8 Nov 2026

GST Compliance After the 56th Council: Simplified Registration, Provisional Refunds and the Appellate Tribunal

GST · Small Businesses, Exporters & Litigants

Who this affects: new applicants for GST registration, exporters, businesses with inverted duty structures, and anyone with a pending GST appeal.

Simplified registration

Per the Council's recommendations, a simplified scheme operates from 1 November 2025 for low-risk applicants whose output tax liability does not exceed Rs 2.5 lakh per month. Registration is to be granted automatically within 3 days. The scheme is voluntary. Check the notifications and the portal functionality before relying on the 3-day timeline for a client.

Refunds

Appellate Tribunal (GSTAT)

The Council indicated that GSTAT would accept appeals by the end of September 2025, begin hearings by the end of December 2025, and allow backlog appeals up to 30 June 2026. If you hold an order that was appealable earlier, confirm that the appeal was filed within the window.

Post-sale discounts and intermediary services

The Council recommended removing the requirement of a pre-existing agreement for post-sale discounts and allowing the discount to pass through a credit note under Section 34, with a clarification that the recipient need not reverse ITC for such discounts. It also recommended omitting Section 13(8)(b) of the IGST Act, which fixed the place of supply of intermediary services at the supplier's location.

Caveat

Some of these items are Council recommendations that need law amendments, rules or circulars to take effect. Always confirm the status of each item in the current CBIC notification before advising.

Sources and verification

Verified on 8 Nov 2026 against the sources below. Laws and notifications change, so confirm the current position before acting.

Need this applied to your business? Talk to CA Nimesh Hariya about your virtual CFO and compliance needs.

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