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Control CheckArticle·7 June 2026

Control Check list for BFS space

By J the App

Executive Summary

The financial services sector continues to remain one of the most litigated and scrutinised sectors under the Goods and Services Tax (GST) regime. Banks, Non-Banking Financial Companies (NBFCs), fintech platforms, payment service providers, asset management companies, stock brokers, depositories and global capability centres operate through complex business models involving exempt supplies, taxable supplies, securities transactions, cross-border services, technology platforms, shared service arrangements and multiple revenue streams.

The evolving GST jurisprudence, increasing use of data analytics by tax authorities, industry-wide investigations by the Directorate General of GST Intelligence (DGGI), and heightened focus on input tax credit reversals, cross-charge mechanisms, valuation disputes and intermediary exposures have significantly increased GST risk across the BFSI sector.

This BFSI GST Risk Review Checklist has been designed as a comprehensive governance and control framework to assist organisations in identifying, evaluating and mitigating GST risks across the enterprise. 

The checklist covers traditional banking and lending operations, treasury activities, payment systems, fintech ecosystems, wealth management services, insurance distribution models, technology arrangements, global capability centre transactions and emerging digital business models.

The objective is not merely to test compliance with GST provisions but to assess whether the organisation possesses a sustainable tax governance framework capable of withstanding regulatory scrutiny, departmental audits, DGGI investigations and litigation challenges.

The implementation of the Goods and Services Tax has fundamentally transformed the indirect tax landscape for the Banking, Financial Services and Insurance...

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