards) Rules, 2006 or the Companies (IndianAccounting Standards) Rules, 2015?(f) A Ltd. had invested 26% in E Ltd. in the past andaccounted E Ltd. as an associate under theCompanies (Accounting Standards) Rule, 2006.FLtd. owns share warrants of E Ltd. that areconvertible into equity shares of E Ltd. that havepotential, if exercised, to give additional votingpower to F Ltd. over the financial and operatingpolicies of E Ltd. E Ltd. and F Ltd. as a standaloneentity do not meet any criteria given in Ind ASroadmap. Whether E Ltd. is required to complywith Ind AS?Response[1] Rule 4(1)(ii)(c) of the Companies (Indian AccountingStandards) Rules, 2015, states as under:(4) (1) The Companies and their auditors shallcomply with the Indian AccountingStandards (Ind AS) specified in Annexureto these rules in the preparation of theirfinancial statements and auditrespectively, in the following manner,namely:-CA. Niket [email protected]

816 Ahmedabad Chartered Accountant Journal December, 2025TM(ii) the following companies shall complywith the Indian Accounting Standards(Ind AS) for the accounting periodsbeginning on or after1st April, 2016,with the comparatives for the periodsending on 31st March, 2016, orthereafter, namely:-(a) companies whose equity or debtsecurities are listed or are in theprocess of being listed on anystock exchange in India oroutside India and having networth of rupees five hundredcrore or more;(b) companies other than thosecovered by sub-clause (a) ofclause (ii) of sub-rule(1) andhaving net worth of rupees fivehundred crore or more;(c) holding, subsidiary, joint ventureor associate companies ofcompanies covered by subclause (a) of clause (ii) of subrule (1) and sub-clause (b) ofclause (ii) of sub- rule (1) as thecase may be;Rule (9) of the Companies (Indian AccountingStandards) Rules, 2015, states that:“Once a company starts following the IndianAccounting Standards (Ind AS) eithervoluntarily or mandatorily on the basis ofcriteria specified in sub-rule (1), it shall berequired to follow the Indian AccountingStandards (Ind AS) for all the subsequentfinancial statements even if any of the criteriaspecified in this rule does not subsequentlyapply to it”.In view of the above requirements,accordingly, the Companies (IndianAccounting Standards) Rules, 2015, willInd AS Insightsbecome applicable to A Ltd. on mandatorybasis from the accounting periodcommencing from 1st April, 2025.As per the Rule 4(1)(ii)(c) of the Companies(Indian Accounting Standards) Rules, 2015, aholding, subsidiary, joint venture or associatecompany of A Ltd. to which the Companies(Indian Accounting Standards) Rules, 2015applies will be required to follow theCompanies (Indian Accounting Standards)Rules, 2015 for preparing and presenting itsfinancial statements.[2] The applicability of Ind AS has been specifiedfor classes of companies specified in Rule 4 ofCompanies (Indian Accounting Standards) Rules,2015. Indian Accounting Standards notified underthe Companies (Indian Accounting Standards)Rules, 2015, are applicable for the corporatesonly. Non- corporates are required to follow theaccounting standards issued by the Institute ofChartered Accountants of India. They cannot beapplied by non-corporate entities evenvoluntarily.However, in case, a relevant regulator specificallyprovides for implementation of Ind AS, the noncorporate entities shall apply Ind AS, for example,SEBI has mandated implementation of Ind AS forInfrastructure Investment Trusts (InvITs) and RealEstate Investment Trusts (REITs). Similarly, ifCentral Government notifies certain bodycorporate under clause (1)(4)(f) of Companies Act,2013, such entities will be required to apply IndAS. For other non-company entities, AccountingStandards issued by the ICAI shall be applicableand there will be no option to follow Ind AS tosuch entities.[3] Sub-rule (2) of Rule 2 of the Companies (IndianAccounting Standards) Rules, 2015, provides asfollows:“Words and expressions used herein and notdefined in these rules but defined in the Act shall

Ahmedabad Chartered Accountant Journal December, 2025 817TMhave the same meaning respectively assigned tothem in the Act”.The term ‘associate’ has been defined in Ind AS28 which is notified as the part of the Companies(Indian Accounting Standards) Rules, 2015.As per paragraph 3 of Ind AS 28, Investments inAssociates and Joint Ventures, an associate isan entity over which the investor has significantinfluence.Ind AS 28 defines ‘Significant influence’ as thepower to participate in the financial and operatingpolicy decisions of the investee but is not controlor joint control of those policies.Paragraph 5 of Ind AS 28, states as follows:“5. If an entity holds, directly or indirectly (e.g.through subsidiaries), 20 per cent or more ofthe voting power of the investee, it ispresumed that the entity has significantinfluence, unless it can be clearlydemonstrated that this is not the case.Conversely, if the entity holds, directly orindirectly (e.g. through subsidiaries), less than20 per cent of the voting power of theinvestee, it is presumed that the entity doesnot have significant influence, unless suchinfluence can be clearly demonstrated. Asubstantial or majority ownership by anotherinvestor does not necessarily preclude anentity from having significant influence.”Paragraph 7 of Ind AS 28 provide as follows:“7. An entity may own share warrants, share calloptions, debt or equity instruments that areconvertible into ordinary shares, or other similarinstruments that have the potential, if exercisedor converted, to give the entity additional votingpower or to reduce another party’s voting powerover the financial and operating policies ofanother entity (i.e. potential voting rights). Theexistence and effect of potential voting rightsthat are currently exercisable or convertible,including potential voting rights held by otherentities, are considered when assessingwhether an entity has significant influence.Potential voting rights are not currentlyexercisable or convertible when, for example,they cannot be exercised or converted until afuture date or until the occurrence of a futureevent.”As per Notification G.S.R 680(E) dated 4thSeptember 2015, issued by the Ministry ofCorporate Affairs (MCA), after rule 4 ofCompanies (Accounts) Rules, 2014, thefollowing rule has been inserted:“4A. Forms and items contained in financialstatements –The financial statements shall be in theform specified in Schedule III to the Actand comply with Accounting Standards orIndian Accounting Standards asapplicable:Provided that the items contained in thefinancial statements shall be prepared inaccordance with the definitions and otherrequirements specified in the AccountingStandards or the Indian AccountingStandards, as the case may be.”[4] In view of the above, the response to each casescenario is as follows:(a) A Ltd. has sold its investment in subsidiary XLtd. on 31st December, 2024, in consequenceof which X Ltd. is no longer subsidiary of ALtd. as at the beginning of 1st April, 2025.Therefore, the Companies (Indian AccountingStandards) Rules, 2015 will not be applicableto X Ltd. Therefore, X Ltd. would continue toprepare financial statements for accountingperiods commencing April 1, 2025 under theCompanies (Accounting Standards) Rules,2006.Ind AS Insights

818 Ahmedabad Chartered Accountant Journal December, 2025TM(b) In the given case, A Ltd. has sold its investmentin subsidiary Z Ltd. on 31st December, 2025.Therefore, Z Ltd. was a subsidiary of A Ltd.as at the beginning of 1st April, 2025. Z Ltd.being a subsidiary of A Ltd. as at the beginningof 1st April, 2025, would have to preparefinancial statements for the accounting periodscommencing 1st April, 2025 as per theCompanies (Indian Accounting Standards)Rules, 2015.(c) In the given case, Ind AS is not applicable topartnership firms, which includes LLP.However, for the purpose of consolidation,A&B LLP will be required to provide financialstatements data prepared as per Ind AS to ALtd. provided A&B LLP qualifies as asubsidiary/joint venture/associate of A Ltd.(d) In the given case, Ind AS is will be applicableto A&C REIT, even if being a non-corporateentity, since mandated by SEBI.Accordingly,A&C REITshould prepare itsfinancial statements as per the Companies(Indian Accounting Standards) Rules, 2015.(e) It may be noted that holding, subsidiary, jointventure, associate companies of companiesfalling under any of the thresholds specifiedin Rule 4(1)(ii) are required to comply withInd AS. Further, it may be noted that thecompanies covered under Section 8 arerequired to comply with the provisions of theCompanies Act, 2013, unless and until anyexemption is provided. Hence, Section 8companies are not exempted from therequirements of section 133 and section 129of the Companies Act, 2013. In view of theabove, in the given case, Company D will berequired to prepare its financial statementsas per the Companies (Indian AccountingStandards) Rules, 2015.(f) In the present case, by applying the relevantrequirements of Ind AS 28, it has beenconcluded that E Ltd. is an associatecompany of F Ltd. since F Ltd. has potentialvoting rights over E Ltd. In the givenscenario, in accordance with Ind AS, E Ltd.also ceases to be an associate of A Ltd.Therefore, E Ltd. need not to comply withInd AS though the company was anassociate company of A Ltd. under previousreporting framework.If F Ltd. voluntarilycomplies with Ind AS or meets any specifiedcriteria on standalone basis, then E Ltd.being its associate company as per Ind AS28 shall comply Ind AS from the samefinancial year from which F Ltd. startspreparing financial statements as per Ind AS.Ind AS Insights

Ahmedabad Chartered Accountant Journal December, 2025 819TMMCA Updates:1. The Companies (Meetings of Board and itsPowers) Amendment Rules, 2025:Vide these amendment rules, Rule 11(2) of theCompanies (Meetings of Board and its Powers)Rules, 2014 has been amended:‘(2) For the purposes of clause (a) of sub-section(11) of section 186 of the Act, the expression“business of financing industrial enterprises”shall include 6i. with regard to a Non-Banking FinancialCompany registered with the Reserve Bankof India, “business of giving of any loan to aperson or providing any guaranty or securityfor due repayment of any loan availed by anyperson in the ordinary course of its business”;andii. with regard to a Finance Company registeredwith the International Financial ServicesCentres Authority, “activities as provided insub-clause (a), or sub-clause (e) of clause (ii)of sub-regulation (1) of regulation 5 of theInternational Financial Services CentresAuthority (Finance Company) Regulations,2021 in the ordinary course of its business”.’[F.No. 1/32/2013-CL-V-Partdated 03.11.2025]IFSC Updates:2. Requirement of Certification on AML/CFT forDesignated Director and Principal Officer underthe IFSCA (AML/CTF/KYC) Guidelines, 2022:In compliance of this circular, all DesignatedDirectors and Principal Officers appointed underthe AML/CFT/KYC Guidelines are now requiredto undergo the specialised certification titled”NISM-IFSCA-01: Certification Course on AntiMoney Laundering and Counter-Terrorist Financingin the IFSC” and the Certification must becompleted within 4 months from the date of thiscircular or from the date of their appointment assuch.[e.F. No.IFSCA-DAC/8/2024-AMLCFTdated17.11.2025]3. Disclosure requirement under Clause 39 of thecircular “Regulatory Framework for GlobalAccess in the IFSC”:Clause 39 of the IFSCA circular “RegulatoryFramework for Global Access in the IFSC” (dated12 August 2025) requires Global Access Providers(GAPs) and Introducing Brokers (IBs) to displaymandatory risk disclosures and disclaimers toclients at every login. In this regard, the Authorityhereby specifies the following key risks /disclaimers:- Market risk- Currency risk- Custody risk- Liquidity risk- Settlement risk- Technology & cyber risk- Product suitability risk- Legal & taxation risk- Remittance risk- Geopolitical risk[eF.No. IFSCA-DSI/12/2025-Capital Marketsdated26.11.2025]CA. Naveen [email protected]

