Rule 86A ledger blocking remains distinct from deemed recovery stay following an appellate pre-deposit, requiring separate unblocking consideration.

Rule 86A ledger blocking remains distinct from deemed recovery stay following an appellate pre-deposit, requiring separate unblocking consideration.Case-LawsGSTRule 86A blocking of an electronic credit ledger is a provisional measure that requires reco…

Rule 86A ledger blocking remains distinct from deemed recovery stay following an appellate pre-deposit, requiring separate unblocking consideration.
Case-Laws
GST
Rule 86A blocking of an electronic credit ledger is a provisional measure that requires recorded reasons and cannot continue beyond one year. Filing an appeal with the prescribed pre-deposit creates a deemed stay of recovery for the remaining demand, preventing appropriation from the electronic cash ledger and the blocked credit ledger. That recovery stay does not automatically lift the separate Rule 86A blocking order. Unblocking must be sought independently, and any refusal should be issued through a speaking order after consideration of the request.
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Provisional GST bank-account attachments lapse after one year, requiring defreezing where no fresh attachment order exists.

Provisional GST bank-account attachments lapse after one year, requiring defreezing where no fresh attachment order exists.Case-LawsGSTProvisional attachment of bank accounts under GST is a pre-emptive revenue-protection measure that ceases by operatio…

Provisional GST bank-account attachments lapse after one year, requiring defreezing where no fresh attachment order exists.
Case-Laws
GST
Provisional attachment of bank accounts under GST is a pre-emptive revenue-protection measure that ceases by operation of law one year after the attachment order. Continued freezing cannot rest on an expired attachment where no fresh provisional attachment order has been issued. Where account holders were not recipients of a later demand-cum-show cause notice, that notice did not provide a basis to maintain restrictions on their accounts. The lapsed attachments required the bank accounts to be defreezed and made operable upon production of a certified copy of the order.
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Incorrect GST head payments may be adjusted against IGST liability without duplicate tax payment or interest.

Incorrect GST head payments may be adjusted against IGST liability without duplicate tax payment or interest.Case-LawsGSTTax paid under the CGST and SGST heads through a clerical error may be appropriated towards the corresponding IGST liability where …

Incorrect GST head payments may be adjusted against IGST liability without duplicate tax payment or interest.
Case-Laws
GST
Tax paid under the CGST and SGST heads through a clerical error may be appropriated towards the corresponding IGST liability where the entire liability was discharged within the prescribed period. Although Section 77 does not expressly address this payment error, its underlying principle avoids requiring the taxable person to make a duplicate payment and then pursue a refund. Interest should not apply where the required tax has already been remitted, albeit under incorrect GST heads. Appropriation may be made on application, with a refund application filed if required procedurally.
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Duplicate GST adjudication on identical issues and periods undermines later State GST assessment and rectification action.

Duplicate GST adjudication on identical issues and periods undermines later State GST assessment and rectification action.Case-LawsGSTParallel Central and State GST proceedings concerning identical issues for the same assessment period require avoidanc…

Duplicate GST adjudication on identical issues and periods undermines later State GST assessment and rectification action.
Case-Laws
GST
Parallel Central and State GST proceedings concerning identical issues for the same assessment period require avoidance of duplicate adjudication. Where Central GST authorities issue an earlier adjudication order and an appeal against it remains pending, subsequent State GST assessment and rectification orders addressing the same issues and period cannot be sustained. The overlap between the two proceedings makes the later State GST action duplicative of the prior Central GST adjudication.
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Mandatory e-way bill compliance was not enforceable before nationwide implementation, preventing detention and penalty for non-production.

Mandatory e-way bill compliance was not enforceable before nationwide implementation, preventing detention and penalty for non-production.Case-LawsGSTMandatory nationwide e-way bill compliance for inter-State movement of goods took effect only from 1 A…

Mandatory e-way bill compliance was not enforceable before nationwide implementation, preventing detention and penalty for non-production.
Case-Laws
GST
Mandatory nationwide e-way bill compliance for inter-State movement of goods took effect only from 1 April 2018, despite rule 138 having provided the operational mechanism earlier. Non-production of an e-way bill for goods intercepted before that date therefore did not justify detention or penalty. Correspondence between the goods, invoice and transport documents, coupled with the absence of discrepancies or material indicating intent to evade tax, supported deletion of the detention proceedings and penalty. The Revenue's challenge against that deletion failed.
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E-way bill validity requires correct Part B vehicle details; expired bills with mismatched vehicles can support tax-evasion penalty.

