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CGST Act Section 142: Miscellaneous transitional provisions | Finin2min

Section 142 - Miscellaneous transitional provisions

Chapter XX - Transitional Provisions
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Source control: The text/status on this page is tied to the official source gateway and the Phase 1 legal-review register. Open official source.

Finin2min Summary - Section in 2 Minutes

Coordinates pre-GST returns, refunds, price revisions, contracts, assessments, appeals and recoveries with the GST regime, generally preserving cash settlement under the existing law and preventing double credit.

Exact operative text

Paragraph-wise decode

Coordinates pre-GST returns, refunds, price revisions, contracts, assessments, appeals and recoveries with the GST regime, generally preserving cash settlement under the existing law and preventing double credit.

Section-Rule-Form-Notification bridge

No direct Rule certified in Phase 1. Check notifications, circulars, forms and corresponding State law.

The mapping is a legal concordance, not a round-robin related-link list. It is limited to instruments certified in this phase.

Practical example

A pre-GST assessment is concluded after GST begins and results in a refund. The refund is paid in cash under the existing law rather than credited to the GST ledger.

Professional alert

The provision prevents double benefit. A cash refund or recovery under the existing law usually does not become GST ITC unless the statute expressly permits it.

Linked Rules and current operative controls Rules are read as a consolidated legal layer. Where a rule is legacy or institutionally transitioned, the current status is stated expressly. Rule 117 RULE TEXT / CONSOLIDATED BASE LAYER 117. Tax or duty credit carried forward under any existing law or on goods held in stock on the appointed day.- Eligible persons were required to submit FORM GST TRAN-1 electronically within the notified period, with prescribed declarations and stock/duty details. The rule contains special declarations for capital goods, goods sent to job workers, centralised registrations and specified stock credits. CURRENT OPERATIVE CONTROL AT 29 JUNE 2026 This is a legacy rule. Apply the statutory conditions, original return data, notified windows and binding judicial/portal reopening directions such as the Supreme Court TRAN-1/TRAN-2 facilitation. Rule 118 RULE TEXT / CONSOLIDATED BASE LAYER 118. Declaration to be made under clause (c) of sub-section (11) of section 142.- Persons to whom the provision applied were required to furnish FORM GST TRAN-1 with the proportion of supply made before the appointed day but invoice issued after it. CURRENT OPERATIVE CONTROL AT 29 JUNE 2026 Legacy transitional declaration; reconcile contract, milestone, invoice and pre-GST tax evidence. Rule 119 RULE TEXT / CONSOLIDATED BASE LAYER 119. Declaration of stock held by a principal and job-worker.- The principal and job worker were to declare appointed- day stock details in FORM GST TRAN-1 within the prescribed period.

CURRENT OPERATIVE CONTROL AT 29 JUNE 2026 Relevant to historical section 141 disputes; preserve challans, stock registers, job-work records and return dates. Rule 120 RULE TEXT / CONSOLIDATED BASE LAYER 120. Details of goods sent on approval basis.- A person holding goods sent on approval not earlier than six months before the appointed day was to submit FORM GST TRAN-1 details within the prescribed period. CURRENT OPERATIVE CONTROL AT 29 JUNE 2026 Apply section 142(12), the approval dispatch date and return/supply timeline. Rule 120A RULE TEXT / CONSOLIDATED BASE LAYER 120A. Revision of declaration in FORM GST TRAN-1.- A registered person who submitted TRAN-1 within time could revise it once within the period specified by the Commissioner. CURRENT OPERATIVE CONTROL AT 29 JUNE 2026 Legacy one-time revision rule; verify whether relief arises from an order, portal reopening or litigation direction. Rule 121 RULE TEXT / CONSOLIDATED BASE LAYER 121. Recovery of credit wrongly availed.- Transitional credit wrongly credited may be recovered under section 73, 74 or, for the legally relevant later architecture, section 74A, as applicable. CURRENT OPERATIVE CONTROL AT 29 JUNE 2026 Notification 20/2024-Central Tax aligned the rule with section 74A from 1 November 2024. Match the period and allegation before selecting the demand section.

