Faceless customs assessment reforms accelerate import clearance through higher facilitation, specialised assessment groups, automated examination orders and anonymised escalation.
Faceless customs assessment is expedited through a higher Risk Management System facilitation level, uniform FAG working hours, a first-decision timeline for Bills of Entry, limited and clearly framed assessment queries, and commodity-based FAG specialisation. Direct Port Delivery is extended to fully facilitated advance Bills of Entry, subject to port, terminal and custodian delivery requirements. Uniform Risk Management System-generated examination orders and First Check routing are introduced. An anonymised ICEGATE escalation mechanism permits importers and Customs Brokers to seek expeditious clearance of Bills of Entry delayed in assessment or examination.

Intermediary services under GST require three parties, a facilitative role, and no principal-to-principal supply.
Clarification under the GST framework explains the scope of intermediary services and aligns the definition with the pre-GST service tax position, with the added reference to supply of securities. The circular states that intermediary activity requires a minimum of three parties, namely two principals to the main supply and one person arranging or facilitating that supply, and that an activity between only two parties cannot be treated as intermediary service. It further emphasizes that the intermediary performs a supportive role and does not supply the main supply on its own account.

Export of services: supplies by Indian incorporated affiliates to their foreign group companies may qualify as export if conditions met.
Supplies between a branch, agency or representational office and another establishment of the same person are treated as inter establishment supplies and excluded from export treatment under condition (v). However, an Indian company incorporated under domestic law and a foreign company incorporated outside India are separate persons; therefore supplies by an Indian subsidiary or related group company to its foreign related company incorporated abroad are not barred by condition (v) and may qualify as export of services, subject to other export conditions including place of supply and receipt in convertible foreign exchange.

Time bound issuance of show cause notices required to protect statutory limitation periods and ensure timely GST adjudication.
The circular directs time bound issuance of show cause notices and strict supervisory monitoring to protect limitation periods under Section 73 and Section 74 of the CGST/UPSGST Act, 2017. It notes few SCNs were issued in detected GST evasion and fraudulent ITC cases for relevant financial years, observes that annual return filing deadlines have elapsed thereby starting statutory limitation clocks, and requires officers to complete investigations promptly, issue SCNs well before limitation cutoffs, prepare action plans to avoid investigations lingering beyond one year, and ensure timely adjudication.

GST classification clarifies rates and exemptions for food delivery, mining rights, amusement admissions, vehicle rentals, and contract manufacturing.
Cloud kitchens and central kitchens supplying cooked food through takeaway or delivery are treated as restaurant services and attract GST at 5% without input tax credit, while pre-manufactured ice cream sold by parlors is a supply of goods taxable at 18%. Government-funded coaching under the Scholarships for Students with Disabilities scheme is exempt where the full expenditure is borne by Government. Renting eligible passenger vehicles to State Transport Undertakings or Local Authorities is covered by the exemption for giving vehicles on hire. Mining rights, specified amusement admissions, and job work relating to alcoholic liquor are subject to the clarified applicable GST treatment.

GST classification clarifications prescribe treatment for food products, reagents, petroleum transfers, bundled batteries, renewable projects and fibre drums.
GST classification clarifications distinguish fresh fruits and nuts from dried or processed products, classify tamarind seeds according to sowing use, and treat copra separately from coconut. They prescribe rates for pure henna, sweet supari, flavoured illaichi, brewing and distilling residues, pharmaceutical goods, and laboratory reagents. Separate pricing of a UPS or inverter and external battery results in distinct supplies. The circular also addresses essentiality certificates for petroleum-operation stock transfers, deemed valuation for specified renewable energy projects, and the treatment of fibre drums during periods of rate ambiguity.

Incorrect GST Head Refund allows claims after correct tax payment when supply classification is later corrected by taxpayer or proceedings.
Refund of tax paid under an incorrect GST head may be claimed where a supply initially treated as intra-State or inter-State is later found to have the opposite character, whether by the taxpayer or in tax proceedings. The claimant must first pay tax under the correct head and file FORM GST RFD-01 within two years from that payment, subject to the transitional period for earlier correct-head payments. Refund is not available where tax has been adjusted through a credit note for the transaction.

