Harun Raaj & AssociatesHarun Raaj & Associates

Jeweller compliance · Hyderabad & Vizag · Integrated

The jeweller's compliance rhythm — one engagement, six statutes.

Most family-run jewellers still use one accountant for GSTR filing, another for the ITR, and treat BIS and PMLA as event-driven work. The customer-level cash trail, HUID register, GST books and year-end stock therefore reach different reviewers at different times. That fragmented model is the recurring source of s.269ST and s.271DA proceedings, unsupported explanations and FIU-IND communications. We place the six workstreams on one operating calendar for jewellers from ₹5 crore to ₹200 crore.

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What's inside the engagement

1

PMLA reporting rhythm

Review customer-level cash receipts for reportable transactions and connected transactions. Prepare CTR data for filing, obtain the Principal Officer’s sign-off, maintain a monthly internal nil-return register where no CTR is reportable, and document STR judgments without treating suspicion as a mechanical threshold test. Month-one onboarding includes FINnet registration with FIU-IND and formal nomination of the Principal Officer and Designated Director.

Cadence: Monthly review and reporting cycle, with unusual activity escalated when identified.

You provide: Cash-receipt ledger by customer, customer-identification records, invoice trail, connected-party indicators and explanations for unusual transactions.

Statutory basis: S.O. 4713(E); Rules 3(1)(A), 7 and 8 of the Prevention of Money-laundering (Maintenance of Records) Rules, 2005

2

s.269ST + 206C(1F) + 40A(3) exception discipline

Test shop-floor receipts against the person, single-transaction and one-event or occasion limbs of s.269ST. Maintain a daily exception log, conduct a weekly aggregated review and assemble a contemporaneous reasonable-cause file if a potential s.271DA exposure arises. Separately control TCS under s.206C(1F), including collection, deposit, customer mapping and the applicable Form 27EQ return cycle. Cash expenditure exceptions under s.40A(3) and Rule 6DD are documented rather than assumed.

Cadence: Daily capture, weekly exception review, monthly TCS close and quarterly Form 27EQ filing.

You provide: Shop cash register, invoice register, customer master, payment-mode data, advance and settlement records, expense vouchers and TCS challans.

Statutory basis: ss.269ST, 271DA, 206C(1F) and 40A(3) Income-tax Act, 1961; Rule 6DD Income-tax Rules, 1962

3

GST — normal + margin scheme + s.194Q reconciliation

Prepare GSTR-1 and GSTR-3B from reconciled sales, purchases and input-tax-credit records. Maintain a separate Rule 32(5) working for eligible second-hand or used-gold transactions acquired from unregistered persons, without applying the margin scheme to ineligible bullion or newly manufactured goods. Reconcile buyer-side TDS under s.194Q with certificates and Form 26AS, then coordinate the annual GSTR-9 and GSTR-9C reconciliation where applicable.

Cadence: Monthly return close, quarterly control review and annual GST reconciliation.

You provide: Sales register, bullion-purchase register, unregistered-dealer purchase log, e-invoice data where applicable, expense register, ITC records and s.194Q certificates.

Statutory basis: CGST Act, 2017; Rules 32(5), 59 and 61 CGST Rules, 2017; s.194Q Income-tax Act, 1961

4

BIS hallmarking + HUID reconciliation

Reconcile HUID-tagged physical stock with the BIS portal register and the sales-to-HUID trail. Identify missing, duplicated or mismatched HUID records, monitor registration-renewal requirements and maintain a documented exception register for old-hallmark stock and any category-specific exemption relied upon.

Cadence: Quarterly control review, with transaction-level HUID capture maintained throughout the quarter.

You provide: HUID-tagged physical stock list, BIS portal register, purchase and job-work records, sales-to-HUID mapping and existing BIS registration documents.

Statutory basis: BIS Act, 2016; BIS (Hallmarking) Regulations, 2018; applicable Quality Control Orders and BIS hallmarking guidelines

5

Stock audit + ICDS-II inventory certification

Compare physical and system quantities by purity, category and location. Report variances and prepare the year-end valuation schedule using the consistently adopted FIFO or weighted-average method, or an appropriately supported retail method where used, with the accounting policy and departures disclosed. Prepare a stock certificate for bank or lender use when the agreed scope and evidence support it.

Cadence: Quarterly physical-to-system review and a year-end valuation close.