E-way bill validity requires correct Part B vehicle details; expired bills with mismatched vehicles can support tax-evasion penalty.Case-LawsGSTE-way bill validity requires Part B to state the actual vehicle used for movement; a concession for minor cl…

E-way bill validity requires correct Part B vehicle details; expired bills with mismatched vehicles can support tax-evasion penalty.
Case-Laws
GST
E-way bill validity requires Part B to state the actual vehicle used for movement; a concession for minor clerical errors does not cover entirely different vehicle particulars. Transport under an expired e-way bill bearing a wholly different vehicle number may support a rebuttable presumption of intent to evade tax. Mens rea is not required for a civil fiscal penalty unless the governing enactment makes it essential. The presumption remains rebuttable through surrounding facts, but failure to provide a satisfactory rebuttal supports penalty under the CGST/UPGST transport-of-goods provisions. On the stated facts, the penalty was sustained and the second appeal dismissed.
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Inverted Duty Refund Turnover Requires Verified Treatment of Differently Taxed Outward Supplies Before Refund Computation

Inverted Duty Refund Turnover Requires Verified Treatment of Differently Taxed Outward Supplies Before Refund ComputationCase-LawsGSTInverted duty structure refund computation requires accurate determination of turnover of inverted-rated supplies and a…

Inverted Duty Refund Turnover Requires Verified Treatment of Differently Taxed Outward Supplies Before Refund Computation
Case-Laws
GST
Inverted duty structure refund computation requires accurate determination of turnover of inverted-rated supplies and adjusted total turnover. The treatment of outward supplies allegedly taxable at a higher rate must be verified before deciding whether they form part of the relevant turnover figures. Where supporting invoices or other documents are unavailable and the relevant issue has not been examined, the admissible accumulated input tax credit refund cannot be correctly quantified. Refund computation requires fresh examination after production of relevant records and a reasonable opportunity for both sides to address the turnover treatment.
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Pre-GST service tax refunds for cancelled flat bookings must be claimed in cash, not through GST input tax credit.

Pre-GST service tax refunds for cancelled flat bookings must be claimed in cash, not through GST input tax credit.Case-LawsGSTPre-GST service tax paid on advances for flat bookings later cancelled after the appointed day does not qualify as input tax u…

Pre-GST service tax refunds for cancelled flat bookings must be claimed in cash, not through GST input tax credit.
Case-Laws
GST
Pre-GST service tax paid on advances for flat bookings later cancelled after the appointed day does not qualify as input tax under the CGST/SGST Acts and cannot be carried as GST input tax credit. Where services are ultimately unprovided, the transitional provision requires the service-tax refund claim to be processed under the existing law and paid in cash. Taxpayers cannot adjust that claim through an electronic credit ledger without specific statutory authority. The claimed GST credit was therefore inadmissible.
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Reasoned GST appellate orders required as unaddressed grounds and procedural objections require fresh adjudication in full.

Reasoned GST appellate orders required as unaddressed grounds and procedural objections require fresh adjudication in full.Case-LawsGSTReasoned appellate orders are required by natural justice: common GST appellate orders confirming demands were invali…

Reasoned GST appellate orders required as unaddressed grounds and procedural objections require fresh adjudication in full.
Case-Laws
GST
Reasoned appellate orders are required by natural justice: common GST appellate orders confirming demands were invalid because they gave only a general conclusion without addressing material appeal grounds, cited judicial authorities, or each appellant's distinct contentions. The failure to give cogent reasons constituted a failure to exercise appellate jurisdiction. Objections concerning show cause notices, availability of relied-upon documents, and effective personal hearing in original proceedings also required consideration. The Tribunal set aside the appellate and original orders and remitted the matters for fresh adjudication after providing relied-upon documents, allowing replies and effective hearings, and issuing reasoned orders.
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Mixed Supply Classification Applies Highest GST Rate to Bundled Digital Cinema Equipment Leasing Under a Single Rental Agreement

Mixed Supply Classification Applies Highest GST Rate to Bundled Digital Cinema Equipment Leasing Under a Single Rental AgreementCase-LawsGSTLeasing digital cinema equipment comprising a projector, server, UPS and VSAT for a single rental is classified …

