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CLAUSE BY CLAUSE ANALYSIS OF THE PROPOSED AMENDMENTS TO THE GOODS AND SERVICES TAX IN THE FINANCE (NO. 2) BILL, 2024

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CLAUSE BY CLAUSE ANALYSIS OF THE PROPOSED AMENDMENTS TO THE GOODS AND SERVICES TAX IN THE FINANCE (NO. 2) BILL, 2024

				By: Siddhant Pathak
				July 26, 2024
All Articles by: Siddhant Pathak View Profile

Contents

CLAUSE BY CLAUSE ANALYSIS OF THE PROPOSED AMENDMENTS TO THE GOODS AND SERVICES TAX IN THE FINANCE (NO. 2) BILL, 2024

PROPOSED AMENDMENTS IN THE CGST ACT, 2017

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

110

9(1)

Subject to the provisions of sub-section (2), there shall be levied a tax called the central goods and services tax on all intra-State supplies of goods or services or both, except on the supply of alcoholic liquor for human consumption, on the value determined under section 15 and at such rates, not exceeding twenty per cent., as may be notified by the Government on the recommendations of the Council and collected in such manner as may be prescribed and shall be paid by the taxable person.

Subject to the provisions of sub-section (2), there shall be levied a tax called the central goods and services tax on all intra-State supplies of goods or services or both, except on the supply of alcoholic liquor for human consumption and un-denatured extra neutral alcohol or rectified spirit used for manufacture of alcoholic liquor, for human consumption, on the value determined under section 15 and at such rates, not exceeding twenty per cent., as may be notified by the Government on the recommendations of the Council and collected in such manner as may be prescribed and shall be paid by the taxable person.

This amendment aims to align the GST framework with industry practices concerning the production of alcoholic beverages.

Prior to this amendment, the inclusion of ENA under the GST regime created complexities in taxation. Alcoholic liquor for human consumption falls outside the purview of GST and is instead subject to state excise duties. However, the inputs used in its production, such as ENA, could potentially fall under GST, leading to dual taxation issues.

Manufacturers of alcoholic beverages could not claim ITC on GST paid for ENA if it was used to produce alcoholic liquor, as the final product was not subject to GST. This resulted in increased costs for manufacturers, as they could not offset the GST paid on ENA against the taxes on their final products.

The tax treatment of ENA varied across states, leading to discrepancies and confusion within the industry. Some states considered ENA as an input for alcohol production (thus outside GST), while others treated it differently, leading to inconsistencies in tax application.

The amendment seeks to align the GST framework with the established practice of excluding alcoholic liquor for human consumption from GST. By excluding ENA from central tax, the amendment ensures consistency in the treatment of both the inputs and the final product. Similar amendments are also proposed in IGST Act and UTGST Act.

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
111	10(5)	If the proper officer has reasons to believe that a taxable person has paid tax under sub-section (1) or sub-section (2A), as the case may be, despite not being eligible, such person shall, in addition to any tax that may be payable by him under any other provisions of this Act, be liable to a penalty and the provisions of section 73 or section 74 shall, mutatis mutandis, apply for determination of tax and penalty.	If the proper officer has reasons to believe that a taxable person has paid tax under sub-section (1) or sub-section (2A), as the case may be, despite not being eligible, such person shall, in addition to any tax that may be payable by him under any other provisions of this Act, be liable to a penalty and the provisions of *section 73 or section 74, or section 74A* shall, mutatis mutandis, apply for determination of tax and penalty.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

112

11A – new section

Notwithstanding anything contained in this Act, if the Government is satisfied that –

(a) a practice was, or is, generally prevalent regarding levy of central tax (including non-levy thereof) on any supply of goods or services or both; and

(b) such supplies were, or are, liable to, –

(i) central tax, in cases where according to the said practice, central tax was not, or is not being, levied, or

(ii) a higher amount of central tax than what was, or is being, levied, in accordance with the said practice,

the Government may, on the recommendation of the Council, by notification in the Official Gazette, direct that the whole of the central tax payable on such supplies, or, as the case may be, the central tax in excess of that payable on such supplies, but for the said practice, shall not be required to be paid in respect of the supplies on which the central tax was not, or is not being levied, or was, or is being, short-levied, in accordance with the said practice.

Section 11A is newly inserted to empower the government to regularize the non-levy or short levy of central tax due to general practice prevalent in trade. This provision enables the government to address discrepancies that arise due to common industry practices, ensuring smoother compliance and rectification processes. A similar provision already exists under the Customs Act, 1962, and the Central Excise Act, 1944. Similar amendments are also proposed in IGST Act and UTGST Act. The question arises whether the Notification would regularise the non-levy or short levy with a sunset date or in perpetuity. The proposed provision is silent in this regard. Although, in our view the regularisation would be upto a particular date on as is where is basis.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

113

13(3)

In case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis, the time of supply shall be the earlier of the following dates, namely: –

(a) the date of payment as entered in the books of account of the recipient or the date on which the payment is debited in his bank account, whichever is earlier; or

(b) the date immediately following sixty days from the date of issue of invoice or any other document, by whatever name called, in lieu thereof by the supplier:

Provided that where it is not possible to determine the time of supply under clause (a) or clause (b), the time of supply shall be the date of entry in the books of account of the recipient of supply:

In case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis, the time of supply shall be the earlier of the following dates, namely: –

(a) the date of payment as entered in the books of account of the recipient or the date on which the payment is debited in his bank account, whichever is earlier; or

(b) the date immediately following sixty days from the date of issue of invoice or any other document, by whatever name called, in lieu thereof by the supplier, in cases where invoice is required to be issued by the supplier; or

(c) the date of issue of invoice by the recipient, in cases where invoice is to be issued by the recipient;

Provided that where it is not possible to determine the time of supply under clause (a) or clause (b) or clause (c), the time of supply shall be the date of entry in the books of account of the recipient of supply:

The proposed amendment aims to provide clarity and streamline the process of determining the time of supply under RCM specifically where self-invoice is required to be issued by the recipient of supply in terms of Section 31(3)(f) upon receipt of notified reverse charge supply from unregistered person.

The time of supply/point of taxation in such cases shall be the date of payment of invoice value by the recipient to the supplier as per clause (a), or the date of issuance of self-invoice by the recipient as per clause (c), whichever is earlier.

The clause (b) which provides for a date immediately following the period of 60 days from the date of issue of invoice by the supplier shall be applicable only in cases where tax invoice is issued by the registered supplier.

To illustrate: The time of supply w.r.t. services supplied by a registered GTA, taxable under RCM, shall be determined as earlier of clause (a) or clause (b). On the other hand the time of supply w.r.t. services supplied by an unregistered Advocate shall be determined as earlier of clause (a) or clause (c).

Notably, a related amendment is proposed u/s 31(3)(f) to provide an enabling provision to the Government to notify the due date for issuance of self-invoice by the recipient where supplier is unregistered. However, the proposed clause (c) u/s 13(3) considers the actual date of issuance of self-invoice and not the due date to be notified u/s 31(3)(f).

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

114

16(5) – new sub-section after 16 (4) w.e.f. 01.07.2017

(4) A registered person shall not be entitled to take input tax credit in respect of any invoice or debit note for supply of goods or services or both after the thirtieth day of November following the end of financial year to which such invoice or debit note pertains or furnishing of the relevant annual return, whichever is earlier.

(5) Notwithstanding anything contained in sub-section (4), in respect of an invoice or debit note for supply of goods or services or both pertaining to the Financial Years 2017 18, 2018-19, 2019-20 and 2020-21, the registered person 89 shall be entitled to take input tax credit in any return under section 39 which is filed upto the thirtieth day of November, 2021.

Section 16(5) is being inserted retrospectively to legitimize the claim of ITC beyond the time limit of 16(4) in respect of an invoice or debit note for the Financial Years 2017-18, 2018-19, 2019-20, and 2020-21, provided the claim was made in any GSTR-3B return filed up to November 30, 2021. However, according to Clause 146, no refund will be granted for ITC that has already been paid, either voluntarily or under departmental pressure, in accordance with the original time limit set by Section 16(4).

16(6) – new sub-section w.e.f. 01.07.2017

Where registration of a registered person is cancelled under section 29 and subsequently the cancellation of registration is revoked by any order, either under section 30 or pursuant to any order made by the Appellate Authority or the Appellate Tribunal or court and where availment of input tax credit in respect of an invoice or debit note was not restricted under sub-section (4) on the date of order of cancellation of registration, the said person shall be entitled to take the input tax credit in respect of such invoice or debit note for supply of goods or services or both, in a return under section 39,–

(i) filed upto thirtieth day of November following the financial year to which such invoice or debit note pertains or furnishing of the relevant annual return, whichever is earlier; or

(ii) for the period from the date of cancellation of registration or the effective date of cancellation of registration, as the case may be, till the date of order of revocation of cancellation of registration, where such return is filed within thirty days from the date of order of revocation of cancellation of registration, whichever is later.

