Zero-rated supplies entitlement: IGST refund cannot be denied solely because exporter claimed higher drawback; statutory rules prevail.
The statutory refund regime treats the shipping bill as a deemed application for IGST refund on exports and allows withholding of refund only in the specific, enumerated circumstances provided by the rules. Administrative circulars cannot override the statute; availing a higher duty drawback or technical limitations in departmental systems do not, without falling within the prescribed withholding contingencies, defeat an exporter's entitlement to IGST refund for zero-rated supplies.

Input Tax Credit time limit: GSTR 3B is a temporary stopgap and does not fix the statutory monthly return deadline.
The Court held that GSTR 3B was implemented as a temporary stopgap and was not intended to replace the statutory monthly return; an administrative press release treating GSTR 3B filing as the outer date to avail Input Tax Credit conflicted with the statutory time limit provision and the rules prescribing the monthly return form and manner.

Place of supply rules: intermediary back office services treated at supplier location and not as export, GST applies.
The applicant's back office and payroll processing activities qualify as services rendered as an intermediary; under the IGST intermediary rule the place of supply is the supplier's location. The services do not satisfy all conditions for export of services (clause (iii) of the export definition fails) and therefore are not zero rated; GST is payable.

Reverse charge on legal services broadened to include advisory and representational work under GST notifications.
Corrigenda amend reverse-charge entries to treat "services provided by an individual advocate including a senior advocate or firm of advocates by way of legal services, directly or indirectly," as taxable, and add an Explanation that "legal service" includes advice, consultancy, assistance in any branch of law and representational services, thereby broadening the scope beyond representational services before courts, tribunals or authorities.

Reversal of Input Tax Credit on switching to composition scheme; capital goods credit prorated by remaining useful life.
Switching to the composition scheme requires reversal of Input Tax Credit on inputs, inputs in semi finished or finished goods held in stock, and capital goods held in stock as on the day before the option is exercised, by payment from the electronic credit or cash ledger after prescribed reductions. For capital goods, reversal is prorated by remaining useful life using an assumed five year useful life, with the credit attributable to remaining months computed as original credit multiplied by remaining months divided by sixty.

Input tax credit eligibility on switching from composition to normal scheme - capital goods credit reduced over time, subject to time bar.
A taxpayer switching from the composition scheme to the normal scheme may claim Input Tax Credit for inputs, inputs in goods held in stock, and capital goods held immediately before liability to pay tax, but credit for capital goods must be reduced by the prescribed periodic reduction measured from the invoice or receipt date, and no credit may be claimed for supplies after one year from the tax invoice date.

Input Tax Credit denial: purchases from composition taxpayers are ineligible for ITC under the GST regime.
A composition scheme taxpayer is excluded from the input tax credit chain, cannot issue a tax invoice or collect tax, and must state that no credit is available. Consequently, a registered person purchasing from a composition dealer cannot claim Input Tax Credit because the supplier does not charge GST in a manner that would enable the recipient to treat the payment as tax paid for ITC purposes.

Composition scheme threshold triggers monthly tax payment and monthly returns requirement for the affected taxpayer.
A taxpayer under the Composition Scheme may pay and file on the quarterly schedule (guidance noting payment on the 18th and quarterly return on the 18th after quarter-end). If the taxpayer crosses the threshold or withdraws from composition, they become a regular taxable person and must pay tax and furnish returns monthly by the 20th of the following month for the remainder of the financial year and subsequent years.

GST payment due date: monthly filers pay with next-month return; composition filers pay with quarterly return.
Tax under GST must be paid not later than the return's due date. Monthly filers must file GSTR-3 and pay tax by the twentieth day of the month following the tax month. Composition taxpayers under the composition scheme file quarterly in GSTR-4 and must pay tax by the eighteenth day after the quarter ends.

