GST WEEKLY UPDATE :27/2026-27 (04.10.2026) By CA Vipul Khandhar

Reading Time: 9 minutes

-By CA Vipul Khandhar

1. Simplified GST Expansion: Understanding the New “Multistate Registration” Facility:

On October 1, 2026, the Goods and Services Tax Network (GSTN) released an important advisory introducing the “Multistate Registration” facility on the common GST portal. Designed specifically for businesses operating across jurisdictional boundaries under a single Permanent Account Number (PAN), this feature streamlines multi-jurisdictional on boarding by eliminating redundant data entry.

Key Features & Core Mechanism

The new process replaces the traditional, state-by-state application workflow with a centralized, two-stage submission architecture:

[GST Common Portal]

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       ├── 1. Select Multiple States/UTs under same PAN

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       ├── 2. Generate Master TRN

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       ├── 3. Complete Common Registration Information (CRI)

       │      (Business details, Promoters/Partners, Authorized Signatories)

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       └── 4. Submit CRI within 15 Days

              │

              ├── Individual TRN (State A) ──► Add PPoB/APoB + Aadhaar Auth

              ├── Individual TRN (State B) ──► Add PPoB/APoB + Aadhaar Auth

              └── Individual TRN (State C) ──► Add PPoB/APoB + Aadhaar Auth

1. Unified Master TRN Generation

Taxpayers can navigate to the dedicated “Multistate Registration” tab on the homepage of the GST Common Portal and select all target States or Union Territories in a single session. This action generates a single Master Temporary Reference Number (TRN).

2. Common Registration Information (CRI)

Using the Master TRN, applicants complete the Common Registration Information (CRI) section. The CRI captures pan-India entity details that remain identical across jurisdictions:

• Core Business Details & Legal Entity Classification
• Promoter / Partner Information
• Authorized Signatories & Representatives
• Broad Categories of Goods and Services

Crucial Timeline: The applicant must submit the CRI using the Master TRN within 15 days of generation.

3. State-Specific Individual TRNs

Once the CRI is submitted, the portal automatically splits the master filing into individual TRNs for each selected State/UT.

• Common details from the CRI automatically pre-fill into each state application (and remain editable if state-level adjustments are required).
• The applicant completes the remaining state-specific compliance requirements for each TRN, including:
  • Principal Place of Business (PPoB) and Additional Places of Business (APoB)
  • State-specific registration details (e.g., Professional Tax, state-level licenses)
  • Aadhaar authentication for designated signatories

Current Scope & Operational Limitations

While a major step forward, the scope of this initial rollout is subject to specific criteria:

• Eligible Category: Currently restricted strictly to Normal Taxpayers. Special registrations (such as Casual Taxable Persons, Non-Resident Taxable Persons, Input Service Distributors, Tax Deductors/Collectors, or Composition Dealers) must continue to use their respective dedicated registration tracks.
• Single PAN Anchor: The workflow applies only to entities expanding operations under the same PAN.

Practical Takeaways for Practitioners and Taxpayers

1. Ease of Compliance: By removing the requirement to re-enter partner profiles, photos, identity proofs, and signatory authorizations for every state, the tool significantly reduces administrative burden and typographical errors.
2. Synchronized Documentation: Ensuring standardized CRI entry across all states minimizes internal discrepancies during initial assessments or subsequent verification procedures.

Action Required: Tax teams planning multi-state rollouts should gather all entity-level documents upfront to ensure the CRI is completed and submitted within the mandatory 15-day Master TRN validity period.

2. Overhauling Cross-Border Trade Compliance: A Deep Dive into RBI’s Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026:

Introduction

On January 13, 2026, the Reserve Bank of India (RBI) issued Notification No. FEMA 23(R)/2026-RB, promulgating the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. Effective from October 1, 2026, this regulatory framework supersedes the erstwhile Foreign Exchange Management (Export of Goods & Services) Regulations, 2015.

Subsequently amended on September 22, 2026 (via Notification No. FEMA 23(R)/(1)/2026-RB), the updated framework introduces significant structural changes, replaces legacy forms (such as SOFTEX), standardizes export declaration mechanisms across service providers, tightens realization windows, and expands the operational authority delegated to Authorised Dealer (AD) Banks.

Key Regulatory Highlights & Architectural Changes

1. Universal Export Declaration Framework (Regulation 3)

The regulations establish a unified process for reporting cross-border exports of both goods and services:

• Goods Exports: For electronic data interchange (EDI) ports, submission of the Shipping Bill acts as a deemed Export Declaration Form (EDF). For non-EDI ports, specified authorities must forward authenticated EDFs to the respective AD bank.
• Services & Software: Exporters of services (including IT, consulting, freelancing, and digital media) must submit an EDF to the specified authority within 30 days from the end of the month in which the invoice was issued.
• Consolidated Reporting: Exporters providing services to multiple recipients within a month are permitted to file a single consolidated EDF.
• Pre-payment Provisions: Service exports (excluding software) can file the EDF on or prior to the date of payment receipt. AD banks hold discretionary powers to extend filing deadlines upon reasonable justification.

[Service/Software Invoice Issued]

               │

               ▼

   (Filing within 30 days   from end of month)

               │

               ▼

    [Submit EDF to AD Bank]

               │

               ▼

[AD Bank Updates & Monitors in EDPMS]

               │

               ▼

[Realization & eBRC Reconciliation via DGFT]

2. Streamlined Realization & Repatriation Timelines (Regulation 5)

As amended in September 2026, the standard timeframes for realization and repatriation of full export proceeds are:

Transaction Type	Realization Timeline
Standard Goods & Services Exports	9 months from shipment date (goods) or invoice date (services).
Warehouse Exports Outside India	9 months from the date of sale of goods from the overseas warehouse.
Project Exports	Governed by specific contractual payment terms.
Invoiced/Settled in INR	Extended realization window of 12 months.

Note: AD banks are empowered to grant extensions beyond these periods upon evaluating valid grounds for delay.

3. De Minimis Thresholds & Simplified Closures (Regulations 4 & 6)

To promote ease of doing business for small-to-medium enterprises (SMEs), freelancers, and digital creators, self-declaration mechanisms have been introduced for low-value transactions:

• EDPMS / IDPMS Entry Closure: For individual shipping bills or invoices valued up to ₹10 lakh (or equivalent in foreign currency), AD banks can close or mark-off entries in EDPMS or IDPMS based on a simple self-declaration from the exporter or importer.
• Bulk Closures: Exporters and importers can submit these self-declarations to AD banks on a quarterly basis to facilitate bulk closure of outstanding entries.
• Reductions in Export Value: Reductions or under-realizations on export values up to ₹10 lakh can similarly be processed based on self-declarations.

Comparative Analysis: 2015 Framework vs. 2026 Regulations

Parameter	Erstwhile Regulations (FEMA 23(R)/2015-RB)	New Framework (FEMA 23(R)/2026-RB)
Standard Realization Window	9 months for goods; varied for services.	9 months uniformly across standard foreign currency exports of goods and services.
INR Settlement Realization	18 months.	Reduced to 12 months.
Software Reporting	Dedicated SOFTEX forms certified via STPI/SEZ nodes.	SOFTEX replaced/subsumed under the unified EDF mechanism handled via AD banks/STPI.
Low-Value Closures	Detailed documentary verification for closures.	Self-declaration threshold up to ₹10 lakh for EDPMS/IDPMS entries and bulk quarterly reporting.
Merchanting Trade (MTT)	Governed under separate Master Directions.	Integrated under Regulation 16; 6-month leg gap constraint retained.
Pre-2026 Historical Cases	Required RBI approvals for specific operational relaxations.	Regulation 20 delegates powers to AD Banks to handle legacy matters requiring erstwhile RBI approvals.

Detailed Examination of Operational Provisions

Set-Off and Third-Party Transactions (Regulations 7 & 8)

• Set-Off of Receivables/Payables: AD banks can permit the set-off of export receivables against import payables involving the same overseas entity or its group/associate entities within the permitted realization timeframe.
• Third-Party Receipts/Payments: Payments or receipts via third parties (entities other than the primary buyer/seller) are permitted provided the AD bank is satisfied with the bona fides of the underlying transaction.

Advance Payments & Unrealized Exports (Regulations 10, 12 & 13)

• Routing Consistency: Exporters and importers handling advance receipts or payments must route subsequent shipments and payments through the same AD bank, unless a formal change-of-bank notification is communicated to both institutions.
• Unrealized Exports Cautionary Rule: If export proceeds remain unrealized for more than one year past the due date (or approved extension), future exports by that entity must be executed exclusively against 100% advance payment or an irrevocable Letter of Credit (LC). Exporters on the Caution List as of September 30, 2026, remain governed by earlier orders until formally removed.

Merchanting Trade Transactions – MTT (Regulation 16)

Merchanting trade transactions are subject to strict structural conditions:

1. The timeframe between outward and inward remittances (or vice versa) must not exceed 6 months, unless extended by the AD bank.
2. Remittances must flow strictly between the designated overseas seller and buyer, with third-party variations subject to AD approval.
3. Both legs of the MTT must be logged, monitored, and updated simultaneously in EDPMS and IDPMS.

Institutional Mandates for AD Banks (Regulation 19)

To ensure smooth operational execution under this delegated framework, AD banks are mandated to formulate comprehensive, publicly disclosed Internal Policies and Standard Operating Procedures (SOPs). These policies must cover:

• Clear internal delegation of powers and explicit escalation/appeal mechanisms for customer grievance redressal.
• Transparent schedules listing processing timelines and documentation requirements.
• Prohibition on Unjust Penalties: AD banks are explicitly prohibited from levying charges or penalties on exporters, importers, or merchant traders for regulatory delays or violations. Charges must remain reasonable and directly proportional to the services provided.  

Practical Impact on Stakeholders

+————————————————————————-+

|                         STAKEHOLDER IMPACT                              |

+—————————-+——————————————–+

| Service Exporters          | Unified monthly EDF filing replaces        |

| & Digital Creators         | fragmented documentation; 30-day post-     |

|                            | month window simplifies compliance.        |

+—————————-+——————————————–+

| MSMEs & Small Traders      | Self-declaration up to ₹10 lakh reduces    |

|                            | administrative burden for small entries.   |

+—————————-+——————————————–+

| Corporate Treasuries       | Realization timelines reduced to 9 months; |

|                            | INR settlements standardized to 12 months. |

+—————————-+——————————————–+

| AD Banks                   | Enhanced operational authority coupled with|

|                            | strict compliance and SOP mandates.        |

+—————————-+——————————————–+

1. For Service Exporters, Consultants, and Content Creators

The inclusion of independent service providers, freelancers, and digital content creators within the structured EDF mechanism brings greater clarity to service exports. The ability to aggregate monthly service exports into a single EDF minimizes recurring filing overheads.

2. For MSMEs and High-Volume Businesses

The ₹10 lakh self-declaration threshold for EDPMS/IDPMS mark-offs provides substantial relief against administrative bottlenecks. Small businesses can streamline reconciliation through quarterly bulk declarations rather than managing individual entries manually.

3. For Corporate Treasuries and Trade Finance Operations

Finance teams must adjust cash flow models and collection cycles to align with the revised 9-month realization window for standard exports and the 12-month window for INR-denominated trade settlements. In addition, companies with outstanding legacy trade issues can resolve them directly with AD banks under delegated authority.

Conclusion

The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 represent a significant modernization of India’s cross-border trade administration. By replacing fragmented procedures with a unified declaration architecture, shifting routine approvals to AD banks, and establishing self-declaration thresholds, the RBI has created a more streamlined framework for global trade while maintaining regulatory oversight.

3. Mandatory Registry Intimation for Supplementary Applications Before the GSTAT:

On September 30, 2026, the Hyderabad Bench of the Goods and Services Tax Appellate Tribunal (GSTAT) issued Public Notice F. No. GSTAT/HYD/2/2026-27/Notifications, introducing an important procedural requirement for all pending litigations.

The directive mandates that litigants and legal representatives must provide a separate intimation to the Registry whenever an interim or supplementary application is filed in an ongoing appeal.

Scope of the Requirement

The public notice applies universally to all stakeholders appearing before the Tribunal, including:

• Taxpayers and Assessees
• Departmental Officers and Authorized Representatives
• Legal Counsel and Advocates

Affected Filings

The requirement covers all non-appeal applications filed during the pendency of a matter, including but not limited to:

• Miscellaneous Applications (MA): Applications for early hearing, condonation of delay, additional evidence, or modification of stay orders.
• Transfer Applications: Pleadings seeking transfer of proceedings across benches or jurisdictions.
• Withdrawal Applications: Requests seeking voluntary withdrawal of pending appeals or cross-objections.
• Rectification Applications: Filings under statutory provisions to rectify mistakes apparent from the record.

Authorisation letter: MH: This directive establishes strict compliance requirements for taxpayer representation during GST proceedings under Nodal Division-2, Pune (Maharashtra).

Core Requirements & Classifications

Representative Category	Authority Document	Applicable Law	Required Stamping
CA / CMA (ICWA) / GSTP / Relatives / Employees	Letter of Authority	Maharashtra Stamp Act, Sec 2(r)	₹500 Stamp Duty (treated as Power of Attorney)
Advocates / Bar Council Members	Letter of Authority / Vakalatnama	Maharashtra Court Fees Act	Court-Fee Stamp (Standard court fee rules apply)

Key Takeaways for Practice

• Strict Scrutiny: Proper Officers have been explicitly instructed not to take a lenient view. Submitting an unstamped or under-stamped Letter of Authority can lead to non-admissibility of the representation.
• Legal Basis: The directive relies on Section 116 of the CGST Act, 2017 (Authorised Representatives) read with Section 2(r) of the Maharashtra Stamp Act and the Supreme Court precedent in Uday Shankar Triyar v. Ram Kalewar Prasad Singh (AIR 2006 SC 269).

Action Required: Before attending hearings or submitting documents on behalf of clients in Pune Nodal Division-2, non-advocate representatives must ensure the Letter of Authority carries a ₹500 stamp duty.      

4. Surat diamond burse has been notified as SEZ:

The Central Board of Indirect Taxes & Customs (CBIC) issued Circular No. 44/2026-Customs approving the relocation and establishment of the new Special Notified Zone (SNZ) at the Surat Diamond Bourse.

Key Operational Framework & Compliance Highlights:Aspect	Operational Requirement	Relevant Provision / Guidelines
New Location	M/s Surat International Diatrade Centre (SIDC), 2nd Floor, Tower-B, SDB, Dream City, Khajod, Surat.	Relocated from Gujarat Hira Bourse (Ichhapore).
Permitted Cargo	Rough diamonds, industrial diamonds, pearls, synthetic/precious stones.	Notified under Sec 7, Customs Act, 1962.
Import Mode	Air Cargo Only. (Express courier & hand carriage prohibited).	Transhipped via Sahar Air Cargo Complex, Mumbai.
Permitted Activities	Viewing, tendering, auction, and negotiated sales.	RBI Circular No. 116 (2014) eligible mining entities.
Lot Rules	Lot-wise sales permitted; sub-lot sales and lot mixing prohibited.	Must be repacked within 60 days of import.
Domestic Clearance	Bill of Entry + Customs Assessment + Duty Payment + Out-of-Charge.	Valuation determined by Foreign Mining Co. Sale Invoice.
Unsold Lots	Re-exported under Shipping Bill within 75 days of import.	Transhipped back via Sahar Air Cargo Complex, Mumbai.
Transition Plan	De-notification of old Ichhapore SNZ to begin within 10 days of operationalization.	Zero interruption to ongoing rough diamond trading operations.

Operational Roadmap for Implementation

1. Section 8 & Section 45 Approvals: SIDC and SDB must submit finalized floor plans, structural layouts, and high-security infrastructure details to obtain Customs Area notification and formal Custodian appointment.
2. Written Operations Order: Operations can officially commence once the Principal Commissioner / Commissioner of Customs, Ahmedabad issues the final written authorization and trade notices.

Security & Visitor Access: GJEPC and SDB will issue photo identity cards to authorized trade participants based on access guidelines shared with Customs.

Disclaimer:

This publication contains information for general guidance only. It is not intended to address the circumstances of any particular individual or entity. Although the best of endeavour has been made to provide the provisions in a simpler and accurate form, there is no substitute to detailed research with regard to the specific situation of a particular individual or entity. We do not accept any responsibility for loss incurred by any person for acting or refraining to act as a result of any matter in this publication.