CBIC GST Circulars 207–222/2024: Detailed Analysis and Key Implications for Businesses

The Central Board of Indirect Tax & Customs (CBIC) has issued GST Circulars 207–222/2024 to clarify critical aspects of GST law, including valuation, input tax credit (ITC), place and time of supply, and sector-specific tax treatments. These circulars directly impact how businesses interpret GST provisions in areas prone to disputes—such as related-party transactions, RCM compliance, insurance taxation, and contractual arrangements.

This analysis provides a circular-wise breakdown of key clarifications, regulatory intent, and practical implications, enabling businesses to align their positions with current GST expectations and reduce compliance risk. For organizations managing complex tax structures, these updates should be evaluated alongside broader taxation advisory and direct tax frameworks to ensure consistency across tax positions.

Detailed Overview of CBIC GST Circulars 207–222/2024

To provide a consolidated view, the table below summarizes all circulars along with their core focus areas. This helps in quickly identifying the applicability of each clarification before moving into detailed analysis. The circulars broadly address litigation thresholds, ITC eligibility, valuation rules, place and time of supply, and sector-specific tax treatments, making them highly relevant across industries.

Analysis of the circulars are as below:

Circular No: 207/01/2024-GST:

Reduction of Government Litigation fixing monetary limits for filing appeals or applications by the department before GSTAT, High Courts and Supreme Court

GST council fixes the following monetary limits below which appeal or application or special leave petition as the case may be shall not be filed by the central tax officers before Goods and Service tax Appellate Tribunal (GSTAT), High Court and Supreme Court under the provisions of the CGST Act, subject to the exclusions.

While determining whether a case falls within the above monetary limits or not, the following principles are to be considered:

Exclusions: Monetary limits specified above for filing appeal or application or special leave petition by the department before GSTAT and High Court and for filing special leave petition or appeal before the Supreme Court shall be applicable in all cases except the following circumstances where the decision to file appeal shall be taken on merits irrespective of the said monetary limits.

1. Ultra vires rules or regulations or provisions and constitutional changes
2. Matters related to valuation, classification, refunds, place of supply of goods or services or other issues
3. Adverse comments or cost imposed against the government/department or their officers

Circular No: 208/02/2024-GST:

Clarifications on various issues pertaining to special procedure for the manufacturers of the specified commodities as per Notification No. 04/2024-Central Tax dated 05.01.2024

 Circular No: 209/03/2024-GST:

Clarifications on the provisions of clause (ca) of section 10(1) of the Integrated Goods & Service Tax Act, 2017 relating to place of supply of goods to unregistered persons 

 Circular No: 210/04/2024-GST:

Clarification on valuation of supply of import of services by a related person where recipient is eligible to full input tax credit

• The second proviso to rule 28(1) of CGST rules, is applicable in all the cases involving supply of goods or services or both between the distinct person as well as related persons, in case where the full ITC is available to the recipient. Accordingly, it is evident that the clarification which has been issued vide circular No. 199/11/2023-GST dated 17.07.2023 in respect of supplies of services between the distinct persons is equally applicable in respect of import of services between related persons.
• Therefore, it is clarified that in case where the foreign affiliate is providing certain services to the related domestic entity and where the full ITC is available to the related domestic entity, value of such supply of services declared in the invoice by the related domestic entity deemed as open market value in terms of second proviso to rule 28(1) of CGST rules.
• Where the full ITC is available to the recipient, if the invoice is not issued by the related domestic entity with respect to any service provided by the foreign affiliate to it, the value of such services may be deemed to be declared as NIL and may be deemed as open market value.

Circular No: 211/05/2024-GST:

Clarification on the time limit under Section 16(4) of CGST Act, 2017 in respect of RCM supplies received from unregistered persons.

• It is clarified that in case of supplies received from unregistered suppliers, where tax has to be paid by the recipient under Reverse Charge Mechanism (RCM) and where invoice is to be issued by the recipient of the supplies in accordance with section 31(3)(f) of CGST Act, the relevant financial year for calculation of time limit for availment of ITC under Section 16(4) of the CGST Act, 2017 will be the financial year in which the invoice has been issued by the recipient under Section 31(3)(f) of the CGST Act, 2017 subject to the payment of tax on the said supply by the recipient and fulfilment of other conditions and restrictions of Section 16 & 17 of the CGST Act, 2017
• If the recipient issues the invoice after the time of supply of the said supply and pay tax accordingly he will be required to pay interest on such delay payment of tax
• In cases of such delayed issuance of invoice by the recipient, he may also liable to penal action under the provision of Section 122 of the CGST Act, 2017

Circular No: 212/06/2024-GST:

Clarification on mechanism for providing evidence of compliance of conditions of Section 15(3)(b)(ii) of the CGST Act, 2017 by the suppliers

• Circular clarifies that till the time a facility is made available on the common portal to enable the suppliers as well as tax officers to verify whether the ITC attributable to such discounts offered through tax credit notes has been reversed by the recipient or not, the supplier may procure a certificate from the recipient of supply issued by the CA or CMA certifying that the recipient has made the required proportionate reversal of ITC at his end.
• Certificate issued by the CA or CMA shall contain Unique Document Identification Number (UDIN) and may include details such as details of credit notes, the details of relevant invoice number against which the said credit note has been issued, the amount of ITC reversal in respect of each of the said credit notes along with the details of Form GST DRC-03/return/other relevant document through which such reversal of ITC has been made by the recipient.
• In case tax involved in the post discount given by the supplier to a recipient through tax credit notes in a financial year is not exceeding Rs. 5 Lakhs, supplier may procure an undertaking/certificate from the recipient instead of CA or CMA certificate.
• Certificates issued by the CA/CMA/ Recipient shall be treated as a suitable and admissible evidence and supplier shall produce such certificate or undertakings before the tax officers if required during any proceedings such as scrutiny, audit investigation etc., even for the past period cases.