820 Ahmedabad Chartered Accountant Journal December, 2025TMPMLA, the Insolvency Professional may file anapplication before the Special Court undersections 8(7) or 8(8) of the PMLA for restitution ofsuch assets.With a view to facilitate the expeditious disposalof such applications by the Special Courts, theInsolvency and Bankruptcy Board of India, inconsultation with the ED, has formulated a standardundertaking to be furnished by the InsolvencyProfessional along with the application forrestitution of assets.[Circular No. IBBI/CIRP/87/2025 dated04.11.2025]6. Strengthening due diligence under Section 29Areg.Section 29A of the Insolvency and BankruptcyCode, 2016 (Code) lays down the ineligibilitycriteria for resolution applicants. Due diligence withrespect to section 29A compliance is paramountas it safeguards the integrity of the process byensuring that only credible resolution applicantsparticipate in the process.Hence, Resolution Professionals (RPs) arehereby directed to place a detailed note on section29A compliance before the CoC when resolutionplans are considered and ensure that deliberationsand observations of the CoC are properlyrecorded in the minutes.[Circular No. IBBI/CIRP/88/2025 dated18.11.2025]4. Clarification on raising of Invoice by IFSCInsurance Offices:The IFSCA has clarified in respect of certainoperational constraints faced by them, on accountof raising of invoice in the currency of theunderlying contract of reinsurance, whiletransacting through the IFSC Banking Units (IBUs).“An IIO transacting re-insurance business may raiseinvoice on Indian insurer(s), foreign insurer(s), reinsurer(s) or cedant(s) as the case may be, in thecurrency of the underlying contract of reinsurance,including in INR:However, the realization of amount against suchinvoice, in the bank account of the IIO, maintainedwith any IBU shall be in the specified foreigncurrencies.Explanation. - For removal of doubt, it is herebyclarified that “Specified Foreign Currency” shallmean the currencies specified in the First Scheduleof the International Financial Services CentresAuthority (Banking) Regulations, 2020, as amendedfrom time to time.[eF.No. 103/IFSCA/Ins/CIRC/1/2021 dated27.11.2025]IBBI Updates:5. Undertaking by IPs before Special Courts underPMLA:In some cases, assets of the corporate debtorare under attachment by the EnforcementDirectorate (ED) under the provisions of thePrevention of Money Laundering Act, 2002(PMLA) and the restitution of such attached assetscan significantly enhance the value of theCorporate Debtor thereby leading to higherrealization. Hence, it is hereby advised that incases where assets of the corporate debtor areattached by the ED under the provisions underCorporate Law Update

Ahmedabad Chartered Accountant Journal December, 2025 821TMSocieties as RERA Promoters: Statutory Frameworkand Case Law AnalysisThe Real Estate (Regulation and Development) Act,2016 (“RERA”) casts a wide net to ensure accountabilityof all players in redevelopment projects. Section 2(zk)of RERA defines a “promoter” very broadly – coveringanyone who constructs or causes construction ofapartments or develops land for sale, housing financesocieties that build for members, and even any personacting under a power of attorney from the landowner.An explicit Explanation states that if one party buildsand another sells, both are deemed promoters andjointly liable under RERA. In short, anyone closelyconnected to causing the project for sale can be apromoter under RERA.RERA’s exhaustive scope was further clarified byregulators. Notably, Maharashtra’s RERA Authorityissued a circular (Circular No.12/2017) confirming thatlandowners or investors with area- or revenuesharing arrangements must be declared aspromoters at project registration. In other words, if asociety or individual owns land and is entitled (byagreement) to a share of the built-up area or salesproceeds, they “fall within the definition of ‘promoter’”and must be shown as such when registering theproject. This aligns with similar clarifications (e.g. byKarnataka RERA) that any landowner-inventor with ashare-right is mandatorily treated as a promoter.Conversely, a society that merely grantsredevelopment rights to a builder without a formalarea/revenue share or its own sales obligation maynot automatically be a promoter, absent anyregisteration or privity.In short, the RERA regime expects: (i) builders/developers who construct for sale are promoters; (ii)landowner-societies with explicit sharing deals or whothemselves sell units are promoters; (iii) any personclaiming to act under the owner’s power of attorney isa promoter. But courts have had to interpret these rulesin redevelopment disputes to protect genuinehomebuyers (allottees) while respecting societies’members. The following examines key judicialpronouncements addressing whether a housing societycan be a promoter under RERA.Statutory Definition: Who Is a “Promoter” UnderRERA?Under RERA, a “promoter” includes (i) anyone whoconstructs or causes construction of a building orconverts existing building into sellable flats; (ii) anyonewho develops land (plots) for sale; (iii) certain publicbodies developing housing; (iv) a housing financesociety or primary co-op society building for itsmembers; (v) **”any other person who acts... by anyother name or claims to be acting as the holder of apower of attorney from the owner of the land”**; and(vi) anyone who constructs any building or apartmentfor sale to the public. Crucially, the Explanation to Section2(zk) says that if the builder and the seller are differentpersons, “both of them shall be deemed to be thepromoters” and jointly liable.This language is deliberately sweeping. It means thateven a person who never signed a sale agreementwith a flat-buyer can still be a promoter if they meetany part of the definition. In Wadhwa Group HousingPvt. Ltd. v. Vijay Choksi (Bombay HC, Feb 2024), thecourt emphasized that under RERA “promoter” has“been so widely defined that it virtually includes everyperson associated with construction of the building”.The Bombay High Court held that all promoters andco-promoters share joint liability, regardless ofCA. Manan [email protected] Corner

822 Ahmedabad Chartered Accountant Journal December, 2025TMwhether each has a direct contract with a particularbuyer. In practical terms, this means that once a societyis deemed a promoter (e.g. at RERA registration), itcannot escape obligations merely because it neverentered into each buyer’s agreement.Alongside the Act’s text, RERA Authorities havereinforced this breadth via circulars. For example,MahaRERA’s Circular No. 12/2017 instructs that anylandowner/investor who falls within the promoterdefinition “shall be specified as such at the time ofonline registration”. In other words, if a society hasany role or interest in sales (such as a revenue/areasharing deal), it must register itself as promoter. Thisensures transparency to buyers that the society sharespromoter status and liabilities.Societies Without Direct Sales: No Privity withBuyersDespite RERA’s wide reach, early court decisions haveconsistently protected cooperative societies thatsimply hand over land to a developer, withoutassuming direct responsibility for selling flats tooutsiders. The landmark case is VaidehiAkash HousingPvt. Ltd. v. New D.N. Nagar Co-op. Housing Society(Bombay HC, 2014). There, the court held that societymembers who transfer redevelopment rights to abuilder are not themselves promoters of the free-saleflats sold by that builder. Crucially, the flat-purchasers(third parties) had no contract (no privity) with the society– only with the developer. The High Court ruled thatonce the development agreement was terminated, allpurchaser rights against the developer wereextinguished, and the purchasers could not enforceany rights against the society or its new developer. Inshort, **”societies are not ‘promoters’ under MOFA (preRERA) in redevelopment; purchasers through aterminated developer have no rights against thesociety”**. Because RERA did not change that basicpremise, Vaidehi’s principle was re-affirmed postRERA.Similarly, in Goregaon Pearl CHS Ltd. v. Dr.SeemaParyekar (Bombay HC, 2019), the court explicitlyreaffirmed Vaidehi after RERA came into force. It heldthat a society which simply authorized redevelopmentfor its own members – and never entered into saleagreements with outsiders – cannot be saddled withthe developer’s obligations. The rationale is equitable:a society’s primary duty is to its members’ housing,not to assume a defunct developer’s liabilities. Thecourt noted that allowing third-party purchasers anyclaim against the society would be unfairly “jeopardizing[the society members’] housing rights and stall[ing]the project indefinitely”.These decisions rest on two points: (a) No privity:the society did not contract with the buyer; and (b)Termination of developer’s appointment: oncelawfully ended (by arbitral award or decree), thedeveloper’s sale-agreements die out. In each case,the remedy for delayed or undelivered flats waslimited to suing the original developer for damages,not calling the society to account. The Bombay HighCourt in Satish Murlidhar Inamdar v. MaharashtraHousing Society (Nov 2025) recently echoed thisview, dismissing injunctions by third-party purchasersand emphasizing that *”once a developer’sappointment is lawfully terminated, purchasersclaiming through such a developer do not acquireenforceable rights against the Society”*.These precedents establish a clear rule: a societymerely leasing land to a builder (with no declaredshare deal and no direct sales) is generally not aRERA promoter for the builder’s third-party unitsales. The society’s obligations stop at providingland and recovering its rightful dues. Courts havegone so far as to say that after termination, third-partybuyers have no claim on the society’s assetswhatsoever. For example, in Kapilkunj CHS Ltd. v.State of Maharashtra (Bombay HC, Dec 2023), thecourt held that after the developer’s agreement wascancelled, all additional development rights (FSI)belonged only to the society’s members, andoutsiders had no leg to stand on.When Societies Are Declared PromotersNot all outcomes favor societies. If a society has beentreated as a promoter in the project’s RERAGujRERA Corner

