Analysis of Notifications and Circulars for Week ending 19th January 2025

Summary: The week ending 19th January 2025 saw significant updates across multiple regulatory domains. In income tax, the Central Power Research Institute (CPRI) was notified as a research association under Section 35(1)(ii), and the Supreme Court ruled that share capital reduction constitutes a transfer under Section 2(47). GST updates included the generation of Draft GSTR-2B for December 2024, revised GST rates on fortified rice kernels, exemptions for gene therapy, and rate changes for used vehicles and hotel services. Customs notifications highlighted updates to duty exemptions for Long Range Surface to Air Missile Systems and the addition of new cargo facilities in Virudhunagar and Kurukshetra. SEBI extended timelines for ESG rating reviews and mandated Information Ratio disclosures for mutual funds. In DGFT updates, a new Dubai laboratory was added for diamond certification, and a standard procedure was outlined for voluntary disclosure of export violations. Notable court judgments addressed the retention of seized cash post-assessment period, the protection of visually impaired AIBE candidates’ rights, and restrictions on re-writing contractual terms by the National Consumer Commission. Additionally, EPFO simplified transfer guidelines for Aadhaar-linked accounts, enhancing ease for members. These updates reflect evolving regulations and judicial interpretations, impacting businesses and individuals alike.

Notifications & Circulars issued during week (13^th – 19^th Jan 2025)

A. Income Tax

Central Power Research Institute (CPRI), Bengaluru notified under section 35(1)(ii) as Research Association for Scientific Research:  The notification notifies Central Power Research Institute (CPRI), Bengaluru  under the category of ‘Research Association’ for ‘Scientific Research’ for the purposes section 35(1)(ii) of the Income-tax Act, read with rules 5C and 5E of the Income-tax Rules. This section allows for deduction equal to one and half times while computing taxes for expenses relating to scientific research. (Income Tax Notification 07/2025 Dated 14/01/2025)

SC, Reduction in share capital results into transfer of capital asset under section 2(47) of Income Tax Act: Case of PCIT vs Jupiter Capital Pvt Ltd, SC Judgement Dated 2nd January 2025. The apex court has held that the reduction in share capital of the subsidiary company and subsequent proportionate reduction in the shareholding of the assessee would be squarely covered within the ambit of the expression “sale, exchange or relinquishment of the asset” used in Section 2(47) the Income Tax Act. Accordingly, petition of revenue dismissed. (SC Judgement Dated 03/01/2025)

HC, Authorities cannot retain seized cash after expiry of period for framing assessment under section 153A of Income tax Act: Case of Gautam Thadani vs Director Income Tax (Investigation), HC Delhi Judgement Dated 10th January 2025. High court has held that income tax authorities cannot retain seized cash once time period for framing an assessment under section 153A of the Income Tax Act has expired and there is no outstanding demand. (HC Delhi Judgement Dated 10/01/2025)

B. GST

Advisory, Generation date for draft GSTR 2B for December 2024:  It is informed that, in light of the extended due dates for filing GSTR-1 and GSTR-3B returns for the month of December 2024 (Quarter Oct-Dec 2024) as per Notifications No. 01/2025 and 02/2025 dated 10th January 2025, the Draft GSTR-2B for the month of December 2024 (Quarter Oct-Dec 2024) will now be generated on 16th January 2025 in accordance with the rule 60 of CGST Rules. (GSTN Advisory Dated 14/01/2025)

Advisory for Waiver Scheme under Section 128A: It is informed that both Forms GST SPL 01 and GST SPL 02 are available in the GST portal and the taxpayers are advised to file applications under waiver scheme. SPL-01 is application for waiver of interest or penalty or both in case of notice or statement. SPL-02 is application for waiver of interest or penalty or both in case of demand order. (GSTN Advisory Dated 14/01/2025)

Amendments to Pre-Packaged and Labelled definition & GST Rates for Fortified Rice Kernel (FRK): The notification, effective from 16^th January 2025 (amends earlier notification 01/2017 dated 28^th June 2017), reduces the GST rate on FRK, classifiable under HSN 1904, to 5%. The amended definition of ‘pre-packaged and labelled’ will now cover all commodities that are intended for retail sale and containing not more than 25 kg or 25 litre, which are ‘pre packed’ as defined under the Legal Metrology Act, or a label affixed thereto is required to bear the declarations under the provisions of the Act and rules. (CGST Notification 01/2025 (Rate) Dated 16/01/2025)

