Major GST Amendments effective from 1 November 2024

The GST landscape is undergoing significant changes, with new amendments announced through Notification No. 17/2024, effective from 1st November 2024. These amendments, originally proposed in the 53rd GST Council meeting and introduced by the Finance Act No. 2 of 2024, are now officially notified. These updates are crucial for taxpayers to understand and ensure compliance with the revised rules.

1. The GST Amnesty Scheme offers relief for taxpayers by waiving interest and penalties on demand notices for FYs 2017-18, 2018-19, and 2019-20, provided the full tax is paid by March 31, 2025. This has been introduced by inserting Section 128A in the CGST Act, allowing conditional waivers for demands raised under Section 73. It’s important to note that this waiver doesn’t apply to erroneous refunds. This measure aims to help taxpayers who struggled during the early GST implementation phase.

Notifications: 22/2024, 21/2024, 20/2024, Circular: 238/32/2024

2. The recent Amendment to Section 7 clarifies that raw materials for liquor production, specifically Extra Neutral Alcohol (ENA), are now excluded from GST. This amendment was proposed in the 52nd GST Council meeting and is aimed at excluding rectified spirit/ENA from the scope of GST when supplied for manufacturing alcoholic liquors meant for human consumption. To implement this, changes were made to Section 9(1) of the CGST Act, ensuring that GST is not levied on ENA used in liquor production.

3. The GST Council has simplified the timeline for issuing demand notices and orders by recommending a unified time limit for cases involving fraud, suppression, or willful misstatement, as well as those not involving such charges. This applies to demands starting from FY 2024-25 onwards.

Additionally, the time limit for taxpayers to avail a reduced penalty by paying the tax demanded along with interest has been extended from 30 days to 60 days, offering more flexibility for compliance.

4. The insertion of Section 11A in the CGST Act is a significant step towards protecting businesses from penalties for following generally accepted but incorrect tax practices. This new provision allows the government, on the recommendation of the GST Council, to regularize situations where GST was not levied or was underpaid due to common trade practices. This amendment aims to provide relief to businesses by ensuring that no retrospective penalties are imposed in such cases.

5. Self-Invoicing Time Limits

  • Clear time limits for self-invoicing related to Reverse Charge Mechanism (RCM) supplies have been established.

New Rule 47A. Time limit for issuing tax invoice in cases where recipient is required to issue invoice.– Notwithstanding anything contained in rule 47, where an invoice referred to in rule 46 is required to be issued under clause (f) of sub-section (3) of section 31 by a registered person, who is liable to pay tax under sub-section (3) or sub-section (4) of section 9, he shall issue the said invoice within a period of thirty days from the date of receipt of the said supply of goods or services, or both, as the case may be

Notification No.20/2024

6. ITC Restrictions

  • Restrictions on ITC claims for tax paid under Section 74 will now only apply to demands from FY 2023-24 and earlier.

Notification No.20/2024

7. Revocation of Registration Cancellations

  • The Central Government is now authorized to set conditions for the revocation of GST registration cancellations.

Notification No.20/2024

8. Mandatory GSTR-7 Filing

  • TDS deductors are required to file GSTR-7 monthly, even when no tax has been deducted.

The Council recommended that return in FORM GSTR-7, to be filed by the registered persons who are required to deduct tax at source under section 51 of CGST Act, is to be filed every month irrespective of whether any tax has been deducted during the said month or not. It has also been recommended that no late fee may be payable for delayed filing of Nil FORM GSTR-7 return. Further, it has been recommended that invoice-wise details may be required to be furnished in the said FORM GSTR-7 return.

Notification No.20/2024

9. IGST Refunds

  • Refunds for IGST on goods subjected to export duty, including exports to SEZs, are restricted.

Amendment in Section 16 of IGST Act and section 54 of CGST Act to curtail refund of IGST in cases where export duty is payable: The Council recommended amendments in section 16 of IGST Act and section 54 of CGST Act to provide that the refund in respect of goods, which are subjected to export duty, is restricted, irrespective of whether the said goods are exported without payment of taxes or with payment of taxes, and such restrictions should also be applicable, if such goods are supplied to a SEZ developer or a SEZ unit for authorized operations.

Refund of additional Integrated Tax (IGST) paid on account of upward revision in price of the goods subsequent to export: The GST Council recommended to prescribe a mechanism for claiming refund of additional IGST paid on account of upward revision in price of the goods subsequent to their export. This will facilitate a large number of taxpayers, who are required to pay additional IGST on account of upward revision in price of the goods subsequent to export, in claiming
refund of such additional IGST

Notification No.20/2024

Circular 233/27/2024

10. Compliance with Summons

  • Authorized representatives can now represent summoned individuals to comply with summons.

Sub-section 1A is being inserted in section 70 of the CGST Act to enable appearance by an authorized representative on behalf of a summoned person.

