This circular provides clarifications on certain practical difficulties faced by registered persons in implementing GST provisions due to disruptions caused by the COVID-19 pandemic, with a view to ensure uniform application of the law.

It clarifies issues relating to insolvency proceedings under the Insolvency and Bankruptcy Code, 2016. The time limit for obtaining GST registration by Interim Resolution Professionals (IRP) or Resolution Professionals (RP) has been extended, and it is clarified that a separate registration is not required where the corporate debtor has already complied with GST return filing prior to the appointment of IRP/RP. Further, where there is a change in IRP or RP, such change is to be treated as a change in authorised signatory and does not require a fresh registration.

The circular also addresses other COVID-19 related compliance issues. It clarifies that the time limit of 90 days for export of goods by merchant exporters, where concessional tax rate is applied, stands extended up to 30 June 2020 if the original period expired during the notified COVID-19 relief period. Additionally, it confirms that the due date for furnishing FORM GST ITC-04 for the quarter ending March 2020 has been extended up to 30 June 2020.

These clarifications are intended to ease compliance burdens and resolve ambiguities arising from pandemic-related disruptions.