— Similar amendments have been made in IGST and UTGST Act. (IGST Notification 01/2025 (Rate) Dated 16/01/2025) (UTGST Notification 01/2025 (Rate) Dated 16/01/2025)

Exemption to Gene Therapy from GST: The notification, effective from 16^th January 2025 (amends earlier notification 02/2017 dated 28^th June 2017), adds Gene Therapy (HSN Code 30) to the list of GST-exempt goods under the Schedule. It also revises the definition of “pre-packaged and labelled” goods to include retail commodities in packages not exceeding 25 kg or 25 litres, in alignment with the Legal Metrology Act, 2009. (CGST Notification 02/2025 (Rate) Dated 16/01/2025)

— Similar amendments have been made in IGST and UTGST Act. (IGST Notification 02/2025 (Rate) Dated 16/01/2025) (UTGST Notification 02/2025 (Rate) Dated 16/01/2025)

GST @ 5% on Food Inputs for Free Distribution under Government Programs: The notification, effective from 16^th January 2025 (amends earlier notification 39/2017 dated 18^th October 2017), introduces a concessional 5% GST rate on food inputs classified under HSN 19 or 21, intended for use in food preparations distributed free of charge to economically weaker sections under government programs. (CGST Notification 03/2025 (Rate) Dated 16/01/2025)

— Similar amendments have been made in IGST and UTGST Act. (IGST Notification 03/2025 (Rate) Dated 16/01/2025) (UTGST Notification 03/2025 (Rate) Dated 16/01/2025)

GST Rate Increased to 18% on Old and Used Vehicles including Electric Vehicles (EVs): The notification, effective from 16^th January 2025 (amends earlier notification 08/2018 dated 25^th January 2018), increase the GST rate from 12% to 18% on the sale of all old and used vehicles, including electric vehicles (EVs), except for those already specified at 18% GST rate. (CGST Notification 04/2025 (Rate) Dated 16/01/2025)

— Similar amendments have been made in IGST and UTGST Act. (IGST Notification 04/2025 (Rate) Dated 16/01/2025) (UTGST Notification 04/2025 (Rate) Dated 16/01/2025)

GST Rate Changes for Hotels and Restaurant Services: The notification, effective from 1^st April 2025, omits the definition of “declared tariff” and revises the definition of “specified premises.” The revised definition links the GST rate for restaurant services in hotels to the value of hotel accommodation supplied in the previous financial year. If the accommodation exceeds Rs 7,500 per unit per day, the GST rate for restaurant services will be 18% with Input Tax Credit (ITC), and 5% without ITC otherwise. It also allows hotels to opt for 18% GST with ITC for restaurant services, provided they file a declaration before the start of the financial year or upon registration. Furthermore, new declarations for “specified premises” must be filed by registered persons or new applicants. (CGST Notification 05/2025 (Rate) Dated 16/01/2025)

— Similar amendments have been made in IGST and UTGST Act. (IGST Notification 05/2025 (Rate) Dated 16/01/2025) (UTGST Notification 05/2025 (Rate) Dated 16/01/2025)

GST Exemption on Insurance Contributions to Motor Vehicle Accident Fund: The notification (amends earlier notification 12/2017 dated 28^th June 2017), exempts GST on contributions made by general insurance companies to the Motor Vehicle Accident Fund. This fund, constituted under Section 164B of the Motor Vehicles Act, 1988, aims to provide compensation and cashless treatment to victims of road accidents, including hit-and-run cases. The exemption applies to contributions from third-party motor vehicle insurance premiums collected by insurers. (CGST Notification 06/2025 (Rate) Dated 16/01/2025)

— Similar amendments have been made in IGST and UTGST Act. (IGST Notification 06/2025 (Rate) Dated 16/01/2025) (UTGST Notification 06/2025 (Rate) Dated 16/01/2025)

Composition Taxpayers are excluded from Reverse Charge: The notification, effective from 10^th October 2024 (amends earlier notification 13/2017 dated 28^th June 2017), excludes taxpayers registered under the composition levy scheme from the reverse charge mechanism applicable to the renting of commercial or immovable property (other than residential dwellings) by unregistered persons to registered persons. This change addresses the concerns of businesses registered under the composition scheme, exempting them from the reverse charge obligations. (CGST Notification 07/2025 (Rate) Dated 16/01/2025)

