Finance Act 2026 Just Changed GST: Every CGST Amendment Explained Section by Section

Section	What It Touches	Status
15(3)(b)	Post-sale discount rules	Awaiting notification
34	Credit notes tied to ITC reversal	Awaiting notification
38	GSTR-2B / ITC statement wording	Awaiting notification
54(6)	Provisional refunds, inverted duty structure	Awaiting notification
54(14)	Refund threshold on exports removed	Awaiting notification
101A	Interim appellate authority	In force from 1 April 2026
107 & 112	Pre-deposit on penalty-only appeals	Awaiting notification
122B (new)	Track and Trace penalty	Awaiting notification
13(8)(b), IGST Act	Intermediary services, place of supply	Awaiting notification

Why This Matters — Before vs After:
 

Section 34: The Credit Note Now Carries the ITC Reversal Obligation

Since Section 15 leans on Section 34 to make discounts valid, this section got a matching update. It now spells out that when a supplier cuts their tax liability through a credit note, the recipient has to reverse the equivalent ITC.

Things to Remember:

1.) Sounds like a technicality, but it shifts real operational weight onto buyers

2.) You'll need to track and act on credit notes through the Invoice Management System (IMS)

3.) Letting credit notes sit unacknowledged is no longer a safe default

Section 38: GSTR-2B Might Not Stay Fully Automatic

Easy to miss, but worth flagging: the word "autogenerated" has been dropped from how the law describes your ITC statement, what most of us just call GSTR-2B. A new clause also gives the government room to add extra details to that statement through future rules.

Practically, this signals a move away from "trust whatever the portal shows you" toward "reconcile it yourself through IMS." If your finance team has been treating GSTR-2B as gospel, that habit may need to change.

Section 54(6): Inverted Duty Structure Refunds Get the Fast-Track Treatment

Exporters have long had access to 90% provisional refunds on zero-rated supplies. Businesses stuck with an inverted duty structure where GST paid on inputs is higher than GST charged on output, never got that same speed. They're getting it now.

What Matters Most:

1) 90% provisional refund now applies to inverted duty structure claims too

2) Brings parity with the treatment zero-rated exports already enjoyed

3) Biggest relief for sectors hit by last year's rate rationalisation, where inputs still cost more in GST than the finished product

Section 54(14): The ₹1,000 Refund Threshold Disappears for Export Refunds

Small exporters shipping through courier or postal channels have run into a frustrating rule for years: refunds below ₹1,000 simply weren't processed. For a business exporting in small, frequent consignments, those amounts add up and just sit unclaimed.

That threshold is now removed but only for refunds on exports made with payment of tax. Every other refund category still has the ₹1,000 floor.

Section 101A: The Only Change Already in Force

Everything else on this list is waiting for a notification date. This one isn't. From 1 April 2026, a new sub-section (1A) lets the government authorise an existing tribunal to hear appeals under Section 101B, the ones arising from conflicting Advance Rulings between states.

Before You Start Filing an Appeal, Know This:

1.) The law always envisioned a National Appellate Authority handling these disputes, but it was never set up

2.) Appeals had nowhere to go until now

3.) An existing tribunal can step in temporarily, and the law explicitly confirms "existing Authority" includes a Tribunal

Sections 107 & 112: Appealing a Penalty Now Costs You 10% Upfront

If your appeal is purely about a penalty, no tax demand attached, you'll now need to put down a 10% pre-deposit before the Appellate Authority (Section 107) or the Appellate Tribunal (Section 112) will hear it. Previously, penalty-only appeals had no deposit requirement at all.

Worth budgeting for if you're planning to contest a penalty order , it's a cash outflow you didn't need to plan for before.

Section 122B: A Brand-New Penalty for Track and Trace Violations

This isn't an amendment to an existing section, it's an entirely new one. It creates penalties specifically for non-compliance with the Track and Trace Mechanism under Section 148A, which applies to certain notified goods considered high-risk for tax evasion. If your business deals in anything covered by that mechanism, this is one to get ahead of.

Section 13(8)(b), IGST Act: A Big Win for Service Exporters

Technically an IGST Act amendment, but it belongs on this list because of how much it changes for intermediary service providers : IT back-offices, consulting firms, marketing agencies arranging deals for overseas clients. The old rule fixed their place of supply at the supplier's location, which meant 18% GST applied even when the client sat entirely overseas.

Essential Information:

1.) Place of supply now follows the general rule under Section 13(2) - (the recipient's location)

2.) Genuine service exports to foreign clients can qualify as zero-rated

3.) Full ITC stays intact on those export supplies