Mixed Supply Classification Applies Highest GST Rate to Bundled Digital Cinema Equipment Leasing Under a Single Rental Agreement
Case-Laws
GST
Leasing digital cinema equipment comprising a projector, server, UPS and VSAT for a single rental is classified as a mixed supply where the items are not naturally bundled in the ordinary course of business and can be supplied independently. The bundled lease therefore does not meet the requirements of a composite supply. GST is payable at the highest rate applicable to any constituent supply, which is the rate applicable to the projector: 28% up to 21 September 2025 and 18% thereafter. The bundled-lease treatment as a mixed supply is accordingly correct.
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Psyllium seed GST classification confirms taxability where godown storage gives supplies a dried character, denying claimed exemptions.

Psyllium seed GST classification confirms taxability where godown storage gives supplies a dried character, denying claimed exemptions.Case-LawsGSTPsyllium seeds (Isabgol) are classified under tariff sub-heading 1211 9013, supported by the express tari…

Psyllium seed GST classification confirms taxability where godown storage gives supplies a dried character, denying claimed exemptions.
Case-Laws
GST
Psyllium seeds (Isabgol) are classified under tariff sub-heading 1211 9013, supported by the express tariff description and HSN coverage of Plantago psyllium herbs and seeds. GST exemption as fresh or chilled plant parts under Entry 87 was denied for supplies stored in godowns before onward sale. Eligibility depends on the goods' condition when supplied by the applicant, and godown storage was treated as giving the seeds a dried character. The supplies were consequently taxable at 5% under Entry 71 of Schedule I. The alternative exemption for goods of seed quality under Entry 77 was also denied.
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Composite coaching supply keeps study materials taxable, while pure-agent fees require strict conditions and forex differences remain outside GST.

Composite coaching supply keeps study materials taxable, while pure-agent fees require strict conditions and forex differences remain outside GST.Case-LawsGSTProfessional coaching supplied by an entity that does not itself deliver a recognised qualifyi…

Composite coaching supply keeps study materials taxable, while pure-agent fees require strict conditions and forex differences remain outside GST.
Case-Laws
GST
Professional coaching supplied by an entity that does not itself deliver a recognised qualifying curriculum, conduct examinations or award qualifications is not exempt as education by an educational institution and is taxable. Examination, registration and related student fees remain within taxable value unless all pure-agent conditions, including student authorisation and separate invoice disclosure, are met. Coaching bundled for a single fee with study materials and digital resources is a composite supply whose principal supply is commercial training. Retained foreign-exchange differences unconnected with separate consideration are outside GST. Training-partner services to universities are taxable where no exempt service or educational-institution status is established; insufficient contractual material prevents precise six-digit classification.
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Agglomerated cork classification permits concessional GST treatment, while inverted-duty refund eligibility remains outside advance-ruling jurisdiction.

Agglomerated cork classification permits concessional GST treatment, while inverted-duty refund eligibility remains outside advance-ruling jurisdiction.Case-LawsGSTAdvance-ruling jurisdiction under section 97(2) does not extend to eligibility for refun…

Agglomerated cork classification permits concessional GST treatment, while inverted-duty refund eligibility remains outside advance-ruling jurisdiction.
Case-Laws
GST
Advance-ruling jurisdiction under section 97(2) does not extend to eligibility for refund of unutilised input tax credit arising from an inverted duty structure; that question is therefore not admissible. Heading 4504 covers agglomerated cork with or without a binding substance, without limits on the binder's quantity or nature. Cork sheets formed from agglomerated cork granules held together by a polymer system, rather than cork used merely as a rubber filler, fall under tariff item 4504 10 10 and qualify for the concessional GST entry. The bar applies only where the same question is pending or decided in proceedings concerning the applicant; absent such proceedings, classification and rate questions remain admissible.
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11th Meeting of National Traders’ Welfare Board Convened in New Delhi

11th Meeting of National Traders’ Welfare Board Convened in New DelhiGSTDated:- 25-9-2026Board Reviews Measures for Trader Welfare, Ease of Doing Business, Digital Empowerment and Export Promotion

The 11th Meeting of the National Traders’ Welfare Bo…

11th Meeting of National Traders’ Welfare Board Convened in New Delhi
GST
Dated:- 25-9-2026

Board Reviews Measures for Trader Welfare, Ease of Doing Business, Digital Empowerment and Export Promotion

The 11th Meeting of the National Traders' Welfare Board (NTWB) was convened at Vanijya Bhawan, New Delhi, in hybrid mode. The Board reviewed a range of measures concerning trader welfare, Ease of Doing Business, digital empowerment, access to finance, Centre-State coordination and export promotion. The deliberations also covered issues relating to GST, MSMEs, trader grievance redressal, digital platforms and strengthening institutional support for traders, retailers, manufacturers, exporters and service providers.

