GST classification clarifications confirm applicable rates on specified goods and regularise past-period issues subject to conditions.
Clarification under section 168(1) classifies dual-energy solar cookers under heading 8516 and confirms the applicable rate; treats all sprinklers, including fire water sprinklers, as falling within the sprinkler entry and applicable rate with past-period regularisation; amends the tariff entry to explicitly include parts of poultry-keeping machinery with the applicable rate and past-period regularisation; narrows the scope of "pre-packaged and labelled" to exclude agricultural farm produce in packages over twenty-five kilogram or litre so such supply will not attract the specified levy, with past-period regularisation; and regularises past supplies of pulses and cereals made to or by government-engaged agencies under approved programmes subject to a Deputy Secretary certificate and reversal or disallowance of input tax credit.

GST exemption scope clarified for railways, SPVs, RERA, digital payment incentives, reinsurance and certain accommodation services.
GST applicability clarified across several service categories: Ministry of Railways supplies to the public and inter division supplies are exempted with past liabilities regularised; SPV supplies permitting use of SPV infrastructure and reciprocal maintenance services are exempted with past period regularisation; statutory collections by RERA are covered by the governmental authority exemption; incentive shares under the RuPay/UPI scheme distributed as decided by NPCI are treated as subsidy and not taxable; reinsurance (including retrocession) of specified exempt and government funded schemes is regularised for past periods; specified accommodation services meeting value and duration criteria are exempted with retrospective regularisation.

CSD refund entitlement: electronic filing with FORM RFD-10A, invoice validation and partial tax refund cap enforced.
CSDs must file refund claims electronically in FORM GST RFD-10A on the common portal, applying quarterly (with an option to club quarters/FYs). Refunds are admissible only for inward supplies received from registered suppliers who have furnished GSTR-1 and filed GSTR-3B; invoices must show supplier GSTIN and CSD GSTIN and be accompanied by an undertaking and declaration. The proper officer will validate invoices against GSTR-2B/GSTR-1/GSTR-3B, exclude already-refunded invoices, ensure a partial tax refund cap, verify ITC reversals, and issue orders in FORM GST RFD-06 with a speaking order.

IGST refund mechanism for post-export price increases: exporters file FORM GST RFD-01; jurisdictional GST officers process claims.
Refunds of additional IGST paid due to upward post-export price revisions are claimable by exporters via FORM GST RFD-01 filed electronically; jurisdictional GST officers will process such claims under rule 89 using GSTN-provided shipping bill and IGST data. Claims require specified documentary proof-shipping bills, original and revised invoices or debit notes, contract evidence, proof of additional IGST and interest payment, foreign exchange remittance (FIRC) and a practising accountant's certificate-and the officer must verify reporting in FORM GSTR-1 and FORM GSTR-3B before issuing a speaking sanction and payment order.

Valuation of corporate guarantee services: GST based on higher of actual consideration or annual percentage of amount guaranteed, with charge mechanics clarified.
The provision of corporate guarantees between related persons to banks or financial institutions is taxable and, for guarantees issued or renewed on or after 26 October 2023, valuation is governed by Rule 28(2). The value equals the higher of actual consideration and one per cent per annum of the amount guaranteed (pro rata for periods under a year and multiplied by years for multi year guarantees). Tax is payable on issuance and on each renewal; domestic intra group guarantees are forward charged with invoicing, foreign issued guarantees to Indian recipients attract reverse charge, and recipients may claim input tax credit subject to conditions.

Pre-deposit payment stay on recovery: electronic ledger payment and undertaking pause recovery until tribunal is operational.
If the Appellate Tribunal is not operational, taxpayers can secure a stay of recovery by paying an amount equal to the pre-deposit via Services Ledgers Payment towards demand, which maps the payment in Electronic Liability Register Part II against the selected order, and by filing an undertaking to appeal before the Tribunal when it is constituted. Payments inadvertently made through FORM GST DRC-03 can be adjusted towards the pre-deposit upon filing FORM GST DRC-03A (subject to exclusions where FORM GST DRC-05 has been issued); absence of payment, undertaking, or timely DRC-03A filing permits recovery under the CGST Act.

Proper officer designation shifted to Superintendent of Central Tax, reallocating registration and composition levy functions and requiring trade notices.
Functions relating to registration and composition levy under specified provisions of the CGST Act and associated CGST Rules are reassigned to the Superintendent of Central Tax, replacing prior assignment to Assistant or Deputy Commissioners/Directors; recipients must issue trade notices and report implementation difficulties to the Board.

Time of supply for spectrum services: GST arises on due or actual installment payments under reverse charge.
GST on spectrum allocation by government is payable by the telecom operator under reverse charge. Where deferred instalment payments create a continuous supply, the time of supply is the earlier of payment (entered in recipient's books or debited) or the date immediately following sixty days from issue of an invoice; Frequency Assignment Letters are bid-acceptance documents and invoices must be issued on or before ascertainable instalment due dates. GST is payable on upfront sums when paid or due, and on instalments when due or paid, whichever is earlier.

Time of supply for HAM road services: invoice date or payment receipt determines tax liability for construction and O&M.
For HAM contracts treated as a single continuous supply covering construction and O&M, the time of supply is the earlier of invoice date or receipt of payment where invoices are issued on or before the contract-specified due date or event-completion date. If invoices are not issued by that date, the time of supply is the earlier of the date of provision of the service (which may be the contract due date) or receipt of payment. Interest included in installments/annuities is includible in the taxable value.