The amendment addresses the technical issue where registered persons could not claim Input Tax Credit (ITC) due to the lapse of the time limit under Section 16(4) during the period when their GST registration was cancelled. Previously, if the ITC became time-barred during this cancellation period, the registered person lost the right to claim it even after revocation. The new provision allows such persons to claim ITC by filing a return within 30 days from the order of revocation, provided the ITC was not already time-barred u/s 16(4) before the cancellation order, thus resolving the issue of unclaimed ITC due to administrative delays in registration revocation.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

115

17(5)(i)

Notwithstanding anything contained in sub-section (1) of section 16 and subsection (1) of section 18, input tax credit shall not be available in respect of the following, namely:-…………

(i) any tax paid in accordance with the provisions of sections 74, 129 and 130.

Notwithstanding anything contained in sub-section (1) of section 16 and subsection (1) of section 18, input tax credit shall not be available in respect of the following, namely: - …………..

(i) any tax paid in accordance with the provisions of section 74 in respect of any period upto Financial Year 2023-24.

The proposed amendment to Section 17(5) of the CGST Act removes the reference to Sections 129 and 130, which pertain to the detention, seizure, and release of goods on payment of penalty or confiscation fine, as the case may be. This removal is justified as these sections pertain solely to penalties and fines, not the recovery of tax, and therefore, do not warrant a restriction on Input Tax Credit (ITC). Additionally, the amendment aligns the restriction of ITC on tax paid under Section 74 with the fiscal year 2023-24, consistent with the sunset clause introduced in Section 74, limiting demands to March 31, 2024.

However, the amendment does not include a reference to the newly proposed Section 74A for the period from 2024-25 onwards, which appears to be an oversight, as Section 74A also governs mala fide tax demands and would logically extend the ITC restrictions. Or perhaps, the government only intends to impose a higher penalty (100%) on demands made under Section 74A in mala fide cases while not disallowing the ITC of such tax recoveries, thereby focusing on deterrence through penalties rather than restricting ITC.

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
116	21	Where the Input Service Distributor distributes the credit in contravention of the provisions contained in section 20 resulting in excess distribution of credit to one or more recipients of credit, the excess credit so distributed shall be recovered from such recipients along with interest, and the provisions of section 73 or section 74, as the case may be, shall, mutatis mutandis, apply for determination of amount to be recovered.	Where the Input Service Distributor distributes the credit in contravention of the provisions contained in section 20 resulting in excess distribution of credit to one or more recipients of credit, the excess credit so distributed shall be recovered from such recipients along with interest, and the provisions of section 73 or section 74 *or section 74A, as the case may be, shall, mutatis mutandis*, apply for determination of amount to be recovered.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.
Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
117	30(2)	The proper officer may, in such manner and within such period as may be prescribed, by order, either revoke cancellation of the registration or reject the application: Provided that the application for revocation of cancellation of registration shall not be rejected unless the applicant has been given an opportunity of being heard.	The proper officer may, in such manner and within such period as may be prescribed, by order, either revoke cancellation of the registration or reject the application: Provided that the application for revocation of cancellation of registration shall not be rejected unless the applicant has been given an opportunity of being heard. *Provided further that such revocation of cancellation of registration shall be subject to such conditions and restrictions, as may be prescribed.*	The proposed amendment seeks to provide for an enabling clause to the government to prescribe conditions and restrictions for revocation of cancellation of registration.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

118

31(3)(f)

31. (3) Notwithstanding anything contained in sub-sections (1) and (2) –…….

(f) a registered person who is liable to pay tax under sub-section (3) or sub-section (4) of section 9 shall issue an invoice in respect of goods or services or both received by him from the supplier who is not registered on the date of receipt of goods or services or both;

31. (3) Notwithstanding anything contained in sub-sections (1) and (2) –…….

(f) a registered person who is liable to pay tax under sub-section (3) or sub-section (4) of section 9 shall, within the period as may be prescribed, issue an invoice in respect of goods or services or both received by him from the supplier who is not registered on the date of receipt of goods or services or both;

The proposed amendment to Section 31(3)(f) seeks to establish an enabling provision for prescribing a specific time period for the issuance of a self-invoice by the recipient in cases involving supplies under the reverse charge mechanism (RCM) from unregistered suppliers.

Currently, the requirement is for the registered recipient to issue the self-invoice on the date of receipt of goods or services. This amendment aims to introduce a more structured timeline for this process.

Notably, a related amendment proposes the insertion of clause (c) under Section 13(3) to define the time of supply (TOS) for services taxable under RCM as the earlier of the date of payment to the supplier or the date of issuance of the self-invoice in case of unregistered supplier, to be prescribed under this new enabling provision. This aims to clarify and streamline the process for determining the TOS in RCM scenarios.

Additionally, Circular No. 211/5/2024-GST dated 26.06.2024 clarified that the time limit under Section 16(4) for claiming ITC on tax paid under RCM on supplies from unregistered persons is linked to the date of issuance of the self-invoice under Section 31(3)(f). Even if the issuance of the self-invoice is delayed, the recipient would only be subject to a penalty under Section 122, rather than being denied ITC.

This raises a question about the relevance of the prescribed time limit for issuing a self-invoice under the proposed amendment. Specifically, it is unclear whether the new prescribed due date for issuing the self-invoice or the actual date of issuance will determine the applicability of the limitation period under Section 16(4). If the latter interpretation is upheld, it could effectively prevent ITC under RCM from becoming time-barred, allowing recipients to claim ITC at any time based on delayed self-invoice, subject only to a nominal penalty under Section 122(3)(e).

Explanation in sub-section (3) of Section 31 is also inserted so as to specify that in case of supplies received from persons liable to deduct TDS u/s 51 who are registered solely as Tax Deductors and not as regular suppliers shall be considered as unregistered suppliers and self-invoice shall be required to be issued by the recipient for reverse charge supplies received from such deductors.

New explanation

Explanation.––For the purposes of clause (f), the expression “supplier who is not registered” shall include the supplier who is registered solely for the purpose of deduction of tax under section 51.’

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
119	35(6)	Subject to the provisions of clause (h) of sub-section (5) of section 17, where the registered person fails to account for the goods or services or both in accordance with the provisions of sub-section (1), the proper officer shall determine the amount of tax payable on the goods or services or both that are not accounted for, as if such goods or services or both had been supplied by such person and the provisions of section 73 or section 74, as the case may be, shall, mutatis mutandis, apply for determination of such tax.	Subject to the provisions of clause (h) of sub-section (5) of section 17, where the registered person fails to account for the goods or services or both in accordance with the provisions of sub-section (1), the proper officer shall determine the amount of tax payable on the goods or services or both that are not accounted for, as if such goods or services or both had been supplied by such person and the provisions of section 73 or section 74 or section 74A, as the case may be, shall, mutatis mutandis, apply for determination of such tax.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

120

39(3)

Every registered person required to deduct tax at source under the provisions of section 51 shall furnish, in such form and manner as may be prescribed, a return, electronically, for the month in which such deductions have been made within ten days after the end of such month.

Every registered person required to deduct tax at source under section 51 shall electronically furnish a return for every calendar month of the deductions made during the month in such form and manner and within such time as may be prescribed:

Provided that the said registered person shall furnish a return for every calendar month whether or not any deductions have been made during the said month.”.

The proposed amendment mandates the electronic filing of return GSTR-7 for each month by registered persons required to deduct tax at source, regardless of whether any deductions have been made during that month. The provision also authorizes the government to prescribe the form, manner, and timeframe for filing such returns through rules.

Rule 66, which governs this area, is already in effect under the general authority of Section 164 of the Act. The proposed amendment appears to aim at solidifying the legal basis for these rules, possibly to preclude challenges to their validity. Interestingly, this approach reflects a reverse sequence in legislative action: specific rules were initially established under the broad powers granted by Section 164, and only afterward are specific statutory provisions introduced to support these rules explicitly.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

121

49(8)

Every taxable person shall discharge his tax and other dues under this Act or the rules made thereunder in the following order, namely:– –

(a) self-assessed tax, and other dues related to returns of previous tax periods;

(b) self-assessed tax, and other dues related to the return of the current tax period;

(c) any other amount payable under this Act or the rules made thereunder including the demand determined under section 73 or section 74;

Every taxable person shall discharge his tax and other dues under this Act or the rules made thereunder in the following order, namely:–

(a) self-assessed tax, and other dues related to returns of previous tax periods;

(b) self-assessed tax, and other dues related to the return of the current tax period

(c) any other amount payable under this Act or the rules made thereunder including the demand determined under section 73 or section 74 or section 74A;

The amendment proposes to incorporate reference to the proposed new Section 74A which will govern demands and recovery from FY 2024-25 onwards.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

122

50(1)

Every person who is liable to pay tax in accordance with the provisions of this Act or the rules made thereunder, but fails to pay the tax or any part thereof to the Government within the period prescribed, shall for the period for which the tax or any part thereof remains unpaid, pay, on his own, interest at such rate, not exceeding eighteen per cent., as may be notified by the Government on the recommendations of the Council.

