GST Amendments

Cheatsheet Content

### 🟢 BASICS: ENA (Sep 2025+) - **The Amendment:** Un-denatured Extra Neutral Alcohol (ENA) or rectified spirit used to manufacture alcoholic liquor for human consumption is permanently excluded from GST. - **Old Provision:** N/A - **Practical Example:** A distillery buying ENA specifically to manufacture whiskey pays no GST. ### 🟢 BASICS: Sch III (May 2026+) - **The Amendment:** Supply of goods warehoused in an SEZ or FTWZ to any person before clearance for export or to the DTA is neither a supply of goods nor services. - **Old Provision:** N/A - **Practical Example:** Trading goods directly from an SEZ warehouse to a buyer before they are cleared for the domestic market. ### 🟢 BASICS: Sch III (Sep 2025+) - **The Amendment:** Apportioned premium paid to a co-insurer, or ceding commission deducted by an insurer from re-insurance, is not a supply (provided gross GST is paid by lead/re-insurer). - **Old Provision:** N/A - **Practical Example:** LIC shares a ₹4k premium with HDFC Life; no GST applies on the ₹4k transfer if LIC paid the gross tax. ### 🟢 EXEMPTIONS (Sep 2025+) - **The Amendment:** Life/Health Insurance to an individual/family is exempt (corporate group policies are NOT exempt). Motor Vehicle Accident Fund insurance to insurers is exempt. Road transport of goods is exempt except for GTAs, couriers, and ECO local deliveries. - **Old Provision:** N/A - **Practical Example:** Buying a family health floater is exempt; an IT company buying bulk group cover remains taxable. ### 🟢 EXEMPTIONS: Training (Sep 2025+) - **The Amendment:** Exemptions modified for specific training bodies recognized by NCVET and NSDC. - **Old Provision:** N/A - **Practical Example:** A certified skill development course under NCVET qualifies for the modified GST exemption. ### 🟠 CHARGE: Rates (Sep 22, 2025) - **The Amendment:** The 12% and 28% GST brackets have been merged/removed. - **Old Provision:** 12% and 28% slabs existed. - **Practical Example:** N/A ### 🟠 CHARGE: RCM (Sep 2025+) - **The Amendment:** Commercial renting of immovable property is taxable under RCM if provided by an unregistered person to a registered person (excluding composition dealers). Sponsorship is RCM if non-corporate to a firm/corporate. - **Old Provision:** N/A - **Practical Example:** An unregistered shop owner rents retail space to Reliance; Reliance pays the GST under RCM. ### 🟠 CHARGE: GTA FCM (Sep 2025+) - **The Amendment:** Under Forward Charge Mechanism (FCM), a Goods Transport Agency (GTA) can now opt to pay 18% (with ITC) or 5% (without ITC). - **Old Provision:** N/A - **Practical Example:** A GTA can charge 18% GST and claim input tax credit on the purchase of their delivery trucks. ### 🟠 CHARGE: ECOs (Sep 2025+) - **The Amendment:** ECOs are liable for local deliveries (unless supplier is registered u/s 22) and restaurants (unless hotel tariff > ₹7,500/day). Tax on ECO commission must be paid in cash only (no ITC). - **Old Provision:** N/A - **Practical Example:** Porter pays GST for a delivery from an unregistered hardware store. Zomato pays tax on its own fee in cash. ### 🔵 TIME/VALUE (Sep 2025+) - **The Amendment:** RCM Time of Supply is the payment date OR 61st day from supplier invoice. Post-supply discount reversal where tax exceeds ₹5 Lakhs requires a CA/CMA certificate. - **Old Provision:** Lottery value was 100/128. - **Practical Example:** Receiving a massive discount resulting in a ₹6 Lakh tax reversal requires a CA's certification. (Lottery is now 100/140). ### 🔵 TIME: RCM Invoice (Sep 2025+) - **The Amendment:** If the recipient is issuing the invoice (unregistered supplier), it must be issued within 30 days of receiving the goods/services. - **Old Provision:** N/A - **Practical Example:** A registered company buys goods from an unregistered vendor; they have 30 days to issue the RCM invoice. ### 🔵 ITC: Mandatory ISD (Jan 2026) - **The Amendment:** Head Offices must mandatorily register as an Input Service Distributor (ISD) to distribute common input services and can accept RCM invoices. - **Old Provision:** Optional distribution. - **Practical Example:** A Head Office receives a nationwide marketing invoice and uses ISD to distribute the ITC to branches. ### 🔵 ITC: Time Limit (Sep 2025+) - **The Amendment:** Maximum time limit to avail ITC is November 30th of the following year, or the date of filing the Annual Return, whichever is earlier. - **Old Provision:** N/A - **Practical Example:** For an invoice dated May 2024, ITC must be claimed by Nov 30, 2025, or when the FY24-25 return is filed. ### 🔵 ITC: Blocked (Sep 2025+) - **The Amendment:** Tax paid u/s 74 is blocked only for periods up to FY 2023-24. SC ruled commercial buildings for rent and telecom towers are not blocked. - **Old Provision:** Sec 74 tax was fully blocked across years. - **Practical Example:** ITC on the construction of a telecommunication tower is now allowed based on the SC precedent. ### 🔴 DEMAND: Sec 74A (FY 2024-25 onwards) - **The Amendment:** Merges Sec 73 and 74 into Sec 74A. SCN limit is 42 months; Order limit is 12 months. Min SCN threshold is ₹1,000. Non-fraud penalty is 10%; Fraud penalty up to 100%. - **Old Provision:** Separate Sections 73 and 74 with different fraud/non-fraud time limits applied. - **Practical Example:** For an error made in FY 24-25, the officer has exactly 3.5 years from the annual return to issue the SCN. ### 🔴 APPEALS (Sep 2025+) - **The Amendment:** Appeals pre-deposit reduced to 10% of tax in dispute (Max ₹20 Cr CGST/₹40 Cr IGST) or 10% of the penalty amount. - **Old Provision:** Higher pre-deposits. - **Practical Example:** Disputing a ₹10 Lakh tax demand at the Appellate Authority now only requires a ₹1 Lakh pre-deposit. ### 🔴 CUSTOMS: IGCR/Job (Sep 2025+) - **The Amendment:** Importers must submit Quarterly IGCR statements. Goods sent to a job worker have a max 1-year processing limit. - **Old Provision:** IGCR statements were monthly. Job worker limit was 6 months. - **Practical Example:** Raw materials sent to a third-party factory for processing can now stay there for up to 12 months without penalty. ### 🔴 CUSTOMS: Assessment (Sep 2025+) - **The Amendment:** Importers/Exporters can voluntarily revise entry post-clearance to pay short-paid duty with interest (treated as a refund claim if excess was paid). - **Old Provision:** N/A - **Practical Example:** An importer realizes they underpaid duty by ₹5,000 after goods cleared customs; they can voluntarily pay it with interest now.