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Corporate News *  Service tax penalty can’t survive when assessee acted on dept.’s own view of non-taxability: Delhi High Court. *  GST section 74 extended limitation questionable when form 26AS mismatch was already known: Karnataka High Court grants interim relief. *  CGST demand prima facie impermissible after state GST settlement under section 128A: Bombay High Court. *  Supreme Court asks GSTAT to sympathetically consider delay as taxpayers pursued remedy before wrong forum. *  Supreme Court stays Tripura High Court ruling protecting genuine buyers from ITC denial over supplier’s GST default. *  Diary entries alone can’t prove clandestine removal of goods: CESTAT quashes excise penalty on steel trader. *  Customs could investigate preferential tariff claims even before sec. 28DA: Delhi High Court. *  Customs dept. relied on fake AI generated case laws: supreme court quashes Rs. 425.28 crore penalty. *  No GST exemption in affiliation and annual registration charges for admission or conduct Of examinations: GSTAT. *  Mere invoices, cheque payments insufficient to establish genuine movement of goods: GSTAT restores Rs. 43.44 lakh ITC demand. *  Consolidated GST show cause notice covering multiple financial years is not without jurisdiction: Delhi High Court. *  Construction of independent houses on separate plots not taxable as ‘Residential Complex’ without common facilities: CESTAT. *  GST penalty exceeding statutory maximum unsustainable; Allahabad High Court quashes ? 50,000/- penalty after taxpayer filed return and paid late fee. *  GST order against standard chartered bank passed without hearing set aside by Bombay High Court. *  Retracted statements can’t be relied upon without cross-examination: CESTAT quashes gold confiscation. *  Burden to prove misclassification lies on customs department: CESTAT. *  CESTAT quashes Rs. 98 lakh excise demand on clearance of used refractory brick scrap. *  Service tax demand on irrigation works quashed: Karnataka High Court rules sale of goods component not taxable as service. *  GSTAT restores tax and penalty for transporting iron scrap without E-way bill citing intent to evade tax. *  Madras High Court stays GST recovery from directors without opportunity to show cause under section 89. *  Madras high court stays GST recovery notice against directors; finds prima facie case on applicability of section 79(1)(c). *  Procedural lapses can’t justify harsh punishment without serious customs breach: CESTAT quashes customs broker licence revocation. *  Service tax payable on land leasing and sports complex charges: CESTAT. *  Settled customs dispute can’t be reopened through Article 226 challenge to interest liability: Delhi High Court. *  Mere facilitation of customs clearance can’t establish knowledge of smuggling: Madras High Court. *  GST registration cancellation stayed: Allahabad High Court questions 99% ITC utilisation cap under rule 86B. *  Composition scheme lapses automatically on crossing Rs. 1.5 crore turnover: GSTAT. *  Gujarat High Court quashes GST cancellation orders after officer relied on non-existent AI-generated case laws. *  Importers liable for customs duty benefits availed through manipulated scrips: Delhi High Court. *  Procedural E-way bill lapse alone can’t justify penalty where genuine transaction and absence of tax evasion are established: GSTAT.
Subject News *  Documentary evidence dominates probe, further custody unwarranted: mumbai court grants bail in Rs. 22.44 crore customs duty evasion case. *  Business premises can’t remain sealed for non-participation in GST search: Allahabad High Court. *  GST pre-deposit must be refunded proportionately when taxpayer partly succeeds in appeal: Bombay High Court. *  Supreme Court grants 30 days to file GST appeal; keeps pre-deposit issue open due to deposit in parallel CGST proceedings. *  GST demand can’t exceed amount proposed in SCN: Allahabad High Court quashes Rs. 20.47 Crore order. *  Hundreds-of-crores GST demand and heavy 10% pre-deposit no ground to bypass statutory appeal: Punjab & Haryana High Court. *  Delhi High Court refuses to entertain challenge to gold confiscation due to statutory appeal remedy and unexplained delay. *  Procedural error in customs broker licence inquiry can be rectified through remand: Delhi High Court. *  GSTR-2A mismatch alone can’t justify ITC denial without invoice-wise verification; personal hearing mandatory: GSTAT. *  GST order passed without uploading personal hearing notices violates sec. 75(4): Allahabad High Court. *  TAX EVASION - Sec. 74 GST SCN quashed for not spelling out fraud, wilful misstatement or suppression: Allahabad High Court. *  STPI’s SOFTEX certification and NoC charges taxable as business support services: CESTAT. *  Suspicion can’t replace proof: CESTAT quashes penalty in alleged gold-smuggling operation. *   Limitation runs from communication of order: Madras High Court upholds rejection of delayed GST Appeals. *  Rajasthan High Court quashes GST demand over unsigned show cause notice. *  ITC recovery upheld where supplier failed to deposit GST: Rajasthan High Court. *  Customs commissioner’s empowered to make port trust liable for duty on pilfered goods: Supreme Court. *  Rectification proceedings can’t be used to challenge an uncontested GST assessment through a writ petition: Andhra Pradesh HC. *  GST proceedings against deceased proprietor unsustainable without notice to legal heir: GSTAT. *  Mere availment of ineligible self-assessed ITC doesn’t amount to suppression without evidence of fraud or wilful misstatement: GSTAT. *  Disposal of mining overburden by entity authorised by mining lease holder constitutes taxable service: CESTAT. *  Toll plaza data not mandatory for ITC refund: GSTAT. *  Disputed GST fraud allegations require investigation: Punjab and Haryana High Court makes interim bail absolute in alleged fraud and GST fraud case. *  Non-manufacturer contractor liable to deposit excess excise duty collected from buyer: CESTAT. *  GST order can’t reject taxpayer’s reply as “not satisfactory” without reasons: Madhya Pradesh High Court. *  Uncorroborated statements can’t establish alleged diversion of duty-free goods: CESTAT. *  Erection services were not liable to service tax prior to 10th september 2004: CESTAT. *  Sec. 74 GST notice must spell out statutory ingredients for invoking extended tax demand proceedings: Allahabad High Court. *  No jurisdictional bar under section 6(2)(b) in parallel CGST SGST proceedings: Delhi High Court refuses to bypass GST appeal remedy. *  Madras High Court remits GST demand for fresh adjudication after taxpayer claims it was unaware of SCN following business closure.  

