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GST Update – Amendments vide Finance Act, 2026

Below is a summary of the major changes:

1. Post-Sale Discount – ITC Reversal Clarified

Section 15(3) & Section 34 amended (CGST Act)

  • Post-sale discounts will now be allowed only if linked to specific invoices through prior agreement.

Mandatory reversal of ITC by the recipient where a credit note is issued for such discounts.

  • Yet to be notified

2. Refund for Inverted Duty Structure

Section 54(6) & 54(14) amended (CGST Act)

  • Provisions extended to allow provisional refund in cases of inverted duty structure.
  • Restriction on refunds for goods exported under the duty payment route has been refined.
  • Yet to be notified

3. National Appellate Authority – Strengthened Framework

Section 101A amended (CGST Act)

  • Government empowered to transfer pending appeals to the National Appellate Authority.
  • Clarification that the Authority shall function as a Tribunal.
  • Effective from 1st April 2026.

4. Place of Supply for Intermediary Services

Section 13(8)(b) omitted (IGST Act)

  • POS for intermediary services will now be determined as per the general rule (location of recipient).
  • Major relief for exporters of services – reduces GST burden on cross-border intermediary services and now can apply for a refund of unutilized ITC.
  • Effective from 1st April 2026.