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Implementation of provisions of GST Laws — Certain
challenges faced by registered persons — Clarification
Subject : Clarification in respect of certain challenges faced by the registered
persons in implementation of provisions of GST Laws - Regarding.
Circular No. 136/06/2020-GST, dated 3-4-2020 [2020 (35) G.S.T.L. C15]
and Circular No. 137/07/2020-GST, dated 13-4-2020 [2020 (35) G.S.T.L. C21] had
been issued to clarify doubts regarding relief measures taken by the Government
for facilitating taxpayers in meeting the compliance requirements under various
provisions of the Central Goods and Services Tax Act, 2017 (hereinafter referred
to as the “CGST Act”) on account of the measures taken to prevent the spread of
Novel Corona Virus (COVID-19). Post issuance of the said clarifications, certain
challenges being faced by taxpayers in adhering to the compliance requirements
under various other provisions of the CGST Act were brought to the notice of the
Board, and need to be clarified.
2. The issues raised have been examined and in order to ensure
uniformity in the implementation of the provisions of the law across the field
formations, the Board, in exercise of its powers conferred under section 168(1) of
the CGST Act hereby clarifies as under :
Sl. Issue Clarification
No.
Issues related to Insolvency and Bankruptcy Code, 2016
1. Notification No. 11/2020-Central Vide notification No. 39/2020-Central
Tax, dated 21-3-2020, issued under Tax, dated 5-5-2020, the time limit
section 148 of the CGST Act required for obtaining registration by
provided that an IRP/CIRP is the IRP/RP in terms of special
required to take a separate procedure prescribed vide
registration within 30 days of the notification No. 11/2020-Central Tax,
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