Hyderabad jewellers: PMLA Reporting Entity registration, 269ST cash rules, BIS hallmarking — under one engagement.

Notification S.O. 4713(E) dated 28 December 2020 brought dealers in precious metals and precious stones into the designated-business framework under the Prevention of Money-laundering Act when they engage in cash transactions of ₹10 lakh or more — whether in one operation or linked operations. A Hyderabad jeweller crossing that threshold is a Reporting Entity by operation of law, not by FIU-IND notice. The absence of a notice is not a defence. The obligation is to register with FIU-IND, appoint a Principal Officer, and maintain due-diligence, recordkeeping and reporting controls.

No. Section 269ST tests receipts from one person on one day across the business — not per counter or per branch. A customer paying ₹1.9 lakh at the Abids showroom in the morning and ₹1.9 lakh at the Secunderabad branch in the evening has paid ₹3.8 lakh to the same business from the same person in one day, breaching limb (a). The section 271DA penalty can equal the prohibited receipt. For the PMLA connected-transaction test, the same-customer aggregation applies across all locations within the reporting period.

Hyderabad is a mandatory hallmarking district. Old-hallmarked jewellery without the six-digit HUID cannot be sold as a new retail article in a mandatory district without being re-hallmarked at a BIS-registered Assaying and Hallmarking Centre. The transition window BIS provided has closed for most categories. The specific article type and applicable Quality Control Order must be checked before making a new sale of old-hallmark stock.

Rule 32(5)'s margin scheme is available only when a registered dealer buys and resells second-hand goods as such or after minor processing that does not change their nature — and provided no input tax credit was taken on the purchase. Melting old gold and manufacturing a new article does not ordinarily satisfy the resale-as-such condition. The Telangana SGST authority has been examining this position in audits of gold dealers; treating the margin scheme as automatically available for all old-gold purchases is a documentation and classification risk.

Per customer, per period — not per invoice. Rule 3(1)(A) of the Prevention of Money-laundering (Maintenance of Records) Rules requires a Cash Transaction Report for cash transactions of ₹10 lakh or more with a customer — whether in a single operation or in several operations that appear linked within a month and whose aggregate exceeds ₹10 lakh. A series of individually smaller receipts from the same customer or related family that appear integrally connected must be aggregated before the CTR decision is made.