Which GST changes in the Finance Act, 2026 are in force?
From 30 March 2026, the place of supply of an intermediary service is the location of the recipient. That is the GST change in the Finance Act, 2026 which is already in force. The Act’s changes to post-supply discounts and to refunds start only when the Central Government notifies them.
Not yet. Sections 153 and 154 of the Finance Act, 2026 make that change, and they start only on the date the Central Government notifies.
What changed for an intermediary?
Section 157 of the Finance Act, 2026 omits section 13(8)(b) of the IGST Act. Before 30 March 2026, the place of supply of an intermediary service was the location of the supplier. From that date, section 13(2) applies, so the place of supply is the location of the recipient. A supply to a recipient outside India can be an export of services when the other conditions are met, including receipt of the payment in the manner the Act allows, and the supplier and the recipient not being merely establishments of the same person. A supply by a foreign intermediary to a recipient in India can be an import. The change is not retrospective.
Which clauses are still waiting?
Sections 153, 154, and 155 of the Finance Act, 2026 are enacted and not yet commenced. Section 153 would let a discount given after the supply be excluded from the value where the supplier issues a credit note and the recipient reverses the input tax credit attributable to that discount. Section 154 would name that discount as a ground for the credit note. Section 155 would let a provisional refund cover unutilised credit from an inverted duty structure, and would take goods exported with payment of tax out of the minimum refund amount. None of those three sections applies until the notified date. A discount today still has to meet the conditions in the unamended section 15(3).
What changed for conflicting rulings?
Section 156 inserted section 101A(1A) with effect from 1 April 2026. Until the National Appellate Authority is constituted, the Central Government may, on the GST Council’s recommendation, notify an existing authority to hear an appeal against conflicting advance rulings of different states. That notification is separate from the section coming into force. An appeal against a single state’s ruling still goes to that state’s appellate authority, within 30 days, as the advance-ruling page states.
Where is the refund rule in force?
A provisional refund of up to 90 percent is the zero-rated case that section 54(6) already covers. Inverted duty is a refund case. It is not yet in that provisional rule. The claim, the two-year limit, and the form are on the refund page. Registration and the returns are on the registration page and the return page.
Frequently asked questions
Four questions cover discounts, inverted duty, an export, and the state appeal.
Are post-supply discounts already allowed without an earlier agreement?
Not yet. Sections 153 and 154 of the Finance Act, 2026 make that change, and they start only on the date the Central Government notifies. Until then, a discount still has to meet the conditions in the unamended section 15(3).
Does inverted duty already get a 90 percent provisional refund?
No. Section 155 would extend that provisional refund, and it is not yet in force. The provisional refund in force is the zero-rated case on the refund page.
Is every intermediary service now an export?
No. From 30 March 2026 the place of supply is the recipient’s location. The supply is an export only when the other export conditions are also met, including the place of supply being outside India and the payment being received as the Act requires.
Does the appellate authority in the state disappear?
No. An appeal against one state’s ruling still goes to that state’s appellate authority. Section 101A deals with conflicting rulings of different states, and the forum for that appeal still needs the government’s notification.
Sources
The Finance Act, 2026 received assent on 30 March 2026. Section 157 omits section 13(8)(b) of the IGST Act from that date. Sections 153 to 155 start on a date the Central Government notifies. Section 156 started on 1 April 2026.