11. Reduced Pre-Deposit for Appeals

  • The pre-deposit amount for filing GST appeals has been lowered, with a new 3-month time limit for appeals set from the notification date.

The Council recommended amendment in rule 142 of CGST Rules and issuance of a circular to prescribe a mechanism for adjustment of an amount paid in respect of a demand through FORM GST DRC-03 against the amount to be paid as pre-deposit for filing appeal.

Notification No.20/2024

Amendment in Section 107 and Section 112 of CGST Act for reducing the amount of pre-deposit required to be paid for filing of appeals under GST: The GST Council recommended reducing the amount of pre-deposit for filing of appeals under GST to ease cash flow and working capital blockage for the taxpayers. The maximum amount for filing appeal with the appellate authority has been reduced from Rs. 25 crores CGST and Rs. 25 crores SGST to Rs. 20 crores CGST and Rs. 20 crores SGST. Further, the amount of pre-deposit for filing appeal with the Appellate Tribunal has been reduced from 20% with a maximum amount of Rs. 50 crores CGST and Rs. 50 crores SGST to 10% with a maximum of Rs. 20 crores CGST and Rs. 20 crores SGST.

In the said rules, in FORM GST APL-01, with effect from the 1st day of November, 2024.–

(a) in entry number 15,– (i)in clause (a), in the Table, in the first column relating to “Particulars”, in item (b) relating to “pre-deposit”, for the brackets, letters, words and figures “(b) Pre- deposit (10% of disputed tax /cess but not exceeding Rs. 25 crore each in respect of CGST, SGST or cess or not exceeding Rs.50 crore in respect of IGST and Rs. 25 crore in respect of cess)”, the brackets, letters, words, and figures

“(b) Pre- deposit (10% of disputed tax /cess but not exceeding Rs. 20 crore each in respect of CGST, SGST, cess, and not exceeding Rs. 40 crore in respect of IGST)” shall be substituted; (ii)in clause (b), in the opening portion, for the brackets, words, figures and letters “ (pre-deposit 10% of disputed tax and cess but not exceeding Rs. 25 crore each in respect of CGST, SGST or cess or not exceeding Rs.50 crore in respect of IGST and Rs. 25 crore in respect of cess)”, the brackets, words, figures and letters “(pre- deposit 10% of disputed tax and cess but not exceeding Rs. 20 crore each in respect of CGST, SGST, cess, and not exceeding Rs. 40 crore in respect of IGST)” shall be substituted

12. Updated Penalty Provisions

  • Penalties for e-commerce operators have been revised to adapt to the evolving digital commerce landscape.

Amendment was recommended to be made in section 122(1B) of CGST Act retrospectively w.e.f. 01.10.2023, so as to clarify that the said penal provision is applicable only for those e-commerce operators, who are required to collect tax under section 52 of CGST Act, and not for other e-commerce operators.

13. Transitional Credit for Services

  • Transitional credit for service invoices received before the appointed date is now allowed retroactively from July 1, 2017.

The Council recommended amendment in section 140(7) of CGST Act retrospectively w.e.f. 01.07.2017 to provide for transitional credit in respect of invoices pertaining to services provided before appointed date, and where invoices were received by Input Service Distributor (ISD) before the appointed date.

14. IPC Sections Replaced by Bharatiya Nyaya Sanhita

Notification No.20/2024

he said rules, in FORM GST INS-01, in paragraph (C), for the words and figures “section 179, 181, 191 and 418 of the Indian Penal Code”, the words, figures and brackets “section 214, 216, 227 and sub-section (3) of section 318 of the Bharatiya Nyaya Sanhita, 2023 (45 of 2023)” shall be substituted.


15. Inclusion of Co-Insurance Premiums

  • Co-insurance premiums and re-insurance commissions are now included in Schedule III the CGST Act, simplifying transactions.

Co-insurance premium apportioned by lead insurer to the co-insurer for the supply of insurance service by lead and co-insurer to the insured in coinsurance agreements, may be declared as no supply under Schedule III of the CGST Act, 2017 and past cases may be regularized on ‘as is where is’ basis.
Transaction of ceding commission/re-insurance commission between insurer and re-insurer may be declared as no supply under Schedule III of CGST Act, 2017 and past cases may be regularized on ‘as is where is’ basis.


GST liability on reinsurance services of specified insurance schemes covered by Sr. Nos. 35 & 36 of notification No. 12/2017-CT (Rate) dated 28.06.2017 may be regularized on ‘as is where is’ basis for the period from 01.07.2017 to 24.01.2018.
GST liability on reinsurance services of the insurance schemes for which total premium is paid by the Government that are covered under Sr. No. 40 of notification No. 12/2017-CTR dated 28.06.2017 may be regularized on ‘as is where is’ basis for the period from 01.07.2017 to 26.07.2018.


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