Law of Taxation
Subjects / Law of Taxation / Introduction and Background of GST
Unit 4 · Unit 4

Introduction and Background of GST

Goods and Services Tax (GST) is a comprehensive, multi-stage, destination-based indirect tax levied on every value addition in the supply chain.

Goods and Services Tax (GST) is a comprehensive, multi-stage, destination-based indirect tax levied on every value addition in the supply chain. Introduced on 1 July 2017 through the 101st Constitutional Amendment, it replaced over 17 Central and State indirect taxes with a unified tax structure under the principle of "One Nation, One Tax."

Legal Framework

Provision Content
Art.246A Special provision: both Parliament and State Legislatures have power to levy GST
Art.269A Levy and collection of IGST on inter-state supply
Art.279A Constitution of GST Council
CGST Act, 2017 Central Goods and Services Tax (intra-state, Central component)
SGST Acts State Goods and Services Tax (intra-state, State component)
IGST Act, 2017 Integrated Goods and Services Tax (inter-state supply)
UTGST Act, 2017 Union Territory GST (for UTs without legislature)
GST (Compensation to States) Act, 2017 Compensation for revenue loss to States (5 years, expired June 2022)

Historical Background

Year Development
2000 Vajpayee Government constitutes Empowered Committee under Asim Dasgupta
2003 Kelkar Task Force recommends GST
2006 Finance Minister announces GST introduction target: April 2010
2011 115th Constitutional Amendment Bill introduced (lapsed)
2014 122nd Constitutional Amendment Bill introduced
2016 101st Constitutional Amendment Act passed (8 September 2016)
2017 GST rolled out on midnight of 1 July 2017

Taxes Subsumed Under GST

Central taxes subsumed State taxes subsumed
Central Excise Duty State VAT / Sales Tax
Additional Excise Duties Purchase Tax
Service Tax Entry Tax (all forms)
Countervailing Duty (CVD) Luxury Tax
Special Additional Duty (SAD) Entertainment Tax (except local bodies)
Central Sales Tax (CST) Taxes on lottery, betting, gambling
Cesses and surcharges (on supply) State cesses and surcharges (on supply)

Why: The pre-GST regime suffered from cascading (tax on tax), multiplicity of taxes, checkpost delays, and lack of input credit across State borders. GST eliminates cascading through a seamless credit chain and creates a common national market.

Salient Features

Feature Explanation
Comprehensive Covers all goods and services (except excluded: alcohol, petroleum, electricity)
Multi-stage Levied at every point of supply chain (manufacturer → wholesaler → retailer → consumer)
Destination-based Tax accrues to consuming State, not producing State
Dual structure Centre (CGST) and State (SGST) levy simultaneously on same transaction
Input Tax Credit Seamless credit across value chain eliminates cascading
Technology-driven GSTN portal handles registration, returns, payments, refunds
Threshold-based Small taxpayers below Rs.40 lakh (goods) / Rs.20 lakh (services) exempt
GST Council Federal body (Centre + States) decides rates, rules, procedures

Recall Check

  1. What constitutional amendment introduced GST?
  2. What principle does "destination-based" taxation mean?
  3. Name five central taxes subsumed under GST.

Key Cases

Mohit Minerals v. Union of India (2022) Mohit-Minerals-v-Union-of-India-2022 Issue: Whether IGST can be levied on ocean freight paid by the foreign seller in CIF contracts (reverse charge). Rule: Art.246A, Art.269A, IGST Act S.5(3); the taxable event must be a "supply" within the meaning of S.7. Held: Levy of IGST on ocean freight under reverse charge in CIF imports amounts to double taxation (as customs duty already includes the freight component in assessable value). The GST Council's recommendations are not binding on Parliament/State Legislatures but have persuasive value. The notification was struck down.

Distinctions

Feature Pre-GST Regime GST Regime
Number of taxes 17+ Central and State taxes 1 tax (CGST + SGST or IGST)
Cascading Tax on tax (no credit across value chain) No cascading (seamless ITC)
Inter-state movement CST + Entry tax + Checkposts IGST (single tax, settled between states)
Tax base Manufacture (excise) / Sale (VAT) / Service (service tax) Supply (unified concept)
Compliance Multiple returns, multiple authorities Single portal (GSTN), unified returns
Rate uniformity Different rates in different states Uniform rates across India
Constitutional power Multiple entries in List I and List II Art.246A (concurrent power)

Flashcards

Q: When was GST introduced in India? A: 1 July 2017.

Q: Which constitutional amendment enabled GST? A: 101st Constitutional Amendment Act, 2016.

Q: What does "destination-based" tax mean? A: Tax revenue accrues to the State where goods/services are consumed (destination), not where they are produced (origin).

Q: What is the GST Council? A: A constitutional body under Art.279A comprising Union Finance Minister (Chair) + Union MoS (Revenue) + Finance Ministers of all States/UTs. It recommends rates, exemptions, rules.

Q: Name three taxes NOT subsumed under GST. A: Alcohol for human consumption, petroleum products (petrol, diesel, ATF, natural gas, crude oil), electricity duty.

Q: What was the main defect of the pre-GST regime? A: Cascading effect (tax on tax): no input credit available across the value chain or across state borders.

Q: How many indirect taxes did GST replace? A: Over 17 Central and State indirect taxes.

Exam Scenario

State X argues that the GST Council's recommendation to increase the rate on a particular commodity is binding and the State Legislature must comply. The Union argues the Council's recommendations are advisory. Analyse the constitutional position.

Approach: Per Mohit Minerals v. Union of India (2022), the SC held that GST Council recommendations under Art.279A are not binding but have "persuasive value." Art.246A grants independent legislative power to both Parliament and State Legislatures. The GST Council is a collaborative federal body; its recommendations carry great weight due to the cooperative federalism model, but legally, neither Parliament nor a State Legislature is bound to implement every recommendation. However, in practice, the unified rate structure requires consensus-based compliance.