Input tax credit reversal under amended Rule 37 requires payment via GSTR-3B and raises proportionality and interest timing ambiguities.
Amendments to Rule 37 (effective 01-07-2022) require reversal of input tax credit via Form GSTR-3B when a recipient fails to pay the supplier within 180 days, replacing the prior obligation to report proportionate unpaid value in Form GSTR-2. The change raises ambiguity whether the entire ITC or only a proportionate share must be paid when part payment remains unpaid, permits re availment of ITC upon subsequent payment to the supplier, and creates uncertainty on the correct start date for interest where an earlier sub rule prescribing interest from date of availment was omitted. (AI Summary)

GST on ROC filing fees: statutory ROC services are taxable unless specifically exempted, often collected under reverse charge.
ROC filing fees are charged for statutory regulatory functions performed by a public authority under the Companies Act. Under GST, government activities can constitute "business" and thus taxable supply unless specifically excluded by notification. Relevant exemptions in Notification No.12/2017 may exclude fees for non business entities, small turnover recipients, low value consideration, or registration under law; absent such exemption, GST may be payable under the Reverse Charge Mechanism u/s 9(3). (AI Summary)

Best judgement assessment risks arbitrary ex parte tax assessments; filing a valid return can trigger automatic withdrawal.
Section 62 authorises the proper officer to make a best judgment assessment where a registered person fails to file returns after notice, relying on available material and issuing a written order within the limitation period. The provision omits an express duty to call for accounts or to afford a hearing, permitting assessments based on records already available and potentially ex parte. A valid return filed and self assessed tax paid within thirty days of the assessment order results in automatic withdrawal of the order, although interest and late fee liabilities continue. (AI Summary)