Intermediary services require a distinct facilitation role; principal-to-principal suppliers and subcontractors performing main services remain excluded.
Intermediary service requires three parties, comprising two principals making the main supply and a third person who separately arranges or facilitates that supply in a supportive agent-like role. A person supplying the main goods, services or securities on a principal-to-principal basis is excluded. Subcontractors performing the main service, wholly or partly, are not intermediaries merely because they interact with the customer. Classification depends on the contractual terms and facts of each arrangement, while the special place-of-supply rule applies only where either service provider or recipient is outside India.

Refund of wrongly paid tax available when a supply is subsequently held inter or intra state, subject to filing and time limits.
The term "subsequently held" includes both taxpayer self reclassification and tax authority findings; refund is available if the taxpayer pays tax under the correct head and files FORM GST RFD 01 within the prescribed limitation period, which for payments made before the rule amendment runs from the rule's commencement. Refund is not available where the tax was adjusted by issuing a credit note; pending applications are to be governed by the amended rule.

Extension of time for revocation of cancelled registration clarifies eligibility, processing and limited further administrative extensions.
Clarification confirms that the executive notification extends the filing deadline for revocation of cancellation of registration to a specified final date for cases whose original due date fell within the affected period, applying to cancellations under the relevant clauses and to applications at any procedural status; officers and appellate authorities must process, admit or reconsider applications accordingly, and the interplay with the proviso permitting incremental administrative extensions is clarified so that in some scenarios the notification deadline is final while in others further limited extensions may be granted by competent officers.

Revocation of cancelled GST registration: filing deadline extended; further extensions available under the proviso on time limits.
The notification extends the due date for filing applications for revocation of cancellation of registration to 30th September, 2021 for cases where original due dates fell between 1 March, 2020 and 31 August, 2021, for cancellations under clause (b) or clause (c) of sub section (2) of section 29. The benefit applies irrespective of whether applications are unfiled, pending, rejected, or at appeal, and officers must process applications considering the extended timelines. The circular clarifies how this extension interacts with the proviso to sub section (1) of section 30 and when further discretionary extensions by Revenue officers may be available.

Export of services: supplies from Indian-incorporated affiliates to foreign-incorporated related entities can qualify as export.
Supplies by a company incorporated in India to establishments of a foreign company incorporated outside India are not treated as merely establishments of the same person under Explanation 1 to section 8, and therefore such supplies are not barred by condition (v) of section 2(6) of the IGST Act and may qualify as export of services, subject to fulfilment of the other conditions in section 2(6).

Input tax credit timing: debit note issuance now fixes financial year for ITC; e invoice QR suffices for transport validation.
For debit notes, the date of issuance of the debit note determines the relevant financial year for input tax credit availment, and the amended provision governs ITC claimed on or after the effective date; e invoices with QR codes embedding an IRN may be produced electronically instead of physical invoices during transport; and the refund restriction on unutilized ITC applies only to goods actually subject to export duty, excluding goods with nil or exempt export duty.

Intermediary services: facilitation between principals is ancillary supply; not applicable to subcontracting or principal-to-principal suppliers.
Clarification explains that an intermediary arranges or facilitates the supply of goods, services or securities between two or more persons and does not supply the main service on his own account; it requires at least three parties, comprises two distinct supplies (main supply and ancillary intermediary service), and excludes persons supplying the main service on a principal-to-principal basis or sub-contractors who provide the main supply. Place-of-supply rules for intermediary services apply only when supplier or recipient is outside India.

Export of services: supplies from Indian-incorporated affiliate to foreign parent can qualify as export if other conditions met.
Condition (v) of the IGST Act excludes supplies between establishments treated as distinct persons under Explanation 1 to section 8; branches, agencies or representational offices are establishments under Explanation 2. A company incorporated in India and a foreign company incorporated outside India are separate persons, so supplies by an Indian-incorporated subsidiary/related company to establishments of the foreign company outside India are not barred by condition (v) and may qualify as export of services if the other export conditions are met.

Intermediary services clarified: must involve facilitation between three parties and exclude principal suppliers and subcontractors.
Intermediary under GST is a broker, agent or similar person who arranges or facilitates the supply of goods, services or securities between two or more persons and excludes anyone who supplies the main supply on their own account. Key requirements: at least three parties, two distinct supplies (main supply and ancillary intermediary service), and a subsidiary facilitative role. Subcontractors who perform the main supply and suppliers acting on principal-to-principal basis are excluded. Place of supply rules for intermediary services apply only where supplier or recipient is outside India.

Extension of time to apply for revocation of cancelled GST registration, with specified further extensions by tax officers.
Time for filing applications for revocation of cancellation of registration is extended to September 30, 2021 for all cancellations under clause (b) or (c) of sub section (2) of section 29 where the due date to file fell between March 1, 2020 and August 31, 2021, irrespective of application status. The circular explains interaction with administrative extensions under the proviso to sub section (1) of section 30, specifying when no further extension is available and when the Joint/Additional Commissioner or the Commissioner may grant further extensions beyond September 30, 2021.