During th

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district level, Women Entrepreneurship Facilitation Desks under NITI Aayog, POSH cells for grievance redressal and strengthening of cyber fraud redressal mechanisms.

Special emphasis was laid on enhancing export participation by traders and MSMEs, increasing awareness regarding export opportunities, strengthening institutional support mechanisms and promoting India's emergence as a globally competitive trading nation. The Board also discussed the need for thematic committees and focused working groups to examine sector-specific issues and provide structured recommendations for policy intervention.

The meeting was chaired by Chairman, NTWB, Shri Sunil J. Singhi. He apprised the Board of major initiatives undertaken towards achieving i

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in Dehradun and Indore, and Tiranga Yatra activities in Chandigarh and Indore.

The Chairman also apprised Members of developments relating to Next Generation GST 2.0 reforms, ONDC integration and expansion of DigiDukaan. DigiDukaan, a B2B procurement and Kirana digitisation initiative by ONDC, is enabling kirana stores to digitise procurement through a single ordering interface, with over 19,000 retailers currently live across Hyderabad and Jaipur.

At the outset of the meeting, Director, DPIIT, Shri Yuvraj Ravindra Patil, welcomed the Board Members and Ex-Officio Members from line Ministries and Departments and outlined the mandate of the NTWB. He emphasised the importance of promoting the Board's initiatives and ensuring wider dissem

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Wrong-head GST payments require appropriation rather than duplicate payment and refund when aggregate liability was timely discharged.

Wrong-head GST payments require appropriation rather than duplicate payment and refund when aggregate liability was timely discharged.NotesGSTWrong-head GST remittances, where a taxpayer timely pays the full aggregate liability but selects an incorrect…

Wrong-head GST payments require appropriation rather than duplicate payment and refund when aggregate liability was timely discharged.
Notes
GST
Wrong-head GST remittances, where a taxpayer timely pays the full aggregate liability but selects an incorrect tax head, are distinct from a later correction of a supply's inter-State or intra-State character. Sections 19 of the IGST Act and 77 of the CGST Act, with Rule 89(1A), address classification errors and the related refund framework, not a pure allocation error. An identifiable wrong-head payment may be appropriated against the correct CGST and SGST liabilities rather than requiring duplicate payment followed by refund. Where funds remain in the electronic cash ledger, Section 49(10) and Rule 87(13) permit inter-head transfer through FORM GST PMT-09; refund may be procedurally necessary if transfer is unavailable.
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GST appeal limitation: statutory condonation remains capped, while exceptional writ review may restore an unheard appeal.

GST appeal limitation: statutory condonation remains capped, while exceptional writ review may restore an unheard appeal.NotesGSTSection 107 of the CGST Act confines GST appeals to a three-month filing period, with condonation by the Appellate Authorit…

GST appeal limitation: statutory condonation remains capped, while exceptional writ review may restore an unheard appeal.
Notes
GST
Section 107 of the CGST Act confines GST appeals to a three-month filing period, with condonation by the Appellate Authority limited to one further month upon sufficient cause. Section 5 of the Limitation Act cannot enlarge that statutory ceiling. Limitation runs from communication; portal availability and postal service under Section 169 may require factual scrutiny, while Rule 108 governs electronic or permitted manual filing where an order is unavailable on the portal. Statutory pre-deposit triggers a deemed stay of recovery for the balance demand. Article 226 may exceptionally restore an unheard appeal where defective communication, prompt action after knowledge and material procedural unfairness justify relief, but is not a routine cure for delay or inaction.
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Draft Warehousing Operations Regulations, 2026 – uploading on the CBIC website for inviting comments/views/suggestions from stakeholders

Draft Warehousing Operations Regulations, 2026 – uploading on the CBIC website for inviting comments/views/suggestions from stakeholders GSTDated:- 25-9-2026F. No. 473/12/2026-LC

Ministry of Finance

Department of Revenue

(Central Board of Indi…

Draft Warehousing Operations Regulations, 2026 – uploading on the CBIC website for inviting comments/views/suggestions from stakeholders
GST
Dated:- 25-9-2026

F. No. 473/12/2026-LC

Ministry of Finance

Department of Revenue

(Central Board of Indirect Taxes & Customs)

Kartavya Bhawan-1, New Delhi,

Dated the 21.09.2026

To,

The CBIC Webmaster

Email: webmaster.cbec@icegate.gov.in

Madam/Sir,

Subject: reg.

Kindly refer to the draft Warehousing Operations Regulations, 2026 attached herewith, which have been approved for placing in the public domain for stakeholder consultation.

2. In view of the above, it is requested to upload the attached draft regulations on the CBIC website for inviting comments/ views /suggestions from stakeholders. The comments/ views/ suggestions may be furnished within 15 days from the date of issuance of this letter in the following format:

FORMAT FOR SENDING SUGGESTIONS/COMMENTS/VIEWS

Sr. No.

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of the powers conferred by section 157 read with sections 57, 58, 59, 60, 61, 64, 67, 68, 69 and 72 and sub-section (2) of section 73A of the Customs Act, 1962 (52 of 1962), and in partial supersession of the Warehouse (Custody and Handling of Goods) Regulations, 2016 and the Warehoused Goods (Removal) Regulations, 2016, in so far as they apply to warehouses governed by these regulations, except as respects things done or omitted to be done before such supersession, the Central Board of Indirect Taxes and Customs hereby makes the following regulations, namely :-

1. Short title and commencement .-

(1) These regulations may be called the Warehousing Operations Regulations, 2026.

(2) They shall come into force on the date of their publication in the Official Gazette.

2. Definitions .-

(1) In these regulations, unless the context otherwise requires,-

(a) “Act” means the Customs Act, 1962 (52 of 1962);

(b) “bond officer” means the officer of customs in charge of a wareh

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ing device, whether mechanical or electronic, used for securing goods during transport, including an electronic seal where so specified by the Board;

(j) “warehouse” means a public warehouse licensed under section 57 or a private warehouse licensed under section 58 of the Act, to which these regulations apply;

(k) “Warehouse Licensing Regulations, 2026” means the regulations made by the Board for licensing of warehouses under the Act; and

(1) “section” means a section of the Act.

(2) Words and expressions used in these regulations and not defined herein shall have the meanings respectively assigned to them in the Act.

3. Application .-

These regulations shall apply to warehouses licensed under section 57 or section 58 of the Act, other than a warehouse in which permission to carry on any manufacturing process or other operations has been granted under section 65 of the Act.

4. Conditions for transport of goods .-

(1) Goods transported-

(a) from a customs stat

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may, having regard to the manner of transport, waive the requirement of transit-risk insurance in respect of liquid bulk cargo transported through pipelines.

5. Receipt and accountal of goods at a warehouse .-

(1) Before the removal of goods from a customs station for deposit in a warehouse,-

(a) the importer shall make a request through the electronic portal to the licensee to receive and store the goods;

(b) the licensee shall record acceptance or rejection of the request on the electronic portal; and

(c) upon acceptance of the request and electronic communication of an order made under sub-section (1) of section 60 of the Act, the goods may be transported to the warehouse.

(2) Upon receipt of goods at a warehouse, whether from a customs station or another warehouse, the licensee shall-

(a) verify the one-time-lock affixed to the container or means of transport, where required under regulation 4;

(b) where the one-time-lock is found broken, tampered with or o

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l.

(3) Upon confirmation of receipt under clause (f) of sub-regulation (2), the confirmation shall be made available electronically on the electronic portal-

(a) in the case of goods received from a customs station, to the proper officer who made the order under sub-section (1) of section 60 of the Act, the bond officer, the importer or owner of the goods and the licensee; and

(b) in the case of goods received from another warehouse, to the owner of the goods and the licensees and bond officers of the source and receiving warehouses.

