CBIC Circular 208/2/2024-GST: What Manufacturers Need to Know

The Central Board of Indirect Taxes and Customs (CBIC) has released a new circular, Circular No. 208/2/2024-GST, providing clarifications on the special procedures for manufacturers of specified commodities (PAN masala, Tobacco etc.).

This follows Notification No. 04/2024-Central Tax dated 05.01.2024. The clarifications aim to ensure uniform implementation of the law across various jurisdictions.

Key Clarifications

1. Machine Details:
   • Issue: Manufacturers using old or second-hand machines lack details such as make, model, and machine number.
   • Clarification: Make and model number are optional in Table 6 of FORM GST SRM-I. The year of purchase can be used as the make number. Machine number is mandatory, and if not available, manufacturers may assign a numeric number.
2. Electricity Consumption Rating:
   • Issue: Lack of specifications for the electricity consumption rating of packing machines.
   • Clarification: The rating should be declared based on available details or calculated by a Chartered Engineer, who must certify it in FORM GST SRM-III.
3. Reporting Values for Non-MRP Goods:
   • Issue: Reporting value in Column 8 of Table 9 of FORM GST SRM-II for goods without MRP.
   • Clarification: The sale price of the goods should be entered in Column 8.
4. Chartered Engineer Qualifications:
   • Issue: Qualifications required for Chartered Engineers providing certificates under the special procedure.
   • Clarification: Chartered Engineers must have a certificate of practice from the Institute of Engineers India (IEI).
5. Special Economic Zones (SEZs):
   • Issue: Applicability of the special procedure to manufacturing units in SEZs.
   • Clarification: The special procedure is not applicable to units in SEZs.
6. Manual Packing Processes:
   • Issue: Applicability to manual processes using electric-operated heat sealers and seamers.
   • Clarification: The special procedure does not apply to manual seamers/sealers or manual packing operations like post-harvest tobacco leaf packing.
7. Multiple Machines in Manufacturing:
   • Issue: Reporting the serial number of machines used for different stages of packing.
   • Clarification: Details should be reported for the machine used in the final packing stage in Table 6 of FORM GST SRM-I.
8. Job Work and Contract Manufacturing:
   • Issue: Responsibility for compliance with the special procedure in cases of job work or contract manufacturing.
   • Clarification: All persons involved in the manufacturing process, including job workers or contract manufacturers, must comply. If unregistered, the principal manufacturer is liable.

Implementation

Trade notices should be issued to publicize the circular’s content. Any difficulties in implementing this circular should be reported to the Board.

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