Provided that the interest on tax payable in respect of supplies made during a tax period and declared in the return for the said period furnished after the due date in accordance with the provisions of section 39, except where such return is furnished after commencement of any proceedings under section 73 or section 74 in respect of the said period, shall be payable on that portion of the tax which is paid by debiting the electronic cash ledger.

Provided that the interest on tax payable in respect of supplies made during a tax period and declared in the return for the said period furnished after the due date in accordance with the provisions of section 39, except where such return is furnished after commencement of any proceedings under section 73 or section 74 or section 74A in respect of the said period, shall be payable on that portion of the tax which is paid by debiting the electronic cash ledger.

The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

123

51(7)

The determination of the amount in default under this section shall be made in the manner specified in section 73 or section 74.

The determination of the amount in default under this section shall be made in the manner specified in section 73 or section 74 or section 74A.

The amendment proposes to incorporate reference to the proposed new Section 74A in Section 51(7) which deals with tax deduction at source under GST.

Section 74A shall be applicable for demands pertaining to FY 2024-25 and onwards.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

124

54(3)

Subject to the provisions of sub-section (10), a registered person may claim refund of any unutilised input tax credit at the end of any tax period:

Provided that no refund of unutilised input tax credit shall be allowed in cases other than––

(i) zero rated supplies made without payment of tax;

(ii) where the credit has accumulated on account of rate of tax on inputs being higher than the rate of tax on output supplies (other than nil rated or fully exempt supplies), except supplies of goods or services or both as may be notified by the Government on the recommendations of the Council:

Provided further that no refund of unutilised input tax credit shall be allowed in cases where the goods exported out of India are subjected to export duty:

Provided also that no refund of input tax credit shall be allowed, if the supplier of goods or services or both avails of drawback in respect of central tax or claims refund of the integrated tax paid on such supplies.

Subject to the provisions of sub-section (10), a registered person may claim refund of any unutilised input tax credit at the end of any tax period:

Provided that no refund of unutilised input tax credit shall be allowed in cases other than––

(i) zero rated supplies made without payment of tax;

~~Provided further that no refund of unutilised input tax credit shall be allowed in cases where the goods exported out of India are subjected to export duty:~~

The proposed amendment plugs the lacuna where the exporters exporting demerit goods were claiming refunds on account of Zero-rated supply by way of payment of IGST while refund of ITC under LUT route was explicitly denied. With the deletion of Proviso under sub-section (3) and insertion of new sub-section (15), the refund of IGST paid on export of goods subject to export duty has also been denied. In nutshell, the goods subject to export duty, whether exported under LUT without payment of IGST or exported with payment of IGST, shall not be entitled for any refund on account of zero-rated supply.

54(15) – new sub-section

Notwithstanding anything contained in this section, no refund of unutilised input tax credit on account of zero rated supply of goods or of integrated tax paid on account of zero rated supply of goods shall be allowed where such zero rated supply of goods is subjected to export duty

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
125	61(3)	In case no satisfactory explanation is furnished within a period of thirty days of being informed by the proper officer or such further period as may be permitted by him or where the registered person, after accepting the discrepancies, fails to take the corrective measure in his return for the month in which the discrepancy is accepted, the proper officer may initiate appropriate action including those under section 65 or section 66 or section 67, or proceed to determine the tax and other dues under section 73 or section 74.	In case no satisfactory explanation is furnished within a period of thirty days of being informed by the proper officer or such further period as may be permitted by him or where the registered person, after accepting the discrepancies, fails to take the corrective measure in his return for the month in which the discrepancy is accepted, the proper officer may initiate appropriate action including those under section 65 or section 66 or section 67, or proceed to determine the tax and other dues under section 73 or section 74 *or section 74A*.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
126	62	Notwithstanding anything to the contrary contained in section 73 or section 74, where a registered person fails to furnish the return under section 39 or section 45, even after the service of a notice under section 46, the proper officer may proceed to assess the tax liability of the said person to the best of his judgement taking into account all the relevant material which is available or which he has gathered and issue an assessment order within a period of five years from the date specified under section 44 for furnishing of the annual return for the financial year to which the tax not paid relates.	Notwithstanding anything to the contrary contained in section 73 or section 74 *or section 74A*, where a registered person fails to furnish the return under section 39 or section 45, even after the service of a notice under section 46, the proper officer may proceed to assess the tax liability of the said person to the best of his judgement taking into account all the relevant material which is available or which he has gathered and issue an assessment order within a period of five years from the date specified under section 44 for furnishing of the annual return for the financial year to which the tax not paid relates.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

127

Notwithstanding anything to the contrary contained in section 73 or section 74, where a taxable person fails to obtain registration even though liable to do so or whose registration has been cancelled under sub-section (2) of section 29 but who was liable to pay tax, the proper officer may proceed to assess the tax liability of such taxable person to the best of his judgment for the relevant tax periods and issue an assessment order within a period of five years from the date specified under section 44 for furnishing of the annual return for the financial year to which the tax not paid relates:

Provided that no such assessment order shall be passed without giving the person an opportunity of being heard.

. Notwithstanding anything to the contrary contained in section 73 or section 74 or section 74A, where a taxable person fails to obtain registration even though liable to do so or whose registration has been cancelled under sub-section (2) of section 29 but who was liable to pay tax, the proper officer may proceed to assess the tax liability of such taxable person to the best of his judgment for the relevant tax periods and issue an assessment order within a period of five years from the date specified under section 44 for furnishing of the annual return for the financial year to which the tax not paid relates:

Provided that no such assessment order shall be passed without giving the person an opportunity of being heard.

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
128	64	On an application made by the taxable person within thirty days from the date of receipt of order passed under sub-section (1) or on his own motion, if the Additional Commissioner or Joint Commissioner considers that such order is erroneous, he may withdraw such order and follow the procedure laid down in section 73 or section 74.	On an application made by the taxable person within thirty days from the date of receipt of order passed under sub-section (1) or on his own motion, if the Additional Commissioner or Joint Commissioner considers that such order is erroneous, he may withdraw such order and follow the procedure laid down in section 73 or section 74 *or section 74A*.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
129	65	Where the audit conducted under sub-section (1) results in detection of tax not paid or short paid or erroneously refunded, or input tax credit wrongly availed or utilised, the proper officer may initiate action under section 73 or section 74.	Where the audit conducted under sub-section (1) results in detection of tax not paid or short paid or erroneously refunded, or input tax credit wrongly availed or utilised, the proper officer may initiate action under section 73 or section 74 *or section 74A*.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
130	66	Where the special audit conducted under sub-section (1) results in detection of tax not paid or short paid or erroneously refunded, or input tax credit wrongly availed or utilised, the proper officer may initiate action under section 73 or section 74.	Where the special audit conducted under sub-section (1) results in detection of tax not paid or short paid or erroneously refunded, or input tax credit wrongly availed or utilised, the proper officer may initiate action under section 73 or section 74 *or section 74A*.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

131

(1) The proper officer under this Act shall have power to summon any person whose attendance he considers necessary either to give evidence or to produce a document or any other thing in any inquiry in the same manner, as provided in the case of a civil court under the provisions of the Code of Civil Procedure,1908 (5 of 1908).

(1A) All persons summoned under sub-section (1) shall be bound to attend, either in person or by an authorised representative, as such officer may direct, and the person so appearing shall state the truth during examination or make statements or produce such documents and other things as may be required.

The amendment proposes allowing a summoned person to appear through an authorized representative, offering a more flexible option for complying with summons. This change formalizes a practice that was previously inconsistently applied, as summoning authorities sometimes denied this option. With this amendment, such denials will no longer be permissible. It is important to note that the deposition by the authorized representative will be binding on the summoned person, highlighting the need for careful selection of representatives.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

132

73 - Heading

Determination of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised for any reason other than fraud or any wilful-misstatement or suppression of facts.

Determination of tax pertaining to the period upto Financial Year 2023-24 not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised for any reason other than fraud or any wilful-misstatement or suppression of facts.

The amendment introduces a sunset clause to Section 73, making it applicable only to demands relating to fiscal years up to 2023-24. For demands from FY 2024-25 onward, the new Section 74A will apply, which establishes a unified time limit for adjudication, eliminating the distinction between normal and extended periods. Under Section 73, the time limit for issuing a Show Cause Notice (SCN) was 33 months from the due date of the Annual Return for the disputed fiscal year.

However, under Section 74A, this time limit has been extended to 42 months, providing a longer period for the issuance of non-fraud SCNs.

73(12) – new sub-section

(12) The provisions of this section shall be applicable for determination of tax pertaining to the period up to Financial Year 2023-24.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

133

74 - Heading

Determination of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised by reason of fraud or any wilful-misstatement or suppression of facts.