6. Removal of warehoused goods from one warehouse to another .-

(1) Where the owner proposes to remove warehoused goods from one warehouse to another under section 67 of the Act,-

(a) the owner shall make a request through the electronic portal to the licensee of the receiving warehouse to receive and store the goods; and

(b) the licensee of the receiving warehouse shall record acceptance or rejection of the request on the electronic p

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records to reflect the quantity so removed and the balance remaining in the warehouse.

(5) Upon receipt of the goods at the receiving warehouse, the licensee shall comply with the requirements specified in sub-regulations (2) and (3) of regulation 5 in respect of goods received from another warehouse.

7. Removal of warehoused goods for home consumption .-

Upon electronic communication of an order made under section 68 of the Act, the licensee shall permit removal only of the quantity specified in the bill of entry for home consumption and the order for clearance, and shall update the electronic records to reflect the quantity removed and the balance remaining in the warehouse.

8. Removal of warehoused goods for export .-

(1) A licensee shall not remove or cause to be removed any warehoused goods for export except upon electronic communication through the electronic portal of an order made by the proper officer under section 69 of the Act.

(2) Upon such communication,

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Act.

10. Furnishing of returns .-

(1) The licensee shall, on or before the tenth day of each month, furnish through the electronic portal a return for the preceding month containing the particulars specified in Form WH-1.

(2) The licensee shall, on or before the tenth day of each month, furnish through the electronic portal the particulars specified in Form WH-2 in respect of goods whose warehousing period under section 61 of the Act is due to expire during the following month.

11. Maintenance of electronic records and documents .-

(1) The licensee shall maintain in the digital warehouse management system complete, accurate and up-to-date electronic records of all transactions relating to the receipt, handling, storage, transfer, operations and removal of warehoused goods, including the balance of such goods and the documents supporting each transaction.

(2) The electronic records and documents shall be securely stored, regularly backed up in a system independent of

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wner of the goods or the licensee concerned to furnish the relevant information or documents.

(2) Where any discrepancy in the receipt or arrival of the goods is recorded on the electronic portal and made available electronically to the bond officer, the bond officer may require the owner of the goods or the licensee concerned to furnish the relevant information or documents.

(3) Where, upon examination of the information or documents furnished or otherwise available, the proper officer has reason to believe that any of the circumstances specified in section 72 of the Act exist, the proper officer may proceed in accordance with that section and other applicable provisions of the Act.

13. Electronic furnishing and acknowledgement .-

(1) Every request, declaration, intimation, confirmation, return or other information required to be furnished under these regulations shall be furnished electronically through the electronic portal in such form and manner as may be provided ther

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e order.

Encl: Forms WH-1 and WH-2

( ……………. )

Under Secretary

FORM WH-1 Monthly Return of a Bonded Warehouse (To be furnished electronically through the electronic portal)

A. General Information

Name of Licensee Address of Licensee Warehouse Code Warehouse Address Return Month Return Year

B. Transaction Details

SI. No. Section Fields to be furnished
1 Receipt of Warehoused Goods from Customs Station Into Bond BE No .; Into Bond BE Date; Port Code of Import; Bond No .; Bond Date; Date of Order under Section 60(1); Registration No. of Means of Transport; OTL No.
2 Receipt of Warehoused Goods from Another Warehouse Into Bond BE No .; Into Bond BE Date; Port Code of Import; Bond No .; Bond Date; Date of Order under Section 60(1); Warehouse Code of Supplier Warehouse; Date and Unique Reference No. of Acknowledgement of Declaration under Regulation 6; Registration No. of Means of Transport; OTL No.
3 Sub-Form for BE (Goods Details) Into Bond BE No .; Into

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8 Details of Relinquishments During the Month Into Bond BE No .; Into Bond BE Date; Description of Goods; Available Quantity; Quantity Relinquished; Upload Acceptance Letter from Commissioner.
9 Removal of Warehoused Goods for Home Consumption Into Bond BE No .; Into Bond BE Date; Date of Order under Section 68(c); Description of Goods Removed; Unit Code; Quantity of Removal; Assessable Value of Goods Removed (INR); Duty Involved on Goods Removed (INR); Interest (INR); Balance Quantity Available in Warehouse Against Into-Bond BE; Remarks, if Any.
10 Removal of Warehoused Goods for Export Into Bond BE No .; Into Bond BE Date; Date of Order under Section 69(1)(c); SB No .; SB Date; Description of Goods Removed; Unit Code; Quantity of Removal; Assessable Value of Goods Removed (INR); Duty Involved on Goods Removed (INR); Interest (INR); Balance Quantity Available in Warehouse Against Into-Bond BE; Remarks, if Any; Date and Time of Removal; Registration No. of Means of Transport; Contai

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Approval of Proper Officer; Any Other Removal During the Month.

