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Circular No.-208/2/2024-GST
F.No. CBIC-20001/4/2024-GST
Government of India
Ministry of Finance
(Department of Revenue)
Central Board of Indirect Taxes and Customs
GST Policy Wing
*****
North Block, New Delhi
Dated the 26th June, 2024
To,
The Principal Chief Commissioners/ Chief Commissioners/ Principal Commissioners/
Commissioners of Central Tax (All)
The Principal Directors General/ Directors General (All)
Madam/Sir,
Subject: Clarifications on various issues pertaining to special procedure for the
manufacturers of the specified commodities as per Notification No. 04/2024 - Central Tax
dated 05.01.2024– reg.
Based on the recommendation of 50th GST Council meeting, a special procedure was
notified vide Notification No. 30/2023-Central Tax dated 31.07.2023 to be followed by the
registered persons engaged in manufacturing of goods mentioned in the schedule to the said
notification. The said notification has been rescinded vide Notification No. 03/2024-Central Tax
dated 05.01.2024 and a revised special procedure has been notified vide Notification No.
04/2024- Central Tax dated 05.01.2024.
2.
Representations have been received from various trade associations seeking clarity on
some issues pertaining to the said special procedure. To ensure uniformity in the implementation
of the provisions of law across the field formations, the Board, in exercise of its powers
conferred by section 168 (1) of the Central Goods & Services Tax Act, 2017 (herein after
referred to as the “CGST Act”), hereby clarifies various issues as under:
.
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S.No.
Issued Raised by Trade
Clarification on the issue
1.
Non availability of make, model number
and machine number -
The trade bodies have raised the issue that
some of the manufacturers of the said
goods are using very old packing machines
since decades including second hand
machines. Therefore, the details of make,
model number and machine number of
these machines are not readily available.
It is clarified that in Table 6 of FORM
GST SRM-I as notified vide Notification
No. 04/2024-CT dated 05.01.2024, make
and model number are optional. However,
where make of the machine is not
available, the year of purchase of the
machine may be declared as the make
number. It is also clarified that the
machine number is a mandatory field in
Table 6 of FORM GST SRM-I to be
filled up by the manufacturer. If the
machine number is not available either on
the machine or as per the available
documents/ records, then the manufacturer
may assign any numeric number to the
said machine and provide the details of the
same in Table 6 of FORM GST SRM-I.
2.
In cases where the electricity consumption
rating of the packing machine is not
available in the specifications of the said
machine or in the documents/record of the
same, then how to declare the electricity
consumption rating of the said machine in
Table 6 of FORM GST SRM-I?
It is clarified that electricity consumption
rating of the packing machine is to be
declared in Table 6 of FORM GST SRM-
I on the basis of details of the same as
available either on the machine or in the
documents/record of the said machine.
However, if the same is not available
either
on
the
machine
or
in
the
documents/records, then the manufacturer
may get such electricity consumption per
hour of the said machine calculated
through a Chartered Engineer and get the
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same certified by the said Chartered
Engineer in the format prescribed in
FORM GST SRM-III, as notified vide
Notification
No.
04/2024-CT
dated
05.01.2024.
The
said
electricity
consumption rating can be declared in
Table
6
of
FORM
GST
SRM-I
accordingly. The copy of such certificate
of the Chartered Engineer needs to be
uploaded along with FORM GST SRM-I.
The details of the documents so uploaded
needs to be provided in Table 10 of the
said form. It is also clarified that in cases
where there are certificates of Chartered
Engineer for more than one machine, then
all such certificates may be uploaded in a
single PDF file.
3.
Which value has to be reported in Column
8 of Table 9 of FORM GST SRM-II in
case of goods having no MRP, for
example, goods manufactured for export
market?
In cases where there is no MRP of the
package, then the sale price of the goods
so manufactured shall be entered in
Column 8 of Table 9 of FORM GST
SRM-II as notified vide Notification No.
04/2024-CT dated 05.01.2024.
4.
What should be the qualification and
eligibility of the Chartered Engineer for
providing Chartered Engineer certificate
under the special procedure notified vide
Notification
No.
04/2024-CT
dated
05.01.2024?
It is clarified that a Practicing Chartered
Engineer having a certificate of practice
from the Institute of Engineers India (IEI)
is qualified to provide Chartered Engineer
certificate under the special procedure
notified vide Notification No. 04/2024-CT
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dated 05.01.2024.
5.
Whether the special procedure notified
vide Notification No. 04/2024-CT dated
05.01.2024
is
applicable
to
the
manufacturing units located in Special
Economic Zone (SEZ)?
It is clarified that the special procedure as
notified vide Notification No. 04/2024-CT
dated 05.01.2024 is not applicable to the
manufacturing units located in Special
Economic Zone.
6.
Whether the special procedure notified
vide Notification No. 04/2024-CT dated
05.01.2024 is applicable to the manual
processes using electric operated heat
sealer and seamer?
It is clarified that the said special
procedure notified vide Notification No.
04/2024-CT dated 05.01.2024 is not
applicable in respect of manual seamer/
sealer being used for packing operations.
Further, it is also clarified that the said
special procedure is not applicable in
respect of manual packing operations such
as those in cases of post-harvest packing
of tobacco leaves.
7.
In cases where multiple machines are
required for filling, capping and packing of
containers, the serial number of which
machine is required to be declared in Table
6 of FORM GST SRM-I?
It is clarified that in a manufacturing
process there may be different machines
being used such as one for filling of
packages, another for putting seal on the
packages and another for final packing.
The detail of that machine is required to be
reported in Table 6 of FORM GST SRM-
I which is being used for final packing of
the packages of the specified goods.
8.
In
case
of
job
work
or
contract
manufacturing, which person shall be
It is clarified that the special procedure
notified vide Notification No. 04/2024-CT
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required to comply with the special
procedure as notified vide Notification No.
04/2024-CT dated 05.01.2024?
dated 05.01.2024shall be applicable to all
persons involved in manufacturing process
including
a
job
worker
/
contract
manufacturer. However, if the job worker/
contract manufacturer is unregistered, then
the liability to comply with the said special
procedure will be of the concerned
principal manufacturer.
3.
It is requested that suitable trade notices may be issued to publicize the contents of this
Circular.
4.
Difficulty, if any, in implementation of this Circular may please be brought to the notice
of the Board. Hindi version would follow.
(Sanjay Mangal)
Pr. Commissioner (GST)