Transfer of SEZ space under Rule 74: independent valuation plus e-auction allocates space and secures asset payment to exiting unit.
Transfer of space under Rule 74 uses an independent valuation and e-auction process: the SEZ Authority engages an independent valuer to assess depreciated physical assets and unutilised portions of upfront lump-sum payments; an identified incoming buyer states lease rent, the Authority conducts an e-auction disclosing that rent, and the highest lease-rent bid wins unless the highest bid is lower than the identified buyer's indicated rent, in which case that buyer secures the space. The successful bidder must pay a predetermined amount equal to the valuer-assessed transfer value to be passed to the exiting unit, and the process must conclude within 100 days of a complete exit application.

GST classification: cloud kitchens 5% without ITC; mining rights and alcohol job work taxed at standard rate-key rate clarifications.
Services by cloud kitchens/central kitchens are classified as restaurant service and attract 5% GST without ITC; ice cream sold by parlors is supply of goods attracting 18% GST. Government funded coaching under the Scholarships for Students with Disabilities scheme is exempt. Satellite launch services to foreign customers qualify as export of services and are zero rated. Overloading charges at toll plazas receive toll treatment. "Giving on hire" includes renting to STUs and local authorities and is exempt when qualifying. Grant of mineral exploration and mining rights is classified under service code 997337 and was taxable at 18% for 01.07.2017-31.12.2018. Admission to amusement parks is 18% except where casino/race club/sporting events invoke 28%. Job work for alcoholic liquor attracts 18%, not the 5% food job work rate.

GST classification clarified: specified goods reclassified with applicable concessional and standard rates, and procedural rules set.
Clarification sets GST classification and rates for specified goods per GST Council recommendations: fresh fruits exempt only when supplied as plucked; dried/processed fruits and nuts taxable under headings 0801/0802. Tamarind seeds (heading 1209) not for sowing attract 5% from 1 October 2021; Copra (heading 1203) attracts 5%. Pure henna (heading 1404) attracts 5%. Value added betel/cardamom products attract 18%. Brewers' spent grain and similar residues (heading 2303) attract 5%. All goods under heading 3006 attract 12%; all goods under heading 3822 attract 12%. DGH import Essentiality certificate is sufficient for inter state stock transfers of same imported goods. UPS/inverter and external batteries sold together are taxed separately by heading. Renewable Energy Projects may use a 70:30 goods to services split for the 1 July 2017-31 December 2018 period; heading 4819 goods (including fibre drums) uniformly taxed at 18% from 1 October 2021.

Export of services: supplies by Indian incorporated subsidiaries to related foreign companies may qualify as export if statutory conditions are met.
Condition (v) of export of services excludes supplies between establishments of a distinct person; a branch/agency of a foreign company in India is an establishment of that foreign company and such intra-company supplies do not qualify as export. A company incorporated in India and a foreign company incorporated outside India are separate persons; therefore services supplied by an Indian-incorporated subsidiary/sister/group company to related foreign incorporated entities outside India are not treated as supplies between merely establishments of a distinct person and may qualify as export of services, subject to the other conditions in section 2(6).

Input tax credit timing: debit note date governs eligibility, e invoice QR suffices for transport, export duty refund restriction narrowed.
The amendment to section 16(4) delinks debit note date from the underlying invoice date for ITC eligibility, making the debit note issuance date the relevant financial year for claiming input tax credit; the amended rule governs ITC claims made on or after the amendment date, irrespective of when the debit note was issued. E invoices need not be carried physically during movement: an electronic QR code embedding the Invoice Reference Number suffices for verification. The first proviso to section 54(3) restricts refunds of unutilized ITC only where goods are actually subject to export duty; nil rated, exempted, or non scheduled goods are excluded from that restriction.

Intermediary services definition clarified: intermediary facilitates a third-party main supply and excludes suppliers acting on their own account.
Intermediary means a broker, agent or similar person who arranges or facilitates a main supply of goods, services or securities between two or more other persons and does not include a person who supplies the main supply on his own account; intermediary arrangements involve two distinct supplies - the main supply between principals and the ancillary facilitation service - require a minimum of three parties, and exclude subcontractors or service providers who supply the main service on a principal-to-principal basis.

