Introduction

Goods and Services Tax (GST) is implemented in India with the slogan of 'one tax one nation'. Simplification of law and procedures are one of the important objectives of GST implementation in India. GST is known as a Good and Simple tax. Nevertheless, with the introduction of GST, the administrative system of the government was forced to issue a large number of notifications in respect of the various provisions of the GST Law. It resulted in the issuance of 718 notifications till 31 December 2022 (not including the notifications issued by various state governments and union territories) which makes the assessment, levy and administration of tax and its collection complex for both the officials and taxpayers

If a law is simple means the number of changes proposed in it should be less. Due to the frequent issuance of notifications under GST, tax payers are finding it difficult when they process a document for filing monthly returns and reply to assessment orders. The notification with regard to the same be changed overnight without being informed in advance and they are to be fined and charged for non-completion of the process within the time span and limit. Frequent changes in notifications increase the compliance cost of taxpayers by way of upgrading/updating software applications.

The small and medium businesses are the ones who may be affected more as they may fall back in getting timely updates and advise for want of engagement of professionals which normally, they cannot afford. A large number of notifications is likely to reduce compliance and adversely affect revenue. The issuance of these notifications is a major hassle with regard to simplifying tax procedures under GST Law.

Studies on GST are focused mainly on the initial implementation issues of GST in India. The structural bias, major concerns include RNR fixation, fiscal autonomy of states, GST rate fixation, issues of small business, compliance level, issues faced under VAT scenario etc. (Alok Kumar Prasanna (EPW, 2016),  Raktim Dutta,  Binod Kumar (EPW 2018), Surajit Das (EPW, 2017), The EPW editorial (EPW, August 2019) Sudipto Banerjee and Sonia Prasad (EPW, September 2017), Sacchidananda Mukherjee (NIPFP WP No.301, 2020). So far very limited study has been conducted on this area. This study is the first attempt to analyse the notifications issued after the implementation of GST.

This study intends to understand the reasons for the alarming number of GST notifications both general and rate under the Central Goods and Services Tax Act (2017)/State Goods and Services Tax Act since its inception in July 2017 till December 2022. The study will also group the various notifications in relation to the different sections concerned and find out how many notifications have been issued under different sections of the Central Goods and Services Tax Act/State Goods and Services Tax Act, 2017. The study also proposes to look into the legal ambiguity if any for making changes under various sections of the Central Goods and Services Tax Act, 2017. The study will also look into the implication on state revenue due to the enormous number of notifications.

Status of GST notifications

GST notifications are issued under Central Goods and Services Tax Act, 2017 (CGST Act) and Integrated Goods and Services Acts, 2017. (IGST Act) .Notifications are under two categories such as central tax notifications and central tax (rate) notifications. The status of notifications issued from the inception of GST to December 2022 is presented in.

Table 1 gives the total number of notifications issued from 2017 to 2022 under various Acts of goods and services tax. It is seen from table 1 that the majority of notifications are issued under central tax category (54.87 per cent). Central tax rate notifications come to 20.61 per cent of the total number of issued notifications. Central tax notifications showed an increase from 2017 onwards and a negligible decrease showed in 2019. In 2020, the number of notifications issued increased to 95. There has been a considerable decline in the number of issuance of notifications from 2021-22. Here one pertinent point to note is that along with CGST notifications, there is a need for the issuance of corresponding notifications under State Goods and Services Tax Act, 2017 (SGST Act) . It is observed that the corresponding SGST notifications are not issued on time. For eg;, in Kerala, only the SGST notifications are available in the website of State Goods and Services Tax Department for a limited period. It is learned that the state taxes department issues corresponding notifications for meeting the administrative requirement but not making them available to the public.