— Similar amendments have been made in IGST and UTGST Act. (IGST Notification 07/2025 (Rate) Dated 16/01/2025) (UTGST Notification 07/2025 (Rate) Dated 16/01/2025)

Definition of “Specified Premises”: The notification, effective from 1^st April 2025 (amends earlier notification 11/2017 dated 28^th June 2017), aligns the term “specified premises” with the definition given in clause (xxxvi) of paragraph 4 of the notification. (CGST Notification 08/2025 (Rate) Dated 16/01/2025)

— Similar amendments have been made in IGST and UTGST Act. (IGST Notification 08/2025 (Rate) Dated 16/01/2025) (UTGST Notification 08/2025 (Rate) Dated 16/01/2025)

Compensation Cess reduced to 0.1% on supplies to merchant exporters: The notification, effective from 16^th January 2025, reduces the rate of compensation cess on intra-state and inter-state supplies of taxable goods made by a registered supplier to a registered recipient for export. The cess is reduced to 0.1% subject to specified conditions, including the issuance of a tax invoice, export within 90 days, and compliance with documentation requirements such as mentioning GSTIN and tax invoice numbers in export bills. The recipient must be registered with an Export Promotion Council or Commodity Board and provide details to the jurisdictional tax officer. Goods must be transported directly to export points or through registered warehouses, with proper endorsements and acknowledgments for aggregated supplies. (GST CESS Notification 01/2025 Dated 16/01/2025)

Guidelines for Arrest and Bail in relation to offences punishable under CGST Act: The amendment follows the Delhi High Court’s ruling in Kshitij Ghildiyal vs DGGI, which emphasized that the grounds for arrest must be communicated in writing to the accused. It aligns with prior SC judgments, which highlighted the distinction between “reasons for arrest” and “grounds of arrest.” While reasons for arrest focus on formal justifications such as preventing further offences or ensuring evidence preservation, grounds of arrest must include specific facts justifying the individual’s detention. The SC emphasised that providing written grounds of arrest is essential to enable the accused to challenge custodial remand or seek bail effectively. CBIC has now mandated that grounds of arrest must be explained to the accused and furnished in writing as an annexure to the arrest memo. (CGST Instructions  01/2025 Dated 13/01/2025)

SC stayed GST notices against online gaming firms: Case DGGSTI vs Gameskraft Technologies, SC Judgement Dated 10th January 2025. The apex court has stayed show-cause notices for goods and services tax (GST) worth a staggering Rs 1.12 lakh crore issued to online gaming companies. It provides temporary relief to the gaming sector while safeguarding the interests of the revenue department. The next hearing on the matter is scheduled for 18^th March 2025.

— The GST law has been amended to impose a 28% tax on the “full face value” of bets or entry amounts in online games, effective October 2023. Online gaming companies argued that the 28% tax should apply only from 1^st October 2023. However, the government contended that the revision clarified an existing law. In online gaming, the prize pools are held in escrow accounts by gaming operators, and the claim of a winner on the money becomes an actionable claim under law. While actionable claims were not previously applicable to online gaming, they were included under the amended GST laws effective from 1^st October 2023.  

HC, Commissioner can Conduct GST Audits Without Restrictions on Frequency or Time: Case of Mag Filter and Equipment Pvt Ltd vs Comm CGST Gurgaon, HC Punjab and Haryana Judgement Dated 11/12/2024. The petitioner argued that the audit was unnecessary as earlier anti-evasion actions and notices under Section 73 had resulted in a tax demand of ₹70.35 crore (along with interest), which was already paid. It also contended that the fresh audit for the same period (FY 2017-22) caused undue harassment and was unwarranted since no new tax evasion was alleged. The High Court, however, dismissed the petition, noting that section 65 of the CGST Act allows the Commissioner to conduct audits without restrictions on frequency or time. (HC P&H Judgement Dated 11/12/2024)

