Case Law Updates
Goods and Services Tax (GST)
§ Time Limit for Claiming Transitional Credit is only Procedural: Gujarat High Court
§ No GST on Duty Free Shops at Airports: Bombay High Court
§ 18% GST applicable on construction services provided to a landowner when the activity does not qualify as a ‘project’ under RERA: Karnataka AAR
Sales Tax / Service Tax
§ State Government cannot reduce / restrict benefits of the Package Scheme of Incentives after the introduction of GST, doctrine of promissory estoppel applies: Bombay High Court
§ No tax on services provided or sales made by a club to its members: Supreme Court
§ Normal loss during regasification process not to be construed as non-monetary consideration accruing to the service provider: CESTAT
§ An appeal can be filed against a self-assessed bill of entry: Supreme Court
§ Value of embedded software and fees for integration includible in the assessable value: Supreme Court
§ Demurrage charges not includible in the assessable value for customs valuation purposes: Orissa High Court
§ Clarification regarding process of claiming refund pursuant to a favourable order from an appellate forum
§ Clarification on payment of GST on Airport levies
§ Dues under FTP / FTD&R Act to be regarded as dues to the government for the purpose of proceedings before the NCLT
§ Notification deferring payment of GST on supply of construction service and development rights rescinded
§ Restriction on availment of Input Tax Credit on invoices not uploaded by supplier in GSTR-1
Goods and Services Tax
Two years of GST has seen unprecedented number of writs being filed in various High Courts and the Supreme Court. While the continuous efforts of the GST Council have laid to rest many contentious issues, the assesses have still sought judicial interventions. Courts, on their part, have also played a major role in streamlining the tax reform by pronouncing judgments that have greatly brought in much-needed clarity.
Independently, while the jury is still out on the effectiveness of Advance Ruling Authorities (AAR) and the Appellate Advance Ruling Authority since a few of the rulings have been challenged in the Courts, these rulings have certainly indicated the revenue authorities’ view and approach on certain significant issues. Thus, paving the road for further litigation.
Given the fact that Courts of the country are instrumental in shaping GST legislation, we have highlighted major judgements of the past three months with KCO’s analysis.
Time Limit for Claiming Transitional Credit is only Procedural: Gujarat High Court
In Siddharth Enterprises v Nodal Officer, the Gujarat High Court held that the due date provided under the Central Goods and Services Tax Rules, 2017 (CGST Rules) for the purposes of claiming transitional credit was procedural in nature and should not be construed as a mandatory provision. Accordingly, the Gujarat High Court directed the revenue authorities to allow filing of declaration in the relevant transition forms, so as to enable the petitioners to claim transitional credit of eligible duties in respect of inputs held in stock on 30 June 2017. The Gujarat High Court held that the assessee’s right to CENVAT credit had become absolute under the Central Excise Act, 1944 and as such was indefeasible. Further, the High Court regarded CENVAT Credit earned by the assessee as its ‘property’ and held that the assessee cannot be deprived of it without the authority of substantive (as opposed to procedural) legislation.
While High Courts across the country have recognized the assessee’s right to input tax credit in the GST regime and have appropriately intervened in cases where such right has been threatened or jeopardized without any fault of the assessees, this decision of the Gujarat High Court stands out on account of its extensive deliberation on the various facets of the aforesaid right. The Gujarat High Court, in express language, has stated that the due date for filing transition forms should not be construed as a mandatory provision. The judgement has been delivered on the heels of the judgement of the Madras High Court in the case of Tara Exports, wherein the Madras High Court had observed the time limit for filing the transition forms to be procedural in nature. However, the Madras High Court had clarified that the judgement had been delivered on the basis of peculiar facts and would not constitute a precedent.
Interestingly, the Gujarat High Court itself has, in the case of Willowood Chemicals and Jay Chemical Industries, held that the time limit for filing transition forms was of considerable importance and not merely a technical requirement. Moreover, the Bombay High Court in the case of JCB India had, in strict terms, laid down that the right to transition credit was not unconditional, indefeasible or absolute.
In view of the conflicting decisions, assessees are now left with no option but to wait for either the GST Council / Central Board of Indirect Taxes and Customs (CBIC) to proactively bring out concessions or for the Supreme Court to finally settle the conflict.
It may, however, be noted that the Gujarat High Court has stayed the operation of the present judgement since a review petition has been filed against it by the revenue authorities.