Circular No: 213/07/2024-GST:

Clarification on the taxability of ESOP/ESPP/RSU provided by a company to its employees through its overseas holding company

• Issuance of shares/securities as ESOP/ESPP/RSU by the foreign holding company to the employees of the domestic subsidiary company neither be treated as supply of goods nor supply of services because securities included shares under GST law are considered neither goods or services in terms of definition of “goods and services”. Accordingly, purchase or sale of shares/securities is neither a supply of goods nor a supply of services. Therefore, GST is not leviable on transaction of sale/purchase/transfer of securities/shares.
• The securities/ shares being issued as a part of remuneration of employee by the employer as per the terms of the employment falls outside the ambit of scope of supply as per Entry 1 of schedule III of the CGST Act, Therefore GST is not leviable on the compensation paid to the employee by the employer as per the terms of the employment contract.
• Where a foreign holding company directly transfer such shares/securities to the employees of the domestic subsidiary company and domestic subsidiary company reimburses an amount for such securities/shares on cost to cost basis i.e. without any additional fee, mark up or commission to the foreign holding co, then the said reimbursement for transfer of shares/securities cannot be treated as import of services by the domestic subsidiary company from the foreign holding company and hence is not liable to GST.
• If the foreign holding company charges any additional fees, mark up or commission for issuing the shares or securities it will be considered as supply of services and in such case GST will be payable by the domestic subsidiary company on a reverse charge basis.

Circular No: 214/08/2024-GST:

Clarification on the requirement of reversal of input tax credit in respect of the portion of the premium for life insurance policies which is not included in taxable value

• Life insurance business includes any unit linked insurance policy or scrips or any such instrument or units which provides a component of investment and a component of insurance issues by an insurer.
• As per Rule 32(4) of the CGST Rules, in case of life insurance policies, the value of supply is only that portion of the premium which is attributable to risk cover. Portion of the premium which is attributable to investment/savings is not included in the value and to be deducted from the gross premium.
• The amount of the premium which is not included in the taxable value cannot be treated as pertaining to a non-taxable or exempt supply and therefore there is no requirement of reversal of ITC as per provisions of Rule 42 or 43 of the CGST Rules.

 Circular No: 215/09/2024-GST:

Clarification on taxability of wreck and salvage value earmarked in the claim assessment of the damage caused to the motor vehicle.

Circular No: 216/10/2024-GST:

Clarification in respect of GST liability and input tax credit availability in cases involving warranty/extended warranty in furtherance to Circular No. 195/07/2023-GST dated 17.07.2023

• Circular No. 195/07/2023-GST dated 17.03.2023 clarifies regarding GST liability as well as liability to reverse ITC, only in cases involving replacement of ‘parts’ and not if goods as such are replaced under warranty. Request has been made to also issue a clarification in respect of cases where the goods as such are replaced under warranty. This circular also clarifies that the provision also applies when the entire goods are replaced under warranty.
• Clarification in respect of cases where the distributor replaces the parts/goods to the customer under warranty out of his own stock and then raises a requisition to the manufacturer for the goods or the parts as the case may be. The manufacturer then provides the said goods or parts to the distributor through a delivery challan without additional cost, no GST is payable on such replenishment further no reversal of ITc is required to be made by the manufacturer in respect of goods or parts so replenished to the distributor.
• Cases, where agreement for extended warranty is made at the time of original supply of goods and the supplier of extended warranty is different from the supplier of goods, the supply of extended warranty and supply of goods cannot be treated as the composite supply. In such case supply of extended warranty will be treated as a separate supply from the original supply of goods and;
• Where the supply of extended warranty is made subsequent to the original supply of goods or where the supply of extended warranty is to be treated as a separate supply from the original supply of goods then supply of extended warranty will be treated as a supply of services distinct from the original supply of goods, and the supplier of the said extended warranty shall be liable to discharge GST liability applicable on such supply of eservices.

Circular No: 217/11/2024-GST:

Entitlement of ITC by the insurance companies on the expenses incurred for repair of motor vehicles in case of reimbursement mode of insurance claim settlement.

Circular No: 218/12/2024-GST:

Clarification regarding taxability of the transactions of providing loan by an overseas affiliate to its Indian affiliate or by a person to a related person.

 Circular No: 219/13/2024-GST:

Clarification on availability of ITC on ducts and manholes used in the network of optical fiber cables (OFC) in terms of Section 17(5) of the CGST Act, 2017

Circular No: 220/14/2024-GST:

Clarification on place of supply applicable for custodial services provided by banks to Foreign Portfolio Investors (FPI)

Circular No: 221/15/2024-GST:

Clarification on time of supply in respect supply of services of construction of road and maintenance thereof of National Highway Projects of National Highways Authority of India (NHAI) in Hybrid Annuity Mode (HAM) model. 

 Circular No: 222/16/2024-GST:

Clarification on time of supply of services of spectrum usage and other similar services under GST.

Additional Resources

• Extension of various income tax due dates by CBDT
• Extension of time limits for income tax compliances
• Extension of timelines under Income Tax Act and Vivad se Vishwas
• Income tax assessment proceedings and timelines