Internal Review Cell scrutiny treats orders passed during the quarter ending March 2025 as the opening balance, with subsequent monthly orders added as accrual. Refund sanction orders and orders where the final demand is lower than the show-cause liability require compulsory scrutiny. High-stake orders may be reviewed for omitted issues. First appeal is preferred against erroneous orders, while suo motu revision is reserved for orders erroneous and prejudicial to revenue. A monthly progress report records scrutiny, discrepancies, pending cases, and statutory remedies.

Three centrally issued GST circulars are adapted for application under the Odisha Goods and Services Tax Act, 2017, to promote uniform implementation. They clarify regularisation of GST on apportioned co-insurance premiums and reinsurance commission, GST applicability to certain services, and late fee applicability for delayed furnishing of FORM GSTR-9C. The clarifications are characterised as clarificatory.

Article 13 of the India-Mauritius tax treaty governs the claimed exemption of current-year long-term capital gains, while Section 74 governs set-off and carry-forward of long-term capital losses. Where those gains are exempt from Indian taxation under the treaty, no taxable capital gain exists for adjustment of brought-forward long-term capital losses; the losses therefore remain available for carry-forward in accordance with law. Treaty-exemption entitlement requires factual verification, with an opportunity of hearing, before this treatment applies.

GST exemption is considered for upfront consideration determined upfront but paid or payable in instalments for long-term leases of industrial or financial-infrastructure plots. Seed testing, inspection, certification and issuance of seed tags together form a composite exempt supply where the certification is legally required for consumer and public safety. Seed tags separately supplied by external departments or manufacturers are taxable goods, classified according to their predominant material.

GST registration is deemed cancelled upon submission of a cancellation application, from the application date or the requested cancellation date. Registration obtained under rule 14B is also deemed cancelled following specified changes involving an electronic commerce operator, the declared principal place of business, or cancellation of the underlying home-State registration, where required amendments are not filed within thirty days. Cancellation does not remove liability for tax, other dues, or GST obligations relating to periods before cancellation.

Change in the effective date of GST registration cancellation may be ordered after a show cause notice, with reasons recorded and the revised cancellation date specified. The available record, any reply, and written or oral hearing submissions may be examined according to the person's response and attendance. The registered person must file pending returns and, where furnishing returns under section 39(1), file FORM GSTR-10 within three months of the order. Earlier tax liabilities and statutory obligations remain unaffected by cancellation.

GST REG-36 provides for dropping proceedings commenced to change the effective date of registration cancellation. Following consideration of the taxpayer's reply to a show cause notice or submissions at a hearing, the proceedings may be vacated with recorded reasons. Proceedings are deemed dropped where no order is issued within sixty days of the show cause notice. A deemed-dropping order is system-generated and does not require the issuing authority's signature.

Existing registered persons electing the concessional tax option must submit FORM GST CMP-02 under the indicated supplier category by 30 April 2019 and furnish FORM GST ITC-03. Eligible applicants for new registration may select the option in FORM GST REG-01. Election for one place of business extends to all registrations under the same Permanent Account Number and operates from the financial year's beginning or, for new registrations, the registration date.

Form GST REG-35 prescribes replies to show cause notices concerning a change in the effective date of cancellation. It requires notice particulars, GSTIN/UIN, legal and trade names, the reply, and a list of uploaded supporting documents. An authorised signatory must verify by solemn declaration that the information is true and correct to the best of knowledge and belief and that nothing has been concealed, and provide signature, name, designation or status, place, and date.

GST REG-34 requires a show cause notice before changing the effective date of cancellation of GST registration. Grounds include fraudulent registration, failure to conduct business from the declared place, issuing invoices without supply, and failure by a voluntarily registered person to commence business within six months. The person is allowed thirty days to reply and an opportunity of personal hearing. Failure to respond or attend may result in an ex parte determination on available records and merits.

Death of a sole proprietor is treated as a transfer of business where a transferee or successor continues the business. Unutilized input tax credit in the deceased proprietor's electronic credit ledger may be transferred after the successor obtains registration and files FORM GST ITC-02 before cancellation of the deceased proprietor's registration. Legal heirs may apply for cancellation while linking the transferee's registration number. The transferee or successor is liable for tax, interest, and penalties due from the transferor.

