Sections 146 to 149 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.
Four short enabling provisions. Two of them are the statutory basis for things every taxpayer deals with daily, and one is the power behind several of the sector-specific regimes.
146 — the Government may, on the Council's recommendations, notify the Common Goods and Services Tax Electronic Portal for facilitating registration, payment, returns, computation and settlement of integrated tax, e-way bills and other prescribed purposes. 147 — the Government may, on the Council's recommendations, notify certain supplies of goods as deemed exports, where the goods do not leave India and payment is received in Indian rupees or convertible foreign exchange, provided the goods are manufactured in India. 148 — the Government may, on the Council's recommendations, notify certain classes of registered persons and the special procedures to be followed by them, including registration, furnishing of returns, payment of tax and administration. 149 — provides for a goods and services tax compliance rating to be assigned to every registered person on prescribed parameters, updated periodically and placed in the public domain.
Section 146: the portal, and why the provision matters
The portal is not merely an administrative convenience — it is notified under a statutory power, and that has consequences.
Where it matters in practice:
Service. Section 169(1) includes making available on the common portal as a mode of service. So an order uploaded to the portal is served, and the date of uploading starts limitation. Section 169 →
Filing. Rule 108(1) requires a first appeal in APL-01 to be filed electronically, with manual filing only where the Commissioner has notified it or the order is not available on the portal. Rule 110, as substituted by Notification No. 13/2025-CT w.e.f. 22.09.2025, requires Tribunal appeals to be filed electronically, with the manual-filing provisos omitted. Rule 110 →
Confidentiality. Section 133(1) penalises wilful disclosure of information or return contents by, among others, any person engaged in connection with the provision of service on the common portal or the agent of the common portal — so the confidentiality obligation binds the portal's service providers. Sections 133 to 136 →
And portal failure is a real issue. With manual routes closing, a documented portal failure — screenshots, timestamps, error text, a grievance reference — is the only material that will support a condonation application. Condonation of delay →
Section 147: deemed exports
The defining feature: the goods do not leave India. A deemed export is a domestic supply that is treated as an export for specified purposes.
The conditions in the section: the supplies must be notified by the Government on the Council's recommendations; the goods must be manufactured in India; and payment must be received in Indian rupees or in convertible foreign exchange.
The consequence that matters — the refund. A deemed export is not a zero-rated supply under s.16 of the IGST Act. So the LUT and with-payment routes do not apply. Instead:
- tax is paid on the supply in the ordinary way;
- and a refund of the tax paid is claimed under s.54 read with Rule 89(1), third proviso — by either the supplier or the recipient, on the prescribed undertakings;
- the third proviso to Rule 89(1) requires an undertaking from the recipient that it has not availed input tax credit on the supply, and that it shall not claim the refund, where the supplier claims it.
So the two parties must agree who claims, and the undertaking must be obtained before filing. That is the recurring practical failure in deemed export refunds. Deemed export refund →
And note the s.147 conditions are cumulative with the notification. A supply that fits the commercial description of a deemed export but is not within the notified categories is an ordinary domestic supply.
Section 148: the special-procedure power
"The Government may, on the recommendations of the Council, and subject to such conditions and safeguards as may be prescribed, notify certain classes of registered persons, and the special procedures to be followed by such persons including those with regard to registration, furnishing of return, payment of tax and administration of such persons."
This is one of the most-used enabling powers in the Act, and it is the basis for regimes that look like separate schemes:
- special procedures for specific classes of taxpayer;
- procedures for manufacturers of specified goods, including declaration and reporting requirements;
- transitional and one-off procedures for particular situations.
Two practical points.
A s.148 notification can impose obligations that appear nowhere in the Act or the general rules. So a business in a notified class must read the notification as its operative compliance document, not the Act alone.
And the conditions and safeguards are prescribed. Where a notification imposes a requirement, the question is whether it falls within the power — a matter for the writ jurisdiction rather than an appeal, since it goes to vires. Choosing between appeal and writ →
Section 149: the compliance rating
"Every registered person may be assigned a goods and services tax compliance rating score by the Government based on his record of compliance with the provisions of this Act."
The section provides for the rating to be determined on the basis of prescribed parameters, to be updated at periodic intervals, and to be intimated to the registered person and also placed in the public domain in the prescribed manner.
Its practical significance today is indirect, because the operative machinery works through other provisions:
Risk-based selection. Rule 91(2), as substituted by Notification No. 13/2025-CT w.e.f. 01.10.2025, requires a provisional refund to be ordered in RFD-04 within seven days on the basis of system-based risk evaluation — a rating-like mechanism operating on refunds. Provisional refund →
Credit restrictions. Rule 86B restricts use of the credit ledger beyond 99% of output liability for specified taxpayers, with exceptions keyed to compliance behaviour. Rule 86B →
Counterparty risk. Rule 37A requires a recipient to reverse credit where the supplier has not furnished the GSTR-3B — which makes a supplier's compliance record a direct commercial matter for its customers. Rule 37A →
So compliance behaviour already carries consequences, through selection, restriction and counterparty reversal, whether or not a published rating is in operation.
Key takeaways
- Section 146 is the statutory basis for the common portal — which fixes service, filing and the confidentiality obligation on its providers.
- Section 147 deemed exports are domestic supplies: goods do not leave India, must be manufactured in India, and payment in rupees or convertible foreign exchange.
- A deemed export is not zero-rated — tax is paid and refunded under s.54 with Rule 89(1), on undertakings.
- Section 148 allows special procedures for notified classes, which may impose obligations found only in the notification.
- Section 149 provides for a compliance rating, updated periodically and placed in the public domain.
- Compliance behaviour already drives risk-based refund evaluation, Rule 86B restrictions and Rule 37A counterparty reversals.
Read next
- Deemed Export Refund: Who Claims, and the Undertakings
- Rule 86B: The Ninety-Nine Per Cent Credit Restriction
- Rule 37A: Reversal Where the Supplier Has Not Filed GSTR-3B
- Sections 162, 163, 164 and 170: Jurisdiction, Fees and Rule-Making
Disclaimer: Positions stated as on 5 September 2026, based on the CGST Act and Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition). Deemed export categories, special procedures and compliance-rating parameters operate by notification and rule and must be checked against the current position.