E invoicing applicability: suppliers exceeding threshold must issue e invoices for supplies to government entities registered for tax deduction.
Government Departments, establishments, government agencies, local authorities and PSUs registered solely for tax deduction at source are to be treated as registered persons; therefore suppliers whose turnover exceeds the prescribed threshold for e invoicing are required to issue e invoices for supplies made to such government entities under the e invoicing rules.

Refund of accumulated input tax credit based on GSTR 2B governs refund admissibility and related portal filings.
Refund of accumulated input tax credit is restricted to ITC reflected in FORM GSTR 2B for the relevant or earlier tax period in which the credit is available, applicable prospectively from the statutory amendments. The undertaking in FORM RFD 01 and related annexures have been amended to remove references to the omitted Section 42 and deleted returns; applicants must undertake compliance only with clause (c) of sub section (2) of section 16. Exports value for "adjusted total turnover" is to be determined as per the newly inserted Explanation to sub rule (4) of Rule 89. Exporters who paid IGST under Rule 96A may claim refund of IGST and unutilized ITC upon actual export or realization, but interest paid under Rule 96A is not refundable.

Taxability of holding company shares: mere holding of subsidiary shares is not a taxable supply under GST.
Holding shares in a subsidiary by a parent company is not a supply under GST merely by virtue of a SAC entry; securities are neither goods nor services and purchase, sale or holding of shares does not constitute a taxable supply unless the statutory definition of supply is otherwise satisfied. The Board's clarification requires uniform application by field formations and directs publicity to trade and reporting of implementation difficulties.

GST on warranty replacement: no tax where replacements are free as included in original supply; extra charges taxable.
Replacement parts and repair services provided free during a warranty period are treated as included in the value of the original supply and are not subject to additional GST; additional consideration charged at replacement/repair is taxable. Manufacturers need not reverse ITC for warranty replacements provided free. Where distributors charge manufacturers for parts or repair services, those supplies are taxable and the manufacturer may claim ITC; if manufacturers supply parts to distributors free for warranty replacement, no GST or ITC reversal arises. Extended warranty is composite if sold with the original supply, otherwise it is a separate taxable contract.

TCS liability: the operator who releases payment to the supplier collects TCS unless the supplier is itself an operator, then the buyer side operator collects it.
Where multiple e commerce operators handle a single supply, collection and compliance under Section 52 of the CGST Act fall on the ECO that ultimately releases payment to the supplier when the supplier side ECO is not the supplier; if the supplier side ECO is itself the supplier, the buyer side ECO that collects payment must collect and remit TCS and perform other Section 52 compliances.

Input Tax Credit reconciliation clarified with capped excess credits allowed subject to supplier reporting, verification and certificates required.
Clarification directs that differences between ITC claimed in FORM GSTR-3B and ITC in FORM GSTR-2A for 01.04.2019-31.12.2021 be addressed by applying Circular No. 183/15/2022-GST for 01.04.2019-08.10.2019, and by allowing additional ITC under rule 36(4) for later subperiods only within prescribed capped excesses subject to verification that tax was paid by the supplier and production of required certificates; from 01.01.2022 ITC is admissible only as communicated in FORM GSTR-2B.

Total input tax credit consideration prevents interest unless combined ITC falls below wrongly availed IGST, triggering interest.
For interest on wrongly availed IGST credit, the relevant benchmark is the total input tax credit in the electronic credit ledger across IGST, CGST and SGST combined, not the IGST-head balance alone. No interest accrues if the combined ITC balance from availment until reversal never falls below the wrongly availed IGST amount; interest is triggered only to the extent the combined balance falls short. Compensation cess credit is excluded from this computation and cannot be used for CGST, SGST or IGST liabilities or reversals.

Suspension of Customs Broker licence: limited to appropriate cases requiring immediate action with recorded reasons.
Suspension of a customs broker licence is permitted only in appropriate cases requiring immediate action; the Commissioner may suspend when an enquiry is pending or contemplated, but must not apply suspension routinely or mechanically and should record reasons explaining why immediate suspension is necessary, taking into account potential disruption to smaller broker enterprises.

Fake GST registration and bogus ITC claims face tighter verification, scrutiny, and enforcement under strengthened tax officer controls.
Strengthened verification of GST registration applications requires proper officers to scrutinise documents, cross-check address proof, examine PAN and Aadhaar history, issue queries for deficiencies, and conduct mandatory pre-registration field verification within prescribed time limits. Applications involving out-of-state applicants, altered mobile numbers, or forged documents are to be closely scrutinised, with police reporting where fraud is detected. The circular also directs intensive ITC verification using analytical tools and enhanced enforcement for sin and other high-valued goods.

Mandatory additional qualifiers for customs declarations extended to allow resolution of implementation and testing issues.
Mandatory additional qualifiers for specified import and export declarations introduced by Circular No. 15/2023-Customs have had the compliance date extended to 01.10.2023 by Circular No. 18/2023 following trade representations, a departmental request and testing-related mismatches; stakeholders are directed to report implementation difficulties to the Additional Commissioner, Airport and ACC, Bengaluru Customs Zone.