Determination of tax pertaining to the period upto Financial Year 2023-24 not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised by reason of fraud or any wilful-misstatement or suppression of facts.

The amendment introduces a sunset clause to Section 74, making it applicable only to demands relating to fiscal years up to 2023-24. For demands from FY 2024-25 onward, the new Section 74A will apply, which establishes a unified time limit for adjudication, eliminating the distinction between normal and extended periods. Under Section 74, the time limit for issuing a Show Cause Notice (SCN) was 54 months from the due date of the Annual Return for the disputed fiscal year.

Under Section 74A, this time limit has been shortened to 42 months, thereby reducing the window for issuing SCNs in cases involving fraud.

74(12) – new sub-section

(12) The provisions of this section shall be applicable for determination of tax pertaining to the period up to Financial Year 2023-24.

Clause no.

Section

Proposed amendment

134

74A – New provision

Determination of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised for any reason pertaining to Financial Year 2024-25 onwards.

74A. (1) Where it appears to the proper officer that any tax has not been paid or short paid or erroneously refunded, or where input tax credit has been wrongly availed or utilised, he shall serve notice on the person chargeable with tax which has not been so paid or which has been so short paid or to whom the refund has erroneously been made, or who has wrongly availed or utilised input tax credit, requiring him to show cause as to why he should not pay the amount specified in the notice along with interest payable thereon under section 50 and a penalty leviable under the provisions of this Act or the rules made thereunder: Provided that no notice shall be issued, if the tax which has not been paid or short paid or erroneously refunded or 93 where input tax credit has been wrongly availed or utilised in a financial year is less than one thousand rupees.

(2) The proper officer shall issue the notice under sub section (1) within forty-two months from the due date for furnishing of annual return for the financial year to which the tax not paid or short paid or input tax credit wrongly availed or utilised relates to or within forty-two months from the date of erroneous refund.

(3) Where a notice has been issued for any period under sub-section (1), the proper officer may serve a statement, containing the details of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised for such periods other than those covered under sub section (1), on the person chargeable with tax.

(4) The service of such statement shall be deemed to be service of notice on such person under sub-section (1), subject to the condition that the grounds relied upon for such tax periods other than those covered under sub-section (1) are the same as are mentioned in the earlier notice.

(5) The penalty in case where any tax which has not been paid or short paid or erroneously refunded, or where input tax credit has been wrongly availed or utilised,–

for any reason, other than the reason of fraud or any wilful-misstatement or suppression of facts to evade tax, shall be equivalent to ten per cent. of tax due from such person or ten thousand rupees, whichever is higher;

for the reason of fraud or any wilful-misstatement or suppression of facts to evade tax shall be equivalent to the tax due from such person.

(6) The proper officer shall, after considering the representation, if any, made by the person chargeable with tax, determine the amount of tax, interest and penalty due from such person and issue an order.

(7) The proper officer shall issue the order under sub section (6) within twelve months from the date of issuance of notice specified in sub-section (2):

Provided that where the proper officer is not able to issue the order within the specified period, the Commissioner, or an officer authorised by the Commissioner senior in rank to the proper officer but not below the rank of Joint Commissioner of Central Tax, may, having regard to the 94 reasons for delay in issuance of the order under sub-section (6), to be recorded in writing, before the expiry of the specified period, extend the said period further by a maximum of six months.

(8) The person chargeable with tax where any tax has not been paid or short paid or erroneously refunded, or where input tax credit has been wrongly availed or utilised for any reason, other than the reason of fraud or any wilful misstatement or suppression of facts to evade tax, may, ––

(i) before service of notice under sub-section (1), pay the amount of tax along with interest payable under section 50 of such tax on the basis of his own ascertainment of such tax or the tax as ascertained by the proper officer and inform the proper officer in writing of such payment, and the proper officer, on receipt of such information shall not serve any notice under sub-section (1) or the statement under sub-section (3), as the case may be, in respect of the tax so paid or any penalty payable under the provisions of this Act or the rules made thereunder;

(ii) pay the said tax along with interest payable under section 50 within sixty days of issue of show cause notice, and on doing so, no penalty shall be payable and all proceedings in respect of the said notice shall be deemed to be concluded.

(9) The person chargeable with tax, where any tax has not been paid or short paid or erroneously refunded or where input tax credit has been wrongly availed or utilised by reason of fraud, or any wilful-misstatement or suppression of facts to evade tax, may,––

(i) before service of notice under sub-section (1), pay the amount of tax along with interest payable under section 50 and a penalty equivalent to fifteen per cent. of such tax on the basis of his own ascertainment of such tax or the tax as ascertained by the proper officer and inform the proper officer in writing of such payment, and the proper officer, on receipt of such information, shall not serve any notice under sub-section (1), in respect of the tax so paid or any penalty payable under the provisions of this Act or the rules made thereunder;

(ii) pay the said tax along with interest payable under section 50 and a penalty equivalent to twenty-five per cent. of such tax within sixty days of issue of the notice, 95 and on doing so, all proceedings in respect of the said notice shall be deemed to be concluded;

(iii) pay the tax along with interest payable thereon under section 50 and a penalty equivalent to fifty per cent. of such tax within sixty days of communication of the order, and on doing so, all proceedings in respect of the said notice shall be deemed to be concluded.

(10) Where the proper officer is of the opinion that the amount paid under clause (i) of sub-section (8) or clause (i) of sub-section (9) falls short of the amount actually payable, he shall proceed to issue the notice as provided for in sub section (1) in respect of such amount which falls short of the amount actually payable.

(11) Notwithstanding anything contained in clause (i) or clause (ii) of sub-section (8), penalty under clause (i) of sub section (5) shall be payable where any amount of self assessed tax or any amount collected as tax has not been paid within a period of thirty days from the due date of payment of such tax.

(12) The provisions of this section shall be applicable for determination of tax pertaining to the Financial Year 2024 25 onwards.

Explanation 1.––For the purposes of this section,––

(i) the expression “all proceedings in respect of the said notice” shall not include proceedings under section 132;

(ii) where the notice under the same proceedings is issued to the main person liable to pay tax and some other persons, and such proceedings against the main person have been concluded under this section, the proceedings against all the persons liable to pay penalty under sections 122 and 125 are deemed to be concluded.

Explanation 2.–For the purposes of this Act, the expression “suppression” shall mean non-declaration of facts or information which a taxable person is required to declare in the return, statement, report or any other document furnished under this Act or the rules made thereunder, or failure to furnish any information on being asked for, in writing, by the proper officer.

Author’s comments:

The proposed amendment seeks to eliminate the previous distinction between normal and extended periods for handling tax demands for the periods FY 2024-25 and onwards. The new Section 74A will address all cases of non-payment, short payment, erroneous refunds, or wrongful availment or utilization of Input Tax Credit (ITC), irrespective of the intent, whether bona fide or mala fide. This new section replaces the former separation under Sections 73 and 74, which differentiated between bona fide cases (non-fraudulent) and mala fide cases (involving fraud, willful misstatement, or suppression of facts). It introduces a standardized limitation period for issuing show cause notices (SCNs) and demand orders for periods 2024-25 and onwards, providing a consistent and uniform approach.

Time Limit for Issuance of SCN: 42 months (3.5 years) from the due date of the annual return.

Time Limit for Issuance of Order: 12 months (1 year) from the date of issuance of SCN, with a possible extension of 6 months granted by the Commissioner.

The amendment retains the differentiation in penalties between bona fide and mala fide cases and continues to provide rebates at various stages of compliance, maintaining the structure of penalties and incentives.

Comparative Table for Section 74A

Situation	Existing Provision Sec 73 (Bona-Fide Cases)	Existing Provision Sec 74 (Mala-Fide Cases)	Proposed Provision Sec 74A (All Cases)
Case Covered	Other than Fraud, willful misstatement, or suppression of facts	Fraud, willful misstatement, or suppression of facts	All cases
Time Limit for Issuance of SCN	3 months prior to the due date of issuance of Order	6 months prior to the due date of issuance of Order	42 months from due date of Annual Return
Time Limit for Issuance of Order	3 years from due date of Annual Return	5 years from due date of Annual Return	12 months from date of issuance of SCN (+ possible 6 months extension)
Applicability	Upto FY 2023-24	Upto FY 2023-24	From FY 2024-25 & onwards

Simplification of Penalty Provisions

Penalty Situation	Bona-Fide Cases (Sec 73)	Mala-Fide Cases (Sec 74)	Proposed Sec 74A
Pre-SCN	No penalty payable	15% of Tax/ITC	No penalty payable for bona-fide; 15% for mala-fide
Post-SCN (Within 30 days)	No penalty payable	25% of Tax/ITC	No penalty payable for bona-fide; 25% for mala-fide
Post Passing of Order (Within 30 days)	Higher of 10% of Tax/ITC or ₹10,000	50% of Tax/ITC	Higher of 10% of Tax/ITC or ₹10,000 for bona-fide; 50% of Tax/ITC for mala-fide
Post Passing of Order (After 30 days)	Higher of 10% of Tax/ITC or ₹10,000	100% of Tax/ITC	Higher of 10% of Tax/ITC or ₹10,000 for bona-fide; 100% of Tax/ITC for mala-fide