Ahmedabad Chartered Accountant Journal December, 2025 823TMregistration or takes an active role in selling flats,tribunals have held it accountable. For instance,MahaRERA’s Appellate Tribunal in D.N. Nagar ShivneriCHS Ltd. v. Kamila Jain &Ors. (2025) dealt with a societywhose redevelopment agreement with a developerwas terminated. The society then self-developed theproject, built the remaining flats, and sold them tohomebuyers. The tribunal found that, post-termination,the society had essentially acted as a “builder” byresuming construction and selling units. As a result, itbecame a promoter “de facto” under RERA, eventhough it had not formally registered as one. Thetribunal held the society liable to comply with RERAobligations for those sales (e.g. paying interest toallottees, delivering possession), as it had taken onthe developer’s role.Similarly, in New Sangeeta CHS Ltd. (MahaRERAAppellate Tribunal, Dec 2024), the society itself wasfound jointly liable with the developer. There the society(after terminating the first developer) applied to thearbitrator for permission to self-develop. The arbitratorallowed it to complete the project, and the societyappointed a new contractor. When allottees latercomplained of delay, the tribunal noted that *”sincethe society being an owner of the property is apromoter within the meaning of… RERA Act”*. It thenupheld the earlier tribunal order directing the societyto hand over possession and pay penalties for RERAviolations. In effect, the society’s ownership and activecompletion of the project – coupled with its new sales– made it jointly responsible for meeting allottees’claims.These cases highlight the flip side: if a society stepsinto the shoes of developer – by building andselling to outsiders – RERA treats it as a promoter.Indeed, the statute itself lists co-op societiesconstructing for allottees (clause iv) or acting underPOA (clause v) as promoters. Once a society sellsunits (whether to members or outsiders), it must abideby RERA norms: register the project, maintain escrowaccounts, hand over possession, etc. MahaRERAthus reminded societies that self-development cannotbe done “under the radar”; failure to register is aviolation (as in Shivneri, where the society’s failure toregister its post-termination sales attracted penaltiesunder RERA).Area/Revenue-Sharing Societies: A Special CategoryOne grey area is when a society shares a portion ofbuilt-up area or sale proceeds with a developer. RERAand circulars treat such societies as co-promoters. Forexample, if a society’s agreement entitles it to 30% ofsaleable flats or a fixed revenue share, MahaRERAmandates disclosure: the society must appear on theRERA registration. Courts have inferred that in suchscenarios, the society is within the “promoter” definitionbecause it “causes construction” through the jointdevelopment pact. Indeed, some authorities havenoted that a landowner receiving a cut of the project’ssales effectively shares construction benefits, drawingthem under the definition.However, even in sharing cases, privity with buyersremains critical. If the society never stepped into sellingor collecting from buyers, some courts have stillhesitated to call it a promoter to the end-consumers,absent express registration. For instance, in Shivneri,the society had no area-sharing reported (it was aMHADA lease), and MahaRERA noted it was notnamed as co-promoter or landowner-promoter atregistration. The tribunal treated it as a passivelandowner, not as co-developer. It stressed that “thereis no document to establish that the society has privityof contract with the allottees”, hence it was not apromoter towards those buyers.In contrast, RERA authorities would treat a society withdisclosed sharing rights differently. If the society isformally a “landowner promoter” on record, third partiescan arguably claim against it (like any promoter). Thedifference is often in the registration status andcontractual setup.Cases at a Glance- Vaidehi Akash Housing Pvt. Ltd. v. New D.N. NagarCHSL (Bombay HC, 2014): Held that societymembers who assign redevelopment rights to abuilder are not promoters for third-party flats underGujRERA Corner

824 Ahmedabad Chartered Accountant Journal December, 2025TMthe then MOFA law. Buyers through the developerhave no enforceable rights against the society.Societies owe nothing to those buyers once thedeveloper’s agreement is cancelled.- Goregaon Pearl CHSL v. Dr.Seema Paryekar(Bombay HC, 2019): Reaffirmed Vaidehi in the RERAera. Observed that RERA’s enactment did notenlarge a society’s liability. Once a developer’srights end, buyer claims cannot be shifted to thesociety.- Wadhwa Group Housing Pvt. Ltd. v. Vijay Choksi(Bombay HC, Feb 2024): Confirmed that RERA’sdefinition is extremely broad. All promoters/copromoters (even those not in direct buyer contracts)are jointly liable for refunds/delays. It is notnecessary for each buyer to have an agreementwith every promoter. This case underscores that ifa society is formally treated as a promoter, it cannotescape liability by lack of privity.- Satish M. Inamdar v. MHADA (Bombay HC, Nov2025): Division Bench dismissed appellants’claims for relief from a terminated developer’sproject. It emphasized *”purchasers claimingthrough a terminated developer acquire noenforceable rights against the society or its newlyappointed developer”*. The only recourse forsuch buyers is damages/compensation from theerstwhile builder. The ruling highlights that settledlaw (Vaidehi/Goregaon) binds society’s nonliability.- New Sangeeta CHS Ltd. v. Allottees (MahaRERAAppellate, Dec 2024): Allottees had booked flatsfrom a developer; after the developer’s termination,the society resumed construction and sold flats (vianew contracts). The Appellate Tribunal upheld theauthority’s order: the society and the developerwere jointly held liable for RERA compliance(possession, interest, penalty). The tribunalexplicitly noted the society, as property-owner, wasa promoter under RERA and must honorallottees’rights.- D.N. Nagar Shivneri CHS Ltd. v. Allottees(MahaRERA Appellate, Oct 2025): Society(MHADA leaseholder) ended its developer’sagreement and did some redevelopment itself.The allottees sued claiming the society was jointlyliable. The Tribunal distinguished Wadhwa Group(where the society was a registered co-promoter)and held Shivneri’s society was not a promoterfor those allottees. It emphasized the developmentagreement gave no privity or obligations to thesociety, and the society was not listed aspromoter/co-promoter at RERA registration. Thus,the society escaped liability for the erstwhiledeveloper’s acts. However, the Tribunal warnedthe society that selling on its own (withoutregistration) would make it a promoter – anadmission of breach of RERA Section 3 (asactually occurred, leading to penalties).- Kapilkunj CHS Ltd. v. State of Maharashtra(Bombay HC, Dec 2023): After a developer’sproject was cancelled, the High Court underscoredthat all development benefits (including extra FSI)accrue to the society’s members. Third-party buyers(who signed with the cancelled developer) couldnot claim against the society’s assets. Thisreinforced that society’s rights and members’interests cannot be overridden by non-members’contracts.- Sandeep Grover &Anr. v. Sai Siddhi Developers& Ors. (NCDRC, New Delhi, 2023): In a contraryvein, the national consumer commission took amore buyer-friendly view. It held that in certainredevelopment disputes (e.g. Goregaon Pearlcases), societies could be treated as promotersand thus be liable to third-party allottees. However,this view clashes with Bombay HC rulings.Importantly, higher courts (Bombay HC andSupreme Court) have preferred the position thatsociety’s obligations do not automatically coveroutsiders after termination of developer’s rights. TheNCDRC’s stance is not binding on courtsinterpreting RERA.GujRERA Corner

Ahmedabad Chartered Accountant Journal December, 2025 825TM- Deepak Prabhakar Thakoor & Ors. v. MHADA(Bombay HC, 2023): A Division Bench againfollowed Vaidehi, holding that once a developer’srights terminate by award, homebuyers’ remediesare confined to the developer, not the society. Itaffirmed that even if buyers have MOUs, letters,etc., they have no enforceable right against thesociety or its new developer.- Tuvin Constructions LLP v. State ofMaharashtra (Bombay HC, Sep 2025): The courtclarified RERA processes in change of promotermid-project. It held that RERA does not requireconsent from purchasers of a terminateddeveloper for re-registration under a newpromoter. This upholds the society’s option tomove forward without being blocked byoutsiders’ claims. It also implicitly signals thatsociety’s status vis-à-vis those purchasersremains extinguished post-termination.Practical Takeaways for SocietiesFor cooperative societies embarking onredevelopment, these developments offer guidance:- Check Privity:If your society only assigns land to a developerand never sells to outsiders, your primaryobligations remain to your members. Courts haveheld that third-party buyers can only claim againstthe (now-terminated) developer. Ensure cleartermination processes and enforce arbitrationawards to conclusively end developers’ authority.- Beware Self-Development:If a project stalls and the society decides to selfdevelop (hire a new builder or contractors), thenany flats sold to outsiders turn the society into apromoter. At that point, the society must registerthe project with RERA as a promoter, maintainescrow accounts, issue compliance certificates,etc. MahaRERA has already penalized a societyfor failing to do so after taking over a project. Inpractice, any society undertaking physicalconstruction of sale-flats should immediatelyregister under RERA.- Area/Revenue Sharing Deals:If your society enters a redevelopment pact whereit gets, say, X% of flats or a fixed revenue share,you must register the society as a promoter/landowner-promoter. Failure to disclose yourshare at registration can later expose you toliability. Conversely, if no share is given, society’sliability may be limited – but only if it has no directsale involvement. Always align your agreementswith RERA’s circular guidance.- Document Relationships Clearly:In all agreements (development agreements,POAs, sale contracts), clarify who is the promoter.Courts will look at the intent and privity. If the society’sdocuments show that the builder acted “in his owncapacity” and the society had no obligations tobuyers, that supports non-promoter status.Conversely, if documents tie the society into thesales (even indirectly), it may weaken society’sdefense.- Monitor Registrations:Follow the project’s RERA registration page. If thedeveloper has listed any co-promoters orlandowners, ensure the society’s name appears ifappropriate. If the society’s interests change midproject (termination, new partner, etc.), update RERAaccordingly to reflect who is now the promoter. Thisavoids later disputes over who has promoterliability.- Prepare for Litigation Risks:Allotment agreements can spawn litigation evenafter years. Societies should budget for legalcontingencies (especially from old developer’sGujRERA Corner

826 Ahmedabad Chartered Accountant Journal December, 2025TMbuyers) and ensure arbitration awards areenforceable. The Bombay High Court hasrepeatedly stressed that arbitral awards endingdeveloper rights bind purchasers as well, sosocieties must diligently pursue such awards andget them upheld.In conclusion, whether a society is a “promoter”under RERA depends heavily on its role in theproject. If it simply held land and the builder handledall sales, courts have mostly said “no” for third-partyobligations. But if the society steps into sales – bybuilding flats itself, by sharing revenues, or byconsenting to being listed as promoter – then RERAtreats it as fully within the promoter net. CAs andlawyers advising societies must therefore navigateboth the strict language of RERA and the developingcase law. By understanding these rulings, societiescan better structure agreements, register projectscorrectly, and avoid unexpectedly shoulderingdeveloper liabilities.GujRERA Corner

