The position, before the reply

Latest practice notes

• Practice note · 2026-10-12

  Anti-Profiteering under Section 171: What the GST Tribunal Has Decided

  Section 171 of the CGST Act requires any reduction in the rate of tax, or the benefit of input tax credit, to be passed on by a commensurate reduction in prices. Notification 19/2024-Central Tax barred fresh requests for examination from 1 April 2025, but pending matters continue and are now decided by the Principal Bench of the GST Appellate Tribunal alone, under the second proviso to section 109(5). The Delhi High Court in Reckitt Benckiser upheld section 171 while rejecting the credit-to-turnover methodology for real estate, directing that project savings be divided by total area; that replacement was upheld in LICHFL Care Homes. Where recipients are identifiable, rule 133(3)(b) requires refund with eighteen per cent interest from the date of collection; where they are not, rule 133(3)(c) requires a Consumer Welfare Fund deposit with interest only from 28 June 2019. Penalty under section 171(3A) applies only to periods after 1 January 2020. An appeal from the Principal Bench lies to the Supreme Court under section 118(1)(a).

• Practice note · 2026-10-11

  Inside the Tribunal: What the GSTAT (Procedure) Rules, 2025 Require

  The Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025 were notified by G.S.R. 256(E) dated 24 April 2025 under section 111 of the CGST Act and came into force on publication. Rule 20 requires the appeal and every miscellaneous application to be typed in double spacing on A4, duly paged, indexed and tagged, with grounds numbered consecutively under distinct heads. Rule 21 requires a certified copy of the order appealed against and, where that order was passed in appeal or revision, of the original order as well. Rule 32 lets the Registrar require defects to be cured within a time not exceeding thirty days and reject the appeal if they are not. Rule 31 bars any ground outside the Form of appeal except by leave. Rule 29 routes every interlocutory application through GSTAT FORM-01 with a supporting affidavit, at a fee of Rs 5,000. Rule 103 requires the order to be pronounced not later than thirty days from the final hearing.

• Practice note · 2026-10-11

  When a GST Notice Lands: What the Act Gives You, and What the Notice Says

  A notice under section 61 must be answered in FORM GST ASMT-11, and section 61(3) allows thirty days or such further period as the proper officer permits. Rule 99(1) lets him ask for an explanation within a shorter time, so a five-day notice is not bad in itself, but he cannot move to section 65, 66, 67, 73, 74 or 74A until thirty days have run. A Full Bench of the Telangana High Court held on 30 September 2026 that a notice or order need not bear a visible digital signature, that uploading it on the common portal is valid service under section 169(1)(d) and that limitation runs from the date of upload, but that the absence of a DIN or RFN renders the document invalid. For periods up to the financial year 2023-24 the demand is made under section 73 or section 74; from the financial year 2024-25 onwards section 74A applies, and the pay-and-close window is sixty days rather than thirty.

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