Export of services: supplies by India incorporated group companies to related foreign entities can qualify as export.
Supplies of services by an Indian incorporated company (including subsidiary, sister or group concerns of a foreign company) to establishments of the foreign company incorporated outside India are not supplies between "merely establishments of a distinct person" and therefore are not barred by condition (v) from being treated as export of services, subject to satisfaction of the other export conditions (supplier in India, recipient outside India, place of supply outside India and receipt of payment in convertible foreign exchange).

Input tax credit timing clarified: debit note date determines financial year for ITC availment under amended GST rules.
The circular clarifies that for availment of input tax credit on debit notes the date of issuance of the debit note-not the underlying invoice-determines the relevant financial year; the amended rule applies to ITC availed on or after the effective date even for debit notes relating to earlier invoices. It further provides that where e invoices are issued, the QR code with the Invoice Reference Number produced electronically suffices instead of a physical invoice, and that the refund restriction for unutilized ITC linked to export duty applies only to goods actually subject to export duty at the time of export.

Intermediary services scope clarified: facilitation between three parties distinguishes ancillary intermediary supply from main supply.
Scope of Intermediary under GST: an intermediary arranges or facilitates a supply of goods, services or securities between two or more other persons and does not include a person who supplies the main goods or services on his own account. Intermediary services require (i) at least three parties, (ii) two distinct supplies - a main supply between principals and an ancillary facilitation service - and (iii) a facilitator role such as agent or broker. Sub-contractors supplying the main service on principal basis are excluded. Place of supply rules apply when supplier or recipient is outside India.

Extension of time for revocation of cancellation of registration permits filing and processing of pending or rejected applications under notification.
Extension of time for applying for revocation of cancellation of registration is granted by notification, extending the due date for filing such applications to 30th September, 2021 for cases with original due dates between 1st March, 2020 and 31st August, 2021. The extension applies to cancellations under the specified statutory clauses and covers unfiled, pending, rejected and appealed applications; authorities must process or accept fresh applications in light of the extension. Clarification addresses interaction with the statutory proviso on administrative extensions and delineates when further discretionary extensions by senior officers may or may not be available.

GST exemption on examination services: fees and input services by central/state boards are exempt, accreditation remains taxable.
The circular confirms that GST exemption applies to services by Central or State Boards in conducting examinations for students, including entrance examinations and associated fees, and to input services relating to admission or conduct of examinations such as online testing, result publication, and printing of admit cards and question papers. It further specifies that other services, notably accreditation or registration of institutions or professionals, are taxable and attract GST.

GST exemption scope for annuity payments clarified: construction annuities remain taxable as exemption covers access services only.
Entry 23A's exemption for annuity payments applies only to access/operation services under Heading 9967 and, therefore, does not exempt annuities or deferred payments made for construction of roads, which fall under Heading 9954 and remain subject to GST applicable to construction services.

GST exemption on catering services: serving food to schools and anganwadis is exempt regardless of funding source.
Services consisting of serving food (catering, including mid-day meals) to schools and Anganwadis are exempt from GST under Entry 66(b)(ii), and this exemption applies irrespective of whether such supplies are funded by government grants or corporate donations.

Extension of time to apply for revocation of cancellation allows officers to grant limited extensions following procedural requests and review.
This SOP operationalises the amended provision permitting staged extensions for filing FORM GST REG-21: applicants who file beyond the initial period must request extension by letter or e mail to the proper officer, who forwards it to the jurisdictional Joint/Additional Commissioner. The Commissioner or Joint/Additional Commissioner may extend time on sufficient cause with reasons recorded, may grant personal hearing if needed, and must communicate grant or rejection via the proper officer; on a grant, the proper officer will process the REG-21 application. The SOP applies until GSTN portal functionality is available.

Extension of limitation applies to GST appeals and revisions, not to original adjudication or enforcement proceedings.
The Supreme Court's extension of limitation applies to judicial and quasi judicial lis-principally appeals, reviews and revisions-and thus extends filing timelines for appeals before appellate authorities and courts. The extension does not cover original adjudication, taxpayer statutory compliance deadlines, enforcement actions such as searches, enquiries or arrests, nor routine steps like issuance of show cause notices; those remain governed by statutory time limits or specific statutory extensions.

Export of services: supplies from Indian-incorporated affiliates to foreign parents can qualify as exports if other conditions are met.
The circular clarifies that a company incorporated in India and a foreign company incorporated outside India are separate persons; therefore supplies of services by an Indian-incorporated subsidiary/sister/group concern to establishments of the foreign parent abroad are not "merely establishments of a distinct person" under Explanation 1 to section 8 and need not be excluded by clause (v) of sub-section (6) of section 2 of the IGST Act, subject to fulfilment of the other export conditions. By contrast, branches, agencies or representative offices of the same foreign company are establishments and supplies between them and the foreign parent do not qualify as export.