Education, Higher Education and Krishi Kalyan Cesses can be transitioned into GST: Madras High Court
In Sutherland Global Services v Assistant Commissioner, CGST and Central Excise & Ors., the High Court held that in the absence of express provisions declaring that the accumulated credit of education, higher education and Krishi Kalyan cesses shall lapse, credit of such cesses shall be allowed to be carried forward into the GST regime. The Court held that the transition provisions under GST which allowed an assessee to transition its CENVAT credit carried forward in the last returns filed, ought to be given full effect and meaning. In the context of education and higher education cesses, it was further held that since the revenue authorities had allowed assessees to carry forward accumulated credit of these cesses in their returns despite their withdrawal in 2015, these cesses represented accumulated CENVAT credit as on June 2017 and were accordingly eligible for transition.
The decision of the Madras High Court has laid down an important principle that tax credits do not lapse merely on account of loss of their fungibility, in the absence of express provision to the contrary. The Madras High Court, in its revised judgement, has observed that the amendment introduced by the CGST (Amendment) Act restricting the scope of section 140(1) only to “eligible duties” specified in the Explanation thereto, did not affect the provisions contained in section 140(8) of the CGST Act. Accordingly, cesses were held to be transition-eligible even in the context of the amended CGST Act. By analysing both the pre-amendment and post-amendment scenarios, the Madras High Court has settled the confusion surrounding transition of cesses and negated the effect of amendments introduced in the transitional provisions by the CGST (Amendment) Act.
No GST on Duty Free Shops at Airports: Bombay High Court
In Sandeep Patil v Union of India & Ors., the Bombay High Court held that supply by Duty Free Shops (DFS) at international airports to outbound passengers and up to 31 January 2019, to inbound passengers, would tantamount to “export” under the Integrated Goods and Services Tax Act, 2017 (IGST Act) and should therefore be zero-rated. The Bombay High Court further held that with effect from 1 February 2019, supply by DFS to inbound passengers would not constitute a “supply” in view of the amendment introduced by the CGST (Amendment) Act. Notwithstanding this, the High Court held that the refund of input tax credit will be allowed to DFS against sales made to outbound or inbound passengers. The Bombay High Court further observed that subjecting Indian DFS to local taxes would put them in a disadvantageous position compared to DFS elsewhere in the world and would consequently hamper the country’s foreign trade.
Sales made by DFS at international airports, by definition, ought to be free from taxes. Unfortunately, the GST law, as enacted, did not provide a precise answer to the question of taxability of sales made by DFS to inbound or outbound passengers. Prior to the decision, the Allahabad High Court in Atin Krishna had held that sales by DFS to outbound passengers would tantamount to “exports” within the meaning of the IGST Act, and those made to inbound passengers were not taxable up to 31 January 2019 i.e. prior to the amendment in Schedule III of the CGST Act. Further, the Bombay High Court in A1 Cuisines had held that sales made to inbound or outbound passengers by DFS were tantamount to a “non-taxable supply”.
Both the above decisions pointed to a situation where GST was not required to be charged on sales made by DFS. It may be noted that the guiding force in all the above decisions was the judgement of the Supreme Court in the case of Hotel Ashoka which inter alia held that DFS were situated outside the customs frontiers and sales made by them could not be taxed under the sales tax laws.
The present decision follows well established principles and corrects a major anomaly in GST which threatened to violate the fundamental purpose of establishing DFS. The controversy arising out of an adverse ruling issued by the AAR New Delhi in the case of ROD Retail on identical facts could be safely said to be put to rest consequent to these decisions.
Additional input tax credit benefit to be passed on to home buyers: NAA
The National Anti-profiteering Authority (NAA) in the case of Shri Hardev Singh & Ors. v M/s Ocean Seven Buildtech Pvt. Ltd., has upheld the claims for profiteering against the builder / developer and directed refund of additional Input Tax Credit (ITC) accrued in the GST regime to the homebuyers. The developer contended that the complaint made by the homebuyer does not stand as he did not pay the complete consideration for the unit. The NAA observed that although the complainant did not pay any amount post GST however, it noted that the buyers had to pay 5% of the total amount at the time of booking. Further, on comparing the ratios of the ITC / Turnover for the period prior to introduction of GST and post the introduction thereof, it observed that that it had increased from zero to 3.73%. The NAA thereby agreed with the investigation and Directorate General of Anti-profiteering (DGAP) report, consequently, directed refunds / adjustments to be made incorporating the interest @ 18% from the date of receipt of the amount by the developer. Moreover, the NAA further directed that since the investigation is only upto
31 August 2018, any ITC benefit accruing subsequently shall also be passed on to buyers by the developers.
This decision of the NAA follows on the heels of few other orders wherein the profiteering claims made against the real estate developers have been upheld. It appears from these decisions that the standard formula applied by the DGAP and the NAA for ascertaining profiteering is the comparison of the ratios of ITC over turnover for the pre-GST and GST period.
