Facts of the Case
A large number of contractors
executing Government works contracts in the State of Jharkhand approached the
High Court through several writ petitions raising a common grievance relating
to the implementation of the GST regime on ongoing works contracts.
The petitioners had entered into
works contracts during the pre-GST regime when taxation was governed by VAT and
other indirect tax laws. After the implementation of GST with effect from
01.07.2017, the applicable tax structure changed substantially, resulting in a
higher tax burden on the contractors.
According to the petitioners,
although they were compelled to pay GST at the revised rates, the concerned
Government departments failed to reimburse the additional tax burden. They also
contended that no uniform mechanism or policy had initially been framed by the
State Government for reimbursement of such differential GST liability.
During the pendency of these
writ petitions, the High Court repeatedly directed the State Government to
formulate appropriate guidelines. Pursuant to those directions, the Government
of Jharkhand issued a Standard Operating Procedure (SOP) dated 26.08.2022
prescribing the procedure for dealing with claims relating to reimbursement of
differential GST in respect of pre-GST works contracts.
Issues Involved
1.
Whether
contractors executing pre-GST works contracts are entitled to reimbursement of
the differential GST burden arising after implementation of GST from
01.07.2017.
2.
Whether
the State Government had framed an adequate mechanism for deciding
reimbursement claims.
3.
Whether
the High Court should examine the validity of the newly issued SOP dated
26.08.2022 in these writ petitions.
4.
Whether
the concerned departments should be directed to decide the reimbursement claims
within a fixed time frame.
Petitioners' Arguments
The petitioners submitted that:
·
Their
contracts were awarded under the VAT regime.
·
GST
introduced a substantially different taxation mechanism and increased tax
burden.
·
The
contracts did not contemplate such enhanced GST liability.
·
Contractors
had already discharged GST liability but were not reimbursed by the concerned
departments.
·
Other
State Governments, Railways and Public Sector Undertakings had already framed
proper mechanisms for reimbursement.
·
The
State of Jharkhand had failed to provide a uniform policy for implementation of
GST on ongoing works contracts.
·
The
reimbursement claims had remained pending for several years causing severe
financial hardship.
Respondents' Arguments
The State Government submitted
that:
·
Pursuant
to directions of the High Court, the Chief Secretary coordinated with various
departments.
·
Workshops
were conducted for implementation of GST reimbursement guidelines.
·
A
comprehensive Standard Operating Procedure (SOP) dated 26.08.2022 had already
been issued.
·
The
SOP provided a mechanism for considering individual reimbursement claims.
·
Since
an appropriate procedure had now been framed, contractors should pursue their
claims before the competent departmental authorities.
Court
Order / Findings
The Jharkhand High Court
observed that the principal objective of these writ petitions had been achieved
because the State Government had framed and notified the Standard Operating
Procedure dated 26.08.2022 for dealing with reimbursement of differential GST
liability arising in pre-GST works contracts.
The Court noted that:
·
The
SOP itself was not under challenge in these writ petitions.
·
Therefore,
the Court considered it inappropriate to examine or comment upon the clauses of
the SOP at this stage.
·
Individual
contractors should submit or pursue their claims before the competent
authorities under the concerned departments.
·
The
authorities are required to examine each claim independently in accordance with
the SOP and applicable law.
·
If
any petitioner remains aggrieved after such decision, a fresh cause of action
would arise and appropriate legal proceedings may be initiated, including a
challenge to any clause of the SOP if necessary.
Considering that the issue had
remained pending since implementation of GST on 01.07.2017, the Court directed
that the reimbursement claims should be decided expeditiously, preferably
within eight weeks
from the date of receipt of the Court's order.
The Court further clarified that
any earlier stand taken by the departments regarding the correctness of the
claims should not prevent them from taking a fresh decision after applying the
SOP dated 26.08.2022.
Important Clarification
·
The
High Court did not
decide whether any particular contractor was entitled to reimbursement.
·
The
Court did not
examine the legality or validity of the SOP.
·
Individual
reimbursement claims must first be decided by the competent departmental
authorities.
·
Contractors
retain the right to challenge any adverse order or any clause of the SOP in
appropriate proceedings.
·
Authorities
should dispose of reimbursement claims preferably within eight weeks.
Sections /
Provisions Involved
·
Article
226 of the Constitution of India
·
Goods
and Services Tax (GST) Regime effective from 01.07.2017
·
Works
Contract provisions under GST
·
Jharkhand
Commercial Taxes Department Notification (S.O. No. 33 dated 26.08.2022)
·
Standard
Operating Procedure (SOP) for reimbursement of GST differential tax
· Government guidelines relating to transition from VAT to GST
Link to
download the order -
https://mytaxexpert.co.in/uploads/1784611206_1543compressed.pdf
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