Exemption Notifications: Which Act They Cross Over To

Exemption Notifications explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

There is exactly one direction in which an exemption notification travels automatically. Every other direction is blocked — which is why the same exemption is always notified twice, once under the CGST Act and once under the IGST Act.

Under section 11(4) of the SGST Act and section 8(4) of the UTGST Act, a notification issued by the Central Government on the Council's recommendation under section 11(1), or an order under section 11(2), of the CGST Act "shall be deemed to be a notification or, as the case may be, an order issued under the SGST/UTGST Act." Nothing else crosses. An IGST exemption does not exempt an intra-State supply, an SGST/UTGST notification does not bind the CGST Act, and an SGST notification does not reach the IGST Act.

The table

One arrow, three walls. That single asymmetry explains almost everything about how GST exemption notifications are drafted.

Why every exemption appears twice

Because the IGST Act is not covered by the deeming, the same relief must be notified separately under section 6(1) of the IGST Act. Hence the parallel pairs the Handbook tabulates:

• Goods — 02/2017-CT(R) and 02/2017-IT(R) (the CGST one superseded by 10/2025-CT(R) dated 17.09.2025);
• Services — 12/2017-CT(R) and 09/2017-IT(R);
• Petroleum operations — 03/2017-CT(R) and 03/2017-IT(R);
• CSD canteens — 07/2017-CT(R) and 07/2017-IT(R);
• Merchant exports — 40/2017-CT(R) and 41/2017-IT(R);
• Research equipment — 45/2017-CT(R) and 47/2017-IT(R);
• Gold to nominated agencies — 26/2018-CT(R) and 27/2018-IT(R);
• Electric buses on hire to local authorities — 13/2019-CT(R) and 13/2019-IT(R).

The numbering is deliberately unaligned in some pairs — 40/2017-CT(R) with 41/2017-IT(R), 45/2017 with 47/2017, 26/2018 with 27/2018 — which is a frequent source of citation errors. Always cite the notification of the Act you are applying.

Where only one Act has a notification

Some reliefs exist under only one Act, and the reason is structural.

CGST only:

• 08/2017-CT(R) — the old ₹5,000-a-day relief from section 9(4) reverse charge on supplies from unregistered persons;
• 09/2017-CT(R) — relief to a tax deductor receiving supplies from an unregistered supplier under section 9(4), where the deductor is not liable to register otherwise than under section 24(vi);
• 10/2017-CT(R) — second-hand goods bought from unregistered persons where the dealer pays under rule 32(5).

All three relate to section 9(4) — reverse charge on supplies from unregistered persons, which by definition arise intra-State. An unregistered person cannot ordinarily make an inter-State supply, so there is nothing for an IGST counterpart to relieve.

IGST only:

• 30/2017-IT(R) — inter-State supply of skimmed milk powder or concentrated milk, subject to conditions;
• 06/2018-IT(R) — IGST on royalty and licence fee on import of a temporary transfer of IPR, where the customs transaction value already includes it and appropriate duties are paid.

Both are inherently cross-border or inter-State, so a CGST counterpart would have nothing to operate on.

And one that is IGST-only by subject matter: the exemption at entry 10 of Notification No. 09/2017-IT(R) for services received from a provider located in a non-taxable territory by Government, a local authority, a Governmental authority or an individual for non-commercial purposes, by a section 12AA entity for charitable activities, by way of online educational journals to specified institutions, or by a person located in a non-taxable territory — "Provided that the exemption shall not apply to online information and database access or retrieval services received by persons specified in item (a) or item (b)."

What the asymmetry means in practice

Never reason from an IGST exemption to an intra-State supply. A supply that is exempt when it crosses a State line is not thereby exempt within a State; the CGST and SGST notifications must be checked on their own terms.

Never rely on a State's own notification against central tax. The Handbook takes this further, into a practical problem for multi-State businesses:

"What would be the position of a registered person having multiple branches in different States and when one State grants or allows exemption while another does not?… any State has given any specific exemption from levy of GST, the supplier has to avail such exemption in that particular State only and in other States the supplier has to collect and pay the GST."

And it adds why this should be rare: "Normally this may not happen because to remove the State wise exemptions etc. GST is being implemented." The design intent is uniformity; the deeming in section 11(4) is what delivers it, and a State-specific relief works against it.

The practical consequence for a group is that an exemption position taken in one State cannot simply be replicated across registrations. Each State's CGST-deemed-SGST position will be identical, but any State-specific relief will not.

A reminder on which exemption to test first

Because the notifications are Act-specific, the sequence is:

1. Determine the place of supply — is this intra-State or inter-State?
2. If intra-State, test the CGST notification; the SGST/UTGST position follows automatically by section 11(4)/8(4).
3. If inter-State, test the IGST notification — 09/2017-IT(R) for services, 02/2017-IT(R) for goods.
4. Check whether the entry you are relying on exists in that Act's notification at all, and with the same wording.

Step 4 is where the errors are. The two sets are largely parallel, but not identical — the IGST services notification carries entries with no CGST counterpart, and the CGST set carries three section 9(4) reliefs with no IGST counterpart.

Key takeaways

• Only one crossing exists: a CGST notification or order is deemed to be an SGST/UTGST one — section 11(4) SGST, section 8(4) UTGST.
• IGST does not cross to CGST/SGST/UTGST, and SGST does not cross to CGST or IGST.
• Hence every exemption is notified twice — under section 11(1) CGST and section 6(1) IGST.
• Notification numbers in a pair often differ (40/41, 45/47, 26/27) — cite the one for the Act you are applying.
• 08/2017, 09/2017 and 10/2017-CT(R) have no IGST counterpart because they address section 9(4), which is intra-State by nature.
• 30/2017-IT(R) and 06/2018-IT(R) have no CGST counterpart because they are inherently inter-State or cross-border.
• A State-specific exemption is available only in that State; other States collect and pay.

Read next

• Section 11: The Power to Exempt, and Its Three Routes
• Exemption, Nil-Rated, Zero-Rated and Non-Taxable, Distinguished
• Retrospective Exemption, and What It Does to Past Periods

Disclaimer: Positions stated as on 5 September 2026, based on section 11 of the CGST Act, 2017 and of the SGST Acts, section 8(4) of the UTGST Act, 2017, section 6 of the IGST Act, 2017, and the exemption notifications listed, as reproduced in the ICAI Handbook on Exempted Supplies under GST (April 2025), read with Notification No. 10/2025-Central Tax (Rate) dated 17 September 2025.