Composition levy on exempt supplies raises eligibility ambiguity due to turnover inclusion versus ineligibility for non leviable supplies.
The composition levy's tax base, as defined by turnover, expressly includes exempt supplies, indicating that composition tax is payable having regard to exempted goods; however, Section 10(2)(b) disqualifies persons making supplies "not leviable to tax," creating an ambiguity whether exempt supplies (which definitionally includes nil rated and wholly exempt supplies and non taxable supplies) render a person ineligible for composition. Commentators note this tension and call for clarification or amendment to reconcile the turnover inclusion with the eligibility restriction.

Eligibility for composition scheme may be barred by prior inter state supplies, even if current turnover is below threshold.
A registered person who made inter state supplies during the previous year is ineligible to opt for the composition scheme in the current year, because eligibility under Section 10 is determined with reference to the preceding financial year; thus the absence of inter state supplies must be assessed for the previous year even if turnover remains below the threshold.

Composition scheme eligibility: turnover in preceding financial year determines entitlement; aggregate turnover is all-India and fresh declaration required.
Eligibility for the composition scheme depends on aggregate turnover in the preceding financial year not exceeding the prescribed threshold; aggregate turnover is computed on an all India basis and includes taxable supplies (excluding inward reverse charge supplies), exempt supplies, exports and inter State supplies by the same PAN, while excluding GST and cess. Eligibility is reassessed each year; a fresh declaration is required to opt into the scheme after becoming eligible.

Composition scheme validity continues while statutory conditions are met; annual intimation is not required for eligible taxpayers.
The composition levy remains valid so long as statutory eligibility conditions and applicable CGST Rules are complied with; no fresh annual intimation is required if those conditions continue to be met.

Composition levy option must be elected before the financial year begins; prior electronic intimation required.
The option to pay tax under the composition levy must be exercised by giving electronic intimation in FORM GST CMP-02 prior to the commencement of the relevant financial year under the Central Goods and Services Tax Rules, 2017.

Composition levy withdrawal: file FORM GST CMP-04 and submit FORM GST ITC-01 detailing stock within the prescribed period.
Withdrawal from the composition scheme is effected by filing a duly signed or verified application in FORM GST CMP-04, and the applicant must electronically furnish FORM GST ITC-01 detailing stock of inputs and inputs contained in semi-finished or finished goods held on the date of withdrawal within thirty days of withdrawal.

Composition scheme: importers may remain in composition though IGST on imports may not yield input tax credit, service providers excluded.
Importers can opt for the composition scheme where otherwise eligible; there is no categorical bar on importers availing composition levy. IGST is payable on import and such tax may not yield input tax credit for a composition taxpayer. Pure service providers remain ineligible for composition, and importing services for business or captive consumption does not automatically make a person a service provider or disqualify composition eligibility.

Composition scheme eligibility: exporters cannot use composition tax where their supplies are treated as inter State, barring such option.
Exports are treated as inter State supplies for GST purposes. The composition levy prohibits a taxpayer from making inter State outward supplies of goods while paying tax under the composition scheme. Therefore, an exporter whose transactions are classified as inter State supplies cannot opt to pay tax under the composition scheme in respect of those export supplies.

Composition scheme: suppliers cannot make inter State outward supplies to SEZ while remaining in the scheme.
Supplies from the domestic tariff area to an SEZ are treated as inter State supplies, and Rule 5/Section 10 conditions for the composition levy prohibit a composition taxpayer from making inter State outward supplies; therefore a person paying tax under the composition scheme cannot make outward supplies of goods to an SEZ while remaining in the scheme.

Composition scheme eligibility denied where stock on appointed day was purchased inter state, imported, or received from outside State.
Persons below the turnover threshold who hold stock on the appointed day cannot opt for the composition scheme if that stock was purchased inter state, imported, or received from an out of State branch, agent or principal; possession of such goods on the appointed day disqualifies a registered person from the composition levy.

Composition scheme eligibility barred for casual and non-resident taxable persons; cannot claim composition as casual dealer.
A taxpayer acting as a casual taxable person or a non-resident taxable person is expressly excluded from the composition levy; therefore casual dealers and non-resident taxable persons cannot avail the composition scheme while operating in that capacity.