Extension of limitation: appeals and revisions under GST are extended, while original adjudication and compliance timelines remain statutory.
The Supreme Court's extension of limitation applies to judicial and quasi judicial proceedings-primarily appeals, reviews, revisions and similar remedies-so time limits for filing appeals before appellate authorities, the Appellate Authority for Advance Ruling, the Tribunal and courts are extended. Original adjudication timelines including scrutiny of returns, issuance of summons, searches, enquiries, investigations, arrests, show cause notices and routine taxpayer compliances remain governed by statutory provisions and notifications and are not broadly covered by the Supreme Court order.

GST classification of services clarified: restaurant delivery, goods treatment for ice cream, exemptions and applicable tax treatments set out.
Services by cloud/central kitchens that cook and supply food, including takeaway and delivery, are classified as restaurant service and attract the concessional restaurant tax without input tax credit; ice cream parlours selling pre manufactured ice cream are supplies of goods and taxed as such; government funded coaching under the disability scholarships scheme is exempt; satellite launch services to foreign recipients qualify as export of service and zero rated; overloading toll charges are treated as tolls for exemption; renting to STUs/local authorities is covered by "giving on hire" exemption; grant of mining rights is licensing for mineral use and taxed at the standard rate for the disputed period; amusement park admissions and job work for alcoholic liquor are treated as specified above.

GST classification clarified: tariff headings determine exemption or concessional tax treatment across seeds, copra, henna, reagents and packaging.
Clarification on GST classification and rates: fresh fruits exempt only if not frozen or dried; dried fruits taxable. Tamarind and seeds under the seeds heading attract concessional GST when not for sowing. Copra excluded from coconut exemption and taxable. Pure henna powder and leaves classify as vegetable dye materials and attract the concessional rate. Laboratory and diagnostic reagents under the reagents heading qualify for the concessional laboratory rate. Original/import essentiality certificate from the Directorate General of Hydrocarbons suffices for intra-company inter State stock transfers when records establish nexus.

Refund of wrongly paid tax: taxpayers can claim when supply classification is subsequently found different, subject to procedure and time limits.
The term subsequently held includes both taxpayer-initiated reclassification and reclassification by tax officers, and refund claims must be filed electronically within two years from the date tax was paid under the correct head, with earlier correct-head payments governed by two years from the date of the relevant notification; refunds are excluded where adjustment was made by issuing a credit note.

Extension of limitation periods for judicial and quasi judicial tax appeals now applies to filing of appeals and revisions under GST law.
Extension of limitation under GST law applies to appeals, reviews, revisions and other judicial or quasi judicial proceedings required to be instituted against quasi judicial orders, whose limitation periods stand extended by the Supreme Court order; taxpayer statutory compliances remain governed by statutory timelines and notifications, while investigative or enforcement actions such as scrutiny, summons, searches, inquiries and arrests are not covered and pending matters should continue to be adjudicated or disposed of physically or virtually.

Export of services: supply by Indian-incorporated group entities to their foreign related companies qualifies as export if other conditions satisfied.
The circular clarifies that an Indian-incorporated company and a foreign-incorporated company are separate legal persons, so supplies of services from an Indian-incorporated subsidiary, sister or group company to related companies incorporated outside India are not supplies between merely establishments of a distinct person and therefore can qualify as export of services, provided the other export conditions-supplier in India, recipient outside India, place of supply outside India, and receipt of payment in convertible foreign exchange-are satisfied.

Input tax credit on debit notes is fixed by the debit note date, and e invoice QR suffices during transport.
Eligibility for input tax credit on debit notes is determined by the debit note's date rather than the underlying invoice date; the amended rule governs availment on or after the amendment effective date while prior availment remains subject to the earlier law. E invoice QR codes embedding the Invoice Reference Number may be produced electronically during movement in lieu of physical tax invoices. The refund prohibition for unutilized input tax credit applies only where goods are actually liable to and suffer export duty; goods at nil rate or exempted from export duty are not covered.