Applicability of GST Compensation Cess creates uncertainty for penultimate export sales and reverse charge purchases absent clarifications.
The GST Compensation Cess treatment on supplies preceding export sales and on reverse charge purchases from unregistered dealers is unclear: central concessions for reduced GST and exemptions apply only if States issue corresponding SGST notifications and the Centre clarifies whether the Compensation Cess applies to penultimate export sales and to acquisitions on reverse charge, otherwise buyers or sellers may remain liable for the cess despite reduced central tax rates. (AI Summary)

Mismatch in GST rates prevents electronic return filing when state SGST notifications lag behind central rates.
Delay in state SGST notifications creates a legal gap because SGST laws lack mutatis mutandis replication of CGST rates; without specific state notifications there is no legal basis for levy of SGST, and temporal divergence in notification dates (illustrated by Goa) produces periods of CGST-SGST misalignment that impede return filing on the GSTN portal. (AI Summary)

Place of supply rules under IGST may reclassify intra state deliveries as inter state when a third party directs delivery.
Section 7(3) deems a directing third person to have received goods and makes that person's principal place of business the place of supply, potentially converting otherwise intra state supplies into inter state supplies (and vice versa). Section 7(4) says where supply does not involve movement the place of supply is the location of the goods at delivery, producing ambiguity in bill to ship to arrangements over whether the third person or the ultimate customer determines tax incidence and related input tax credit consequences. (AI Summary)