ICAI CA Final September 2025: Essential Statutory Updates on Indirect Tax Laws

Key Statutory Coverage and Applicability

• GST Laws:
  
• Central Goods and Services Tax (CGST) Act, 2017 and Integrated Goods and Services Tax (IGST) Act, 2017 as amended by the Finance (No. 2) Act, 2024.
  
• Only those amendments, notifications, and circulars effective up to 28 February 2025 are relevant for the September 2025 exam.
  
• Amendments made but not notified by this date are excluded.
  
• Customs Laws:
  
• Customs Act, 1962 and Customs Tariff Act, 1975 as amended by the Finance (No. 2) Act, 2024.
  
• Only effective amendments up to 28 February 2025 are included.
  
• Important Exclusions:
  
• Amendments to certain sections (e.g., sections 9, 9A, 9C of the Customs Tariff Act, and sections 65, 65A of the Customs Act) not yet notified are not applicable.
  
• Some case studies, exemptions, and transitional provisions are also excluded to streamline exam preparation.
  
• No GST on Penal Charges by Banks/NBFCs:
  
• Penal charges levied by regulated entities (banks/NBFCs) for non-compliance with loan terms (as per RBI directions) are not subject to GST, as these are not considered consideration for tolerating an act.
  
• Reverse Charge Mechanism (RCM) Updates:
  
• Sponsorship services to body corporates/partnership firms and renting of immovable property (other than residential dwellings) by unregistered persons to registered persons are now notified under RCM from 16 January 2025.
  
• E-Commerce Operators (ECOs):
  
• ECOs liable to pay tax under section 9(5) for notified services are not required to reverse input tax credit (ITC) proportionately. However, ITC cannot be used to pay tax under section 9(5); such tax must be paid in cash.
  
• Online Services to Unregistered Recipients:
  
• Suppliers must record the state of the unregistered recipient on tax invoices for all online/digital services, OIDAR, and online money gaming, regardless of value. This state is deemed the address on record for place of supply determination.
  
• Expanded/Amended Exemptions:
  
• Services incidental to electricity transmission/distribution and certain skill development services have updated exemption descriptions from 16 January 2025.
  
• New exemption: Insurance services by the Motor Vehicle Accident Fund against contributions from third-party insurance premiums.
  
• Clarifications:
  
• Facility management services to MCD headquarters are not exempt under Entry 3A, as they are not related to municipal functions.
  
• RBI-regulated Payment Aggregators are exempt from GST on settlement services up to ₹2,000 per transaction, but Payment Gateways are not.
  
• Vouchers:
  
• Transactions in vouchers, whether RBI-recognized pre-paid instruments or not, are neither supply of goods nor services. Only the underlying supply redeemed via the voucher may be taxable.
  
• Ex-Works Contracts:
  
• Dealers can avail ITC once goods are handed over to the transporter at the supplier’s (OEM’s) premises under Ex-Works contracts, not when physically received at their own business premises.
  
• Time Limit for Invoices under RCM:
  
• Recipients liable under RCM must issue invoices within 30 days of receipt of goods/services from unregistered suppliers (Rule 47A, effective 1 November 2024).
  
• Unique Enrolment Number:
  
• Unregistered persons transporting handicraft goods inter-state or opting to generate e-way bills must obtain a unique enrolment number from the portal (effective 11 February 2025).
  
• Section 74A Reference Added:
  
• Rule 88B now includes section 74A for interest calculation on delayed tax payment, aligning limitation periods for demands, with higher penalties for fraud/suppression cases (effective 1 November 2024).
  
• GSTR-7 Filing:
  
• TDS deductors must file GSTR-7 for every month, whether or not tax was deducted, by the 10th of the succeeding month (effective 1 November 2024).
  
• ITC Mismatch:
  
• Rule 88D now references section 74A for dealing with excess ITC availment in GSTR-3B over GSTR-2B.
  
• Export Proceeds Not Realized:
  
• Rule 96B now refers to section 74A for recovery of refunds where export proceeds are not realized within FEMA timelines.
  
• Quarterly Compliance:
  
• Importers must maintain detailed records and submit quarterly statements on the portal. Procedures for job work, unit transfer, supply to end-use recipients, and re-export of unutilized/defective goods have been streamlined.
  
• Depreciation on Capital Goods:
  
• Straight-line depreciation rates specified for capital goods cleared after use, with voluntary payment options for duty and interest.
  
• Stakeholder Consultation:
  
• FTP 2023 now formally provides for stakeholder consultation in policy formulation/amendment, with a mechanism (on best-effort basis) to inform reasons for non-acceptance of stakeholder views, subject to certain exceptions.
  
• Scope:
  
• Only amendments, notifications, and circulars effective up to 28 February 2025 are relevant for September 2025 exams.
  
• Exclusions and non-notified provisions must be carefully noted to avoid unnecessary study.
  
• Study Materials:
  
• Candidates should use the May 2024 edition of the Study Material, the latest statutory update, and supplementary reading as released by ICAI.
  
• Practical Focus:
  
• Emphasis is on clarity of legislative changes, their applicability, and practical impact, especially on GST compliance, ITC, RCM, and procedural aspects.

Conclusion

The September 2025 CA Final exam on Indirect Tax Laws will test candidates on a well-defined set of amendments and clarifications, with a strong focus on GST and Customs law changes effective up to 28 February 2025. Staying updated with the official ICAI statutory update, understanding the rationale behind each amendment, and focusing on exam-relevant content are key to success.

For a detailed chapter-wise breakdown and further reading, refer to the ICAI’s official statutory update and supplementary materials for September 2025 examination.

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