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
135	75(1)	Where the service of notice or issuance of order is stayed by an order of a court or Appellate Tribunal, the period of such stay shall be excluded in computing the period specified in sub-sections (2) and (10) of section 73 or sub-sections (2) and (10) of section 74, as the case may be.	Where the service of notice or issuance of order is stayed by an order of a court or Appellate Tribunal, the period of such stay shall be excluded in computing the period specified in sub-sections (2) and (10) of section 73 or sub-sections (2) and (10) of section 74, *or sub-sections (2) and (7) of section 74A,* as the case may be.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.
	75(2A) – new sub-section	-	(2A) Where any Appellate Authority or Appellate Tribunal or court concludes that the penalty under clause (ii) of sub-section (5) of section 74A is not sustainable for the reason that the charges of fraud or any wilful misstatement or suppression of facts to evade tax has not been established against the person to whom the notice was issued, the penalty shall be payable by such person, under clause (i) of sub-section (5) of section 74A.”;	The proposed amendment, associated with the introduction of the new Section 74A, aligns with the existing sub-section (2) of Section 75, which addresses cases under Sections 73 and 74. It stipulates that if charges of fraud cannot be substantiated at the appellate stage against a person initially served with a notice alleging fraud, the penalty will be reduced from the proposed 100% to 10%, consistent with penalties applicable in cases not involving fraud.
	75(10)	The adjudication proceedings shall be deemed to be concluded, if the order is not issued within three years as provided for in sub-section (10) of section 73 or within five years as provided for in sub-section (10) of section 74.	(10) The adjudication proceedings shall be deemed to be concluded, if the order is not issued within the period specified in sub-section (10) of section 73 or in sub-section (10) of section 74 or in sub-section (7) of section 74A	The amendment is consequential to introduction of new Section 74A. It provides that proceedings shall be deemed to be concluded if the Order is not passed within the stipulated period u/s 73, 74, or 74A, as the case may be.
	75(11)	An issue on which the Appellate Authority or the Appellate Tribunal or the High Court has given its decision which is prejudicial to the interest of revenue in some other proceedings and an appeal to the Appellate Tribunal or the High Court or the Supreme Court against such decision of the Appellate Authority or the Appellate Tribunal or the High Court is pending, the period spent between the date of the decision of the Appellate Authority and that of the Appellate Tribunal or the date of decision of the Appellate Tribunal and that of the High Court or the date of the decision of the High Court and that of the Supreme Court shall be excluded in computing the period referred to in sub-section (10) of section 73 or sub-section (10) of section 74 where proceedings are initiated by way of issue of a show cause notice under the said sections.	(11) An issue on which the Appellate Authority or the Appellate Tribunal or the High Court has given its decision which is prejudicial to the interest of revenue in some other proceedings and an appeal to the Appellate Tribunal or the High Court or the Supreme Court against such decision of the Appellate Authority or the Appellate Tribunal or the High Court is pending, the period spent between the date of the decision of the Appellate Authority and that of the Appellate Tribunal or the date of decision of the Appellate Tribunal and that of the High Court or the date of the decision of the High Court and that of the Supreme Court shall be excluded in computing the period referred to in sub-section (10) of section 73 or sub-section (10) of section 74 *or sub section (7) of section 74A* where proceedings are initiated by way of issue of a show cause notice under the said sections.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.
	75(12)	Notwithstanding anything contained in section 73 or section 74, where any amount of self-assessed tax in accordance with a return furnished under section 39 remains unpaid, either wholly or partly, or any amount of interest payable on such tax remains unpaid, the same shall be recovered under the provisions of section 79.	Notwithstanding anything contained in section 73 or section 74 *or section 74A*, where any amount of self-assessed tax in accordance with a return furnished under section 39 remains unpaid, either wholly or partly, or any amount of interest payable on such tax remains unpaid, the same shall be recovered under the provisions of section 79.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.
	75(13)	Where any penalty is imposed under section 73 or section 74, no penalty for the same act or omission shall be imposed on the same person under any other provision of this Act.	Where any penalty is imposed under section 73 or section 74 *or section 74A*, no penalty for the same act or omission shall be imposed on the same person under any other provision of this Act.	The amendment proposes to incorporate reference to the proposed new Section 74A which will govern issuance of SCN and Adjudication Orders for demands pertaining to FY 2024-25 onwards in place of the existing Sections 73 and 74.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

136

104(1)

Where the Authority or the Appellate Authority or the National Appellate Authority finds that advance ruling pronounced by it under sub-section (4) of section 98 or under sub-section (1) of section 101 or under section 101C has been obtained by the applicant or the appellant by fraud or suppression of material facts or misrepresentation of facts, it may, by order, declare such ruling to be void ab-initio and thereupon all the provisions of this Act or the rules made thereunder shall apply to the applicant or the appellant as if such advance ruling had never been made:

Provided that no order shall be passed under this sub-section unless an opportunity of being heard has been given to the applicant or the appellant.

Explanation. – The period beginning with the date of such advance ruling and ending with the date of order under this sub-section shall be excluded while computing the period specified in sub-sections (2) and (10) of section 73 or sub-sections (2) and (10) of section 74.

Provided that no order shall be passed under this sub-section unless an opportunity of being heard has been given to the applicant or the appellant.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

137

107(6)

No appeal shall be filed under sub-section (1), unless the appellant has paid-

(a) in full, such part of the amount of tax, interest, fine, fee and penalty arising from the impugned order, as is admitted by him; and

(b) a sum equal to ten per cent. of the remaining amount of tax in dispute arising from the said order subject to a maximum of twenty-five crore rupees, in relation to which the appeal has been filed.

Provided that no appeal shall be filed against an order under sub-section (3) of section 129, unless a sum equal to twenty-five per cent. of the penalty has been paid by the appellant.

No appeal shall be filed under sub-section (1), unless the appellant has paid-

(a) in full, such part of the amount of tax, interest, fine, fee and penalty arising from the impugned order, as is admitted by him; and

(b) a sum equal to ten per cent. of the remaining amount of tax in dispute arising from the said order subject to a maximum of twenty crore rupees, in relation to which the appeal has been filed.

Provided that no appeal shall be filed against an order under sub-section (3) of section 129, unless a sum equal to twenty-five per cent. of the penalty has been paid by the appellant.

The proposed amendment seeks to reduce the maximum amount of pre-deposit required for filing appeal before the First Appellate Authority from 50 crores (25 crores under CGST and SGST each) to 40 crores (20 crores under CGST and SGST each). This means if the tax demand under CGST exceeds Rs. 200 crores even then pre-deposit shall be restricted to Rs. 20 crores.

107(11)

The Appellate Authority shall, after making such further inquiry as may be necessary, pass such order, as it thinks just and proper, confirming, modifying or annulling the decision or order appealed against but shall not refer the case back to the adjudicating authority that passed the said decision or order:

Provided that an order enhancing any fee or penalty or fine in lieu of confiscation or confiscating goods of greater value or reducing the amount of refund or input tax credit shall not be passed unless the appellant has been given a reasonable opportunity of showing cause against the proposed order:

Provided further that where the Appellate Authority is of the opinion that any tax has not been paid or short-paid or erroneously refunded, or where input tax credit has been wrongly availed or utilised, no order requiring the appellant to pay such tax or input tax credit shall be passed unless the appellant is given notice to show cause against the proposed order and the order is passed within the time limit specified under section 73 or section 74.