HC, GST levy on licence fees collected by Electricity Regulatory Commissions (ERCs) is invalid: Case of Central Electricity Regulatory Commission Vs Additional Director Directorate General of GST Intelligence (DGGI) & Anr., HC Delhi Judgement dated 15th January 2024. Tax authorities sought to draw a dichotomy between the ‘adjudicatory’ and ‘regulatory’ functions discharged by these two statutory bodies to essentially hold that the revenue earned from the latter would be subject to tax under the CGST and IGST Acts. The court observed that grant of a licence to transmit or distribute is clearly not in furtherance of business or trade but an extension of the statutory obligation placed upon a Commission to regulate those subjects. HC quashed the GST levy on licence fees collected by Electricity Regulatory Commissions. (HC Delhi Judgement Dated 15/01/2025)

HC stays GST circular on corporate guarantees following Vedanta petition: Case of Vedanta Limited vs Union of India, HC Bombay Judgement Dated 8th January 2025. The petitioner company sought a declaration that the activity of a holding company providing a corporate guarantee to its subsidiary is not a ‘supply’ and/or ‘supply of service’ taxable under GST law. HC has stayed the effect and operation of the GST Circular relating to corporate guarantee. It granted time to the Respondents (Central Governments and others) to file their affidavit- in-reply. (HC Bombay Judgement Dated 08/01/2025)

C. Central Excise

No Notification/ Circular during the week.

D. Custom Duty

Customs Duty exemption for International Atomic Energy Agency (IAEA) inspection equipment: The notification exempts all equipment and consumable samples imported by the International Atomic Energy Agency (IAEA) Inspection Team from customs duty and integrated tax, subject to specific conditions. It is aimed at facilitating nuclear verification and inspections under international agreements. (Custom Notification 01/2025 (T) Dated 16/01/2025)

Custom Duty exemption update for Long Range Surface to Air Missile System (LRSAM) Systems and Parts: The updated description now includes “systems, sub-systems, equipment, parts, sub-parts, tools, test equipment, and software meant for LRSAM.” These items are eligible for customs duty exemptions under Section 25 of the Customs Act, and Section 3(12) of the Customs Tariff Act. (Custom Notification 02/2025 (T) Dated 16/01/2025)

New Cargo Facility at Virudhunagar, Ahmedabad: The notification adds Virudhunagar, Ahmedabad in Gujarat to the list of locations for the unloading of imported goods and loading of export goods or any class of such goods. (Custom Notification 01/2025 (NT) Dated 14/01/2025)

Amend Sea Cargo Manifest and Transhipment Regulations: The notification has extended the date till 31^st March 2025, by which the specific transitional provisions are applicable. (Custom Notification 02/2025 (NT) Dated 15/01/2025)

Fixation of Tariff Value of Edible Oils, Brass Scrap, Areca Nut, Gold and Silver: CBDT notified the Tariff Values of Edible Oils, Brass Scrap, Areca Nut, Gold and Silver, which shall come into force w.e.f. 16^th January 2025. The tariff value for crude palm oil is set at USD 1137 per metric ton, while gold and silver have tariff values of USD 858 per 10 grams and USD 961 per kilogram, respectively. The tariff value for areca nuts is fixed at USD 6448 per metric ton. (Custom Notification 03/2025 (NT) Dated 16/01/2025)

New Cargo Facility at Dhirpur, Kurukshetra: The notification adds Dhirpur, Kurukshetra, in Haryana to the list of locations for the unloading of imported goods and loading of export goods or any class of such goods. (Custom Notification 04/2025 (NT) Dated 17/01/2025)

Extension of Sea Cargo Manifest and Transhipment Regulations (SCMTR) implementation for certain ports: The original schedule for SCMTR, which began phase wise implementation across nine sea ports, faced challenges with filing of certain SCMTR messages. As a result, the implementation has been extended vide notification 02/2025 (NT) dated 15^th January 2025, as an interim measure to ensure smooth EXIM operations without penalizing the trade community. The extension aims to allow adequate time for stakeholders to comply with the regulations. (Custom Circular 02/2025 Dated 17/01/2025)

HC, Recovery of encashment of bank guarantee cannot be made effective until expiry of appeal period: Case of Amar Singh and Sons Tree Nuts LLP vs Superintendent of Customs, HC Delhi Judgement Dated 9th January 2025. After considering the submission of the parties, it has been held that, no coercive measures can be taken against the petitioner during the period when the limitation for filing of the appeal has not expired. In addition, if the pre-deposit has already been made the remaining amount cannot be recovered by encashment of the bank guarantee. Hence, department is restrained from any recovery. (HC Delhi Judgement Dated 09/01/2025)