Ahmedabad Chartered Accountant Journal December, 2025 827TMSummary:The rupee fell to a record low, breaching the Rs. 91-per-dollar mark, amid sustained foreign portfoliooutflows, rising hedging demand, and uncertainty overthe India–U.S. trade deal. In November 2025, Indianequity markets ended at record high levels, with theSensex closing at 85,707 and the Nifty 50 at 26,203,supported by easing inflation, rate-cut expectationsand strong domestic inflows, even as gains moderatedtoward month-end amid FPI outflows and mixedsectoral performance.Primary market includes the IPOof Gujarat Kidney &Super Speciality Hospital Limited, where one of theobject of the IPO is acquisition of Parekhs Hospital Pvt.Ltd. from the proceeds. We are happy to share thatVora Corporate Finance acted as exclusive financialadvisor to Parekhs Hospital Pvt. Ltd. in this deal.Key M&A and PE deals include Morgan Stanleybacked Omega Hospitals acquiring 100% of CytecareHospitals and Waaree Energy Storage raising Rs.1,000 crore to expand battery manufacturing andenergy storage solutions.Economic Update:Rupee Slides Past 91 in Historic Low on HeavyCapital FlightThe Indian rupee slid to a record low on December16, breaching the Rs. 91-per-dollar mark for the firstCA. Karan [email protected] in intra-day trade, as sustained foreign portfolioinvestor (FPI) outflows, elevated hedging demand, anduncertainty over the India–U.S. trade deal weighed onsentiment. The currency is down about 5.3% year-todate in 2025, its steepest annual decline since 2022,placing it among the weakest-performing emergingmarket and Asian currencies this year. Dealers attributethe move to persistent portfolio exits, tighter globalfinancial conditions, and the impact of higher U.S. tariffson Indian exports, which have pressured trade andcapital flows.Despite some improvement on the external balance,pressures remain uneven. India’s current accountdeficit narrowed to 1.3% of GDP in Q2, improving bynearly 90 basis points year-on-year, supported byservices exports and remittances. However, themerchandise trade deficit widened to a record $41.7billion in October, underscoring continued stress onthe goods trade. The rapid depreciation—from Rs. 89to Rs. 91 per dollar in under two weeks—has raisedhedging costs, with the one-month dollar/rupee forwardpremium rising to about 23.25 paise, a seven-monthhigh.Market participants note that the RBI’s intervention hasbeen relatively limited, suggesting tolerance for aweaker rupee to support export competitiveness amidongoing trade negotiations and also probably anexpectation that the Rupee will stabilize soon on itsown in due time.Secondary Market:- The BSE Sensex closed at 85,707 up by 2.11%,and the Nifty 50 closed at 26,203 up by 1.87% inNovember 2025, supported by rate-cutexpectations, easing inflation, India–US trade dealoptimism, and an improving earnings outlook.

828 Ahmedabad Chartered Accountant Journal December, 2025TMCapital Market- Market momentum moderated toward the end ofthe month, as investors turned cautious ahead ofthe release of Q2 FY26 GDP and IIP data, resultingin range-bound trading and consolidation at recordindex levels.- On November 28, Sector-wise, Nifty Auto led thegains with a 0.62% rise, while Nifty Pharma andNifty Media also advanced by over 0.50%. On theflip side, Nifty Oil & Gas came under pressure,falling 0.69%, followed by Nifty Realty and Nifty IT,which declined 0.19% and 0.11%, respectively.- Inflation remained subdued, with CPI at 0.25% andWPI at –1%, supporting corporate profitability andinvestor sentiment by easing cost pressures andsustaining market stability.- Global macro conditions were broadly supportive,with the US Federal Reserve cutting policy ratesby 25 bps to 3.75–4.00%, Brent crude oil pricesmoderating to around $64 per barrel,as expectationsof a Russia-Ukraine peace agreement gainedmomentum.- Foreign portfolio investor (FPIs) remained volatile,with net equity outflows of approximately Rs. 3,765crore during November, reflecting elevated globalrisk aversion, increased volatility in globaltechnology stocks, and a measured shift inallocations towards primary markets oversecondary markets.- The advance-decline ratio on the BSE stood at2,019 advances against 2,128 declines, with 165stocks remaining unchanged.- The Nifty’s forward P/E stood at 20x FY27Eearnings, near its long-term average, supported byan expected 12–13% earnings CAGR over FY25–27 supporting a constructive medium to long-terminvestment outlook.Equity Markets Oct-25 Nov-25 % ChangeBSE Sensex 83,938.71 85,706.67 2.11% Nifty 50 25,722.10 26,202.95 1.87% BSE 500 37,214.04 37,535.84 0.86% BSE Healthcare 44,529.77 44,883.80 0.80% BSE IT 35,012.88 36,305.54 3.69% BSE FMCG 20,660.05 20,407.47 2.40% BSE Metal 35,128.74 34,112.07 -2.89%

Ahmedabad Chartered Accountant Journal December, 2025 829TMCapital MarketPrimary Market Update:There were 12 main board IPO in November includingof Orkla India Limited, Studds Accessories Limited,Lenskart Solutions Limited, Billionbrains GarageVentures Limited, Pine Labs Limited, PhysicswallahLimited, Emmvee Photovoltaic Power Limited, TennecoClean Air India Limited, Fujiyama Power SystemsLimited, Capillary Technologies India Limited, ExcelsoftTechnologies Limited and Sudeep Pharma Limited,against 17 main board IPOs in October 2025. Therewere 06 SME IPOs in November 2025 as against 27SME IPOs in October 2025.Sudeep Pharma Limited:About the Incorporated in 1989, Sudeep PharmaCompany Limited (SPL) manufactures excipientsand specialty ingredients for thepharmaceutical, food, and nutritionindustries, with a portfolio of 100+products. The company operates threemanufacturing facilities in Gujarat with anannual available capacity of 65,579 MT,along with an overseas manufacturingfacility in Ireland. SPL was among thelargest exporters of mineral ingredientsfrom India by export volume in 2024serving over 1,100 customers acrossapproximately 100 countries, with repeatcustomers contributing over 78% ofrevenue in Fiscal 2025. The companyemploys 740 personnel and operatestwo R&D facilities as of June 30, 2025.The company reported revenue of Rs.502 crore in FY25, up 9% from Rs. 459crore in FY24 and posted a PAT of Rs.139 crore compared to profit of Rs. 133crore in the previous year.Funds The IPO proceeds from fresh issue willUtilization be utilized towards a capex for procuringmachinery for the production line atNandesari facility and general corporatepurposes.Anchor The company raised Rs. 268.50 croreInvestors from anchor investors including SBI MF,& Selling HDFC MF, ICICI Prudential MF, NipponShare- India MF, Whiteoak CapitalMF, Adityaholders Birla Sun Life MF, Motilal Oswal MF,Quant MF, Bandhan MF, UTI MF,Edelweiss MF, Tata AIA Life Insurance,and SBI Life Insurance, alongsideindividual investors like Mukul Agarwaland Prashant Jain, with sellingshareholders includes promoters SujitJaysukh Bhayani, Shanil Sujit Bhayani,Avani Sujit Bhayani, and Sujeet JaysukhBhayani HUF.IPO Per- The Rs. 895 Crore IPO comprised offormance fresh issue of Rs. 800 Crore and OFS ofRs. 95 Crores. The issue was subscribedover 93.71 times, with QIBs subscribedthe most at 213 times to the issue. Sharesof Sudeep Pharma Limited made a stellardebut on the exchange, and got listed atRs. 730 on NSE and Rs. 733.95 on BSE,i.e. a premium of 24% over the issueprice of Rs 593.Gujarat Kidney & Super Speciality Limited:About the Incorporated in 2019, Gujarat Kidney andCompany Super Speciality Limited (GKSSL)operates a regional chain ofmultispeciality hospitals offering servicesacross orthopaedics, joint replacement,general and minimally invasive surgeryand obstetrics & gynaecology. On aconsolidated basis, the companyoperates 7 multi-specialty hospitals and4 in-hospital pharmacies across keycities in Gujarat. GKASSL has a total bedcapacity of 490 beds, with approvedcapacity of 445 beds and operationalcapacity of 340 beds. The company hasexpanded its footprint through multipleacquisitions, strengthening its presencein Vadodara, Godhra, Bharuch, Borsadand Anand. As of June 30, 2025, GKASSLemployed 89 doctors, 332 nurses and338 other staff. The company hadreported pro forma consolidated revenueof Rs. 120 crore, EBITDA of Rs. 29 crore,and net profit of Rs. 15 crore for FY25(year ended March 31, 2025).

