GST treatment of related party loans: interest only consideration exempt, separate processing fees are taxable services.
Under the CGST Act, supply between related persons is treated as supply, but services of extending loans where consideration is only interest or discount are exempt; therefore loans between related parties charging only interest/discount do not attract GST, whereas any separate processing or administrative fees charged in addition to interest constitute taxable consideration for supply of services and are liable to GST.

Input tax credit availability for insurers on motor-vehicle repair costs follows insurer's approved reimbursement liability and invoicing.
Where garages issue invoices in the insurer's name for approved repair costs under reimbursement-mode claim settlements, the insurer is the recipient to the extent of its approved liability and may claim input tax credit for motor vehicle repair services used in supplying insurance. If invoices include amounts beyond the approved claim cost, ITC is limited to the insurer's reimbursed portion unless separate invoices allocate the approved cost to the insurer. No ITC is available where invoices are not in the insurer's name.

Extended warranty as separate supply: warranty sold separately is taxable as a service and supplier must discharge GST.
Clarification extends prior guidance so that GST and ITC rules for replacement of parts apply equally where goods themselves are replaced under warranty, reading references to 'parts' as 'goods or its parts'. Replenishment by a manufacturer to a distributor, provided without separate consideration via delivery challan after the distributor replaced goods from its stock on the manufacturer's behalf, attracts no GST and requires no reversal of ITC by the manufacturer. Extended warranty supplied by a person different from the goods supplier, or supplied after original supply, is a separate supply treated as a service and taxed accordingly with the extended-warranty supplier responsible for GST.

Salvage ownership determines GST liability: insurer must pay GST when salvage vests with insurer on full settlement.
GST on salvage/wreck value hinges on ownership and the presence of a supply. If the insurer deducts salvage value as a pre agreed deductible under the contract, ownership remains with the insured and the insurer has no GST liability on that salvage. If the insurer pays full IDV without deducting salvage, the salvage vests in the insurer and the insurer must discharge GST on its disposal or sale.

Valuation exclusion in life insurance premiums does not require reversal of input tax credit under GST rules.
The portion of life insurance premium excluded from taxable value under Rule 32(4) is a valuation exclusion and is not a non-taxable or exempt supply; therefore, reversal of input tax credit under Section 17(1)/(2) read with Rules 42 and 43 is not required in respect of that excluded amount.

Taxability of ESOP/ESPP/RSU: cost to cost reimbursements not taxable, but additional fees attract GST on reverse charge.
Transfers of ESOP/ESPP/RSU by a foreign holding company directly to employees of an Indian subsidiary, with the subsidiary reimbursing the market cost on a strict cost to cost basis, are not supplies of goods or services under GST and are not taxable. Any additional fee, markup or commission charged by the foreign holding company constitutes consideration for facilitating services and is taxable as import of services, with GST payable by the domestic subsidiary on reverse charge basis.

Proportionate ITC reversal verification: suppliers may use CA/CMA certificates or recipient undertakings as admissible evidence pending portal facility.
Where portal verification of recipients' proportionate reversal of input tax credit is unavailable, suppliers issuing post supply tax credit notes may rely on a CA/CMA certificate from the recipient detailing credit note and invoice references, ITC reversal amounts and the GST return or FORM DRC-03/other document evidencing reversal, and containing a UDIN. For smaller-value cases, a recipient's undertaking with equivalent details may be accepted. Such certificates/undertakings shall constitute admissible evidence of compliance and must be produced to tax officers when required, including for past periods.

Time limit for input tax credit under reverse charge clarified - relevant year is year of recipient issued invoice, subject to tax payment.
Where a registered recipient must issue the invoice and pay tax 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 that recipient-issued invoice is issued; availment remains subject to payment of tax, fulfilment of other statutory conditions for ITC, payment of interest for delayed tax, and possible penal consequences for delayed issuance or payment.

Deemed open market value: invoice value governs valuation of imported related party services where recipient claims full input tax credit.
The circular clarifies that where a registered person in India imports services from a related person abroad and the recipient is eligible for full input tax credit, the value declared in the invoice shall be deemed the open market value for valuation. This applies to reverse charge imports where the Indian recipient must issue a self-invoice and pay tax; if no supplier invoice exists the recipient's declared nil value may be treated as the open market value.

Place of supply for goods to unregistered persons now follows the delivery address on the invoice where billing and delivery differ.
Place of supply for goods to an unregistered person is the location as per the recipient's address recorded in the invoice; if no recipient address is recorded the place of supply is the supplier's location. Recording only the recipient's State on the invoice is sufficient to constitute an address. Where billing and delivery addresses differ, the delivery address recorded on the invoice determines the place of supply, and suppliers may record the delivery address as the recipient's address for that purpose.

Special procedure compliance: manufacturers must record machine identity and obtain Chartered Engineer-certified electricity ratings for SRM filings.
The Goa tax authority adopts the CBIC Circular on the revised special procedure for specified manufacturers, directing uniform application under the Goa GST Act. FORM GST SRM-I requires a mandatory machine number (assignable if unavailable) while make/model are optional; electricity consumption must be certified by a Practicing Chartered Engineer in FORM GST SRM-III and uploaded. The procedure excludes SEZ units and manual packing operations, requires reporting of the final-packing machine where multiple machines are used, and makes all persons in the manufacturing chain liable, with the principal manufacturer responsible if a job worker is unregistered.