E. Directorate General of Foreign Trade (DGFT)

Notification of Schedule-II (Export Policy), in sync with Finance Act 2024: The notification consolidates the export policy of all ITC(HS) codes, including applicable conditions. The notification also revises the General Notes to the Export Policy to ensure consistency with the updated schedule. (DGFT Notification 50/2025 Dated 13/01/2025)

SOP for Voluntary Disclosure of Non Compliance/ Violations related to Export of SCOMET Items: The Public Notice details the Standard Operating Procedure (SOP) for voluntary disclosure of non-compliance or violations related to the export of SCOMET items. It aims to encourage exporters to disclose unintentional violations of export control laws under the Foreign Trade Policy, Weapons of Mass Destruction Act, and Customs Act. Voluntary disclosures apply to unauthorized exports, misuse of authorizations, and other violations, excluding SCOMET Category 0 and specific CWC schedules. The DGFT processes and places all voluntary disclosure cases before the Inter-Ministerial Working Group (IMWG)  for recommendations, ensuring adherence to applicable laws. (DGFT Public Notice 40/2025 Dated 15/01/2025)

Addition of new laboratory GIA Laboratory, DMCC, Dubai, UAE: A new entry, “GIA Laboratory, DMCC, Dubai, UAE,” has been added to Paragraph 4.73 of the Handbook of Procedures. This inclusion authorizes the GIA Laboratory in Dubai to certify and grade diamonds of 0.25 carat and above. (DGFT Public Notice 41/2025 Dated 15/01/2025)

F. Securities and Exchange Board of India (SEBI)

Timeline for Review of ESG Rating pursuant to occurrence of Material Events: Initially, ESG Rating Providers (ERPs)  were required to review ratings within 10 days of material developments, including Business Responsibility and Sustainability Reporting (BRSR) publication. However, in response to operational challenges cited by ERPs, SEBI has extended the review period for BRSR-related updates to 45 days. Reviews for other material events must still occur within 10 days. (SEBI Circular Dated 17/01/2025)

Disclosure of Information Ratio (IR) for Mutual Fund Schemes: The circular mandate the disclosure of the Information Ratio (IR) for equity-oriented mutual fund schemes. This measure aims to provide a more comprehensive view of risk-adjusted returns (RAR) for investors. AMCs are required to calculate IR using a standardized formula that incorporates portfolio and benchmark returns along with the standard deviation of excess returns. (SEBI Circular Dated 17/01/2025)

Consultation Paper, Amendments to LODR Regulations, for encouraging dematerialization of securities and streamlining processes: The key proposals include mandating the issuance of securities in dematerialized form for actions like stock splits, consolidations, and schemes of arrangements (mergers/demergers). Moreover, certain outdated provisions, including the registration of transfers and maintaining proof of delivery, are suggested for removal. The comments/ feedback from stakeholders is invited. (SEBI Consultation Paper Dated 14/01/2025)

G. Ministry of Corporate Affairs (MCA)

No Notification/ Circular during the week.

H. Insolvency and Bankruptcy Board of India (IBBI)

NCLAT, Assessment proceedings cannot be continued by EPFO after initiation of moratorium under section 14(1) of IBC: Case of EPFO Regional Office vs Jaykumar Pesumal Arlani, NCLAT Delhi Judgement Dated 3rd January 2025. The Appellant Authority has held that after initiation of moratorium under section 14(1) of the Insolvency and Bankruptcy Code, 2016 [IBC], no assessment proceedings can be continued by EPFO. Accordingly, appeal dismissed. (NCLAT Delhi Judgement Dated 03/01/2025)

I. Reserve Bank of India (RBI)

Coverage of customers under the nomination facility: The notification mandates that all deposit accounts, safe custody articles, and safety lockers must have a nomination. Financial institutions are required to raise awareness and encourage customers to use the nomination facility. The Customer Service Committees of these entities will regularly review progress, and quarterly reports will be submitted to the RBI starting March 31, 2025. (RBI Notification 104/2025 Dated 17/01/2025)