Verification

I declare that the information furnished in this return is true, correct and complete.

Name of authorised signatory Designation Place Date Authentication
Digital Signature Certificate (DSC)

FORM WH-2

Details of Bills of Entry in Respect of Which the Warehousing Period Is Expiring in the Following Month

(To be furnished electronically through the electronic portal)

A. General Information

Name of Licensee Address of Licensee Warehouse Code Warehouse Address Return Month Return Year

B. Bill of Entry Details

SI. No. Section Fields to be furnished
1 Main Form-BE Details Into Bond BE No .; Into Bond BE Date; Port Code of Import; Bond No .; Bond Date; Date of Order under Section 60(1); Remarks, if Any.
2 Sub-Form for BE (Line Items) Into Bond BE No .; Into Bond BE Date; Line-Item No. of the Warehousing BE; Description of Goods; Unit Code; Quantity (Weight/Volume/Numbers etc.); Ass

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Expansion of show cause notice at appellate stage requires a chance to respond before refund rejection is reconsidered.

Expansion of show cause notice at appellate stage requires a chance to respond before refund rejection is reconsidered.Case-LawsGSTExpansion of a show cause notice at the appellate stage cannot support rejection of accumulated input tax credit refunds …

Expansion of show cause notice at appellate stage requires a chance to respond before refund rejection is reconsidered.
Case-Laws
GST
Expansion of a show cause notice at the appellate stage cannot support rejection of accumulated input tax credit refunds without allowing the taxpayer to answer the added grounds. The High Court treated the notice as the foundation of proceedings and found that reliance on grounds introduced only in appeal deprived petitioners of an effective opportunity to reply. Without examining the merits of those grounds or the refund claim, the High Court set aside the adjudication and appellate orders and remitted the matter for fresh adjudication, requiring a comprehensive reply opportunity and personal hearing.
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Opportunity of hearing in GST first appeals requires restoration where dismissal for default followed inadequate hearing intimation.

Opportunity of hearing in GST first appeals requires restoration where dismissal for default followed inadequate hearing intimation.Case-LawsGSTDismissal of a duly constituted GST first appeal for non-prosecution, despite pre-deposit and alleged inadeq…

Opportunity of hearing in GST first appeals requires restoration where dismissal for default followed inadequate hearing intimation.
Case-Laws
GST
Dismissal of a duly constituted GST first appeal for non-prosecution, despite pre-deposit and alleged inadequate notice of hearing, should not leave the appellant remediless or compel a second appeal. Statutory procedure permits the Appellate Tribunal to dismiss an appeal for default and set aside that dismissal. High Court set aside the dismissal where there was no apparent reason for the appellant to abandon its appeal after making the pre-deposit, and remanded the matter to the Appellate Authority for fresh adjudication after due opportunity of hearing.
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Net ITC treatment protects zero-rated supply refunds from unrelated earlier-period compensation cess reversals under the statutory formula.

Net ITC treatment protects zero-rated supply refunds from unrelated earlier-period compensation cess reversals under the statutory formula.Case-LawsGSTNet ITC for refunds of unutilised compensation cess on zero-rated supplies comprises credit actually …

Net ITC treatment protects zero-rated supply refunds from unrelated earlier-period compensation cess reversals under the statutory formula.
Case-Laws
GST
Net ITC for refunds of unutilised compensation cess on zero-rated supplies comprises credit actually availed and attributable to the relevant refund period. A reversal recorded in that period reduces Net ITC only where the reversed credit was availed during the same period. Residual credit from earlier periods, not included in the claimed Net ITC for the refund period, cannot reduce the eligible refund. Departmental clarification must operate consistently with the statutory refund formula and cannot require deduction of every reversal irrespective of when the underlying credit arose. The refund sanction was therefore upheld and the Revenue challenge rejected.
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Net ITC under the statutory refund formula excludes prior-period reversals, preserving refund of unutilised cess credit.

