54th GST council meeting - notification no. 20/2024

[Govinda Raju]

Amendment / omission of sub rule 96(10) is retrospective or prospective Implementation.

[Shilpi Jain]

Prospective.

Though for the past one may consider challenging the provision itself as it seems to be ultra vires.

[KASTURI SETHI]

It is prospective. 

[Amit Agrawal]

You may also refer to Circular No. 233/27/2024-GST, dated 10th September, 2024.

These are ex facie views of mine and the same should not be construed as professional advice / suggestion or recommendation.

AI Summary

Prospective application of the sub rule amendment affirmed; past application may be open to ultra vires challenge under GST guidance. Amendment or omission of sub rule 96(10) is to operate prospectively; advisory responses treat implementation as effective only from the amendment date. Stakeholders may consider challenging past application of the provision as ultra vires. Circular No. 233/27/2024 GST is cited as relevant administrative guidance. The replies are individual non professional views and not formal legal advice.