Notifications, circulars and implementation controls Instrument Date/status Why it matters CGST Rules 117-121 and TRAN forms Legacy appointed-day framework Prescribed declarations for carried-forward credit, stock, job work, approval goods and recovery. Notification 48/2018- Central Tax 10 September 2018 Extended/modified transitional declaration mechanisms for specified taxpayers. Notification 02/2020- Central Tax 1 January 2020 Inserted rule 117(1A) and related relief for specified technical difficulties. Union of India v. Filco Trade Centre Pvt. Ltd. Supreme Court orders, 2022 Directed a special GST portal window for TRAN-1/ TRAN-2 filing/revision and officer verification. Circular 180/12/2022-GST 9 September 2022 Issued guidelines for verifying transitional credit claims filed through the Supreme Court-directed window. Notification 20/2024- Central Tax 8 October 2024; relevant change from 1 November 2024 Aligned rule 121 recovery wording with section 74A. Reading rule: Notifications determine class, date and conditions; circulars guide administration but cannot override the Act, Rules, Gazette or binding courts.

CA / finance / professional case studies Case 1: TRAN-1 technical failure Facts: Eligible credit was in the last return, but portal logs show failed filing. Question: What evidence matters? Analysis: Reconcile the last return, ledger, attempted filing screenshots/help-desk record, Supreme Court window filing and verification order. Technical relief does not remove substantive eligibility conditions. References: s.140; r.117; Filco orders Case 2: Capital-goods balance credit Facts: Half of eligible duty credit was taken under the old law. Question: Can the balance transition? Analysis: Apply section 140 capital-goods condition and ensure the balance was admissible both under existing law and GST, with invoice and fixed-asset records. References: s.140(2) Case 3: Stock without duty invoice Facts: A trader held specified goods on 30 June 2017 but lacked duty-paying documents. Question: Is deemed credit automatic? Analysis: No. It depended on the then-applicable provisos, notification/rule conditions, stock statements and sale/payment timelines. Reconstruct the historical scheme rather than applying current ITC rules. References: s.140; r.117

Case 4: Pre-GST inputs at job worker Facts: Inputs sent in May 2017 returned after the statutory transition period. Question: What follows? Analysis: Test section 141 return-time conditions and any permitted extension. If not met, quantify the deemed consequences and reconcile job-worker declarations. References: s.141; r.119 Case 5: Price revision after GST Facts: A pre-GST contract price is increased after 1 July 2017. Question: How is the adjustment documented? Analysis: Issue the statutory supplementary invoice/debit note within the section 142 window and pay GST where required, while preventing duplication with existing-law tax. References: s.142(2) Case 6: Legacy refund order Facts: A pre-GST excise appeal succeeds in 2026. Question: Cash or GST credit? Analysis: Section 142 generally routes the refundable amount in cash under the existing law, subject to unjust enrichment and other preserved provisions; rejected amount does not become GST ITC. References: s.142 Case 7: Legacy demand after adjudication Facts: A service-tax demand becomes final after GST. Question: How is it recovered? Analysis: Recover as an arrear under the existing/GST saving architecture as section 142 directs; do not debit current ITC unless law permits. References: s.142; s.174

Case 8: Return revised after appointed day Facts: An old-law return revision increases credit. Question: Can the increase be taken as GST ITC? Analysis: Apply the specific section 142 revision clause and its time/eligibility limitations. Increases are not automatically transferable merely because the old return was revised. References: s.142(9)

Finin2min Q&A 1. Are transitional credits still a live compliance topic? They are closed for ordinary filing but remain relevant in verification, litigation, recovery and legacy audit. 2. Was every closing credit transferable? No. Section 140 imposed eligibility under both existing law and GST plus documentation and return conditions. 3. What was TRAN-1 used for? Migration of specified carried-forward, stock, capital-goods, job-work and related transitional details. 4. Can a technical portal failure create substantive eligibility? No. Technical relief may reopen filing, but the underlying credit must still be legally admissible. 5. What did the Filco orders do? They directed a special portal window and verification process for TRAN-1/TRAN-2 claims. 6. How are pre-GST goods with job workers handled?

Implementation checklist

  1. Fix the transaction, taxable period and jurisdiction.
  2. Read every subsection, proviso, explanation and omission marker.
  3. Open the mapped Rule, form, notification and circular.
  4. Test State/UT variation and portal version.
  5. Preserve evidence, approvals, working papers and acknowledgements.
  6. Record the conclusion, assumptions, source date and reviewer.

Evidence and retention checklist

Practical Q&A

What does section 142 regulate?
It regulates miscellaneous transitional provisions. Read the exact text, conditions, exceptions and transaction date together.
Which subordinate law should be checked?
No direct CGST Rule has been certified in this phase. Notifications, circulars, forms and the corresponding SGST/UTGST layer may also apply.
What evidence should be retained?
Preserve the contract or transaction record, invoice or form, portal acknowledgement, payment/ledger evidence, correspondence, legal working and the official source version used.
Can portal behaviour override the statute?
No. Portal functionality is operational evidence; legal entitlement and liability remain controlled by the Act, Rules, notifications and binding decisions.