18% GST applicable on construction services provided to a landowner when the activity does not qualify as a ’project’ under RERA: AAR, Karnataka
The AAR, Karnataka, in the case of Teamview Developers LLP held that construction services provided to a landowner under a joint development agreement will attract GST at the rate of 18%, in a case where the development activity does not qualify to be a ‘project’ under Real Estate (Regulation and Development) Act, 2016 (RERA). In the aforesaid case, the developer entity was entitled to a part of the constructed property, which it had capitalised in its books of account since it was not intended for sale. The AAR, Karnataka observed that a construction activity not intended for sale would not qualify as a ‘project’ under RERA and consequently, the construction services carried out for the landowner would attract GST at the rate of 18% under the residuary entry. The AAR, Karnataka, further held that the developer entity would not be entitled to input tax credit of goods and services used for construction to the extent attributable to the developer entity’s share, since such construction was being carried out by the developer entity ‘on its own account’.
The new scheme of taxation introduced for the real estate sector with effect from 1 April 2019 accords primacy to ’projects registered under RERA’. Construction activities under a joint development agreement (JDA) not intended for sale or otherwise not required to be registered under RERA, do not qualify as ‘projects’ and are therefore not eligible for the concessional rates introduced under the new scheme. The ruling has brought in much-needed clarity in this regard.
Sales Tax / Service Tax
A few major rulings related to the erstwhile tax regime have put in place few basic principles of indirect tax that will have a far-reaching effect even on the current GST reform.
State Government cannot reduce / restrict benefits of the Package Scheme of Incentives post introduction of GST, doctrine of promissory estoppel applies: Bombay High Court
In K. M. Refineries and Infraspace Pvt. Ltd. v State of Maharashtra & Ors., the Bombay High Court held that the State Government cannot unilaterally reduce or tone down the benefits prescribed under the Package Scheme of Incentives, 1993 under the pretext of introduction of GST, being a new comprehensive system of indirect taxation. The Bombay High Court further held that any such action would be in violation of the doctrine of promissory estoppel and adversely affect the directive principle laid down in Article 39(c) of the Constitution of India. It was held that the State Government cannot be permitted to reduce or withdraw the benefits of the said scheme post implementation of GST, particularly since the Petitioner, relying upon the promises and assurances made by the State vide the said scheme, had opened a new industrial undertaking and incurred liabilities. The Bombay High Court directed the respondents to implement the said scheme without reducing or restricting any of its benefits but allowed them to modify it so as to make it consistent with the GST law.
This decision of the Bombay High Court is one of the first few decisions after the introduction of GST to give relief to several assessees who were affected by the changes made in the tax incentive schemes which would effectively reduce the benefits promised to them. While the principle of promissory estoppel has limited operation under tax law and there have been decisions in the erstwhile regime wherein the courts have granted relief, there was an apprehension that the Courts may take a divergent view. It is to be seen if this view is upheld by the other courts as well before whom petitions have been filed challenging the reduction of tax benefits / refunds under the central excise area-based exemption schemes and other state incentive schemes which offered remission from entertainment tax, value added tax, etc.
No tax on services provided or sales made by a club to its members: Supreme Court
In State of West Bengal & Ors. v Calcutta Club Limited, the Supreme Court, by according primacy to the doctrine of mutuality and its own judgement in the case of Young Men’s Indian Association, held that no sales tax could be levied on sales purported to be made by a club or association, whether or not incorporated, to its members. The Supreme Court held that though the 46th Constitutional Amendment and the relevant sales tax laws appeared to authorise levy of tax on supply of goods by any unincorporated association or body of persons to a member thereof for consideration, the same had not been achieved inasmuch as no sale could be said to have taken place between a club and its members owing to the doctrine of mutuality. The Supreme Court further held that the assumption of the legislature that clubs in an incorporated form were already amenable to sales tax even prior to the 46th Amendment was unfounded, since the doctrine of mutuality applied to such clubs also in equal measure. Even post the 46th Amendment, since the expression “body of persons” fell short of including bodies corporate within its scope, the Supreme Court held that incorporated clubs continued to remain outside the ambit of sales tax.
