GST Updates – November 2025: What Changed & How to Comply
Effective month: November 2025 | Audience: MSMEs, exporters, service providers, distributors & accountants
Slide 1 – Executive Summary (Read This First)
- Provisional refunds @ 90% for eligible export/IDS claims using risk-based processing.
- Simplified Registration (optional) for low-risk / low-liability taxpayers with quick auto-approval.
- Intermediary services – place of supply shift to recipient location (impacting export status).
- Post-sale discounts: cleaner credit-note + ITC reversal mechanics; fewer disputes.
- Rate / exemption tweaks (salons & wellness, small hotels, biomedical waste, certain insurance, etc.).
Slide 2 – Provisional Refunds (90%) for Exports & IDS
What’s new: System risk-score drives 90% provisional sanction for eligible refunds; some categories may be notified as ineligible.
How to file (Step-by-Step)
- On the GST portal, file refund under Zero-Rated or Inverted Duty as applicable.
- Ensure KYC, returns, e-invoices & e-way bills are consistent to improve your risk score.
- Track status → watch for provisional 90% credit; retain complete documentation for post-sanction checks.
- If you fall in a notified “no-provisional” class, expect detailed scrutiny before sanction.
Slide 3 – Simplified Registration (Optional)
Who can consider: Low-risk applicants and businesses with B2B output tax ≤ ₹2.5 lakh / month (overall GST components).
Steps to adopt
- Go to Registration → New Registration and select Simplified Registration.
- Declare the low-liability threshold and attach clean KYC; avoid risky geotags/addresses with prior cancellations.
- Expect auto-approval within a few working days if risk flags are clear.
- Monitor turnover; you can switch out if your profile changes.
Slide 4 – Intermediary Services: Place of Supply = Recipient Location
What changes: Special rule for intermediaries is removed; default rule applies—place of supply is where the recipient is located.
Action Checklist
- Identify contracts involving arranging/marketing/facilitation.
- If the recipient is outside India, evaluate as export of services (subject to standard conditions).
- Update POS/invoice settings from the effective date; align LUT/IGST treatment accordingly.
- Maintain contracts/POs proving recipient location and independence of establishments.
Slide 5 – Post-Sale Discounts: Valuation & Credit Notes
What’s improved: Credit-note flow simplified; no need for rigid pre-supply discount linkage for every invoice in genuine commercial cases.
How to implement
- For value-reducing discounts, issue a GST credit note referencing the original invoice.
- Inform the recipient to reverse proportionate ITC where the taxable value is reduced via GST credit note.
- For purely financial/commercial payouts (no value change), issue financial CN without GST—no ITC reversal.
- Update ERP mappings: credit-note type, ITC reversal triggers, and sales schemes.
Slide 6 – Key Rate & Exemption Changes
| Sector / Service | Old Treatment | New Treatment (from notifications) | Immediate To-Dos |
|---|---|---|---|
| Beauty & physical well-being (SAC 99972) | 18% with ITC | 5% without ITC | Change POS/HSN mapping; train staff on no-ITC condition. |
| Hotel accommodation ≤ ₹7,500/day | 12% with ITC | 5% without ITC | Update booking engine; handle advances spanning the date. |
| Bio-medical waste treatment (to clinical establishments) | 12% with ITC | 5% with ITC | Revise rate cards; recheck contracts for tax-inclusive quotes. |
| Individual life/health insurance (incl. certain reinsurance) | Taxable | Exempt | Coordinate with insurers; ensure correct endorsement wording. |
Note: Apply final rates as per the specific notifications; adjust for “without ITC” restrictions wherever applicable.
Slide 7 – Tobacco/Pan Masala: RSP-Based Valuation
- Prepare systems for Retail-Sale-Price based valuation once rules/notifications issue.
- Synchronise with packaging vendors for MRP display; revisit pricing and abatement assumptions.
Slide 8 – November Compliance Checklist
- Refunds: File with full docs; reconcile outward supplies vs e-invoice/e-way bills; track 90% provisional credit.
- Registration: New/lite businesses—evaluate Simplified Registration; maintain risk-clean profile.
- Intermediaries: Mark eligible cross-border contracts as exports; update POS settings.
- Discounts: Route value-reducing schemes via GST credit notes; automate recipient ITC reversal communication.
- Rates: Update item/service masters; reissue price lists; train billing teams on “without ITC”.
Slide 9 – Mini Examples
A) Exporter (goods): Refund of unutilised ITC under zero-rated supplies filed on/after the effective date → expect provisional 90% if risk-clean; keep shipping bills, LUT & matching GSTR-1/2B ready.
B) Salon Chain: Rate moves to 5% without ITC → stop availing input credits on consumables; re-cost treatments accordingly.
C) Marketing intermediary to overseas principal: With recipient outside India, POS shifts outside India → evaluate supply as export; bill under LUT/IGST per your model.
Slide 10 – FAQs
1) Are changes automatic? They take effect through the formal notifications/circulars/Act amendments. Use the notified dates on invoices/credit notes.
2) What if a discount relates to old invoices? Use the credit-note mechanism applicable on the date of issue; align ITC reversal only when the credit note reduces taxable value.
3) How to improve refund risk score? Timely returns, reconciled e-invoices/e-way bills, consistent KYC/bank details, and avoidance of high-risk counterparties.
Slide 11 – Final Notes & Help
We’ll update this post as soon as notifications publish. Need a rate-change switch-over checklist or an ERP mapping sheet? Comment below and we’ll add downloadable templates.
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