You provide: Physical count sheets, system stock, purity and category master, branch and job-work stock, purchase costs, wastage records and lender format where applicable.

Statutory basis: ICDS II — Valuation of Inventories; applicable accounting framework; s.145 Income-tax Act, 1961

6

Annual s.44AB tax audit + income-tax return

Use the reconciled PMLA, cash, GST, HUID and stock records as the audit trail rather than rebuilding the year after it closes. Prepare Form 3CD and the tax-audit report, file ITR-3, ITR-5 or ITR-6 as applicable, and schedule advance-tax reviews from current-year results. Material differences are resolved before the audit report and return are finalised.

Cadence: Annual statutory close, supported by periodic advance-tax reviews.

You provide: All recurring engagement records, final trial balance, financial statements, fixed-asset schedule, related-party data, tax-payment records and prior-year filings.

Statutory basis: ss.44AB, 139, 208 and 211 Income-tax Act, 1961; Rules 6G and applicable income-tax return rules

What “one rhythm” means

Days 1–5

Close the previous month’s customer-level cash register and CTR working; update the margin-scheme register; reconcile TCS collections, deposits and the Form 27EQ data set.

Days 6–10

Finalise outward-supply reconciliation and file GSTR-1 after resolving invoice, credit-note and HUID-mapping exceptions.

Days 11–20

Complete the ITC and tax-payment reconciliation, file GSTR-3B and place the CTR, nil-return register and STR judgment log before the Principal Officer for review and sign-off.

Quarterly

Perform physical-to-system stock review, BIS registration check and HUID-to-sales reconciliation; file Form 27EQ on its statutory quarterly cycle.

Annual

Roll the reconciled monthly and quarterly records into the inventory close, Form 3CD tax audit, applicable ITR, GSTR-9 and GSTR-9C where required.

Why not leave every role with the ITR-filer accountant?

The Principal Officer’s independence question

PMLA responsibility belongs inside the reporting entity. The Principal Officer must be able to challenge customer aggregation, missing identification records and explanations supplied by the person who entered or prepared the data. If the same person maintains the books, decides whether an exception exists and closes the review, structural challenge is weakened. We therefore separate shop-side preparation, management sign-off and external compliance review.

The tax auditor’s independence question

A s.44AB auditor must evaluate threats created by bookkeeping or management involvement before accepting the audit. There is no useful independence in recreating the books, choosing management judgments and then auditing the same work without safeguards. We document the responsibility matrix, keep decisions with management and allocate preparation and audit roles according to professional requirements.

One engagement does not mean one unchecked signatory

Integration means one calendar, one data trail and one exceptions register. It does not mean that one individual should enter the cash receipt, decide its PMLA treatment, approve the filing and later audit the annual result. The engagement is designed so each statutory output reaches the correct reviewer and signatory with the supporting evidence attached.

Five-step onboarding sequence

  1. Diagnostic — 2 hours. Review the current books, cash register, GST trail, stock records, BIS registration and existing PMLA setup. Deliver a statute-by-statute gap map with priority, owner and required evidence.
  2. FIU-IND registration + Principal Officer nomination. Complete or regularise FINnet registration and document the Principal Officer and Designated Director appointments, access ownership and reporting workflow.
  3. BIS registration audit. Verify the existing registration, outlet and category coverage, portal records and renewal position. Where the business is new or registration is incomplete, prepare the registration data and coordinate the application.
  4. Cash-log dashboard + shop-side SOP. Install the customer-aggregation and exception dashboard, define invoice-to-receipt identifiers and train the shop-side data owner on s.269ST, TCS and PMLA escalation.
  5. First month operationalised end-to-end. Run one full close from the source registers through CTR or nil-return documentation, GSTR-1, GSTR-3B, TCS controls and the signed statutory exception log.

What we do NOT do

No hallmarking-centre affiliation

BIS-recognised Assaying and Hallmarking Centres are separate entities. We reconcile your BIS and HUID records and monitor registration matters; we do not select a centre in exchange for a commission or represent that HRA performs hallmarking.

No PMLA legal defence in adjudication

We prepare compliance records, reporting support and factual reconciliations. A notice, prosecution question or contested adjudication requiring legal representation is referred to specialist counsel, with our schedules supplied as instructed.

No physical valuation of gold

We reconcile quantity and prepare accounting valuation workings from supported cost records. Purity testing, gemological assessment and independent physical valuation require an appropriately qualified valuer whose certificate is engaged separately.