As regards applicability of service tax on the services purported to be rendered by clubs to its members, the Supreme Court held that the observations made in the context of sales tax, particularly the emphasis on the doctrine of mutuality and the case of Young Men’s Indian Association, would similarly apply. The Supreme Court finally held that the Finance Act, 1994 did not purport to levy service tax on clubs in the incorporated form.
The decision of the Supreme Court sheds significant light on the jurisprudence surrounding the doctrine of mutuality and clears the air on its applicability after the 46th Constitutional Amendment in the context of sales tax. With respect to taxability of sales or services purported to be made or provided by incorporated clubs to its members, the Supreme Court has unsettled the previously held notion that such transactions were subject to sales tax / service tax. The principles emanating from this landmark decision are likely to be equally applicable in the GST regime inasmuch as taxability of members’ clubs is concerned, on account of similarly enacted charging provisions.
Normal loss during regasification process not to be construed as non-monetary consideration accruing to the service provider: CESTAT
In Petronet LNG Limited v Principal Commissioner of Service Tax, Delhi-I, the CESTAT held that the Liquefied Natural Gas (LNG) which was lost during the process of regasification, cannot be regarded as non-monetary consideration accruing to the service provider. Consequently, no service tax could be demanded on such amount identified to be towards “allowed loss” (normal loss) in terms of the relevant agreement. The CESTAT held that the “allowed loss” effectively represented remittance of the performance of regasification, since such loss was unavoidable and was recognised internationally. The CESTAT further relied on the decision of the Apex Court in the case of Bhayana Builders to hold that the LNG lost or consumed in the process of regasification could not be regarded as “consideration” charged by the service provider.
Normal losses during processing are often unavoidable in nature and cannot be regarded as additional or non-monetary consideration accruing to the service provider. Conversely, such losses, due to their unavoidable nature, are inextricably linked to the performance of the obligation contemplated under the contract. The CESTAT, while accepting the aforesaid proposition, has done well to distinguish the amount received towards the provision of service (consideration) from the value of goods lost in processing.
An appeal can be filed against a self-assessed bill of entry: Supreme Court
In ITC Limited v Commissioner of Central Excise, Kolkata-IV, the Supreme Court held that a refund application under section 27 of the Customs Act, 1962 (Customs Act) would not lie directly against a self-assessed bill of entry, unless the “order of self-assessment” is first modified by an appellate authority. The Supreme Court further held that the endorsement made on the bill of entry is an “order of assessment”, since the term “assessment” includes “self-assessment”. Notwithstanding the fact that an endorsement on the bill of entry does not constitute a “speaking order”, the Supreme Court held that an appeal shall lie against the same.
Post introduction of the self-assessment regime in 2011, the proper officer of Customs was not required to pass a speaking order against every bill of entry. In the event of excess payment of duty, the importer was at a liberty to file a claim for refund, and such practice was accepted and acknowledged by the revenue authorities. The Supreme Court has upset this established practice by holding that a self-assessed bill of entry is an appealable “order”, and a refund claim against the same shall lie only if the bill of entry is challenged and modified in appeal. In doing so, the Apex Court has curiously relied upon the judgements delivered inter alia, in the case of Priya Blue and Flock (India), both of which pertained to the pre-2011 regime wherein the proper officer of Customs was required to pass an order of assessment prior to clearance of goods.
Value of embedded software and fees for integration includible in the assessable value: Supreme Court
In Indusind Media & Communications Ltd. v Commissioner of Customs, New Delhi, the Supreme Court held that the value of software embedded in the transmission equipment imported by the assessee, and the amount paid to the foreign supplier for carrying out integration of the said equipment were includible in the assessable value for customs valuation purposes. Further, the Supreme Court held that the components of equipment, even though imported individually, intended to contribute to a clearly defined function and would accordingly merit classification under the heading reserved for the transmission equipment itself and not under the headings reserved for the individual components.
In this particular case, the value of the goods physically presented, and the embedded software were declared in the same invoice. Considering the peculiar scenario, the Supreme Court upheld the view taken in the case of Toyota Kirloskar.