Transfer of two GST-related writ petitions was sought so that they could be heard with an existing batch before another High Court. The request was confined to the identified writ petitions, and no objection to their transfer was raised by the appearing respondent. The proceedings were transferred for consolidated hearing with the pending batch, enabling common consideration of related anti-profiteering matters.

PSLCs traded between banks through the e-Kuber portal are treated as supplies of goods in the course of inter-State trade or commerce, requiring IGST for both relevant periods. For the earlier period, the seller bank pays GST under forward charge at 12 per cent; from 28 May 2018, the buyer bank bears liability under reverse charge. No additional IGST is required where the liable bank has already paid CGST/SGST or CGST/UTGST on the same supply.

Grant-funded research and development services supplied by specified Government entities and notified institutions may claim exemption on a certificate from the institution's head confirming that the activity is R&D rather than consultancy. Separately recovered registration, insurance, FASTag, and related expenses in motor-vehicle leases form part of the composite leasing supply and are taxable at the leasing-service rate. Notional interest under bank Fund Transfer Pricing for loans or advances falls within the interest exemption, while NBFC lending services to banks in co-lending arrangements are taxable at the contractually agreed value.

Complete GST registration cancellation applications in FORM GST REG-16 should be accepted within 30 days unless incomplete or, in a transfer, merger or amalgamation case, the successor entity is unregistered. Deficiencies require written intimation, time to respond, a hearing before rejection, and recorded reasons. Cancellation does not extinguish tax liabilities. The taxpayer must furnish FORM GSTR-10 and pay the higher of input tax attributable to closing stock and capital goods or output tax payable, with any shortfall paid in cash. Non-filing of the final return may result in notice and assessment.

Sublimation paper is classified under heading 4809 and attracts GST at 18%, while past disputes are recommended for regularisation on an "as is where is" basis. Toy entries cover all toys under heading 9503, with respective treatment for non-electronic and electronic toys. Under the old and used motor vehicle margin scheme, input tax credit restriction applies only to tax paid on procurement of second-hand vehicles; credit on other inputs and input services remains available subject to the CGST Act. Registered seaweed extract-based bio-stimulants are classified as fertilisers under heading 3101.

Following a deficiency memo in FORM GST RFD-03, taxpayers must rectify and resubmit the existing refund application under the original ARN, without re-credit of debited input tax credit through FORM GST RFD-01B. Exporters receiving capital goods under the Export Promotion Capital Goods Scheme remain eligible for IGST refund on exports after the amended restrictions took effect, whereas exporters importing goods under specified customs exemption arrangements are ineligible.

Form GST REG-05A intimates rejection of applications for amendment, registration under rule 14B, or cancellation. Rejection may result from an unanswered notice, cancellation of the applicant's or supporting electronic commerce operator's registration, cancellation of the operator's tax-collection registration, cancellation of the selected home-State registration, or mismatch between the proposed principal-place address and the operator's consent. Unsuccessful physical verification may also justify rejection of an amendment application. Cancellation applications may be rejected where registration under rule 14B has already been cancelled.

Time-expired drugs or medicines returned through the supply chain may be treated either as a fresh supply or through a credit note. Registered non-composition returners issue an invoice and may use the original supply value; recipients may avail input tax credit subject to applicable conditions. Composition returners issue a bill of supply, while unregistered persons use a commercial document without tax. Under the credit-note route, tax liability adjustment depends on compliance with the prescribed time limit and input tax credit conditions. Input tax credit reversal on destruction differs according to the route adopted.

Customs cargo-handling locations appointed under section 7 of the Customs Act, 1962 are expanded by inserting Anekollu, Krishnagiri District, in the Tamil Nadu entry of the applicable table. Anekollu is added as item (xiv) at serial number 11 and authorises unloading of imported goods and loading of export goods, or any class of such goods. The location and operational purpose are inserted in columns (3) and (4), respectively.