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GST UPDATE ON REQUIREMENT OF CREDIT REVERSAL ON SALE OF BUSINESS AS GOING CONCERN 98/2020-21

GST UPDATE ON REQUIREMENT OF CREDIT REVERSAL ON SALE OF BUSINESS AS GOING CONCERN 98/2020-21
In our earlier update no. 97/2020-21, we had discussed that sale of business as a ‘going concern’ is an exempt service in terms of serial no. 2 of the Notification No. 12/2017-Central Tax (Rate) dated  28.06.2017 and  consequently, the provisions contained in Rule 42 of the CGST Rules, 2017 would apply. We have received lot of messages regarding the issue raised by us and so we attempt to discuss this point in the present update.
 
If the definition of ‘exempt supply’ as given in section 2(47) of the CGST Act, 2017 is referred, it is found that it includes services which attracts nil rate of tax or which is wholly exempt from tax under section 11. Consequently, there is no doubt as regards the fact that the transfer of business by way of going concern is an exempted service. Furthermore, as per the amended CGST Act, 2017, Explanation to section 17(3), value of exempt supply shall not include the value of activities or transactions specified in Schedule III, except those specified in paragraph 5 of the said Schedule. Consequently, the only exception where provisions of credit reversal would not apply is transactions specified in Schedule III subject to paragraph 5. Hence, as per legal provisions in force, provisions of credit reversal as contained in Rule 42 would apply even in cases of transfer of business by way of going concern. It is understandable that this provision is very harsh and illogical but still the assessees need to abide by the same. Now, the next question arises is what will be the mechanism for computation of the credit reversal in such cases? Well, there is no express provision in this regard but we can infer that one may at the most require to reverse common credit availed in the tax period in which such transfer is taking place. However, this will lead to credit reversal at extremely higher side as the exempted value would be the transfer value whereas the denominator would be total turnover for the said tax period which is not at all justifiable. Hence, it is practically impossible to comply with the requirement of credit reversal in cases where business is transferred as going concern and so the government should either carve out exception in the explanation to section 17(3) of CGST Act, 2017 by including it in Schedule III to CGST Act, 2017 or provide mechanism for credit reversal, though it appears to be logically incorrect.  
 
In our opinion, there should not be requirement of complying with the credit reversal provisions in case of transfer of business as going concern but the interpretation of law indicates so. However, in this context, we wish to point out that there is no logic for requiring the transferor to reverse input tax credit as the transferee would be paying GST on the stock transferred or will use the machinery for supplying goods liable for GST. This situation can be very well co-related with the issue of credit reversal by job-worker in the erstwhile regime which was finally settled in favour of the assessee. In the erstwhile era, one of the common issue raised was requirement to reverse credit by the job-worker on clearance of job-worked goods as the said goods were not liable to central excise duty in terms of notification no. 214/86-CE. However, the matter reached upto High Court and was settled in the case of COMMISSIONER VERSUS STERLITE INDUSTRIES (I) LTD. [2009 (244) E.L.T. A89 (BOM)] wherein it was ruled that as far as central excise duty is being paid by the principal manufacturer and ultimately tax is being received by the government, there is no requirement for reversing credit by the job worker. We can contend that similar analogy applies in the present situation also because as far as the transferee is paying GST, the transferor should not be required to reverse credit, merely because the said transaction is exempted from levy of GST by way of exemption notification. We hope that the anomaly as pointed is considered by the government soon so that unwarranted litigation is not instigated by the department.

This is solely for educational purpose.
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