As per Section 19(7) of GST Law, registration is required to be granted with in prescribed period. Further As per section 19(9), if registration is not granted with in stipulated period and also no deficiency is communicated to the dealer, the registration under GST law shall be deemed to have been granted. Comments: This is a welcome provision under GST law. This is just like section 12AA(2) of Income tax law, where after six months from end of month in which application for grant of registration of trust is made, if application is not rejected, the assesse trust is granted deemed registration. Such like provision does not exist in present vat or service tax law. [GST Law Note-4]

U/s 11 of Model GST law, remission of tax on quantities found deficient due to natural causes has been allowed. U/r 21 of Central excise law similar remission is available for deficiencies arising out of natural as well as accidental cases and other cases where goods found unfit for consumption or marketing before removal. U/R 21 of PVAT Rules, ITC is required to be reversed where goods are lost or destroyed due to whatever reasons. Hence remission should be allowed under GST law on quantities found deficient on account of reasons other than natural causes also. Although Schedule I of Model GST law, dealing with supplies without consideration also does not include deficiencies due to unnatural reasons with in definition of supply but perhaps matter needs a bit of more clarification also. [GST Law Note-3]

As per Section 10(4)(b) of Model GST Law, every exemption notification and its clarification shall be made available on official site. It should better be stretched to include all types of notifications. At present, on the site of CBEC while, all the notifications especially old notifications are not available, the site of Punjab Vat which once used to be one stop destination for all notifications/circular has lost its sheen of being so virtuoso with times. Legislating the old demand of the Industry is welcome and the respective governments should follow suit to adopt the better practices [GST Law Note-2]

Under Model GST Law Section 9(3)(c), thresh hold exemption limit is also available for supply of services by reverse charge mechanism , where services are for personal use other than for use in the course or furtherance of business. Note that exemption is available only for services under RCM and not for supply of goods, if covered by RCM. Further no threshold limit is available if services are received for business purpose. This feature was not available under present service tax law and under vat law also purchase tax is leviable from Re.1. [GST Law Note-1]