830 Ahmedabad Chartered Accountant Journal December, 2025TMFunds The IPO proceeds will be utilized forUtilization acquisitions including Parekhs Hospitaland Ashwini Medical Centre, setting upa new Vadodara hospital, purchasingrobotics equipment, repayment ofborrowings, acquiring additional stake inHarmony Medicare Pvt. Ltd. and fundingfuture inorganic growth and generalcorporate purposes.Vora CorporateFinance acted as exclusive financialadvisor to Parekhs Hospital Pvt. Ltd. inits acquisition by Gujarat Kidney andSuper Speciality Limited.Anchor The company raised over Rs. 100 croreInvestors from anchor investors ahead of the IPO.Funds Mobilization by Corporates (Rs. In Crore)Particulars Sept-25 Oct-25I. Equity Issues 20,779 51,336a. IPOs (i+ii) 11,312 41,783i. Main Board 9,584 40,402ii. SME Platform 1,728 1,381b. FPOs 0 0c. Equity Rights Issues 1,602 1,050d. QIPs/IPPs 2,085 1,100e. Preferential Allotments 5,780 7,403II. Debt Issues 74,357 78,540a. Debt Public Issues 200 834b. Private Placement of Debt 74,157 77,706III. REITs/ InvITs 1,000 3,248a. REITs 1,000 0b. InvITs 0 3,248Total Funds Mobilized (I+II+III) 96,137 1,33,124Capital MarketIPO Per- The IPO comprised entirely of fresh issueformance of Rs. 250.80 Crore. The issue wassubscribed over 5.21 times, with retailinvestors subscribed the most at 19.04times to the issue. Shares of GujaratKidney & Super specialty HospitalLimitedmade a muted debut on the exchanges,and listed at Rs. 120 presenting apremium of approximately 6% over theissue price of Rs. 114.Proposed structure of GKSL after successfulcompletion of the proposed acquisition of ParekhsHospital Pvt Ltd, Ashwini Medical Centre and HarmonyMedicare Private Limited:Mergers and Acquisitions (M&A) and Private Equity(PE) key deals:M&A: Omega Hospitals Acquires Cytecare Hospitals,marks entry into Bengaluru oncology marketTransaction:- Morgan Stanley Private Equity–backed OmegaHospitals has acquired 100% of Cytecare HospitalsPvt. Ltd., Bengaluru, through its operating entity,Hyderabad Institute of Oncology Pvt. Ltd.- The transaction comprised secondary acquisitionof shares from existing shareholders along with aprimary capital infusion for growth; the exact financialterms of the deal were not disclosed.About Cytecare Hospitals Private Limited:- Founded in 2016, Cytecare is a 155-bed, fullyintegrated oncology centre of excellence offeringcomprehensive cancer care across surgical,

Ahmedabad Chartered Accountant Journal December, 2025 831TMmedical and radiation oncology, supported by amultidisciplinary treatment model.- The hospital provides advanced immunotherapies,including CAR-T Therapy and NK-Cell Therapy, andderives approximately 85% of its activity fromsurgical and oncology services.- Cytecare has treated 13,000+ inpatients and160,000+ outpatients, administered 50,000+radiation therapy fractions, conducted around 6,500PET-CT scans, and has been backed by keyinvestors including Goldman Sachs and Gi GlobalHealth.About Omega Hospitals:- Founded in 2010 by surgical oncologist Dr MohanaVamsy, Omega Hospitals operates 10+ hospitalswith 1,500+ beds, including 3 hospitals inHyderabad including 400-bed Centre of Excellencein Gachibowli, with presence in 8+ other cities.- While oncology is the core focus, the group offersmulti-specialty services across cardiology,neurology, gynecology, ENT and allied specialties,serving thousands of inpatients and outpatientsannually.Rationale:- Cytecare has treated 5,000+ patients, includingfrom India, Africa, Eastern Europe, and the MiddleEast, supporting its scalability as an oncologyplatform.- The acquisition marks Omega Hospitals’ entry intothe North Bengaluru oncology market, expandingbeyond its core geographies of Andhra Pradeshand Telangana.- It is part of Omega’s pan-India expansion strategy,following recent entries into Jabalpur, Tirupati, Surat,Vijayawada and Yamuna Nagar.- Cytecare will be developed as Omega’s centre ofexcellence for quaternary cancer care, withinvestments planned for senior clinical talent andadvanced medical equipment.- In June 2018, Cytecare raised $31 million (SeriesA) investment from Goldman Sachs, to supportexpansion across 4–5 Indian cities.- In June 2024, Omega Hospitals secured Rs. 500Crore in funding from Morgan Stanley Private EquityAsia, supporting strategic acquisitions and networkexpansion.- Also in FY24, Cytecare reported Rs. 91.6 crorerevenue (+19% YoY) and reduced net loss to Rs.15 crore, while Omega recorded Rs. 380 crorerevenue (+45% YoY) with Rs. 6 crore net profit,demonstrating growth and improving financialperformance.PE: Waaree Energy Storage Raises Rs. 1,000 Cr toScale Battery ManufacturingTransaction:- Waaree Energy Storage Systems Pvt. Ltd., thebattery storage arm of Waaree Energies, raisedRs. 1000 Crore in a funding round led by Suratbased boutique investment firm Niveshaay, whichinvested $14.3 million (Rs. 128 crore).- The round also saw participation from Vivek Jain,Saket Agarwal, and other high-net-worth individualinvestors.About Waaree Energy Storage Systems PrivateLimited:- Incorporated in 2020 (formerly Sangam Solar TwoPvt. Ltd.), Waaree Energy Storage Systems Pvt.Ltd. is the battery storage arm of the Waaree Group,which operates GW-scale solar modulemanufacturing and EPC operations.- The company is engaged in cell manufacturing,battery pack assembly, and containerised BatteryEnergy Storage Systems (BESS) for utility-scaleand commercial & industrial applications, servingIndian and global customers.About Niveshaay:- Niveshaay is a SEBI-registered AlternativeInvestment Fund (AIF) manager operating CategoryII and Category III funds, along with sector-focusedinvestment vehicles.- The firm focuses on early-stage, high-convictioninvestments in India’s manufacturing and energyCapital MarketContinued to page 834

832 Ahmedabad Chartered Accountant Journal December, 2025TMInd AS 19 Employee BenefitsAnnual Report 2024-25HCL Technologies LimitedI. Provident fund: Employees of the Company andits subsidiaries in India receive benefits under theprovident fund, a defined benefit plan. Theemployee and employer each make monthlycontributions to the plan.A portion of the contribution is made to the providentfund trust managed by the Group or Governmentadministered provident fund; while the balancecontribution is made to the Governmentadministered pension fund, a defined contributionplan. For the contribution made by the Companyand its subsidiaries in India to the provident fundtrust managed by the Group, the Company has anobligation to fund any shortfall on the yield of theTrust’s investments over the administered interestrates. The liability is actuarially determined (usingthe projected unit credit method) at the end of theyear. The funds contributed to the Trust are investedin specific securities as mandated by law andgenerally consist of federal and state governmentbonds, debt instruments of government-ownedcorporations, equity and other eligible marketsecurities.II. In respect of superannuation, a definedcontribution plan for applicable employees, theCompany contributes to the superannuation trustand the scheme is administered on its behalf byappointed fund managers and such contributionsfor each year of service rendered by theemployees are charged to the statement of profitand loss. The Company has no further obligationsto the superannuation plan beyond itscontributions.III. Gratuity liability: The Company and its subsidiariesin India and certain foreign geographies providefor gratuity, a defined benefit plan (the “GratuityPlan”) covering eligible employees. The GratuityPlan provides a lump sum payment to vestedemployees at retirement, death, incapacitation ortermination of employment, of an amount basedon the respective employee’s base salary andthe tenure of employment (subject to a maximumlimit in accordance with regulatory requirement ofrespective geography). The liability is actuariallydetermined (using the projected unit creditmethod) at the end of each year. Actuarial gains/losses are recognized immediately in the balancesheet with a corresponding debit or credit to othercomprehensive income in the year in which theyoccur.In respect to certain employees in India, theCompany contributes towards gratuity liabilities tothe Gratuity Fund Trust. Trustees of the Companyadminister contributions made to the Trust andcontributions are invested in a scheme with LifeInsurance Corporation of India as permitted by law.IV. Compensated absences: The employees of theGroup are entitled to compensated absenceswhich are both accumulating and non-accumulatingin nature. The employees can carry forward up tothe specified portion of the unutilized accumulatedcompensated absences and utilize it in futureperiods or receive cash at retirement or terminationof employment. The expected cost ofaccumulating compensated absences isdetermined by actuarial valuation (using theprojected unit credit method) based on theadditional amount expected to be paid as a resultof the unused entitlement that has accumulated atthe balance sheet date.CA. Pamil H. [email protected] PublishedAccounts

Ahmedabad Chartered Accountant Journal December, 2025 833TMThe expense on non-accumulating compensatedabsences is recognized in the statement of profitand loss in the year in which the absences occur.Actuarial gains/losses are immediately taken tothe statement of profit and loss and are notdeferred.V. In certain subsidiaries outside India, the Groupprovide retirement benefit pension plans inaccordance withthe local laws. The liability isactuarialy determined (using the projected unitcredit method) at the end of each year.Contributions to other defined contribution plansare recognized as expense when employeeshave rendered services entitling them to suchbenefits.Kotak Mahindra Bank LimitedI. Defined Benefit Plans:Gratuity:The Group provides for gratuity coveringemployees in accordance with the Payment ofGratuity Act, 1972, service regulations and serviceawards as the case may be. The Group’s liabilityis actuarially determined using projected unit creditmethod at the balance sheet date. The Bank andseven of its subsidiaries make contributions to agratuity fund administered by trustees andmanaged by Life Insurance companies. In othersubsidiaries gratuity obligation is wholly unfunded.The contribution made to the trusts is recognisedas planned assets.Pension:In respect of pension payable to certainemployees of erstwhile ING Vysya Bank Limited(eIVBL) under Indian Banks’ Association (IBA)structure, the Bank contributes 10% of basic salaryto a pension fund and the difference between thecontribution and the amount actuarially determinedby an independent actuary is trued up based onactuarial valuation conducted as at the balancesheet date. The pension fund is managed by aLife Insurance company. The present value of theBank’s defined pension obligation is determinedusing the projected unit credit method as at thebalance sheet date.Employees covered by the pension plan are noteligible for employer’s contribution under theprovident fund plan.The contribution made to the pension fund isrecognised as planned assets.The defined benefit obligation recognised in thebalance sheet represents the present value of thedefined benefit obligation as reduced by the fairvalue of the plan assets.Actuarial gains or losses in respect of all definedbenefit plans are recognised immediately in theprofit and loss account in the year in which theyare incurred.II. Defined Contribution Plans:Provident Fund:Contribution as required by the statute made tothe government provident fund or to a fund set upby the Bank and administered by a board oftrustees is debited to the profit and loss accountwhen an employee renders the related service.The Group has no further obligations.Superannuation Fund:The Group makes contributions in respect ofeligible employees, subject to a maximum of H0.01 crore per employee per annum to a fundadministered by trustees and managed by LifeInsurance companies. The Group recognises suchcontributions as an expense in the year when anemployee renders the related service. The Grouphas no further obligations.New Pension Scheme:The Group contributes upto 10% of eligibleemployees’ salary per annum, to the New PensionFund administered by a Pension Fund Regulatoryand Development Authority (PFRDA) appointedpension fund manager. The Group recognisessuch contributions as an expense in the year whenan employee renders the related service.DIFC Employee Workplace Savings Scheme(DEWS):From Published Accounts

