The Interim Budget 2019 did not propose any changes with respect to Indirect Tax. In as much as GST is concerned, the GST Council in its 28th meeting held on July 21, 2018, recommended certain amendments in the CGST Act, IGST Act, UTGST Act and the GST (Compensation to States) Act, 2017. These amendments were passed by the Parliament and got published in the official Gazette of India on August 30, 2018, after receiving the assent of the Hon’ble President of India on August 29, 2018, as the CGST Amendment Act, 2018, IGST Amendment Act, 2018, UTGST Amendment Act, 2018 and the GST (Compensation to States) Amendment Act, 2018, respectively. Most of the amendments to the GST law passed by the Parliament in August 2018 took effect from February 1, 2019.
A pressing issue faced by the businesses and other stakeholders was that, earlier, the law as well as the GSTN portal accepted a single credit note and/or debit note against one invoice. However, assessees faced practical difficulties in issuing individual credit/ debit notes against individual invoices, more specifically in those industries, where a significant/ multiple levels of credit/debit notes are involved like pharmaceutical, auto component, etc.
Now, Section 34 of the CGST Act, 2017 (“the CGST Act”) has been amended to allow registered persons to issue consolidated credit/debit notes in respect of multiple invoices issued in a Financial Year. This will obviate the procedural difficulties faced by assessees at large, effective from February 1, 2019.
With this background, the present article discusses some insights in respect of the above amendment, its implications on business transactions and certain open issues still hanging unresolved, while also considering the latest circular of the CBIC in respect of tax treatment of various sales promotion schemes & discounts issued on March 7, 2019.