Monetary thresholds for government appeals limit departmental litigation and set exclusions for constitutional, valuation, classification, refunds and recurring issues.
Fixes monetary limits below which the tax department shall not file appeals or applications before GSTAT, High Courts or the Supreme Court, prescribes computation principles for disputed tax, interest, penalty, late fee or refund amounts (including aggregation for composite orders), requires recording reasons for non-filing so such decisions carry no precedent value or imply acquiescence, and lists exclusions-including constitutional questions, valuation, classification, refunds, place of supply, recurring issues, adverse comments or costs-where appeals must be decided on merits regardless of the thresholds.

Section 61 scrutiny notices to be processed by deputy/assistant state tax officers; SCN issuance governed by pecuniary limits.
Scrutiny notices (ASMT-10/ASMT-12) issued before restructuring are to be further processed and finalized by Deputy State Tax Officers/Assistant State Tax Officers; such scrutiny instruments are not show cause notices and are not subject to pecuniary limits at the scrutiny stage. If amounts remain unpaid after intimation, DSTOs/ASTOs shall initiate proceedings under the recovery provisions, compute demand per prior circular instructions, and issue SCNs within their pecuniary limit or place draft SCNs before higher authorities when the amount exceeds their competence.

CSD refund processing follows a revised electronic filing regime with quarterly claims, invoice validation, and capped tax refund eligibility.
Processing of refund applications filed by the Canteen Stores Department is to be done electronically on the common portal in FORM GST RFD-10A under the revised procedure introduced after insertion of rule 95B. The CSD may file quarterly refund claims, with clubbing of multiple quarters and financial years, subject to the two-year limitation from the last day of the quarter in which the inward supply was received. Refund is limited to fifty per cent of the applicable tax on eligible inward supplies and requires supporting invoices, an undertaking, and a declaration against double claim.

Refund of additional IGST on export price revision must follow prescribed GST portal filing, documentation, and officer verification.
Refund of additional Integrated Tax paid on account of upward revision in the price of export goods subsequent to export is to be claimed electronically in FORM GST RFD-01 and processed by the jurisdictional GST officer under rule 89 of the GST Rules. Until a separate refund category is available, the claim may be filed under "Any other" with the prescribed remark, together with statements 9A and 9B and supporting documents showing the revised price, payment of additional IGST and interest, and receipt of additional foreign exchange remittance.

Corporate guarantee valuation under GST clarified: tax applies on guaranteed amount, with annual computation and ITC treatment explained.
Clarification is issued on the taxability and valuation of corporate guarantee services between related persons under GST. The circular explains that the service was taxable even before Rule 28(2), that valuation is based on the amount guaranteed rather than the loan actually disbursed, and that input tax credit remains available subject to the Act and Rules. It also addresses co-guarantors, takeover of loans, forward charge and reverse charge treatment, annual valuation, deemed invoice value where full input tax credit is available, and non-applicability to export of such services.

Pre-deposit adjustment and recovery stay govern confirmed GST demands pending appeal to the tribunal.
Guidelines are issued for recovery of outstanding dues where the first appellate authority has confirmed a demand, but appeal to the Appellate Tribunal cannot yet be filed because the Tribunal is not operational. Taxpayers may make the prescribed pre-deposit through the electronic liability register and furnish an undertaking to file appeal within the statutory time once the Tribunal becomes available. On compliance, recovery of the remaining confirmed demand stays pending appeal; otherwise, recovery may proceed according to law.

GST applicability clarified for composite supplies, pure agent treatment, job work maltification, leasing exclusion and governmental exemptions.
Clarifies that concessional input credit and 5% transport rate apply only to passenger transport and renting with operator, excluding leasing without operator; bundled electricity with renting/maintenance is a composite supply taxed at the principal supply rate unless supplied by a pure agent on actual basis; job work converting barley to malt is job work in relation to food products and attracts the food job work rate; DMFTs are Governmental Authorities eligible for exemptions; horticulture services to CPWD with goods value 25% are exempt under the cited state notification.

GST rate on imitation zari thread clarified: metallised polyester/plastic-film yarn included under reduced treatment; no inversion refunds.
Imitation zari thread or yarn made from metallised polyester film or plastic film that meets the HS description of yarn combined with or covered by metal is covered by the imitation zari entry in Schedule I and attracts the reduced GST rate; amendments to the State notification implement this, and no refund is permitted for polyester (metallised)/plastic film on account of tax inversion.

Taxability of guarantees: personal guarantees may be taxable zero where no consideration; corporate guarantees valued per prescribed rule.
Personal guarantees by directors are supply between related persons even without consideration; due to regulatory prohibition on paying consideration to such guarantors, their open market value may be treated as zero and thus taxable value zero unless remuneration is in fact paid. Corporate guarantees between related companies, including holding-subsidiary guarantees, are supply and their taxable value is to be determined by the prescribed valuation rule; a newly inserted sub-rule governs valuation of such corporate guarantees and applies irrespective of input tax credit availability. The valuation sub-rule does not apply to personal guarantees.