Wednesday, 31 August 2022

IGST on import of goods – ‘duty of customs’ or IGST

 


1. The case concerned classification of imported goods and application of IGST rate thereon. The customs officer went with the what a layman would do, trace goods into IGST rate notification and do the rest of the math (right or wrong)

2. But convinced with the argument that IGST unlike a revenue-based tax, is rather a set-off based tax, hence it should not be called as ‘duties of customs’ [para 9, 12]

3.  Sec. 3 (7) of the Customs Tariff Act is not an independent source of levy, but rather supporting (sub-servient) provision to Sec. 5 of the IGST Act [para 11]

4. Because the Import IGST is a tax under the IGST legislation, the power to assess rests with the ‘central tax officers’ to the exclusion of proper officers under the Customs Act [para 13]

   the argument has a good foundation, but most likely not survive in the sense that proviso to Sec. 5 (1) translates the entire mechanism for its collection under the Customs Act which should necessarily also translation of powers of assessment with the proper officers appointed under the Customs Act as well

5.The rate notification under the GST to be accommodated jointly with the Customs Tariff Schedule – this observation essentially strikes to the very core of residuary entry [S. No. 453 of Schedule] – to the extent that if goods are not classifiable under any of the CTH under the Tariff, then it is not taxable [para 15]

there are goods which are not classifiable under the Tariff at all, particularly those having short shelf life (e.g. hot iron, waste and scrap of wires/ cables) if this principle is accepted then, all these rare products would lose its taxability

6. Also worthwhile is to see how Expl. (iii) and (iv) are placed in GST rate notification. While clause (iv) apropos application of interpretation rules is limited if the same goes against interpretation otherwise discernible from the GST law [see the words ‘so far as may be’], however clause (iii) applies with full force i.e. it requires presence of a CTH in Tariff for rate notification to kick in.

7. Having come to terms that IGST levy is under IGST Act, the Tribunal cedes its jurisdiction to venture into the exercise of classification under IGST law. That said, the Tribunal still goes on to decide the list basis that it can rule upon the classification of ‘imported goods’, thus indirectly assuming jurisdiction over IGST law (loop) [13].

the contrary observations, firstly ceding the jurisdiction (source of law being IGST legislation), then indirectly assuming the jurisdiction (dialect of import of goods with Customs Act) is facially dichotomous.

8. The conclusion of the judgment appears to impact other similarly placed controversies as well such that only one GST is leviable on an SEZ to DTA supply (IGST under forward charge) but, this results perhaps does not marry with government’s intention to treat SEZ to DTA supply as import akin (see ya DESH Bill).

9. Also impacted is the Indigo (re-import) case, where Delhi Tribunal had held IGST not to be ‘duty of customs’ (the case is appealed before SC). This decision fuels the case in favour of assessee. Further, the reactive notifications and explanation may also be declared ultra vires. Further, interestingly the notification in order to expand the scope of taxability placed reliance on “GST Council’s decision”, this type of explanation sans the backing of sound law may not survive in the light of Mohit Minerals case. Overall, therefore the IGST levy on fair cost of repairs (of re-imports) is in serious doubt (for both pre-amendment period and post-amendment period).

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