Section 122(1A) of the CGST Act extends penalty exposure to...

Section 122(1A) of the CGST Act extends penalty exposure to registered and unregistered persons, not only taxable persons, for specified invoice and input tax credit contraventions. Liability requires cumulative proof that the person retained the benefit of the identified transaction and that it was conducted at that person's instance; status as a director, employee, signatory or associate is insufficient. Proceedings must identify the covered underlying contravention and make person-specific, evidence-based findings on both elements, consistent with natural justice and reasoned adjudication. The provision does not create general vicarious liability and applies prospectively only to underlying acts or transactions occurring on or after 1 January 2021.