Net ITC under the statutory refund formula excludes prior-period reversals, preserving refund of unutilised cess credit.Case-LawsGSTRule 89(4) confines Net ITC for refund of unutilised cess credit on zero-rated supplies to credit actually availed durin…

Net ITC under the statutory refund formula excludes prior-period reversals, preserving refund of unutilised cess credit.
Case-Laws
GST
Rule 89(4) confines Net ITC for refund of unutilised cess credit on zero-rated supplies to credit actually availed during the relevant refund period. An ITC reversal recorded in GSTR-3B reduces Net ITC only where the reversed credit was availed in that same period; reversals relating to earlier tax periods do not affect the refund computation. Paragraph 43(c) of the departmental circular cannot require deduction of all reversals made during the refund period irrespective of the underlying credit period, as a circular cannot override or expand the statutory refund formula. The accumulated cess-credit refund was consequently sustained.
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Net ITC computation excludes reversals of earlier-period credit unrelated to the refund period under the statutory formula.

Net ITC computation excludes reversals of earlier-period credit unrelated to the refund period under the statutory formula.Case-LawsGSTNet ITC for refund of unutilised Compensation Cess credit on zero-rated supplies is confined to input tax credit actu…

Net ITC computation excludes reversals of earlier-period credit unrelated to the refund period under the statutory formula.
Case-Laws
GST
Net ITC for refund of unutilised Compensation Cess credit on zero-rated supplies is confined to input tax credit actually availed and attributable to the relevant refund period. A reversal recorded in that period need not reduce Net ITC where records establish that it relates to residual unutilised credit from earlier tax periods and was not included in the credit supporting the refund claim. Paragraph 43(c) of the departmental circular must operate consistently with the statutory refund formula and cannot require deduction of every reversal reported during the period, thereby curtailing a statutory refund entitlement.
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Statutory appellate-admission discretion permits refusal where the penalty falls within the prescribed monetary threshold for discretionary admission.

Statutory appellate-admission discretion permits refusal where the penalty falls within the prescribed monetary threshold for discretionary admission.Case-LawsGSTStatutory discretion governing appellate admission applies where a penalty does not exceed…

Statutory appellate-admission discretion permits refusal where the penalty falls within the prescribed monetary threshold for discretionary admission.
Case-Laws
GST
Statutory discretion governing appellate admission applies where a penalty does not exceed the prescribed monetary threshold. In an appeal by a managing director against a penalty order issued under section 107, the penalty fell within the threshold for discretion under section 112(2). The Tribunal exercised that discretion to refuse admission, so the appeal was not admitted.
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Procedural defect non-compliance can lead to appeal rejection after repeated opportunities to cure filing defects remain unused.

Procedural defect non-compliance can lead to appeal rejection after repeated opportunities to cure filing defects remain unused.Case-LawsGSTRule 24(4) of the GSTAT (Procedure) Rules, 2025 permits rejection of an appeal where filing defects remain unrec…

Procedural defect non-compliance can lead to appeal rejection after repeated opportunities to cure filing defects remain unused.
Case-Laws
GST
Rule 24(4) of the GSTAT (Procedure) Rules, 2025 permits rejection of an appeal where filing defects remain unrectified despite adequate opportunities. The appellant received six hearing opportunities, including three before the Bench and three before the Registrar, but neither appeared nor sought adjournment. No additional material was uploaded to cure the notified defects. Persistent non-attendance and failure to rectify defects support treating the appeal as not being actively pursued and considering rejection under the procedural rule.
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Agricultural warehousing exemption does not cover separately rented godowns; rent remains taxable, with reverse charge for unregistered lessors.

Agricultural warehousing exemption does not cover separately rented godowns; rent remains taxable, with reverse charge for unregistered lessors.Case-LawsGSTStorage and warehousing of agricultural produce is exempt, but that exemption does not extend to…

Agricultural warehousing exemption does not cover separately rented godowns; rent remains taxable, with reverse charge for unregistered lessors.
Case-Laws
GST
Storage and warehousing of agricultural produce is exempt, but that exemption does not extend to separately hired godowns used exclusively for the exempt outward service. Renting such godowns constitutes an independent supply of rental or leasing of non-residential property and attracts GST at 18%. Where the lessor is registered, tax is payable under forward charge. Where an unregistered person rents a godown to a registered recipient, the amended reverse-charge entry applies, making the recipient liable to pay GST at 18% from 10.10.2024.
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