Deficiency memo in GST refunds risks time barred claims when resubmission is treated as a fresh application by authorities.
Issuance of a deficiency memo under the GST refund rules often compels taxpayers to resubmit a fresh refund application, which administrative practice and certain circulars treat as restarting the statutory limitation period, thereby risking time barred claims. The rules implicated include acknowledgement and scrutiny under rule 90, recredit to the electronic credit ledger under rule 93(1), and notice procedures under rule 94(3). The article warns that technical or format deficiencies enforced by circulars can prejudice taxpayers and recommends filing early, adhering to master circular formats, and seeking clarification that limitation runs from the original filing when substantive entitlement is unaffected. (AI Summary)

Reverse charge on director services: only remuneration for services in director capacity attracts RCM; salaries treated as employment.
GST liability depends on the capacity in which a director provides services: remuneration for services performed in a directorial capacity is subject to reverse charge under Notification No. 13/2017, whereas salary paid to executive directors-treated and taxed as employment income with TDS under the salary provisions-falls under the Schedule III exclusion and is not a taxable supply. Payments to non executive directors such as sitting fees or commission for directorial services are prima facie taxable under RCM, while remuneration for non director individual activities should be taxed under forward charge. (AI Summary)

Rule 36(4) relaxation may enable excess input tax credit claims, risking reversal and interest exposure upon cumulative reconciliation.
Relaxation of Rule 36(4) for February-August 2020 is to be given cumulative effect in the GSTR-3B of September 2020. Cumulative application risks excess ITC claims where suppliers have not uploaded invoices to GSTR-2A, requiring reversal in September and exposing taxpayers to potential interest and recovery under provisions addressing irregular or excess credit. Monthly reconciliation reduces excess-claim risk and allows time to obtain missing supplier uploads; cumulative relief may be used selectively to protect working capital if missing invoices can be secured by the September reconciliation point. (AI Summary)

GST input credit rules reshape real estate costs and compliance, altering pricing, working capital, and registration obligations.
Under the GST regime works contracts will be treated as a supply of service and input credit on inputs and capital goods will be broadly available, provided purchases are from registered suppliers; this reduces embedded costs and classification disputes but raises registration, matching-based credit controls, reverse charge exposure, valuation inclusion for free supplies, potential taxation of stock transfers, and increased compliance and working capital requirements for builders. (AI Summary)

GST consolidation simplifies indirect taxes but reshapes input tax credit, stock transfer taxation and compliance burden.
The Model GST consolidates indirect levies into a single, multi component tax and changes credit mechanics, registration, and compliance: manufacturers gain seamless input tax credit and state level registration while losing the primacy of the manufacture concept; GST also accelerates goods movement but taxes stock transfers, tightens time of supply rules, restricts credit from unregistered sellers and excludes certain petroleum credits. Traders obtain broader input credit and simplified disclosure but face loss of inter state preferential forms, altered warehouse decisions and a substantially increased compliance and returns burden. Transitional provisions permit migration of eligible legacy credits to an electronic ledger, subject to final determination. (AI Summary)