Extension of audit period under section 65 granted due to GSTN system glitches, allowing additional time to complete the audit.
The Commissioner invoked the proviso to sub section (4) of section 65 of the WBGST Act, 2017 to extend the audit completion period for M/s G H Agencies Private Limited (GSTIN: 19AACCG3795M1ZY) for the period commencing on or after 1 April 2019 and ending on or before 31 March 2020. The audit began on 24 April 2023 and could not be completed within three months due to GSTN back office system glitches; an additional six month period from the original due date is granted and the order is effective immediately.

Document Reference Number verification is required for offline GST communications, enabling taxpayer validation and strengthening administrative transparency.
Offline GST communications issued by proper officers to taxpayers must carry an electronically generated Document Reference Number (RFN). Officers may generate and search RFNs through the GST portal's RFN service, and the generated RFN must be included in the communication. Taxpayers may verify the RFN on the GST common portal before or after login. The requirement applies to all communications not generated online by the system, and non-compliance is stated to be treated seriously.

Inter-office service taxation: clarifies ITC distribution options and valuation where offices are distinct persons.
Head office and branch offices that are treated as distinct persons may either distribute input tax credit (ITC) through the Input Service Distributor (ISD) mechanism (requiring ISD registration) or the head office may issue tax invoices to branches so branches can claim ITC; ISD distribution or invoicing is permitted only if services are attributable to or actually provided to the recipient. Where the recipient branch is eligible for full ITC, the invoice value shall be deemed the open market value, and salary costs need not be mandatorily included in taxable value where full ITC is unavailable.

E-invoicing applicability: suppliers above threshold must issue e-invoices to TDS-registered government entities.
Supplies by a registered person whose turnover exceeds the e-invoicing threshold to Government Departments, agencies, local authorities or PSUs that are registered solely for tax deduction at source must be invoiced using the e-invoicing mechanism because those entities are treated as registered persons under GST law; the supplier is therefore required to issue e-invoices under the relevant e-invoice rule.

Refund of accumulated input tax credit restricted to ITC reflected in GSTR 2B; circular clarifies undertaking, turnover and export refund rules
Refund of accumulated Input Tax Credit under section 54(3) is restricted to ITC reflected in FORM GSTR 2B for the relevant tax period or earlier periods on which credit is available; this applies to refund claims for periods from January 2022 onwards. The undertaking in FORM RFD 01 is amended to remove references to section 42 and GSTR 2/GSTR 3, relating the undertaking solely to compliance with clause (c) of sub section (2) of section 16. Export related refunds and calculation of adjusted total turnover are clarified, and procedural amendments to Annexure A and portal categories are provided.

Taxability of shareholding: mere holding of subsidiary shares is not a taxable supply under GST.
Securities, including shares, are neither goods nor services and mere purchase, sale or holding of shares does not constitute a supply. A transaction is taxable as a service only if it meets the statutory definition of supply; classification entries describing holding company activities do not convert passive shareholding into a taxable supply. Therefore, mere holding of subsidiary shares by a parent company is not a supply of services and is not subject to GST.

Warranty replacements and repairs: no additional GST where covered in original supply; GST applies to any additional consideration.
Where a manufacturer's original supply includes the expected cost of warranty replacements and repairs, replacements or repairs provided during the warranty without separate consideration attract no further GST and do not require reversal of input tax credit. If additional consideration is charged, GST applies to that consideration. Distributor actions are taxable only when they constitute a supply invoiced to the manufacturer; manufacturer-provided parts to distributors for warranty replacement without consideration do not attract GST or ITC reversal. Repair services charged by a distributor to the manufacturer are taxable and the manufacturer may claim ITC. Extended warranty at sale is part of the composite supply; post-sale extended warranty is a separate taxable contract.

TCS liability where multiple e commerce operators are involved: the ECO releasing payment must collect and remit TCS.
Where multiple ECOs are involved and the supplier side ECO is not the supplier, the supplier side ECO who ultimately releases payment to the supplier must collect and remit TCS and perform Section 52 compliances. If the supplier side ECO is itself the supplier, the buyer side ECO collecting payment must collect and remit TCS and comply with Section 52 when making payment to that supplier/ECO.

Input Tax Credit reconciliation: capped availment based on GSTR 2A discrepancies for specified periods, subject to verification and conditions.
The Circular directs reconciliation of Input Tax Credit claimed in FORM GSTR-3B with FORM GSTR-2A for 01.04.2019-31.12.2021, applying Circular No.183/15/2022-GST to early months and enforcing the caps provided by rule 36(4) for sub-periods; availment remained subject to the payment condition in clause (c) of sub-section (2) of Section 16, cumulative adjustment provisos for certain month clusters must be considered, and from 01.01.2022 ITC is allowable only to the extent communicated in FORM GSTR-2B.

Interest on wrongly availed IGST credit depends on the combined ITC balance across IGST, CGST and SGST heads.
The total ITC balance in the electronic credit ledger-aggregating IGST, CGST and SGST-must be used to determine whether wrongly availed IGST credit was utilized; no interest is chargeable if the combined ITC balance never fell below the wrongly availed amount between availment and reversal, but when the combined balance falls below that amount the shortfall measures utilization and attracts interest. Compensation cess credit is excluded from the aggregation and cannot be used for this purpose.