Demurrage charges not includible in the assessable value for customs valuation purposes: Orissa High Court
In M/s. Tata Steels Ltd. v Union of India & Ors., the Orissa High Court observed that though the Customs Act contained provisions for inclusion of various costs and expenditures such as royalties and licence fees, costs of transportation to the place of importation, insurance, etc. incurred by the importer in the assessable value of goods for valuation purposes, the Customs Act was silent with respect to inclusion of demurrage charges. However, the legislature sought to include demurrage charges in the assessable value of goods through an explanation inserted in the Customs Valuation Rules. The Orissa High Court relied on the settled principle that the rules are subordinate to the parent enactment and held that the relevant explanation was ultra vires the Customs Act and the Constitution of India and accordingly struck it down.
This decision clarifies the position after the amendment (insertion of Explanation to Rule 10) was introduced in the Customs Valuation Rules, 2007 which mandated the inclusion of demurrage charges in the assessable value of the imported goods. The decision of the Orissa High Court is consistent with the views take in the cases of Wipro Ltd., Mangalore Refinery & Petrochemicals Ltd., and Essar Steel Ltd. wherein the scope of the assessable value of the imported goods were examined closely to understand if such costs like demurrage, ullage and other similar charges would be excluded from the assessable value of the goods for the period prior to such amendment in 2007.
Circulars / Notifications / Orders
Clarification regarding process of claiming refund pursuant to a favourable order from an appellate forum
The CBIC has clarified that claimant has to file a fresh refund claim in form GST RFD-06 pursuant to such favourable order granting refund following rejection at the adjudication level. The disposal of the new refund application shall ensure re-credit of the amount of the input tax credit, the refund of which was rejected.
This settles the confusion prevalent in the trade regarding the process to be followed post receipt of orders in their refund claims which were being processed in an offline mode currently.
Clarification on payment of GST on Airport levies
The CBIC has clarified that airport operators (and not airlines) shall be liable to charge GST on the User Development Fee (UDF) and Passenger Service Fee (PSF) collected by airlines from passengers at the time of issuing tickets. It has been clarified that airlines act in the capacity of pure agents of airport operators and shall therefore exclude the component of UDF and PSF from the taxable value, while charging GST on the primary supply of transportation services.
This CBIC has provided clarity by keeping the aforesaid practice consistent with that followed under the erstwhile regime and has thus put to rest the confusion created by the seemingly wide scope of section 15 of the CGST Act, containing provisions for calculation of value of taxable supply.
Dues under FTP / FTD&R Act to be regarded as dues to the government for the purpose of proceedings before the NCLT
The Directorate General of Foreign Trade (DGFT) has instructed any company / firm coming under the adjudication proceedings before the NCLT to inform the concerned Regional Authority and the NCLT of any outstanding export obligations / liabilities under any of the schemes under Foreign Trade Policy (FTP). The DGFT has further clarified that the total outstanding duty saved amount / dues along with interest, and any penalty imposed under Foreign Trade (Development and Regulation) Act, 1992, (FRD&R Act) or any other dues, shall be counted as part of the dues to the government against the said firm / company.
The aforesaid instruction has ostensibly been issued in order to protect dues to the government under the FTP from getting extinguished in view of the limitation prescribed under the Insolvency and Bankruptcy Code, 2016.
Notification deferring payment of GST on supply of construction service and development rights rescinded
The CBIC, in January 2018, had issued a notification deferring payment of GST on supply of construction services by a developer and supply of development rights by a landowner until the date of transfer of possession or right in the complex or building (by way of a conveyance deed or an allotment letter). The CBIC has now clarified that the said notification shall not apply to development rights supplied on or after 1 April 2019.
The CBIC has apparently withdrawn the said notification in view of the new scheme of taxation introduced for the real estate sector with effect from 1 April 2019. The new scheme too, provides for deferred payment of GST on supply of construction services and development rights in certain situations.
It may however be noted that such deferred payment of GST is allowed exclusively for ‘projects registered under RERA’. Construction activities under a JDA not intended for sale or otherwise not required to be registered under RERA do not qualify as ‘projects’, and the liability to pay GST on supply of construction services and development rights in respect of such projects was hitherto deferred, on account of it being grandfathered by the said notification. Withdrawal of the said notification now implies that GST on the aforesaid supplies would be required to be discharged according to the ‘time of supply’ of the aforesaid supplies.