834 Ahmedabad Chartered Accountant Journal December, 2025TMThe Bank’s branch in DIFC contributes up to 8.33%of eligible branch employees’ salary per annumto the DIFC Employee Workplace SavingsScheme (DEWS). The Bank recognises suchcontributions as an expense in the year when anemployee renders the related service. The Bankhas no further obligation.III. Compensated Absences: Other Long-TermEmployee Benefits:The Group accrues the liability for compensatedabsences based on the actuarial valuation as atthe balance sheet date conducted by anindependent actuary, which includes assumptionsabout demographics, early retirement, salaryincreases, interest rates and leave utilisation. Thenet present value of the Group’s obligation isdetermined using the projected unit credit methodas at the balance sheet date. Actuarial gains orlosses are recognised in the profit and lossaccount in the year in which they arise.IV. Other Employee Benefits:As per the Group policy, employees are eligiblefor an award after completion of a specified numberof years of service with the Group. The obligationis measured at the balance sheet date on thebasis of an actuarial valuation using the projectedunit credit method.The undiscounted amount of short-term employeebenefits expected to be paid in exchange for theservices rendered by employees is recognisedduring the period when the employee renders theservice. These benefits include performanceincentives.From Published Accountstransition ecosystem, with recent investmentsincluding Rs. 52 crore in CIMCON Software.Rationale:- The Rs. 1,000 crore ($113 million) fundraise followsan earlier Rs. 300 crore ($33.6 million) capitalinfusion from the parent, providing sufficient balancesheet strength to support the next phase of growth.- The proceeds will be deployed towards expandingcell and battery pack manufacturing capacity,including investments in engineering, testing, andvalidation, enabling scale-up while enhancingsystem reliability, safety standards, and productperformance.- The investment supports the scaling ofcontainerised Battery Energy Storage Systems(BESS) for utility-scale and commercial applications.aligned with rising demand for energy storagesolutions.- The transaction aligns with India’s clean energytransition, supported by policy measures such asthe Production Linked Incentive (PLI) scheme foradvanced cells and Energy Storage Obligation(ESO) mandates.- The investment leverages the Waaree Group’s GWscale solar manufacturing and EPC platform,enabling integrated generation-plus-storageofferings and improving customer acquisitionefficiency.Acknowledgements: RBI Bulletin(www.bulletin.rbi.org.in), SEBI (www.sebi.gov.in), NSE(www.nseindia.com), BSE (www.bseindia.com)Capital Market Continued from page 831

Ahmedabad Chartered Accountant Journal December, 2025 835TMCA. Kunal A. [email protected] the Government CA. Ashwin H. [email protected] the cancellation proceedings are notdropped automatically on the same day afteradding bank details, the taxpayer canmanually initiate the process using the “InitiateDrop Proceedings” button available at:Services > User Services > View Notices andOrders > Initiate Drop Proceedings.- Exemptions:Furnishing bank account details is notmandatory for OIDAR and NRTP taxpayers.However, for OIDAR taxpayers who select“Representative Appointed in India” as ‘Yes’,furnishing bank account details is mandatory.2) Advisory on reporting values in Table 3.2 ofGSTR-3B (GST updates, dated 5th December,2025)1. Table 3.2 of Form GSTR-3B captures theinter-state supplies made to unregisteredpersons, composition taxpayers, and UINholders out of the total supplies declared inTable 3.1 & 3.1.1 of GSTR-3B and is autopopulated from corresponding suppliesdeclared in GSTR-1, GSTR-1A, and IFF inthe requisite tables.2. It is to inform you that from November-2025tax period onwards, value of supplies autopopulated in Table 3.2 of GSTR-3B from thereturns/forms mentioned above, shall bemade non-editable. The GSTR-3B shall befiled henceforth with the system generatedauto-populated values only in table 3.2.3. Further, in case any modification/amendmentis required in the auto-populated values ofGOODS AND SERVICE TAX1) Auto Suspension of GST Registration due toNon-Furnishing of Bank Account Details as perRule 10A (GST updates 5th December,2025)In pursuance of Rule 10A, taxpayers (except thoseregistered under TCS, TDS, or Suo-motoregistrations) must furnish their bank account detailswithin 30 days of grant of registration or beforefiling details of outward supplies in GSTR-1 or IFF,whichever is earlier.The following updates have been implementedon the GST Portal with respect to Rule 10A:- Automatic Suspension:If a taxpayer fails to furnish bank accountdetails within 30 days of registration, thesystem will automatically suspend theregistration. The suspension order can beviewed at: Services > User Services > ViewNotices and Orders.- Adding Bank Account Details:Taxpayers can add bank account detailsthrough a non-core amendment by navigatingto: Services > Registration > Amendment ofRegistration (Non-Core Fields).- Automatic Dropping of CancellationProceedings:Once bank account details are furnished,cancellation proceedings will beautomatically dropped by the system.- Manual Option to Drop Proceedings:

836 Ahmedabad Chartered Accountant Journal December, 2025TMTable 3.2 of GSTR-3B, then the same can bedone through GSTR-1A for the same taxperiod. The values thus reported in GSTR1A shall change the auto-populated valuesof table 3.2 in GSTR-3B instantly and thetaxpayers can file their GSTR-3B with theupdated values. Moreover, the amendmentof such supplies can always be reported inForm GSTR-1/IFF filed for subsequent taxperiods.4. To ensure that GSTR-3B is filed accuratelywith the correct values with no hassle offrequent amendments, it is advised to reportthe correct values in GSTR-1, GSTR-1A, orIFF. This will ensure the auto-populated valuesin Table 3.2 of GSTR-3B are accurate andcompliant with GST regulations.FAQ’s- What are the recent changes related to reportingsupplies in Table 3.2?Starting from the November 2025 tax period, theauto-populated values in Table 3.2 of GSTR-3Bfor inter-state supplies made to unregisteredpersons, composition taxpayers, and UIN holderswill be non-editable, and taxpayers will need tofile their GSTR-3B with the system-generated autopopulated values only.- How can I rectify values in Table 3.2 ofGSTR-3B if incorrect values have been autopopulated after November 2025 period onwardsdue to incorrect reporting of the same throughGSTR-1?If incorrect values are auto-populated in Table 3.2after November 2025, then the taxpayers need tocorrect the values by making amendments throughForm GSTR-1A for the same tax period. Thevalues thus reported in GSTR-1A shall change theauto-populated values of table 3.2 in GSTR-3Binstantly and the taxpayers can file their GSTR-3Bwith the updated values.Moreover, the amendment of such supplies canalways be reported in Form GSTR-1/IFF filed forsubsequent tax periods.- What should I do to ensure accurate reportingin Table 3.2 of GSTR-3B?Taxpayers should ensure that their supplies arereported correctly in their GSTR-1, GSTR-1A, orIFF. It is advised to review the draft GSTR-1 orGSTR-1A before filing so that any mistakes in thestatement can be corrected therein. This willensure that the accurate values are auto-populatedin Table 3.2 of GSTR-3B.- Till what time/date I can amend values furnishedin GSTR-1 through Form GSTR-1A?As there is no cut-off date for filing Form GSTR-1Abefore GSTR-3B which means Form GSTR-1A canbe filed after filing Form GSTR-1 and till the timeof filing Form GSTR-3B. Hence, any amendmentrequired in auto-populated values of table 3.2,same can be carried out through Form GSTR-1Atill the moment of filing GSTR-3B.From the Government

Ahmedabad Chartered Accountant Journal December, 2025 837TMDecoding AI: A Chartered Accountant’s Guide toUnderstanding the Technology Behind the Buzz -Part 2In Part 1 of this series, we explored the foundationalconcepts of AI, understanding what Large LanguageModels (LLMs) and Small Language Models (SLMs)are, the significance of training and knowledge cutoffs,and the critical skill of prompt engineering. We sawthat AI tools, while powerful, are pattern recognitionsystems rather than thinking entities, and that the qualityof their outputs depends heavily on how we interactwith them.Building on that foundation, Part 2 delves into themore advanced concepts and practical challengesthat arise as AI integration deepens in professionalpractice. We will explore how AI systems accessexternal knowledge, the phenomenon ofhallucinations and how to detect them, thedevelopments around autonomous AI agents, theimportance of guardrails, and the implications ofchoosing between open-source and proprietarymodels. These concepts are essential for CharteredAccountants who want to move beyond basic AI usageand integrate these tools responsibly and effectivelyinto their workflows.Advanced Capabilities: Expanding AI’s ReachRAG (Retrieval Augmented Generation): Bridging theKnowledge GapOne of the most significant limitations we discussedin Part 1 is the knowledge cutoff. An LLM’s trainingends at a specific point in time, and it cannotautonomously update itself with new information. Thisposes a serious challenge for professionals whoneed current data, whether it is the latest GSTnotification, a recent court ruling, or updatedaccounting standards. This is where RetrievalAugmented Generation, or RAG, becomestransformative.RAG is a technique that enhances an LLM’s capabilitiesby allowing it to access and retrieve information fromexternal sources in real-time. Instead of relying solelyon its training data, a RAG-enabled system can searchthrough databases, documents, websites, or internalknowledge repositories to find relevant, up-to-dateinformation and then use that retrieved information togenerate a response.Think of it this way. A traditional LLM is like a scholarwho memorized an entire library years ago but hasnot read any new books since. When you ask aquestion, the scholar draws only from their memory. ARAG-enabled LLM, on the other hand, is like that samescholar but with access to a constantly updated library.When asked a question, the scholar first searches thelibrary for the most current and relevant materials, readsthem, and then formulates a response based on boththeir existing knowledge and the newly retrievedinformation.For Chartered Accountants, RAG has immense practicalvalue. Imagine building a system where your firm’sinternal database of GST circulars, notifications, pastclient advisories, and research notes is indexed andaccessible to an AI. When you ask a question about aspecific compliance issue, the AI retrieves the mostrelevant documents from your firm’s repository andgenerates a response based on that firm-specificknowledge, rather than generic public information. Thisensures that the advice is tailored, current, andgrounded in your firm’s established expertise anddocumentation.CA. Tapas [email protected]

