Harakh Maloo submits detailed suggestions on issues facing bullion traders; seeks ban on futures trading, simpler GST compliance and relief for small jewellers
Raipur : Former president of the Raipur Sarafa Association, Harakh Maloo, has written a detailed letter to Prime Minister Narendra Modi, raising a series of concerns related to the country’s bullion trade and proposing measures to improve transparency, reduce compliance burdens and provide relief to small and traditional jewellers.
In his letter, Maloo said the bullion trade is not merely a commercial activity but is closely linked to India’s economy and the savings of millions of families. He stressed the need to protect the sector from excessive speculation and artificial price volatility.
“The trader community has always stood with the government with the spirit of Nation First. Therefore, I have urged the Prime Minister to consider these issues positively.” — Harakh Maloo, former president, Raipur Sarafa Association
Demand for Complete Ban on Gold and Silver Futures Trading
One of the key demands in the memorandum is a complete ban on futures trading in gold and silver.
Maloo argued that futures trading has elements of speculation and can contribute to artificial fluctuations in bullion prices.
According to him, sudden and significant price movements can particularly affect small and traditional jewellers, who may have limited capacity to absorb market volatility.
He has therefore urged the government to take steps to eliminate what he describes as speculative activity in the bullion market.
Gold Import Duty Should Be Reduced from 15% to 6%
Another major demand is to reduce the import duty on gold from 15 per cent to 6 per cent.
Maloo said the government had increased the duty with the objective of conserving foreign exchange. However, he argued that higher import duties have not necessarily reduced demand for gold and may instead have contributed to an increase in smuggling.
He suggested that a lower import duty could encourage more gold imports through official channels, potentially helping curb illegal imports while increasing government revenue.
Call for an All-India Bullion Market
Maloo has also proposed the establishment of an All-India Sarafa Market or bullion exchange to bring greater uniformity and transparency to gold and silver prices across the country.
He has suggested establishing such markets in Delhi and Mumbai, with prices determined there serving as a benchmark for bullion transactions across India.
According to the proposal, a standardised national pricing mechanism could help reduce differences in gold and silver prices between states and cities.
Such a system, he believes, could:
- Improve price transparency
- Reduce regional price differences
- Provide traders with a clear benchmark
- Make price comparisons easier for consumers
- Promote a more uniform bullion pricing system nationwide
Surprise Inspections of BIS Purity Testing Centres
The letter also calls for surprise inspections of purity testing centres operated under the Bureau of Indian Standards (BIS) framework.
Maloo has sought stronger monitoring of such centres to ensure that the purity-testing process remains reliable and transparent.
He has also called for simplification of the hallmarking and HUID (Hallmark Unique Identification) process and a reduction in related charges.
Relief for Small and Traditional Jewellers
The concerns of small bullion traders and jewellers form an important part of the memorandum.
Maloo has proposed simplifying procedures related to hallmarking and HUID while reducing associated costs.
According to the proposal, simpler compliance requirements would reduce the administrative and financial burden on small traders and help traditional jewellers operate their businesses more efficiently.
Action Against Misleading Gold Savings Schemes
The former association president has also called for restrictions on what he describes as misleading gold savings schemes operated by large companies.
He has suggested that such schemes should be permitted only for BIS-registered bullion and jewellery traders, with appropriate safeguards for consumers.
The proposal seeks greater regulatory oversight of gold-linked savings programmes and improved protection for customers participating in such schemes.
GST Compliance Process Should Be Simplified
Maloo has also raised concerns regarding GST compliance in the bullion trade.
He has proposed simplifying the process for filing returns relating to the 3 per cent GST applicable to gold and suggested that the filing requirement be changed to once every three months.
He believes such a change would particularly benefit small traders by reducing their compliance burden and allowing them to focus more on their core business activities.
Focus on Transparency in the Bullion Market
A central theme of the letter is the need for greater transparency and uniformity in India’s bullion market.
Maloo’s proposals — ranging from a national price benchmark and stronger purity-testing oversight to simplified hallmarking and GST compliance — are aimed at creating a more organised and transparent trading environment.
The proposals also seek to address the challenges faced by small and traditional jewellers, particularly in relation to compliance costs and regulatory procedures.
Major Demands at a Glance
| No. | Issue | Key Proposal |
|---|---|---|
| 1 | Futures Trading | Complete ban on gold and silver futures trading |
| 2 | Gold Import Duty | Reduce duty from 15% to 6% |
| 3 | All-India Bullion Market | Establish bullion markets/exchanges in Delhi and Mumbai |
| 4 | Uniform Pricing | Introduce a national benchmark for gold and silver prices |
| 5 | BIS Centres | Conduct surprise inspections of purity-testing centres |
| 6 | HUID & Hallmarking | Simplify procedures and reduce charges |
| 7 | Gold Savings Schemes | Restrict misleading schemes and strengthen regulation |
| 8 | GST | Simplify 3% GST return compliance and make it quarterly |
| 9 | Small Traders | Reduce regulatory and compliance burden |
What the Proposals Could Mean for the Bullion Trade
The bullion industry plays an important role in India’s economy and is closely connected with household savings, jewellery consumption and investment demand.
Changes in import duties, taxation, hallmarking regulations and market structures can therefore have a significant impact on both traders and consumers.
Maloo’s letter seeks policy intervention in these areas, with particular emphasis on reducing costs for smaller businesses and creating a more transparent pricing mechanism.
Government Action Will Be Closely Watched
The proposals have now been placed before the Prime Minister’s Office for consideration through the letter.
The key issues raised — particularly the proposed reduction in gold import duty, regulation of futures trading, creation of a national bullion market and simplification of GST and hallmarking procedures — could have wider implications for India’s jewellery and bullion industry if taken up for policy consideration.
Conclusion
Former Raipur Sarafa Association president Harakh Maloo has urged Prime Minister Narendra Modi to consider a series of reforms aimed at improving India’s bullion trade.
His key demands include reducing gold import duty from 15 per cent to 6 per cent, banning gold and silver futures trading, establishing an All-India bullion market, simplifying HUID and hallmarking procedures, strengthening BIS oversight, regulating gold savings schemes and simplifying GST compliance for small traders.
The proposals reflect concerns raised by sections of the bullion trade over taxation, price volatility, regulatory compliance and market transparency. The industry’s attention will now be on whether the government considers these suggestions and whether any policy measures are introduced in response.