Restriction on availing Input Tax Credit on invoices not uploaded by supplier in GSTR-1
A registered person shall be allowed to avail ITC in respect of invoices not uploaded by suppliers in GSTR-1 subject to such ITC being up to 20 per cent of the ITC available in respect of invoices uploaded by suppliers in GSTR-1.
The CBIC has, by way of an amendment in the CGST Rules, limited the amount of ITC that an assessee can claim in respect of invoices not uploaded by suppliers in GSTR-1. However, such a restriction appears to be in conflict with section 41 of the CGST Act which entitles an assessee to claim the entire eligible ITC on a provisional basis. Further, no clarification has been provided with respect to (i) whether the restriction would apply to GSTR-1 filed for September 2019; and (ii) whether the limit of 20 per cent is required to be calculated for every return period or cumulatively from the beginning of a financial year.
The aforementioned Circular is expected to usher in a slew of writ petitions challenging the aforesaid restriction, with the Delhi High Court already having issued a notice to the Union of India in the case of Bharti Telemedia where the Petitioner had challenged the provision of the CGST Act restricting ITC to the recipient on account of non-payment of GST by the supplier.
It may, however, be noted that the Andhra Pradesh High Court in the case of Royal Sundaram General Insurance Company has already granted an interim stay in respect of a show cause notice issued by the revenue authorities for recovery of ITC on account of a mismatch in forms GSTR-3B and GSTR-2A.
§ Submission of annual return has been made optional for those registered persons whose aggregate turnover in financial years 2017-18 and 2018-19 has not exceeded INR 2 crores and who have not submitted the annual return so far.
§ The due date for submitting the annual return for the period July 2017 to March 2018 has been extended to 31 December 2019 and the due date for the period 1 April 2018 to 31 March 2019 has been extended to 31 March 2020.
§ CBIC has simplified filing of Annual Return and Reconciliation Statement by notifying CGST (seventh amendment) Rules, 2019 which will take effect from the date of publication in the Gazette. Few salient points are as follows:
- Relaxation in reporting the breakup of ITC as inputs, capital goods and input services or reporting the entire consolidated ITC under the “inputs” row,
- Relaxation in reporting the supplies as exempted, nil rated, non-GST supply separately or reporting consolidated information in “exempted” row only,
- In case of any difficulty filling of Table 4B to 4E and Table 5A to 5F by declaring the amendments / debit / credit notes separately, then these tables can be filled as net of amendments/debit/credit notes as required
- Relaxation for HSN level information of outputs or inputs for inward supplies.
§ The due dates for submitting Forms GST TRAN-1 and GST TRAN-2 in respect of registered persons who could not submit the said form by the original due date on account of technical difficulties on the GSTN common portal and whose cases have been recommended by the GST Council, have been extended to 31 December 2019 and 31 January 2020 respectively.
§ Procedure regarding: (i) export of imported Special Chemicals, Organisms, Materials, Equipment and Technologies (SCOMET) items for repair / replacement and (ii) re-export of indigenous SCOMET items after repair / replacement, has been revised by amending the Handbook of Procedures of Foreign Trade Policy 2015-20.
 Writ Petition No. 4773 of 2018
 Writ Petition No. 2209 of 2018 (Nagpur Bench)
 Case No. 55/2019 dated 5 November 2019
 Advance Ruling No. KAR ADRG 104/2019 dated 30 September 2019
 2007 (213) ELT 4 (SC)
 2015 (319) ELT 177 (SC)
 2015 (325) ELT 214 (SC)
 2015 (319) ELT 202 (SC)
 Circular No. 111/30/2019 – GST dated 3 October 2019
 Circular No. 115/34/2019-GST dated 11 October 2019
 Notification No. 25/2015-2020 dated 18 October 2019
 Notification No. 4/2018-Central Tax (Rate) dated 25 January 2018
 Notification No. 23/2019-Central Tax (Rate) dated 30 September 2019
 Notification No. 6/2019-Central Tax (Rate) dated 29 March 2019
 Notification No. 49/2019-Central Tax dated 9 October 2019
 Writ Petition No. 11997 of 2019
 Notification No. 49/2019-Central Tax dated 9 October 2019
 Order No. 8/2019-Central Tax dated 14 November 2019
 Notification No. 56/2019-Central Tax dated 14 November 2019
 Notification No. 49/2019-Central Tax dated 9 October 2019
 Public Notice No. 36/2015-20 dated 27 September 2019