838 Ahmedabad Chartered Accountant Journal December, 2025TMMany modern AI tools, including conversational searchengines and enterprise AI platforms, alreadyincorporate RAG. When you use a tool that claims to“search the web” or “access your documents” beforeanswering, it is likely using some form of RAG.Understanding this concept helps you evaluate whetheran AI tool can truly meet your need for current, domainspecific information or whether it is limited to its statictraining data.AI Agents and Agentic AI: From Responding toActingSo far, we have primarily discussed AI as a responsivetool. You provide a prompt, the AI generates aresponse, and the interaction ends. This is aconversational, turn-based model. However, the fieldis rapidly evolving in two related but distinct directions:Agentic AI as a capability, and AI Agents as specificimplementations of that capability. Understanding thedistinction is important.Agentic AI refers to the broader concept of AI systemsthat possess agency, meaning they can operate witha degree of autonomy to achieve goals. This is acharacteristic or capability of an AI system. An AI withagentic capabilities can plan, reason about tasks,make decisions about what steps to take next, usetools or access resources, and adapt its approachbased on intermediate results. Agentic AI is not aspecific product or tool; it is a way of describing howan AI system behaves. Think of it as a property orquality, like saying a car is “autonomous” when it candrive itself.An AI Agent, on the other hand, is a specificapplication or implementation that leverages agenticcapabilities to accomplish tasks. It is a concretesystem built with agentic AI principles. Whensomeone says “I am using an AI agent,” they arereferring to a particular tool, software, or platform thathas been designed to act autonomously toward adefined objective. AI agents are the “what” thatembodies the “how” of agentic AI.To illustrate with a practical example in the context ofGST compliance, consider the task: “Prepare aIT Cornerreconciliation report comparing our sales register withGSTR-1 for the last quarter and highlightdiscrepancies.” A traditional LLM would require you tomanually upload the data, format it, and then askspecific questions at each step. An AI agent, however,is a tool specifically built with agentic capabilities thatcould autonomously perform the following sequence:access the internal ERP system to extract the salesregister data, download the GSTR-1 data from the GSTportal using credentials you have authorized, performdata cleaning and standardization, execute thereconciliation logic, identify discrepancies, generatea formatted report, and even draft an email summarizingthe findings. All of this happens without you needingto micromanage each step. The agentic AI capabilityis what allows the AI agent tool to operateautonomously.This evolution from simple responsive AI to systemswith agentic capabilities represents a fundamentalchange in how we interact with technology. Insteadof being tools that assist with individual tasks, AIagents become co-workers capable of handling endto-end workflows. The implications for productivity aresignificant. Tasks that currently take hours, such asdata extraction, reconciliation, report generation, andclient communication, could be automated almostentirely through AI agents, freeing professionals tofocus on higher-value activities like strategicplanning, advisory services and relationshipmanagement.However, the introduction of agentic capabilities alsobrings new risks. The more autonomy you grant to anAI agent, the greater the potential for errors topropagate if the system makes an incorrect assumptionor encounters unexpected data. This is why humanoversight, verification, and well-defined guardrails,which we will discuss shortly, remain critical. The goalis not to eliminate the human from the loop but toposition AI agents as highly capable assistants thathandle routine, repetitive, and time-consuming tasksunder appropriate supervision, leveraging their agenticcapabilities while remaining accountable to humanjudgment.

Ahmedabad Chartered Accountant Journal December, 2025 839TMCritical Limitations and Safeguards: Navigating thePitfallsHallucinations: When AI Confidently InventsInformationPerhaps the most discussed and concerningphenomenon in AI is hallucination. In the context ofLLMs, a hallucination occurs when the model generatesinformation that sounds plausible and is presented withconfidence but is factually incorrect or entirelyfabricated. This can range from inventing case lawcitations, misquoting regulations, or fabricating statisticsto creating nonexistent entities or events. We haveseen cases in the recent past where either thecounsels have cut a sorry figure for citing judgementsthat are non-existent or where even tribunal courts haverecalled their judgements after realizing that the caselaws relied upon for passing the judgements were nonexistent. While these may not have been intentionally“fabricated” by any party, these instances highlight areal concern of relying on AI without applying HI (HumanIntelligence).Hallucinations arise from the fundamental nature of howLLMs work. These models predict the next most likelyword or phrase based on patterns in their training data.They do not “know” facts in the way humans do, nordo they have access to a verified database of truth.They generate text that is statistically coherent, butstatistical coherence does not guarantee factualaccuracy. If the model has never encountered specificinformation, say, a recent GST notification, it might stillgenerate a response that mimics the structure andlanguage of such notifications, creating the illusion ofknowledge where none exists.I shared an example in my previous article – pitfalls ofusing AI – about a friend who asked me to find a specificAdvance Ruling under GST. He provided details suchas the party name, the state, the case number, and thepronouncement date, all of which he claimed camefrom a Custom GPT trained on GST topics. When Isearched for it, the ruling did not exist. The AI hadhallucinated the entire case. Had my friend used thisfabricated citation in a client advisory or a legalsubmission, the consequences could have beensevere, ranging from professional embarrassment tolegal liability.Detecting hallucinations requires vigilance and asystematic approach. First, always verify criticalinformation, especially legal citations, statistics, dates,and technical details. If an AI provides a case reference,a notification number, or a specific data point, crosscheck it against official sources or reliable databases.Second, be skeptical of overly specific details thatseem too convenient or perfectly aligned with yourquery, particularly if the topic is niche or recent. Third,if possible, ask the AI to provide sources or explainits reasoning. Some advanced models can cite theirsources or indicate uncertainty, which helps flagpotential hallucinations.From a practical standpoint, treating AI-generatedcontent as a first draft rather than a final output is aprudent strategy. Use the AI to speed up the processof drafting, research, or analysis, but always applyyour professional judgment and verify the informationbefore relying on it or sharing it with clients orauthorities.Guardrails: Building Safety into AI SystemsGuardrails are mechanisms built into AI systems toconstrain their behavior, ensuring that outputs remainsafe, ethical, compliant, and aligned with userexpectations. Just as physical guardrails on a highwayprevent vehicles from veering off the road, AI guardrailsprevent the system from generating harmful,inappropriate or erroneous content.Guardrails can be implemented at multiple levels. Atthe technical level, developers incorporate filters andrules that prevent the AI from generating certain typesof content, such as illegal advice, harmful instructions,or biased outputs. At the application level,organizations can configure guardrails specific to theirdomain. For instance, a CA firm might implement arule that any AI-generated tax advice must include adisclaimer stating that it should be reviewed by aqualified professional, or that the AI should neverIT Corner

840 Ahmedabad Chartered Accountant Journal December, 2025TMaccess or process certain types of sensitive client datawithout explicit authorization.From a user perspective, understanding thatguardrails exist and can be configured is importantfor two reasons. First, it helps explain why an AI mightrefuse certain requests or provide cautious, hedgedresponses in sensitive areas. The system is not beingobstinate; it is operating within designed safetyconstraints. Second, it highlights the importance ofsetting your own professional guardrails whenintegrating AI into your practice. This includes definingwhat tasks AI should and should not handleautonomously, establishing verification protocols, andensuring compliance with data privacy regulationssuch as India’s Digital Personal Data Protection Act,2023.Professional guardrails for Chartered Accountantsmight include rules like: never upload raw clientfinancial data to a public AI model withoutanonymization, always verify legal citations providedby AI, never rely on AI-generated tax calculationswithout manual review, and ensure that any AI-assistedclient communication is reviewed for tone, accuracy,and compliance before sending. These self-imposedconstraints ensure that the convenience and speedof AI do not compromise professional standards orclient trust.Data Privacy and Client ConfidentialityOne of the most critical ethical and legal considerationsin using AI tools is data privacy. Many popular AIplatforms, especially free or consumer-grade versions,operate on cloud-based models where the data youinput is transmitted to external servers for processing.In some cases, this data may be retained and used toimprove the AI model, meaning your client’s financialinformation could inadvertently become part of thetraining data accessible to others.For Chartered Accountants, this poses a direct conflictwith professional obligations regarding clientconfidentiality. Uploading unredacted trial balances,ledgers, bank statements, or any documentscontaining personally identifiable information to apublic AI platform without client consent and withoutunderstanding the platform’s data handling policiesis a serious breach of trust and may violate dataprotection laws.The solution lies in adopting enterprise-grade AI toolsthat offer private hosting, local deployment, or explicitguarantees that user data will not be used for modeltraining. At a minimum, sensitive data should beanonymized or redacted before uploading. Personalidentifiers such as names, addresses, PAN numbers,and bank account details should be masked. However,even redacted datasets can sometimes leak patternsthat identify individuals or reveal business secrets, socaution is always warranted.Additionally, many AI platforms now offer business orprofessional tiers with enhanced privacy controls.These versions typically include features like dataencryption, compliance with industry standards, andcontractual commitments not to use customer data fortraining purposes. Investing in these tools is not just amatter of convenience but a professional and ethicalnecessity when handling client information.Understanding the AI Ecosystem: Open Source vs.Proprietary ModelsOpen Source Models: Transparency andCustomizationOpen-source AI models are those whose underlyingcode, architecture, and sometimes training data arepublicly available. Examples include models likeMeta’s Llama, Mistral, and various communitydeveloped projects. The primary advantage of opensource models is transparency. You can inspect howthe model works, understand its limitations, and evenmodify it to suit specific needs. For organizations withtechnical expertise, open-source models offer thepossibility of customization, fine-tuning on proprietarydata, and deployment in secure, on-premisesenvironments.From a data privacy perspective, open-source modelscan be particularly attractive. Because you can deploythem locally, client data never leaves your infrastructure,IT Corner