(11) The Appellate Authority shall, after making such further inquiry as may be necessary, pass such order, as it thinks just and proper, confirming, modifying or annulling the decision or order appealed against but shall not refer the case back to the adjudicating authority that passed the said decision or order:

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
138	109(1)	The Government shall, on the recommendations of the Council, by notification, establish with effect from such date as may be specified therein, an Appellate Tribunal known as the Goods and Services Tax Appellate Tribunal for hearing appeals against the orders passed by the Appellate Authority or the Revisional Authority.	The Government shall, on the recommendations of the Council, by notification, establish with effect from such date as may be specified therein, an Appellate Tribunal known as the Goods and Services Tax Appellate Tribunal for hearing appeals against the orders passed by the Appellate Authority or the Revisional Authority *or for conducting an examination or adjudicating the cases referred to in sub-section (2) of section 171, if so notified under the said section.*	The proposed amendment seeks to enhance the scope of empower the Appellate Tribunal to examine or adjudicate the Anti-profiteering cases as to whether input tax credits availed by any registered person or the reduction in the tax rate have actually resulted in a commensurate reduction in the price of the goods or services or both supplied by him, if so notified u/s 171(2). A related amendment is proposed u/s 171 to include Appellate Tribunal in the scope of ‘Authority’ u/s 171 so that Appellate Tribunal may be notified by the Government to act as Anti-profiteering Authority.
	109(5)	The Principal Bench and the State Bench shall hear appeals against the orders passed by the Appellate Authority or the Revisional Authority: Provided that the cases in which any one of the issues involved relates to the place of supply, shall be heard only by the Principal Bench.	The Principal Bench and the State Bench shall hear appeals against the orders passed by the Appellate Authority or the Revisional Authority: Provided that the cases in which any one of the issues involved relates to the place of supply, shall be heard only by the Principal Bench. *Provided further that the matters referred to in subsection (2) of section 171 shall be examined or adjudicated only by the Principal Bench.* *Provided also that the Government may, on the recommendations of the Council, notify other cases or class of cases which shall be heard only by the Principal Bench.*	The new 2^nd Proviso seeks to provide that Anti-profiteering matters shall only be examined or adjudicated by the Principal Bench. The said matters shall not be handed by the State Benches. The new 3^rd Proviso seeks to empower the Government to notify cases or class of cases shall be heard only by the Principal Bench.
	109(6)	The President shall, from time to time, by a general or special order, distribute the business of the Appellate Tribunal among the Benches and may transfer cases from one Bench to another.	*Subject to the provisions of subsection (5),* the President shall, from time to time, by a general or special order, distribute the business of the Appellate Tribunal among the Benches and may transfer cases from one Bench to another.	The amendment is consequential to the newly inserted provisos under sub-section (5), which prevent State Benches from handling certain notified cases. As a result, the President will have the authority to distribute cases among the other Benches of the Appellate Tribunal, excluding the notified cases that are reserved exclusively for the Principal Bench.

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
139	112(1) w.e.f. 01.08.2024	Any person aggrieved by an order passed against him under section 107 or section 108 of this Act or the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act may appeal to the Appellate Tribunal against such order within three months from the date on which the order sought to be appealed against is communicated to the person preferring the appeal.	Any person aggrieved by an order passed against him under section 107 or section 108 of this Act or the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act may appeal to the Appellate Tribunal against such order within three months from the date on which the order sought to be appealed against is communicated to the person preferring the appeal *or the date, as may be notified by the Government, on the recommendations of the Council, for filing appeal before the Appellate Tribunal under this Act, whichever is later.*	The proposed amendment aims to empower the government to specify the date from which the three-month limitation period for filing appeals before the not yet operational Appellate Tribunal (GSTAT) will commence. Recently, Circular 224/18/2024, dated 11-07-2024, was issued, arbitrarily stating that taxpayers must fulfill the pre-deposit condition under Section 112 immediately if they intend to appeal to the GSTAT in future. This has raised concerns, as the government has not yet established the tribunals, yet it is requiring taxpayers to make pre-deposits prematurely.
	112(3) w.e.f. 01.08.2024	The Commissioner may, on his own motion, or upon request from the Commissioner of State tax or Commissioner of Union territory tax, call for and examine the record of any order passed by the Appellate Authority or the Revisional Authority under this Act or the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act for the purpose of satisfying himself as to the legality or propriety of the said order and may, by order, direct any officer subordinate to him to apply to the Appellate Tribunal within six months from the date on which the said order has been passed for determination of such points arising out of the said order as may be specified by the Commissioner in his order.	The Commissioner may, on his own motion, or upon request from the Commissioner of State tax or Commissioner of Union territory tax, call for and examine the record of any order passed by the Appellate Authority or the Revisional Authority under this Act or the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act for the purpose of satisfying himself as to the legality or propriety of the said order and may, by order, direct any officer subordinate to him to apply to the Appellate Tribunal within six months from the date on which the said order has been passed *or the date, as may be notified by the Government, on the recommendations of the Council, for the purpose of filing application before the Appellate Tribunal under this Act, whichever is later*, for determination of such points arising out of the said order as may be specified by the Commissioner in his order.	The proposed amendment is in parity with the proposed amendment under sub-section (1). The time limit to file appeal by the department before the Appellate Tribunal shall also commence from the date to be notified by the government.
	112(6)	The Appellate Tribunal may admit an appeal within three months after the expiry of the period referred to in sub-section (1), or permit the filing of a memorandum of cross-objections within forty-five days after the expiry of the period referred to in sub-section (5) if it is satisfied that there was sufficient cause for not presenting it within that period.	The Appellate Tribunal may admit an appeal within three months after the expiry of the period referred to in sub-section (1) or permit the filing of an application within three months after the expiry of the period referred to in sub-section (3), or permit the filing of a memorandum of cross-objections within forty-five days after the expiry of the period referred to in sub-section (5) if it is satisfied that there was sufficient cause for not presenting it within that period.	The proposed amendment seeks to align the provisions for filing appeals before the Appellate Tribunal for both taxpayers and the department. Previously, taxpayers had a standard 3-month period with an additional 3-month condonable period for filing appeals. In contrast, the department had a standard 6-month period without a condonable period. The amendment now allows the department an additional condonable period of 3 months beyond the standard 6-month period for filing appeals.
	112(8)	No appeal shall be filed under sub-section (1), unless the appellant has paid–– (a) in full, such part of the amount of tax, interest, fine, fee and penalty arising from the impugned order, as is admitted by him, and (b) a sum equal to twenty per cent. of the remaining amount of tax in dispute, in addition to the amount paid under sub-section (6) of section 107, arising from the said order subject to a maximum of fifty crore rupees, in relation to which the appeal has been filed.	No appeal shall be filed under sub-section (1), unless the appellant has paid–– (a) in full, such part of the amount of tax, interest, fine, fee and penalty arising from the impugned order, as is admitted by him, and (b) a sum equal to *ten* per cent. of the remaining amount of tax in dispute, in addition to the amount paid under sub-section (6) of section 107, arising from the said order subject to a maximum of *twenty* crore rupees, in relation to which the appeal has been filed.	The proposed amendment aims to reduce the required pre-deposit amount for appeals to Appellate Tribunal from 20% to 10% of the disputed tax, in addition to the pre-deposit already made for filing an appeal with the First Appellate Authority (FAA). Furthermore, the maximum pre-deposit required for filing an appeal before the Appellate Tribunal has been lowered from ₹100 crores (₹50 crores under CGST and ₹50 crores under SGST) to ₹40 crores (₹20 crores under CGST and ₹20 crores under SGST). Consequently, even if the tax demand under CGST exceeds ₹200 crores, the pre-deposit will be capped at ₹20 crores, whereas prior to amendment it would have been Rs. 40 crores under CGST (20% subject to maximum of 50 crores)

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

140

122(1B)

w.e.f. 01.10.2023

Any electronic commerce operator who—

(i) allows a supply of goods or services or both through it by an unregistered person other than a person exempted from registration by a notification issued under this Act to make such supply;

(ii) allows an inter-State supply of goods or services or both through it by a person who is not eligible to make such inter-State supply; or

(iii) fails to furnish the correct details in the statement to be furnished under sub-section (4) of section 52 of any outward supply of goods effected through it by a person exempted from obtaining registration under this Act,

shall be liable to pay a penalty of ten thousand rupees, or an amount equivalent to the amount of tax involved had such supply been made by a registered person other than a person paying tax under section 10, whichever is higher.

Any electronic commerce operator, who is liable to collect tax at source under section 52,—

(i) allows a supply of goods or services or both through it by an unregistered person other than a person exempted from registration by a notification issued under this Act to make such supply;

(ii) allows an inter-State supply of goods or services or both through it by a person who is not eligible to make such inter-State supply; or

The proposed amendment, effective retrospectively from the introduction of the penal provision, clarifies that only e-commerce operators liable to collect Tax Collected at Source (TCS) under Section 52 will be subject to penalties.

Under Section 52, e-commerce operators must collect TCS on the net value of taxable supplies made through their platform by other suppliers when the operator is responsible for collecting payment for such supplies. This does not include services notified under Section 9(5), where the e-commerce operator is responsible for paying the full tax on the services provided by the supplier, such as in the cases of platforms like Ola/Uber, MakeMyTrip, or Urban Company.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

141

127

Where the proper officer is of the view that a person is liable to a penalty and the same is not covered under any proceedings under section 62 or section 63 or section 64 or section 73 or section 74 or section 129 or section 130, he may issue an order levying such penalty after giving a reasonable opportunity of being heard to such person.

Where the proper officer is of the view that a person is liable to a penalty and the same is not covered under any proceedings under section 62 or section 63 or section 64 or section 73 or section 74 or section 74A or section 129 or section 130, he may issue an order levying such penalty after giving a reasonable opportunity of being heard to such person.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

142

128A – new section

Waiver of interest or penalty or both relating to demands raised under section 73, for certain tax periods.

