GSTR-1 IFF Amendment Tables for E-Commerce and Inverted Duty Structure Refund: GST Advisory and Case Law Update
This advisory covers two important developments in India’s indirect tax compliance landscape: a GSTN advisory on new amendment tables introduced in GSTR-1 and IFF for e-commerce transactions under GST Notification No. 26/2022-Central Tax and a significant judicial ruling clarifying the eligibility for Inverted Duty Structure (IDS) refunds under Section 54 of the CGST Act, 2017. Both updates carry direct compliance implications for registered taxpayers engaged in e-commerce supplies and those with accumulated unutilized input tax credit.
GSTN Advisory: New Amendment Tables 14A and 15A in GSTR-1 and IFF
What Has Changed and Why It Matters
As per Notification No. 26/2022-Central Tax dated 26th December 2022, GSTN has introduced two new amendment tables, Table 14A and Table 15A in GSTR-1 and the Invoice Furnishing Facility (IFF). These tables are designed to capture amendment details of supplies previously reported through e-commerce operators, where the operator is liable to collect or pay tax under the following:
- Section 52 of the CGST Act, 2017: governing Tax Collected at Source (TCS) by e-commerce operators on behalf of suppliers
- Section 9(5) of the CGST Act, 2017: where the e-commerce operator is directly liable to pay GST on specified services (such as passenger transport, accommodation, and restaurant services supplied through the platform)
Tables 14A and 15A are now live on the GST portal and are available in GSTR-1/IFF from the February 2024 tax period onwards. They are applicable specifically to taxpayers who have previously reported supplies in Table 14 or Table 15 in earlier tax periods and need to file amendments to those entries.
Key Highlights of GST Notification No. 26/2022-Central Tax
- Two new amendment tables 14A and 15A introduced in GSTR-1 and IFF
- Designed to enable accurate amendment reporting for e-commerce supplies where tax liability rests with the operator
- Applicable to taxpayers who have reported original entries in Table 14 (Section 52 supplies) or Table 15 (Section 9(5) supplies) in prior periods
- Effective from the February 2024 tax period onwards on the GST portal
Compliance Action Required for E-Commerce Suppliers and Operators
Taxpayers who supply goods or services through e-commerce platforms and whose transactions fall under Section 52 or Section 9(5) must review their GSTR-1 filing process to determine whether any previously reported entries in Tables 14 or 15 require amendment. Failure to correctly report amendments through the designated tables (14A or 15A) can result in mismatches in the tax data available to the department, potentially attracting scrutiny or demand proceedings.
Businesses operating in the e-commerce supply chain should verify that their GST reporting systems are updated to reflect these new tables. For detailed guidance, the official GSTN advisory is available at the following link: Read the full GSTR-1 IFF advisory on the GST portal.
Taxpayers who are uncertain about whether their e-commerce transactions fall under Section 52 or Section 9(5), or who require support in updating their filing processes, should seek guidance through an experienced GST advisory and compliance team before the next filing cycle.
Case Law Update: Inverted Duty Structure Refund Cannot Be Denied on Account of Prior Zero-Rated Refund
Facts of the Case: VSM Weavess India Pvt. Ltd. v. Assistant Commissioner
In VSM Weavess India (P) Ltd. v. Assistant Commissioner [Writ Petition Nos. 960, 964, and 968 of 2024], the petitioner was a textile manufacturer engaged in producing viscose fabrics (taxable at 5%) using viscose yarn as an input (taxable at 12%). This rate differential created a classic Inverted Duty Structure (IDS), where the GST rate on inputs exceeds the rate on the output supplied, resulting in the accumulation of unutilized input tax credit.
The petitioner had previously received a refund under IGST in connection with zero-rated supplies. Subsequently, the petitioner applied for a separate refund of unutilized ITC arising from the Inverted Duty Structure under Section 54 of the CGST Act, 2017. The Assistant Commissioner rejected this refund claim on the ground that since the petitioner had already claimed a refund pertaining to zero-rated supplies, a further IDS refund was not admissible.
Judicial Findings and Legal Principle Established
The Court held that the rejection of the IDS refund claim was legally untenable. Under Section 54 of the CGST Act, 2017, a registered taxpayer may claim a refund of unutilized ITC in two distinct and independent circumstances:
- Unutilised ITC accumulated on account of an Inverted Duty Structure refund claim, where the GST rate on inputs exceeds the rate on output supplies
- Zero-rated supplies made without payment of tax, where ITC on inputs remains unutilised
The Court confirmed that these are two separate and non-competing refund claims. A taxpayer who has availed a refund on zero-rated supplies is not thereby disentitled from also claiming a refund under the IDS provision. The two claims arise from different legal grounds under Section 54 and cannot be conflated or used to disqualify each other.
The Court directed that the petitioner be permitted to submit additional supporting documents and that the GST department must consider them, afford a reasonable opportunity of hearing, and pass a speaking and reasoned order on the refund application.
What This Judgment Means for Businesses Facing IDS Refund Rejections
This ruling has significant practical value for manufacturers and businesses operating in sectors where input tax rates exceed output rates, including textiles, construction materials, fertilizers, and certain pharmaceutical inputs. The principle established is clear: prior receipt of a zero-rated refund does not extinguish or bar a separate claim for IDS refund under Section 54. Businesses whose refund applications have been rejected on this or similar grounds should review their positions in light of this judgment.
Where refund rejections are being contested or departmental proceedings are pending, MBG’s indirect tax litigation team can assist in preparing representations, filing writ petitions where appropriate, and managing the full refund dispute resolution process.
Additional Resources
For further reading on related GST compliance developments, refund claims, and judicial updates, refer to the following MBG advisories: