India's Goods and Services Tax regime replaced seventeen different indirect taxes with a single framework — and created, in doing so, the largest indirect tax litigation wave the country has ever seen. Classification disputes are endemic. Input Tax Credit eligibility is contested on transactions that every business considered settled. The reverse charge mechanism catches businesses by surprise. Transitional credits from the pre-GST era remain unresolved in GSTAT proceedings that have only recently commenced sitting. And the GST Appellate Tribunal — GSTAT — whose formation was delayed for years, is now hearing appeals that date back to 2017.
Goldschmidt Pallonji's GST practice is built on the same structural principle as our Direct Tax practice — Chartered Accountants and GST lawyers working together from the first instruction. A classification dispute requires financial analysis of the transaction, legal analysis of the HSN/SAC code, and an understanding of the GST Council's intent when the rate was set. None of those three analyses is sufficient on its own. GP provides all three simultaneously.
For international businesses entering India — or Indian businesses with cross-border supply chains — the GST dimension is particularly complex. The place of supply rules for services, the treatment of intermediary services, the import of services under reverse charge, and the zero-rating of exports all require advice that integrates Indian GST law with an understanding of the counterparty's jurisdiction. GP's five international corridors provide that integrated perspective for Australia, Singapore, GCC, Hong Kong, and UK-sourced transactions.
Advisory, compliance, and litigation across the full GST framework — from structuring a supply chain to arguing a classification dispute before the Supreme Court.
Pre-transaction GST analysis for M&A, business restructurings, and new supply chain models. Classification of goods and services under HSN/SAC, rate determination, and place of supply analysis for complex multi-state transactions. GST implications of cross-border supply arrangements — import of services, intermediary characterisation, and zero-rating eligibility for exports. Supply chain redesign to optimise ITC flow and minimise GST cost.
Learn More →ITC eligibility analysis under Section 16 and 17 of the CGST Act — blocked credits, proportionate credits, and reversal requirements. ITC reconciliation between GSTR-2A/2B and books of accounts. Recovery of ITC incorrectly denied by the Department. Defence against ITC reversal demands arising from supplier defaults, GSTR mismatches, and the amended Section 16(4) limitation. ITC on capital goods, construction, and employee benefits.
Learn More →Response to GST show-cause notices — classification disputes, ITC demands, reverse charge demands, and penalty proceedings. Representation before the Adjudicating Authority and the GST Appellate Authority. GSTAT appeals for matters where the Appellate Authority order is challenged. High Court writ petitions where the statutory appeal remedy is inadequate or where constitutional issues arise. Pre-deposit strategy and stay applications to manage cash flow during appeals.
Learn More →Applications before the Authority for Advance Ruling (AAR) and the Appellate Authority for Advance Ruling (AAAR) for binding determinations on classification, rate, ITC eligibility, and place of supply — before a transaction is entered into. Strategy and drafting of AAR applications for maximum binding effect. Challenge of unfavourable AAR orders before the AAAR and, where constitutional issues arise, before the High Court.
Learn More →GST on import of services under reverse charge — applicability, valuation, and compliance for Indian recipients of international services. Export of services — conditions for zero-rating, LUT/bond procedures, and recovery of accumulated ITC. Customs duty classification and valuation disputes. Anti-dumping and safeguard duty advisory. IGST on imports and the interface between Customs Act and GST on cross-border transactions for Australian, Singapore, GCC, and UK counterparties.
Learn More →GST for e-commerce operators under Section 9(5) — TCS obligations, supplier compliance, and platform liability. GST on virtual digital assets, cryptocurrency transactions, and NFTs — classification and rate disputes following the 2022 amendments. Online gaming — the 28% GST on actionable claims, the retroactive demand controversy, and the Supreme Court reference. OIDAR services — taxability of digital services supplied by foreign companies to Indian consumers.
Learn More →When GST replaced the pre-GST indirect tax regime in 2017, businesses were entitled to carry forward their CENVAT credit and VAT credits as opening ITC under TRAN-1 and TRAN-2. The Department disputed many of these transitional credit claims — on procedural grounds, on the basis of system errors, and on substantive eligibility. The Supreme Court in Filco Trade Centre allowed revision of TRAN-1 filings. GSTAT is now hearing the residual disputes. Businesses with unresolved transitional credit claims — some running to crores — need to act now before GSTAT procedures become established against them.
