GST from 1 November 2026: easier post-sale discounts, 90% provisional refunds for inverted duty

From 1 November 2026, three GST changes made by the Finance Act, 2026 are in force. CBIC notified the start date in Notification No. 03/2026-Central Tax, dated 26 October 2026. It brings sections 153 to 155 of the Finance Act into effect, which amend sections 15, 34 and 54 of the CGST Act.

What has changed

• Post-sale discounts (section 15): a discount given after the sale no longer needs an agreement made before the sale, or a link to specific invoices, to reduce the taxable value. The supplier must still issue a GST credit note, and the buyer must still reverse the input tax credit for that discount.
• Credit notes (section 34): credit notes for these discounts are now expressly covered. The usual time limit for issuing a credit note still applies.
• Inverted duty refunds (section 54(6)): 90% of a refund of accumulated ITC under an inverted duty structure can now be paid provisionally, as already allowed for zero-rated supplies.
• Exports of goods (section 54(14)): the ₹1,000 minimum refund limit no longer applies to tax paid on goods exported with payment of IGST.

What to do

• Keep written discount schemes, workings and approvals. Genuineness still matters.
• Issue credit notes on time and tell buyers to reverse the matching ITC.
• If you have stuck inverted duty ITC, reconcile GSTR-1, GSTR-3B and GSTR-2B before filing the refund.
• Watch for CBIC rule or form changes. Treatment of discounts on sales made before 1 November is not yet clear.

Need help with credit notes or a GST refund? Call or WhatsApp +91 93113 95139.

Sources: CAclubindia (Notification 03/2026-CT), TaxGuru, CAclubindia article, CBIC.