Ahmedabad Chartered Accountant Journal December, 2025 841TMeliminating concerns about third-party access or dataretention policies. This level of control is especiallyvaluable for CA firms handling sensitive financialinformation or operating in highly regulatedenvironments.However, open-source models come with trade-offs.They typically require significant technical expertiseto deploy, maintain, and optimize. Performance maylag behind cutting-edge proprietary models, andongoing support or updates depend on the communityor the sponsoring organization. For most small to midsized CA firms, the technical overhead of managingopen-source models may outweigh the benefits unlessthere is a specific need for customization or absolutedata control.Proprietary Models: Performance and ConvenienceProprietary AI models, such as OpenAI’s GPT series,Anthropic’s Claude, and Google’s Gemini, aredeveloped and maintained by commercial entities.These models are typically more polished, userfriendly, and performant than their open-sourcecounterparts. They come with extensive support,regular updates, and features like web interfaces, APIaccess, and integrations with popular productivitytools.The convenience of proprietary models is their greateststrength. You can start using them immediately withoutworrying about infrastructure, model updates, ortechnical maintenance. For most professionals, thisplug-and-play approach is the most practical option.However, this convenience comes at the cost oftransparency and control. You are dependent on thevendor’s policies regarding data privacy, pricing, andfeature availability. If the vendor changes its terms,raises prices, or discontinues the service, you havelimited recourse.When choosing between open-source and proprietarymodels, the decision should be guided by yourspecific needs, technical capabilities, and risktolerance. For general-purpose use, drafting, andresearch, proprietary models are often the best choice.For scenarios requiring maximum data privacy,customization, or long-term cost control, open-sourcemodels may be worth the investment in technicalinfrastructure.Practical Application Framework for CAsWhich Concepts Matter for Different Tasks?Understanding these advanced concepts is valuable,but knowing when and how to apply them in your dailywork is what truly matters. Here is a practical frameworkfor Chartered Accountants:For research and advisory work, RAG-enabled toolsare invaluable. They allow you to query currentregulations, recent case law, and firm-specificknowledge bases, ensuring your advice is bothaccurate and up-to-date. When researching acomplex GST issue, using a tool that can search thelatest circulars and notifications in real-timesignificantly reduces the risk of relying on outdatedinformation.For compliance automation, agentic AI holds the mostpromise. Tasks like reconciliation, data extraction,report generation, and routine correspondence canbe handled by AI agents, freeing you to focus onexceptions, client interactions, and strategic planning.However, always maintain verification protocols andnever allow the AI to execute tasks with legal or financialconsequences without human review.For client communication, prompt engineering is yourmost important skill. The ability to craft precise, contextrich prompts ensures that AI-generated drafts align withyour firm’s tone, client expectations, and professionalstandards. Investing time in mastering this skill paysimmediate dividends in the quality and usability of AIoutputs.For data analysis, understanding the limitations ofhallucinations and the importance of guardrails iscritical. Use AI to identify patterns, flag anomalies, andgenerate hypotheses, but always validate findingsthrough manual checks or cross-referencing withreliable data sources. AI is a powerful analyticalassistant, but it should not be the sole arbiter of truth.IT Corner

842 Ahmedabad Chartered Accountant Journal December, 2025TMFor sensitive or confidential work, prioritize data privacy.Use enterprise tools with robust privacy guarantees,anonymize data before uploading, and establish clearinternal policies about what information can and cannotbe shared with AI systems. Your professionalreputation and client trust depend on maintainingconfidentiality.Building a Balanced AI PracticeThe goal is not to adopt AI indiscriminately but tointegrate it thoughtfully, leveraging its strengths whilemitigating its weaknesses. This requires a balancedapproach: AI for speed and efficiency, humanprofessionals for rigor, judgment, and ethicaloversight.Start by identifying high-volume, low-risk tasks in yourworkflow that are prime candidates for AI automation.These might include initial drafts of routinecorrespondence, data formatting and cleaning,preliminary research summaries, or generatingchecklists and templates. Gradually expand AI usageas you develop confidence in the technology andestablish robust verification processes.Invest in continuous learning. AI is evolving rapidly,and staying informed about new capabilities, emergingrisks, and best practices is essential. Encourage yourteam to experiment with different tools, share insights,and develop a collective understanding of what worksand what does not.Finally, maintain a critical mindset. AI is a tool, not apanacea. It can augment your capabilities, but it cannotreplace your expertise, judgment, or professionalresponsibility. The professionals who thrive in the AIera will be those who master the art of collaborationwith these systems, knowing when to rely on them,when to question them, and when to override them.Conclusion: Empowered by UnderstandingThe rapid evolution of AI presents both extraordinaryopportunities and significant challenges for CharteredAccountants. By understanding the terminology andconcepts that underpin these technologies, from LLMsand SLMs to RAG, agentic AI, hallucinations, guardrails,and the distinction between open-source andproprietary models, you position yourself to makeinformed decisions about how to integrate AI into yourpractice.The knowledge gap that once made AI feel like anintimidating black box is now closable. You do notneed to become a data scientist to use these toolseffectively. What you do need is a conceptualframework for understanding how they work, what theycan and cannot do, and how to interact with them inways that maximize value while minimizing risk.The AI revolution is not slowing down. If anything, thepace of innovation is accelerating. But as we haveexplored in this series, understanding the languageand logic behind AI transforms it from a source of anxietyinto a source of competitive advantage. It empowersyou to leverage these tools confidently, responsibly,and effectively, ensuring that your professional practicenot only keeps pace with technological change butthrives because of it.The future belongs to those who understand and masterthese tools, not as passive users but as informed,empowered professionals who blend human judgmentwith machine capability. Armed with the knowledge fromthis series, you are well-equipped to navigate thatfuture with confidence.IT Corner

Ahmedabad Chartered Accountant Journal December, 2025 843TMRise of Resilience: Gujarat’s First Dedicated WomenIndustrial Park Becomes a Beacon of EmpowermentGujarat has always been a land of enterprise, courage,and innovation. Yet, history is being written anew atSanand GIDC with the establishment of the state’s firstever dedicated Women Industrial Park, a landmarkinitiative that places women entrepreneurs at the centerof Gujarat’s industrial future.This vision did not emerge overnight. It is the outcomeof years of commitment, grassroots engagement, andrelentless passion led by Nita Shah, President ofVibrant Women Industrial Networking Association.Coming from a modest textile family, Nita grew upwitnessing both the fragility and the strength of businesslife , from boom phases to deep downturns, from riskto reinvention. But instead of deterring her, theseexperiences shaped her into a leader who understoodthe power of resilience and the importance of creatingopportunities for women who aspire to stand on theirown feet.The Women Industrial Park at Sanand is more thanan industrial zone , it is a movement. A movementthat brings together government support, CSR backedtraining, entrepreneurship development, and a platformwhere women can transform ideas into thrivingenterprises. The Gujarat government has extendedsubsidies and policy support, ensuring womenownedunits receive the boost they need during their earlyyears. This financial handholding has already begunattracting first generation women entrepreneurs, manyof whom had talent but lacked resources or structuredguidance.A defining pillar of this ecosystem is skill andentrepreneurship training, delivered through the Centerof Entrepreneurship Institute, NGOs, and corporatesunder their CSR missions. From financial literacy todigital skills, from supply chain management to productinnovation, the training modules are curated to equipwomen with real world capabilities. Over the years,Nita Shah has personally trained more than one lakhwomen , a contribution that has quietly but powerfullyshaped the economic and social landscape of Gujarat.These women are now artisans, microentrepreneurs,factory supervisors, and business owners who carryforward the belief that independence is not a luxury , itis a necessity.The launch of this industrial park is a testimony to thetransformative potential of collective effort. Imagine themultiplier effect: one woman who becomes financiallyindependent uplifts her family, educates her children,supports her community, and inspires more women tostep forward. When thousands of such women cometogether in one industrial cluster, the outcome is notjust economic development , it is social evolution.CA. Siddharth Bhatt CSR Stories [email protected] to page 844

844 Ahmedabad Chartered Accountant Journal December, 2025TMCA. Sulabh PadshahHon. SecretaryAssociation NewsCA. Ashish SharmaHon. Secretary1. Glimpses of Past Events.Day & Date Program Speaker Venue23th December- 2025- CAAA Winter League -2025 - Ground 83,27th December-2025 Nr Sardar Dham,AhmedabadCAAA organised its Winter Cricket League with 10 teams participating and more than 100 Chartered Accountants playing their best game.The Sports Committee headed by CA Jay Parekh set a new benchmark with the event being a great success. It was appreciated by all theparticipants and turned out to be very good break after the taxing season.2. Forthcoming Events.Day & Date Program Speaker Venue19th January, 2026 Cricket Match- President XI vs Secretary XI - Sardar Patel Stadium,Saturday Navrangpura,AhmedabadGujarat’s Women Industrial Park is poised to becomea hub of innovation, manufacturing, andentrepreneurship powered entirely by women. It willgenerate employment, encourage newage businessideas, and strengthen MSME participation led bywomen. Most importantly, it sends a powerful message, that gender is not a barrier to ambition, leadership,or success.As Gujarat takes this bold step, it sets a precedent forthe entire nation. A dedicated industrial park for womenis not just infrastructure; it is an investment in thedreams, strengths, and futures of millions of womenwho dare to build.And at the heart of this revolution stands one woman ,Nita Shah, whose leadership proves that when womenrise, families prosper, industries grow, and the nationmoves forward.This is just the beginning. The Women Industrial Parkat Sanand is not merely a destination , it is a doorwayto a new India where women are not just contributorsbut creators of tomorrow’s economy.Continued from page 843 CSR Stories

Ahmedabad Chartered Accountant Journal December, 2025 845TMAcross1. In performing the Internal Audit, Auditor has to applythe principles and broad guidelines laid down bythe _____________ on Internal Audit issued by ICAIfrom time to time.2. In an _______ merger, the foreign holding companymerges into its wholly owned Indian subsidiary.3. _____________ is an independent managementfunction, which involves a continuous and criticalappraisal of the functioning of an entity with a viewto suggest improvements thereto and add valueand strengthen the overall governancemechanism.ACAJ Crossword Contest - 54Notes:1. The Crossword puzzle is based on this issue ofACA Journal.2. Two lucky winners on the basis of a draw will beawarded prizes.3. The contest is open only for the members ofChartered Accountants Association and nomember is allowed to submit more than one entry.4. Members may submit their reply either physicallyat the office of the Association or by emailat [email protected] on or before31-01-20265. The decision of Journal Committee shall be finaland binding.Prize CourtesyWinners of ACAJ Crossword Contest – 531. CA. Atul Shah2. CA. Rinkesh ShahACAJ Crossword Contest 53 - SolutionAcross: Down:1. Control 4. Practice2. RealEstate 5. December3. Life 6. LargeDown4. The market for AI in accounting is growing at morethan __________ percent annually.5. ___________ refers to the strategic restructuringof a corporate group whereby the ownership of aforeign parent company is transferred andconsolidated into its Indian subsidiary.6. From November 2025 tax period onwards, valueof supplies auto-populated in Table 3.2 of GSTR3Bshall be ___________.