The 2019 amendments to GST on real estate — the shift from 12%/8% with ITC to 5%/1% without ITC — produced a compliance crisis for developers with ongoing projects. Works contract services, joint development arrangements, and the GST treatment of land value in under-construction property remain actively litigated. GP's real estate and GST practices work together to advise developers on the classification of development activities, the ITC position on commercial vs residential projects, and the correct GST treatment of JDA consideration.
A GST inspection under Section 67, a search under Section 67(2), or a summons under Section 70 is the beginning of what can become a multi-year dispute. The statements made by your employees during an inspection are admissible. The documents removed from your premises during a search can form the basis of a demand that runs to crores. GP's response to a GST inspection combines the financial discipline of our CA team — who understand immediately what the inspector is looking for — with the legal strategy of our litigation team, who understand what the inspector is entitled to see and what must be challenged from the first hour.
Most GST disputes reach a lawyer only after the CA has already filed GSTR returns, responded to preliminary notices, and made statements to the Department. By that point, the legal position has been shaped — sometimes adversely — by decisions made without legal advice. At GP, the lawyer is involved from the first notice, the first inspection, and the first AAR application. The financial analysis and the legal strategy are built together, not reconciled after the fact.
The opening of GSTAT has caught many businesses unprepared — their appeals were filed years ago, the files are incomplete, and the legal arguments were never developed beyond the appellate authority response. GP has been preparing GSTAT-quality briefs since 2022. For clients who come to us with legacy GST disputes, our first task is a GSTAT readiness audit — assessing the strength of the existing record and rebuilding it where necessary before the tribunal hearings begin.
For Australian companies paying for Indian services, GCC businesses receiving Indian IT support, or Singapore entities in back-to-back service arrangements with Indian entities — the India GST position cannot be advised without understanding the counterparty's tax position in their own jurisdiction. GP's founding directors have practised in each of these jurisdictions. The advice we give on the Indian GST treatment of a cross-border transaction is informed by what is happening on the other side of the invoice — not just on the Indian side.
Complete confidentiality maintained. These matters illustrate the nature and depth of our GST practice.
Represented a listed manufacturing company in a ₹18 crore ITC reversal demand arising from GSTR-2A mismatches with seventeen suppliers whose GST registrations were cancelled retrospectively. Built the defence on the constitutional validity of retrospective ITC denial on a recipient who had no knowledge of the supplier's default. Secured a stay of demand pending GSTAT hearing. GSTAT brief filed and listed — matter ongoing with favourable interim position maintained.
The Indian subsidiary of a Singapore technology company was exporting software support services to the Singapore parent — claiming zero-rating as an export of services. The Department reclassified the subsidiary as an intermediary, denying zero-rating and raising a ₹9.4 crore demand on services billed over three years. GP coordinated the Indian GST defence with an analysis of the Singapore GST treatment of the same services — demonstrating that the economic substance of the arrangement was a direct service export, not intermediary facilitation. High Court petition filed challenging the intermediary classification. Stay obtained.
Advised a mid-size real estate developer on the GST treatment of a joint development arrangement where the landowner received constructed units in exchange for land. Obtained an AAR ruling on the classification of the developer's supply, the valuation methodology for the in-kind consideration, and the ITC eligibility on construction inputs for the residential component. The ruling avoided a ₹12 crore demand that the Department had proposed in a pre-notice consultation — and provided the developer with a binding position for all future JDA transactions on the same model.
The practice is led by a senior indirect tax lawyer with specific experience in GSTAT and High Court GST matters, working alongside a CA with deep experience in GST compliance, ITC reconciliation, and audit defence. The team also includes former indirect tax officials who understand the Department's investigation methodology and decision-making process — the same intelligence that shapes our defence strategy from the first show-cause notice.
The GST practice works in constant coordination with our Direct Tax team — because many of the most consequential GST disputes also have income tax dimensions — and with our Real Estate, Banking, and Startup practices where GST compliance is integral to the commercial transaction being structured.
The GST Appellate Tribunal is now operational. This bulletin sets out the appeal process, the pre-deposit requirements, the timeline for listing, and the immediate steps every business with a stayed or pending GST dispute must take to protect their position.
Read Bulletin →Import of services, reverse charge, zero-rating of exports, and the intermediary classification trap — explained for Australian and GCC businesses contracting with Indian service providers or establishing Indian operations.
Read Guide →Whether you have received a GST show-cause notice, are facing an ITC reversal demand, need to file a GSTAT appeal, or want an AAR ruling before entering a complex transaction — our CA and lawyer team responds within 24 hours.
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