(1) Notwithstanding anything to the contrary contained in this Act, where any amount of tax is payable by a person chargeable with tax in accordance with,

(a) a notice issued under sub-section (1) of section 73 or a statement issued under sub-section (3) of section 73, and where no order under sub-section (9) of section 73 has been issued; or

(b) an order passed under sub-section (9) of section 73, and where no order under sub-section (11) of section 107 or sub-section (1) of section 108 has been passed; or

(c) an order passed under sub-section (11) of section 107 or sub-section (1) of section 108, and where no order under sub-section (1) of section 113 has been passed,

pertaining to the period from 1st July, 2017 to 31st March, 2020, or a part thereof, and the said person pays the full amount of tax payable as per the notice or statement or the order referred to in clause (a), clause (b) or clause (c), as the case may be, on or before the date, as may be notified by the Government on the recommendations of the Council, no interest under section 50 and penalty under this Act, shall be payable and all the proceedings in respect of the said notice or order or statement, as the case may be, shall be deemed to be concluded, subject to such conditions as may be prescribed:

Provided that where a notice has been issued under sub section (1) of section 74, and an order is passed or required to be passed by the proper officer in pursuance of the direction of the Appellate Authority or Appellate Tribunal or a court in accordance with the provisions of sub-section (2) of section 75, the said notice or order shall be considered to be a notice or order, as the case may be, referred to in clause (a) or clause (b) of this sub-section:

Provided further that the conclusion of the proceedings under this sub-section, in cases where an application is filed under sub-section (3) of section 107 or under sub-section (3) of section 112 or an appeal is filed by an officer of central tax under sub-section (1) of section 117 or under sub-section (1) of section 118 or where any proceedings are initiated under sub-section (1) of section 108, against an order referred to in clause (b) or clause (c) or against the directions of the Appellate Authority or the Appellate Tribunal or the court referred to in the first proviso, shall be subject to the condition that the said person pays the additional amount of tax payable, if any, in accordance with the order of the Appellate Authority or the Appellate Tribunal or the court or the Revisional Authority, as the case may be, within three months from the date of the said order:

Provided also that where such interest and penalty has already been paid, no refund of the same shall be available.

(2) Nothing contained in sub-section (1) shall be applicable in respect of any amount payable by the person on account of erroneous refund.

(3) Nothing contained in sub-section (1) shall be applicable in respect of cases where an appeal or writ petition filed by the said person is pending before Appellate Authority or Appellate Tribunal or a court, as the case may be, and has not been withdrawn by the said person on or before the date notified under sub-section (1).

(4) Notwithstanding anything contained in this Act, where any amount specified under sub-section (1) has been paid and the proceedings are deemed to be concluded under the said sub-section, no appeal under sub-section (1) of section 107 or sub-section (1) of section 112 shall lie against an order referred to in clause (b) or clause (c) of sub-section (1), as the case may be.

The proposed Section outlines a special mechanism for concluding tax proceedings for the initial tax periods, specifically from July 1, 2017, to March 31, 2020, as recommended by the 53d GST Council meet, under specified conditions.

The provision applies where tax liability arises u/s 73 and either adjudication is pending, or appeal is underway.

The provision allows for the conclusion of proceedings without the payment of interest or penalties if the taxpayer pays the full amount of tax due as per the relevant notice, statement, or order issued u/s 73, by a specified date, as notified by the government. Notably, the Press Release issued after 53^rd Council Meet had intimated the cut-off date as 31.03.2025 but the law makers have deemed it fir to vest powers with the Government which can even notify an extended deadline.

In cases where a demand was confirmed under Section 74 but, following an appeal to the Appellate Authority, the proper officer is directed to issue an order under Section 75(2) because the charges of fraud required under Section 74 could not be substantiated, the demand shall be treated as confirmed under Section 73 and shall be eligible for resolution under this provision.

The provision does not apply to demands related to erroneous refunds.

If an additional tax liability arises from appellate or court proceedings as a result of the department's appeal, or as a result of order of Revisional Authority, the taxpayer must pay the specified amount within three months of the order to fully conclude the proceedings.

No refund of already paid interest and penalties will be granted, indicating that the provision is prospective in terms of relief.

Once the specified tax amount is paid under this provision, the taxpayer cannot file an appeal against the orders covered by the provision, effectively closing the dispute from further judicial review.

The provision warrants withdrawal of pending appeals or writ petitions before the notified date.

Notably, there is no restriction on payment of tax demand through e-credit ledger.

Issues that need further clarification are:

Does Section 128A apply if an order under Section 73(9) is issued solely for interest or penalties, without any underlying tax demand? In our opinion, the benefit should be extended.

Is the benefit under Section 128A available only if the case is currently alive under adjudication or appeal? Specifically, does a taxpayer need to file an appeal against adverse demand orders for FY 2018-19 and onwards to avail of the scheme's benefit?

In our opinion, an Appeal should be filed until clarified considering the language employed in clauses (a), (b) & (c) which imply that the matter must be alive and should not have attained finality. Once appeal is filed, the taxpayer may exercise the option under the scheme by making payment of tax before the notified date and withdraw the appeal.

If an appeal is not filed, can recovery actions be enforced before the provision is formally enacted, in cases where the taxpayer plans to settle under the scheme?

In our opinion, it is advisable to file appeal before the FAA/Appellate Tribunal so that the dispute is alive in terms of clauses (a), (b), and (c). Subsequently, the same will be required to be withdrawn in terms of 128A(3).

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
143	140 – w.e.f. 01.07.2017	Notwithstanding anything to the contrary contained in this Act, the input tax credit on account of any services received prior to the appointed day by an Input Service Distributor shall be eligible for distribution as credit under this Act, within such time and in such manner as may be prescribed, even if the invoices relating to such services are received on or after the appointed day.	Notwithstanding anything to the contrary contained in this Act, the input tax credit on account of any services received prior to the appointed day by an Input Service Distributor shall be eligible for distribution as credit under this Act, within such time and in such manner as may be prescribed, *whether the invoices relating to such services are received prior to, on or after, the appointed day.*	The retrospective amendment proposes to allow the transitional credit of eligible CENVAT credit on account of input services received by an ISD prior to the appointed day, for which invoices were received after appointed date.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

144

171(2)

The Central Government may, on recommendations of the Council, by notification, constitute an Authority, or empower an existing Authority constituted under any law for the time being in force, to examine whether input tax credits availed by any registered person or the reduction in the tax rate have actually resulted in a commensurate reduction in the price of the goods or services or both supplied by him.

Provided that the Government may by notification, on the recommendations of the Council, specify the date from which the said Authority shall not accept any request for examination as to whether input tax credits availed by any registered person or the reduction in the tax rate have actually resulted in a commensurate reduction in the price of the goods or services or both supplied by him.

Explanation.1–For the purposes of this sub-section, “request for examination” shall mean the written application filed by an applicant requesting for examination as to whether input tax credits availed by any registered person or the reduction in the tax rate have actually resulted in a commensurate reduction in the price of the goods or services or both supplied by him.

Explanation 2.– For the purposes of this section, the expression “Authority” shall include the “Appellate Tribunal”.

The proposed amendment seeks to empower the government to notify a sunset clause for the Anti-profiteering measures, after which new applications will no longer be accepted by the Anti-profiteering authority.

This aligns with the original intent of these provisions, which were introduced to prevent suppliers from taking undue advantage of the transition to the GST regime, such as by exploiting increases in input tax credit or reductions in tax rates. The aim was to ensure that the benefits of GST implementation were passed on to consumers through reduced prices.

Additionally, the amendment proposes the inclusion of the Appellate Tribunal as one of the Anti-profiteering Authorities, allowing it to examine and adjudicate such matters. This is in line with the proposed changes in Section 112, which grant the Principal Bench of the Appellate Tribunal the authority to examine and adjudicate anti-profiteering issues.

Clause no.

Section

Existing provision

Proposed amendment

Author’s comments

145

Para 9 of Schedule III – new insertion

Activity of apportionment of co-insurance premium by the lead insurer to the co-insurer for the insurance services jointly supplied by the lead insurer and the co-insurer to the insured in coinsurance agreements, subject to the condition that the lead insurer pays the central tax, the State tax, the Union territory tax and the integrated tax on the entire amount of premium paid by the insured.

Schedule III prescribes the activities that are deemed as neither supply of goods nor supply of services, thereby not leviable to GST.

The amendment pertains to co-insurance arrangements where multiple insurers (lead insurer and co-insurers) jointly provide insurance services to the insured. In such agreements, a lead insurer typically collects the entire insurance premium from the insured and then apportions the relevant shares to the co-insurers.

The specific activity proposed to be covered by Schedule III is the apportionment of the co-insurance premium by the lead insurer to the co-insurers. This involves the distribution of the total premium collected from the insured among the participating insurers as per their respective shares in the co-insurance agreement.

The amendment provides that this apportionment activity, carried out by the lead insurer, will not be treated as a separate supply of services under GST. This is contingent upon the condition that the lead insurer pays the applicable central tax, State tax, Union territory tax, and integrated tax on the entire premium amount paid by the insured. Essentially, this means the GST liability on the premium is discharged in full by the lead insurer on behalf of all participating insurers.

