Place of supply for unregistered persons: delivery address on the invoice governs place of supply, not billing address.
Clause (ca) of Section 10(1) fixes the place of supply for goods to unregistered persons as the location recorded in the invoice for that person, with the supplier's location applying if no recipient address is recorded; recording the State alone suffices. Where billing and delivery addresses differ, the delivery address recorded on the invoice determines the place of supply. Suppliers may record the delivery address as the recipient's address on the invoice to govern place of supply.

Special procedure compliance for manufacturers clarified; machine IDs, energy certification, applicability and job work responsibilities specified.
Adopts CBIC clarifications for the special procedure under Notification No. 04/2024: make/model in Table 6 of FORM GST SRM-I are optional, machine number is mandatory (manufacturers may assign one if absent); electricity consumption must be declared from records or certified by a Practicing Chartered Engineer in FORM GST SRM-III and uploaded; sale price substitutes for absent MRP in Table 9; the CE must hold IEI certificate of practice; SEZ units and manual packing operations are excluded; report only the final-packing machine; job workers are covered, and an unregistered job worker's principal manufacturer is liable for compliance.

Monetary limits for appeals reduce government litigation; appeals below thresholds generally not filed, with specific exclusions.
The Board prescribes monetary thresholds under the CGST Act below which Central tax officers shall not file appeals before GSTAT, High Courts or the Supreme Court, with specified rules for calculating the disputed amount (tax, interest, penalty, late fee, and refunds) and aggregation across composite orders. Exclusions require appeals to be decided on merits irrespective of thresholds, and non-filing under the thresholds must be recorded as not creating precedent or departmental acquiescence; officers may file appeals in other cases where amounts or questions of law warrant contestation.

Supply characterization of related party loans: interest only consideration is exempt under GST; processing fees are taxable.
Extending loans/credit/advances between related persons is a supply under Schedule I read with section 7(1)(c), but services of granting loans are exempt insofar as consideration is only interest or discount. Amounts charged over and above interest-such as processing, administrative or service fees-constitute taxable consideration for processing/facilitating/administration services and attract GST; where no such fees are charged between related parties, no processing supply arises and Rule 28 valuation need not be applied.

Input tax credit entitlement for insurers on reimbursed motor vehicle repair costs is available, limited to approved reimbursed amounts.
Insurers are the recipient of motor vehicle repair services to the extent of approved repair liability and may claim ITC in reimbursement mode, subject to credit conditions. If garages issue separate invoices one to insurer for approved cost and one to insured for excess, ITC may be available on the insurer's invoice; if a single invoice is issued to the insurer but reimbursement covers only the approved cost, ITC is limited to that reimbursed approved amount. No ITC is available where the invoice is not in the insurer's name.

Extended warranty treated as a distinct service when separate from the goods supplier, attracting GST on the warranty supply.
Clarifies that replacements of goods "as such" during warranty are to be read as replacements of 'goods or its parts' and follow prior guidance on GST liability and ITC reversal; replenishment by a manufacturer to a distributor via delivery challan without consideration is not a taxable supply and does not require ITC reversal by the manufacturer; and extended warranty supplied by a person different from the goods supplier or supplied after original sale is a distinct supply of services, with the extended-warranty supplier liable to discharge GST on that service.

Supply of salvage: insurers must discharge GST when they acquire and sell wreckage after full claim settlement.
Where an insurance contract provides for deduction of salvage/wreck value from the claim (deductible), ownership of the wreckage remains with the insured and the insurer has no GST liability on that deducted value; however, if the insurer settles the full insured declared value without deducting salvage, the salvage vests in the insurer and the insurer must discharge GST on disposal or sale of the salvage.

Input tax credit availability: ducts and manholes in OFC networks treated as plant and machinery permitting ITC for telecom services.
Ducts and manholes used as conduits and network nodes for optical fiber cable networks are treated as plant and machinery under the Explanation to the GST provision and therefore availment of input tax credit on such ducts and manholes is not barred by the blocked credit clauses that restrict ITC for immovable property or related works contract receipts.

GST treatment of related-party loans clarified: interest-only lending is exempt, while loan-processing fees remain taxable.
Taxability of loans between related persons or between an overseas affiliate and its Indian affiliate is clarified under GST. A loan granted between related persons in the course or furtherance of business is a supply under Schedule I, but where the only consideration is interest or discount, the transaction of extending deposits, loans or advances is exempt from GST. Where no processing fee, administrative charge, service fee or loan-granting charge is levied over and above interest or discount, the lending arrangement is not to be treated as a supply of processing, facilitating or administering the loan.

Input tax credit entitlement for insurers on motor vehicle repair expenses confirmed where insurer bears approved repair liability through reimbursement.
ITC is available to general insurance companies for motor vehicle repair services reimbursed by them because the insurer, by reimbursing approved repair cost, is the recipient to that extent. Where separate invoices distinguish approved claim cost and excess amounts, ITC may be claimed on the invoice issued to the insurer; if a single invoice in the insurer's name covers full amount but insurer reimburses only approved cost, ITC is limited to the reimbursed approved cost. Absence of invoice in insurer's name precludes ITC.