Why HRA?

Harun Raaj & Associates is a firm of Chartered Accountants based in Visakhapatnam, with extended engagement coverage for Hyderabad jewellers. The service is structured independently of any single bookkeeping, PMLA-approval or tax-audit role: records can move through one operating calendar while preparation, management responsibility, review and statutory signing remain appropriately separated.

Frequently asked questions

How is this different from my existing ITR + GSTR accountant?

An ITR-and-GSTR assignment usually begins with period-end totals. This engagement begins with the underlying customer cash trail, HUID movement, inventory, margin-scheme eligibility and statutory exception logs. The same monthly close then supports PMLA reporting, s.269ST review, GST returns, BIS reconciliation and the eventual s.44AB audit. Your existing accountant can continue bookkeeping; the responsibility matrix prevents duplication and identifies who prepares, reviews, files and signs each output.

What does a Principal Officer under PMLA actually do daily?

The Principal Officer is the jeweller’s nominated management-level official responsible for the reporting process under the PML Rules. Daily work means ensuring customer and transaction records reach the review system, escalating unusual patterns, protecting confidentiality around STR consideration and resolving missing data. The formal CTR cycle is monthly under Rules 3 and 8, but the control cannot operate only once a month.

Do I have to physically be in your office in Vizag?

No. Hyderabad and Visakhapatnam engagements can run through secure document exchange, scheduled video reviews and a defined shop-side data owner. Physical attendance is arranged when the onboarding diagnostic, stock verification scope or control design requires it. Routine GSTR, CTR-support and exception reviews do not require a monthly office visit.

Can the same firm act as our tax auditor and PMLA Principal Officer?

The Principal Officer should be an appropriately nominated management-level official of the reporting entity; an external CA firm ordinarily supports the process rather than replacing that internal responsibility. A firm may separately accept the s.44AB audit only after evaluating professional independence, self-review threats and the bookkeeping work it performs. We allocate preparation, internal approval and audit roles only after that assessment; one engagement does not mean one person signs every document.

What if we already have a monthly retainer with an in-house accountant?

The in-house accountant can remain the source-book owner. We agree a responsibility matrix covering cash capture, customer aggregation, HUID tagging, GST preparation, TCS, PMLA review, stock counts and audit schedules. We review the control outputs and return structured exceptions instead of recreating the books. This preserves operational continuity while adding statutory review and an evidence trail.

Is the BIS reconciliation genuinely quarterly or annual?

HUID capture must occur with the underlying purchase, stock and sale movement; it cannot be reconstructed reliably only at year-end. Quarterly is the formal reconciliation cadence in this engagement, not a statutory claim that BIS prescribes one universal quarterly return for every jeweller. Exceptions affecting a sale or inspection are escalated when identified, and the annual close uses the four quarterly reconciliations.

What’s the fee structure?

The engagement is priced as a retainer band based on turnover, outlet count, transaction volume, accounting-system quality, stock complexity and whether records need reconstruction. Tax audit, exceptional catch-up work, physical attendance and specialist assignments are scoped transparently in the engagement letter. We do not publish a single rupee figure because a ₹5 crore single-outlet jeweller and a ₹200 crore multi-location jeweller do not present the same review load.

How fast is onboarding — can I start next month?

Usually, yes, if management nominations, FINnet access, BIS records and transaction data are made available promptly. The first step is a two-hour diagnostic, followed by a dated gap map and responsibility matrix. A clean record can enter the next monthly cycle; missing customer aggregation, HUID or opening-stock data may require a catch-up phase before the first complete reporting close.

Book a jeweller compliance diagnostic

A two-hour working session on your current books, cash controls, PMLA setup, GST trail, BIS records and stock-close process.

Before the meeting, you share the latest cash register, GST returns, sales and purchase registers, stock summary, BIS registration and any FIU-IND correspondence. During the session, we examine:

  • PMLA registration, appointments and reporting trail
  • s.269ST aggregation and s.271DA exposure points
  • TCS and cash-expenditure exception controls
  • GST margin-scheme and ITC workings
  • BIS, HUID and physical-stock reconciliation
  • s.44AB and year-end inventory readiness

After the session, you receive a statute-by-statute gap map and the recommended sequence for entering the next monthly close.

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Jeweller resource centres.269ST checkerPMLA CTR checker