The amendment acknowledges that in co-insurance arrangements, multiple insurers collectively provide a single insurance service to the insured, and there is no supply of goods or services between the insurers themselves. Instead, the insurers merely share the revenue or premium based on their respective contributions to the joint service. Since there is no inter-insurer supply, this activity should not attract GST.

However, prior to the amendment, the tax authorities were issuing Show Cause Notices (SCNs) and raising substantial demands on the premium amounts apportioned among insurers, treating these as taxable supplies. To counteract these artificial demands, which lacked an underlying supply of goods or services, the amendment clarifies that the apportionment of premiums in such co-insurance agreements is deemed neither a supply of goods nor a supply of services, thereby exempting it from GST.

Para 10 of Schedule III – new insertion

Services by insurer to the reinsurer for which ceding commission or the reinsurance commission is deducted from reinsurance premium paid by the insurer to the reinsurer, subject to the condition that the central tax, the State tax, the Union territory tax and the integrated tax is paid by the reinsurer on the gross reinsurance premium payable by the insurer to the reinsurer, inclusive of the said ceding commission or the reinsurance commission.

The proposed amendment addresses the treatment of ceding commissions or reinsurance commissions in the context of reinsurance agreements.

In reinsurance, an insurer (ceding insurer) transfers part of the risk it has assumed from policyholders to another insurer (reinsurer). This is done by paying a reinsurance premium to the reinsurer. The reinsurer, in return, may pay a ceding commission or reinsurance commission to the ceding insurer, which is typically deducted from the reinsurance premium.

The ceding commission or reinsurance commission compensates the ceding insurer for acquiring and administering the insurance business. It effectively reduces the net reinsurance premium payable by the ceding insurer to the reinsurer.

Prior to this amendment, there was ambiguity about the GST treatment of ceding commissions or reinsurance commissions. Specifically, it was unclear whether these amounts should be treated as a consideration for a separate supply of services by the insurer to the reinsurer, thereby attracting GST.

The amendment proposes that services provided by the insurer to the reinsurer, for which the ceding commission or reinsurance commission is deducted, should not be treated as a separate taxable supply. Instead, these services are considered part of the overall reinsurance transaction.

The reinsurer is required to pay GST on the gross reinsurance premium, which includes the ceding commission or reinsurance commission. This means the tax base for GST is the total premium amount before the deduction of any commissions. This approach simplifies compliance by consolidating the tax liability with the reinsurer.

The amendment provides certainty and uniformity in the GST treatment of reinsurance transactions. It eliminates the disputes and differing interpretations regarding the taxability of commissions in reinsurance contracts.

The inclusion of Para 10 in Schedule III ensures that ceding commissions or reinsurance commissions are not treated as separate taxable supplies, provided that GST is paid on the gross reinsurance premium by the reinsurer.

Clause no.	Section	Existing provision	Proposed amendment	Author’s comments
146	-	-	*No refund shall be made of all the tax paid or the input tax credit reversed, which would not have been so paid, or not reversed, had section 114 been in force at all material times.*	This clause prevents the taxpayers from claiming refund of tax paid or ITC reversed by virtue of original limitation u/s 16(4) which is now proposed to be extended by Clause 114 of this Finance Bill to 30.11.2021 by insertion of new sub-section 16(5) for the initial FYs from 2017-18 to 2020-21. The benefit shall be available to those who are either contesting the demand or from whom recovery has not been enforced.

PROPOSED AMENDMENTS IN THE IGST ACT, 2017

Clause no.	Section of IGST Act	Author’s comments
147	5(1)	This clause proposes the same amendment in Section 5(1) of the IGST Act, 2017, as the clause 110 in Section 9(1) of the CGST Act, 2017, w.r.t. undenatured extra neutral alcohol or rectified spirit used for manufacture of alcoholic liquor, for human consumption
148	6A	This clause proposes to insert Section 6A in the IGST Act, 2017, same as clause 112 proposes insertion of Section 11A in the CGST Act, 2017, w.r.t. regularisation of non-levy or short-levy due to industry practice.
150	20	The proposed amendment is line with the amendment carried out by Clause 137 and 139 to Sections 107(6) and 112(8) of the CGST Act respectively by capping the maximum amount of pre-deposit to Rs. 40 crores. To illustrate: if the disputed IGST demand before Appellate Authority or Appellate Tribunal is 250 crores then the 20% pre-deposit shall be restricted to Rs. 40 crores.

Clause no.

Section of IGST Act

Existing provision

Proposed amendment

Author’s comments

149

16(4)

The Government may, on the recommendation of the Council, and subject to such conditions, safeguards and procedures, by notification, specify-

(i) a class of persons who may make zero rated supply on payment of integrated tax and claim refund of the tax so paid;

(ii) a class of goods or services which may be exported on payment of integrated tax and the supplier of such goods or services may claim the refund of tax so paid.

The Government may, on the recommendation of the Council, and subject to such conditions, safeguards and procedures, by notification, specify–

(i) a class of persons who may make zero rated supply on payment of integrated tax and claim refund of the tax so paid in accordance with the provisions of section 54 of the Central Goods and Services Tax Act or the rules made thereunder;

(ii) a class of goods or services or both, on zero rated supply of which, the supplier may pay integrated tax and claim the refund of tax so paid, in accordance with the provisions of section 54 of the Central Goods and Services Tax Act or the rules made thereunder.

The proposed amendment seeks to link the claim of refund of IGST paid on zero-rated supply in accordance with the provisions of Section 54 of the CGST Act and the Rules made thereunder. While practically, prior to amendment also Section 54 of the CGST governed the refunds and was equally applicable to the Refund of IGST in accordance with Section 20 of the IGST Act however, this amendment has incorporated specific reference of Section 54 and the Rules made thereunder in Section 16 of the IGST Act. As a result, the refund of IGST paid on export of goods would also be governed by Section 54 and Rules made thereunder.

16(5) – new sub-section

Notwithstanding anything contained in subsections (3) and (4), no refund of unutilised input tax credit on account of zero-rated supply of goods or of integrated tax paid on account of zero rated supply of goods shall be allowed where such zero rated supply of goods are subjected to export duty.

The proposed amendment is replica of the amendment carried out by Clause 124 in Section 54 of the CGST Act to plug the lacuna which allowed the exporter of goods to claim refund of IGST paid on export of goods subjected to export duty while refund of ITC under LUT route was explicitly denied by virtue of proviso to Section 54(3) of the CGST Act. The amendment brings the LUT route and IGST payment route at par for export of goods subjected to export duty by disallowing the refunds associated to zero-rated supplies.

PROPOSED AMENDMENTS IN THE UTGST ACT, 2017

Clause no.	Section of UTGST Act	Author’s comments
151	7(1)	This clause proposes the same amendment in Section 7(1) of the UTGST Act, 2017, as the clause 110 in Section 9(1) of the CGST Act, 2017, w.r.t. undenatured extra neutral alcohol or rectified spirit used for manufacture of alcoholic liquor, for human consumption
152	8A	This clause proposes to insert Section 8A in the UTGST Act, 2017, same as clause 112 proposes insertion of Section 11A in the CGST Act, 2017, w.r.t. regularisation of non-levy or short-levy due to industry practice.

PROPOSED AMENDMENTS IN THE GST (COMPENSATION TO STATES) ACT, 2017

Clause no.	Section	Author’s comments
153	8A	This clause proposes to insert Section 8A in the GST (Compensation to States) Act, 2017, same as clause 112 proposes insertion of Section 11A in the CGST Act, 2017, w.r.t. regularisation of non-levy or short-levy due to industry practice.

All clauses (from 110 to 153) of the FINANCE (NO. 2) BILL, 2024, will come into force from a date to be notified by the GST Council (prospectively), unless stated above otherwise. It's important to note that these provisions are currently part of the Finance Bill, which will become law only after receiving the assent of the President of India. Only then will the GST Council have the authority to notify the effective date for these amendments.

By: Siddhant Pathak - July 26, 2024

Discussions to this article

WELL DONE SIDHANT JI WHILE PREPARING THE SAID COMPARISON SHEET '

PLEASE DO THIS ON DIRECT TAXES ALSO

ALL THE BEST

By: harjinder singh
Dated: July 27, 2024

insightful analysis and comprehensive coverage of the GST topic have significantly contributed to our understanding of the complexities involved

Your article was not only informative but also well-researched and articulated with clarity. The manner in which you dissected the implications of various amendments and provided a balanced perspective is commendable.

By: harjinder singh
Dated: July 27, 2024

Very good and detailed analysis ji

By: PAWANKUMAR SONI
Dated: July 27, 2024

Sh.Siddhant Pathak Ji,

I have read your all articles on this forum. You have not given your profile in this forum. Your creations speak for itself. You are possessing old head on young shoulders. Excellent articles indeed. To cap it all, every Tom, Dick and Harry does not possess such talent.. Kudos to you. Keep it up.