GST liability on salvage value in motor vehicle insurance claims turns on whether ownership stays with the insured or passes to the insurer.
GST liability on salvage or wreck value in motor vehicle insurance claim settlements depends on the insurance contract. If salvage value is deducted from the claim as a pre-agreed deductible and ownership remains with the insured, the insurer is not liable to pay GST on that salvage value. If the claim is settled for the full insured declared value without deduction and the salvage passes to the insurer, GST is payable on the outward supply arising from disposal or sale of the salvage.

Input tax credit reversal on life insurance premium excluded from taxable value is not required under GST rules.
The portion of premium in life insurance policies excluded from taxable value under Rule 32(4) of the Andhra Pradesh GST Rules, 2017 is not to be treated as a non-taxable supply or exempt supply. Mere exclusion from taxable value does not make that portion exempt, and therefore input tax credit reversal is not required under Section 17 read with Rules 42 and 43 in respect of such amount.

ESOP and RSU GST treatment clarified for foreign holding company share allocations and cost-to-cost reimbursements.
Clarification is issued on the GST treatment of ESOP, ESPP and RSU arrangements where a foreign holding company directly allocates shares or securities to employees of an Indian subsidiary as part of the compensation package. The circular explains that the transfer of shares or securities is not a supply of goods or services under GST, and that employee participation under the employment contract is outside GST under Schedule III. Cost-to-cost reimbursement by the subsidiary is not treated as import of services, but any additional fee, markup or commission charged by the foreign holding company is taxable as a facilitation or arranging service on reverse charge basis.

Reversal of Input Tax Credit: interim certificate requirement for post supply discounts to validate exclusion from taxable value.
Where suppliers issue tax credit notes post supply, the discount is excludable from taxable value only if it meets the Section 15(3)(b) conditions including proportionate reversal of input tax credit by the recipient; until portal verification exists, suppliers must obtain a CA/CMA certificate (with UDIN) from the recipient detailing credit notes, relevant invoices, ITC reversal amounts and supporting FORM GST DRC 03/return evidence, or where tax involved is below a low threshold, an undertaking from the recipient; such documents constitute admissible evidence and must be produced to tax officers on demand.

Reverse charge input tax credit timing: ITC tied to the financial year of recipient-issued invoice, subject to tax payment and conditions.
Where a registered recipient must self-issue an invoice and pay tax in cash under the reverse charge mechanism for supplies from unregistered persons, the relevant financial year for the time limit to avail input tax credit is the financial year in which the recipient issues that invoice, provided tax is paid and other statutory conditions for ITC are fulfilled; delayed issuance and delayed tax payment attract interest and may attract penal consequences.

Valuation of import of services: invoice-declared value deemed open market value where recipient claims full input tax credit.
Where a registered person in India imports services from a related person outside India and is eligible for full input tax credit, the value declared in the recipient's invoice/self-invoice shall be deemed to be the open market value under the second proviso to Rule 28(1). The recipient must pay tax under reverse charge and issue a self-invoice; if no invoice is issued and the recipient declares Nil, that Nil declaration may be treated as the open market value for valuation purposes.

Place of supply for unregistered recipients follows the delivery address recorded on the invoice, not the billing address.
Clause (ca) to Section 10(1) of the IGST Act makes the invoice-recorded address of an unregistered person the determinative place of supply, and where invoice records no address the supplier's location applies; recording the State name suffices. For supplies (including via e-commerce) where billing and delivery addresses differ, the delivery address recorded on the invoice shall determine the place of supply, and suppliers may record the delivery address as the recipient's invoice address for that purpose.

Special procedure compliance for manufacturers requires machine identification, certified electricity ratings, and principal liability for unregistered job workers.
The circular clarifies compliance under the special procedure of Notification No. 03/GST-2: make and model in Table 6 of FORM GST SRM-I are optional (year may substitute for make), machine number is mandatory and may be assigned if absent; electricity consumption must be declared from machine records or certified per-hour by a Practicing Chartered Engineer in FORM GST SRM-III and uploaded; sale price is to be entered where no MRP exists in Table 9; SEZ units and manual packing/sealing are excluded; report final packing machine in Table 6; job workers are covered but the principal manufacturer bears liability if the job worker is unregistered.

Monetary limits for government appeals restrict departmental appeals, subject to specified exclusions and merit-based exceptions.
Fixes monetary thresholds below which State tax officers shall not file appeals or Special Leave Petitions under the HGST Act, prescribes principles for computing the amount in dispute (tax, interest, penalty, late fee, or refund), applies aggregation rules for composite orders, and lists exclusions requiring appeals on merits irrespective of thresholds. It mandates recording reasons for non-filing, clarifies non-precedential effect of non-filing and absence of departmental acquiescence, and requires departmental counsel to inform tribunals or courts that non-filing was due to monetary limits.

Salvage or wreck value taxability in motor insurance claims is subject to uniform goods and services tax guidance.
Taxability of salvage or wreck value earmarked in insurance claim assessments for motor-vehicle damage is clarified for uniform implementation of goods and services tax law. State tax officers are instructed to follow the attached central guidelines on the treatment of such salvage or wreck value in claim assessments relating to damaged motor vehicles.