Place of supply for custodial services: treat as non-account holder supplies, apply default recipient location rule under GST.
Custodial services by banks to FPIs-consisting of safekeeping and maintenance of securities accounts-are not services provided to an account holder for the supplier-location rule. By analogy to prior Service Tax guidance, custodial, depository and trust services are excluded from the account-holder category and therefore the place of supply must be determined under the default place-of-supply rule, i.e., by reference to the recipient's location where ascertainable and otherwise the supplier, within the IGST framework.

Input tax credit on ducts and manholes in optical fiber networks allowed as plant and machinery, ITC not barred.
Ducts and manholes used in optical fiber cable networks serve as necessary conduits and network nodes for transmission of telecommunication signals and, under the Explanation to Section 17, fall within the definition of plant and machinery. They are not specifically excluded as land, building, other civil structures, telecommunication towers or certain pipelines. Consequently, input tax credit on such ducts and manholes is not barred by the immovable-property exclusions in sub-section (5) of Section 17 and is available to taxable persons providing telecommunication services.

Related party loan interest exemption affirmed; processing fees for loan facilitation attract GST as taxable consideration when charged.
Loans or advances between related persons are supply under Schedule I, but services of extending loans are exempt insofar as consideration is only interest or discount; processing/administrative/service fees charged in addition to interest constitute taxable consideration for facilitation/processing services and attract GST, whereas absence of such fees between related parties does not give rise to a deemed taxable processing service or obligation to apply open market valuation.

Input tax credit entitlement for insurers affirmed where insurer bears approved repair liability despite reimbursement to the insured.
Where an insurer reimburses an insured for approved motor vehicle repair costs, the insurer is the liable party for the approved repair cost and therefore constitutes the recipient of the repair service to that extent; input tax credit on such repair services is available to the insurer. If two invoices are issued-one to the insurer for the approved cost and one to the insured for the excess-credit may be taken on the invoice to the insurer subject to reimbursement mechanics. If a single invoice is issued to the insurer but only the approved cost is reimbursed, credit is available only to the extent of the reimbursed approved cost. Credit is not available where the invoice is not in the insurer's name.

Extended warranty as service: sold separately or after original sale is taxable as a distinct service, supplier liable for GST.
Clarification extends prior guidance so that replacement of entire goods under warranty is treated like replacement of parts for GST and input tax credit (ITC) purposes; distributor replacement from own stock followed by manufacturer replenishment by delivery challan without consideration is not taxable and requires no ITC reversal by the manufacturer; and extended warranty supplied by a different person or sold after original supply is a distinct supply of services with the warranty supplier liable to discharge GST.

Salvage value taxation: GST applies when insurer acquires salvage on full claim settlement, otherwise not.
GST attaches only where a supply exists. If the insurer deducts salvage/wreck value from the claim (per contract), ownership of salvage remains with the insured and no GST liability arises for the insurer. If the insurer pays full claim amount without deducting salvage so that salvage vests in the insurer, the insurer must discharge GST on disposal or sale of the salvage.

Reversal of input tax credit clarified: non includible portion of life insurance premium is not treated as exempt supply.
The portion of life insurance premium excluded from taxable value under Rule 32(4) is not a nil rated, exempted or non taxable supply merely by virtue of its exclusion; accordingly, that portion does not trigger reversal of input tax credit under the reversal provisions applicable when supplies are exempt or non taxable, and no reversal is required for taxable life insurance policies.

GST on employee share transfers: cost reimbursements not import of services; markups or fees taxable on reverse charge.
Where a foreign holding company issues ESOP/ESPP/RSU directly to employees of its Indian subsidiary and the subsidiary reimburses only the cost of the securities on a cost-to-cost basis, such reimbursement is not a supply of goods or services and is not liable to GST; however, any additional fee, markup, or commission charged by the foreign holding company is taxable as consideration for facilitation/arrangement services and attracts GST payable by the domestic subsidiary on reverse charge basis.

Proportionate input tax credit reversal verification: suppliers may rely on CA/CMA certificates or recipient undertakings to evidence reversal.
The Circular clarifies that post-supply discounts excluded from taxable value require that the recipient has effected the proportionate reversal of input tax credit. Due to lack of portal verification, suppliers may obtain a CA/CMA certificate from the recipient detailing credit notes, related invoice numbers, ITC reversal amounts and the form/return evidencing reversal, with UDIN. For small-value discounts within a financial year, a recipient's undertaking with similar details is permissible. These certificates/undertakings are admissible evidence for tax officers and may be procured retroactively if required.

Reverse charge input tax credit: ITC timing follows the financial year of the recipient issued invoice, subject to tax payment.
Where tax is payable by the recipient under the reverse charge mechanism for supplies from unregistered persons, the relevant financial year for the time limit to claim input tax credit is the financial year in which the recipient issues the invoice under the recipient invoice requirement, provided the recipient pays the tax and satisfies other conditions and restrictions; delayed issuance after time of supply attracts interest on late tax payment and possible penal consequences.

Open market value: invoice value for import of services from related persons deemed where recipient eligible for input tax credit.
Where a registered person in India imports services from a related person abroad and the recipient is eligible for full input tax credit, the invoice value declared by the recipient may be deemed to be the open market value for valuation purposes; if no invoice is issued by the supplier, a declared nil value by the recipient may be treated as the declared value and deemed the open market value. Tax on such import of services is payable by the recipient under the reverse charge mechanism and the recipient must issue a self invoice.