Finance Act 2026: Every GST Amendment, and When Each One Starts

Finance Act 2026 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.

The Finance Act, 2026 (No. 4 of 2026, assented 30 March 2026) carries five GST amendments across sections 153 to 157. That is a small number. What makes it awkward is that those five start on three different dates, and the Act's own commencement clause is what separates them.

Read the amendments without reading section 1(2), and you will apply at least two of them a year early.

Sections 153, 154 and 155 — the CGST amendments to s.15(3)(b), s.34(1) and s.54 — come into force on a date the Central Government notifies. They are not in force yet. Section 156 — the s.101A(1A) advance-ruling appeal fix — came into force 1 April 2026. Section 157, which omits IGST s.13(8)(b) "intermediary services", was not deferred at all and so took effect on enactment, 30 March 2026. That last one is the biggest change in the Act.

The commencement clause, first

Section 1(2) of the Finance Act, 2026 says:

• clause (a) — sections 2 to 129, clause (b) of section 152 and section 156 come into force on 1 April 2026;
• clause (b) — sections 153 to 155 come into force on such date as the Central Government may, by notification, appoint.

Section 157 appears in neither clause. A provision that the commencement clause does not defer takes effect on the date the Act receives assent. For the Finance Act, 2026 that is 30 March 2026.

The ICAI Bare Law's own footnotes confirm the split: the s.15 and s.54 changes are annotated "effective from a date to be notified", while the IGST omission is annotated "w.e.f. 30.03.2026".

Section 157 — intermediary services, gone from IGST s.13(8)

This is the amendment that actually moves money.

IGST section 13(8)(b) deemed the place of supply of intermediary services to be the location of the supplier. For an Indian broker, agent or facilitator earning commission from a foreign principal, that fixed the place of supply inside India, defeated the export test in s.2(6) of the IGST Act, and made the commission a domestic supply liable to 18%.

Section 157 omits clause (b) outright. With it gone, an intermediary service falls back to the residual rule in s.13(2) — the location of the recipient. Where the recipient is outside India and the other export conditions hold, the supply is now an export of services and therefore zero-rated.

Nearly a decade of litigation sat on this clause. It ends on 30 March 2026 — prospectively. What the intermediary change means in practice →

Sections 153 and 154 — post-supply discounts, rewritten

Section 153 replaces s.15(3)(b). The old clause allowed a post-supply discount out of value only if the discount was established by an agreement entered into at or before the time of supply and specifically linked to relevant invoices, and the recipient reversed the attributable credit.

The substituted clause drops both of those conditions. It now reads: the discount is excluded from value if a credit note has been issued by the supplier and the input tax credit attributable to the discount has been reversed by the recipient, in accordance with section 34.

Section 154 makes the matching change to s.34(1), adding a discount under s.15(3)(b) to the list of grounds on which a credit note may be issued — closing the gap where a discount was allowed under s.15 but had no clean home in s.34.

The commercial effect is large: the pre-agreement requirement disappears. Volume rebates, year-end incentives and negotiated post-supply reductions that were never documented up front stop being fatal. What matters instead is a credit note plus the recipient's reversal.

Both are waiting on a notification. Until it issues, the old two-condition test still governs. Post-supply discounts under the new s.15(3)(b) →

Section 155 — two refund amendments

Section 155 makes two changes to s.54:

s.54(6) — provisional refund of 90% currently applies only to a claim on account of zero-rated supply. The amendment extends it to unutilised ITC allowed under clause (ii) of the first proviso to s.54(3) — that is, inverted duty structure refunds. After GST 2.0 pushed many outputs to 5% while inputs stayed at 18%, inverted-duty claims grew sharply, and 90% up front is real working capital. Provisional refund for inverted duty →

s.54(14) — the sub-section bars any refund under s.54(5) or (6) below ₹1,000. The amendment carves out claims on account of goods exported out of India with payment of tax, so a small IGST-paid export refund is no longer swallowed by the floor.

Both wait on the same notification.

Section 156 — an existing Tribunal can act as the NAAAR

The National Appellate Authority for Advance Ruling has existed on paper in s.101A since 2019 and has never been constituted. Divergent State AAAR rulings on identical questions therefore had no forum to resolve them.

New s.101A(1A) lets the Government, on the Council's recommendation, empower an existing Authority — expressly including a Tribunal — to hear s.101B appeals until the NAAAR is constituted. Where it does, sub-sections (2) to (13) fall away and every reference to the NAAAR reads as a reference to that authority.

In force since 1 April 2026. It is enabling, not self-executing: a notification still has to name the authority. The NAAAR workaround →

What is live today

Key takeaways

• Five amendments, three commencement dates. Section 1(2) governs, not the amendment text.
• IGST s.13(8)(b) is already gone — intermediary services can now be exports.
• s.101A(1A) is live but needs a notification naming the authority.
• The discount and refund changes are not in force. Applying them now is premature.
• The old s.15(3)(b) test — pre-agreement, invoice-linked — still applies until notified.

Read next

• IGST 13(8)(b) Omitted: Intermediary Services Can Now Be Exports
• Post-Supply Discounts Under the New Section 15(3)(b)
• Provisional Refund for Inverted Duty Structure
• GST 2.0: The Two-Rate Structure Explained

Disclaimer: Positions stated as on 5 September 2026, based on the Finance Act, 2026 (No. 4 of 2026) and the ICAI Bare Law, 12th edition (amendments to 31 March 2026). Commencement notifications change; verify on cbic.gov.in before relying on a deferred amendment.