Prevention of financial frauds perpetrated using voice calls and SMS: RBI has directed regulated entities (REs) such as banks, co-operative banks, and NBFCs to utilize the Mobile Number Revocation List (MNRL) to prevent misuse. REs must implement Standard Operating Procedures (SOPs) to monitor accounts linked to revoked numbers and ensure customer care numbers are verified with the Department of Telecommunications (DoT) for inclusion on the “Sanchar Saathi” portal. The guidelines also stress the use of specific numbering series for transactional and promotional calls, aiming to reduce fraud risks. (RBI Notification 105/2025 Dated 17/01/2025)

Amendment to FEMA Deposit Regulations: The key changes include, the allowance for authorised dealers’ branches outside India to handle deposits and the facilitation of fund transfers between repatriable Rupee accounts for bona fide transactions. It also expand the scope of Special Non-Resident Rupee (SNRR) accounts, permitting their use for  permissible current and capital account transactions with both Indian residents and persons outside India. Units in International Financial Services Centres (IFSCs) can now open SNRR accounts with authorised dealers in India for business transactions outside the IFSC. (RBI FEMA Notification Dated 14/01/2025)

Amendment to FEMA Currency Accounts by a person resident in India Regulations: The changes enable Indian exporters to open, hold, and maintain foreign currency accounts with overseas banks. These accounts may be used for the realisation of export earnings, advance remittances, and import payments. However, exporters must repatriate any remaining funds to India by the end of the subsequent month after adjusting for forward commitments. (RBI FEMA Notification Dated 14/01/2025)

Amendment to FEMA Mode of Payment and Reporting of Non- Debt Instruments Regulations: The changes streamline payment methods and reporting for investments by persons residing outside India. Equity instruments can be purchased or sold through inward remittance, foreign currency accounts, or repatriable Rupee accounts. Companies must issue shares within 60 days of receiving payment. Foreign Portfolio Investors (FPIs) can use foreign currency or Special Non-Resident Rupee (SNRR) accounts for investments, with remittance options for sale proceeds. Payments for investments in Limited Liability Partnerships, investment vehicles, and Indian Depository Receipts can be made through inward remittance or designated accounts. Sale or maturity proceeds can be repatriated or credited to specified accounts. Indian startups issuing convertible notes must receive payments via inward remittance or designated accounts. Sale or repayment proceeds can be remitted outside India or credited to such accounts. (RBI FEMA Notification Dated 14/01/2025)

SC, National commission cannot re-write terms of contract entered between bank and credit cardholder: Case of Hongkong and Shanghai Banking Corp vs AWAZ, SC Judgement Dated 20th December 2024. The appeal was filed against judgement of National Consumer Disputes Redressal Commission, which had held that the charging of interest at rates ranging from 36% to 49% p.a. is exorbitant and amounts to the exploitation of the borrowers/debtors and is usurious. The apex court held that the National Commission had no jurisdiction to re-write the terms of the contract entered between the banks and the credit cardholders, which the parties have mutually agreed to be bound by. Thus, RBI cannot be directed to impose cap on charging interest from credit cardholders in case of default and delay in payment not questionable. (SC Judgement Dated 20/12/2024)

J. Miscellaneous

Simplified Employee Provident Fund (EPF) Account Transfer Guidelines: The requirement to route online transfer claims through either the previous or current employer has been removed in certain cases. These include transfers involving Member IDs linked with the same or different UANs, provided the UANs were issued on or after 1^st October 2017, and are Aadhaar-linked. Transfers involving UANs issued before 1^st October 2017, are also eligible if linked with Aadhaar and if key details (name, date of birth, and gender) are consistent across the Member IDs. (EPFO Circular Dated 15/01/2025)

SC Allows Visually Impaired to Take AIBE on Computer: Case of Yash Dadani vs Union of India, SC Judgement Dated 11^th December 2024. The apex court addressed the issue of providing equal opportunities for visually challenged candidates appearing for the All India Bar Examination (AIBE). The petitioners requested that visually impaired students be allowed to take the AIBE exam on a computer, rather than using a scribe. The Bar Council of India (BCI), in response, expressed willingness to accommodate the option of a scribe but also recognized the need for facilitating computer based responses for candidates who preferred this method. SC after reviewing the issue, directed the BCI to make all necessary arrangements for visually impaired candidates to answer the exam questions on a computer if they so wished, while also allowing them the choice of using a scribe.

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Disclaimer: The contents of this article are for informational purposes only. The user may refer to the relevant notification/ circular/ decisions issued by the respective authorities for specific interpretation and compliances related to a particular subject matter)