GSTArticle

7 GST Circulars That Just Ended Years of Disputes

Between 26 and 28 October 2026, CBIC issued ten circulars following the 57th GST Council meeting. Seven of them move money — they unblock credit, kill old demands and regularise past periods. Ranked by how much each one could matter to your business.
SA
Shree Achi Advisorrs Pvt. Ltd.By CA Lalit Agarwal
Published 3 November 2026

For eight years, exporters fought refund demands under Rule 96(10). Car dealers lost credit on demo vehicles. Banks argued with officers over interest their own branches never paid anyone. In one week, CBIC settled all of it.

Between 26 and 28 October 2026, following the 57th GST Council meeting, CBIC issued ten circulars, numbered 257 to 266. The seven most recent, Circulars 260 to 266, are the ones that move money: they unblock credit, kill old demands and regularise past periods on an "as is where is" basis.

We have ranked them by how much they could matter to a business, starting with the biggest win. For each one you get the short version, what changed, who wins and what to do next.

One caveat worth remembering: circulars bind tax officers, not taxpayers or courts. But they are exactly what the officer across the table must follow in your next audit, refund or notice. That makes them your best argument.

The other three in the series cover procedure: registration (257), demand and adjudication (258) and appeal pre-deposits (259).

1. Exporters win an eight-year fight: Rule 96(10) is wiped out from day one

Circular 264/10/2026-GST, dated 26 October 2026

The short version: refund demands under Rule 96(10), and under Rules 89(4A) and 89(4B), should now collapse.

What happened. Rule 96(10) denied IGST refunds to exporters who had imported inputs duty-free under Advance Authorisation or EOU schemes. It was dropped from 8 October 2024, but officers kept chasing refunds for earlier years. Then, on 6 August 2026, the Supreme Court ruled in Goodluck India Ltd v. Union of India that a rule omitted without a saving clause cannot survive for pending cases.

What changed. CBIC has accepted the ruling. The omission now applies from 23 October 2017, the day the rule was born. Officers must close pending proceedings in line with the judgment.

Who wins: every exporter with a show cause notice, order or appeal on these rules.

Do this: pull out every pending Rule 96(10) file and ask for it to be dropped, citing the circular and the judgment.

2. Car dealers get their demo-vehicle credit back

Circular 262/08/2026-GST, dated 26 October 2026

The short version: dealers on the agency model can claim ITC on demo vehicles.

What happened. Under the new dealer-agency model, the manufacturer sells the car straight to the customer and the dealer earns a commission. In 2024, Circular 231 said these dealers could not claim ITC on demo cars, because they were not "further supplying" vehicles.

What changed. That paragraph, 4.6, is withdrawn. CBIC now accepts that a demo car does the same job under both models: it is bought on a tax invoice, capitalised, held for the required period and then sold with GST. Denying credit merely because the manufacturer makes the final sale was unfair.

Who wins: car and two-wheeler dealers whose brands have moved to the agency model.

Do this: claim the credit going forward, and review whether earlier denials can still be contested.

3. Shipping lines, banks and R&D labs get relief; NBFCs get a bill

Circular 266/12/2026-GST, dated 28 October 2026

The short version: six service-sector disputes settled in one go, mostly in the taxpayer's favour.

  • Foreign shipping lines — relief. Services imported free of charge by the Indian branch from group entities are exempt from 1 November 2026, and GST for the period 1 July 2017 to 31 October 2026 is regularised.
  • Banks — relief. Notional interest between branches under fund transfer pricing is "interest" and therefore exempt, ending demands that taxed it as an inter-branch service.
  • R&D institutions — relief. For the grant exemption, a certificate from the head of the institution that the work is research and not consultancy may be enough.
  • Vehicle lessors — clarity. Road tax, registration, insurance and FASTag recovered from the lessee form part of the lease value and are taxed at the leasing rate.
  • TRAI — adverse. It is not "Government" under section 2(53), so Government-only exemptions do not apply.
  • NBFCs in co-lending — adverse. Sourcing, KYC, appraisal, servicing and collection carried out for a bank are taxable, on the contract value.

Do this: shipping lines and banks should use the circular to close open demands; NBFCs should start charging GST on co-lending fees.

4. Banks and NBFCs get a clear rulebook for the 50% ITC option

Circular 261/07/2026-GST, dated 26 October 2026

The short version: a step-by-step method for section 17(4), and no penalty for having done it differently in the past.

Banks and NBFCs can take a flat 50% of eligible ITC instead of working it out invoice by invoice. Officers and banks had long disagreed on how. CBIC now spells out the sequence:

  1. Permanently reverse non-business and section 17(5) credit in GSTR-3B Table 4(B)(1).
  2. Take credit from a same-PAN registration that has also opted, in full.
  3. Take 50% of what remains.
  4. Park credit that is not yet eligible in Table 4(B)(2), or keep the invoice pending on IMS, and reclaim it later.

Only registrations that accept deposits or lend can opt. Once one does, all such registrations of the entity must follow.

Who wins: banks with old reporting differences. Officers are told not to take an adverse view of past methods, provided the credit taken fits these principles.

5. Dolls, puzzles and seaweed: four goods disputes settled

Circular 265/11/2026-GST, dated 28 October 2026

The short version: clear rates for four goods, and two past disputes regularised.

  • Toys, heading 9503. Officers had read the concessional entry as covering only tricycles, scooters and pedal cars. Dolls, doll carriages, scale models and puzzles are now covered too, at 5% for non-electronic toys and 18% for electronic ones.
  • Seaweed bio-stimulants. Classified under heading 3101 at 5% if registered under the Fertiliser Control Order, with the past period regularised.
  • Sublimation paper. Classified under heading 4809 at 18%, with the past period regularised.
  • Used cars under the margin scheme. Dealers were being denied ITC on all inputs. Only ITC on the used vehicles themselves is barred; spares, repairs, rent and advertising remain claimable.

Who wins: toy makers, agri-input companies and used-car dealers.

6. Exporters: more ways to get paid that still count as exports

Circular 263/09/2026-GST, dated 26 October 2026

The short version: payment routes that officers had questioned are now accepted.

A service counts as an export only if the money comes in foreign exchange, or in rupees where the RBI allows it. CBIC confirms that these routes qualify:

  • Repatriable rupee accounts such as SNRR and INR Nostro accounts. Stockbrokers paid by FPIs, NRIs and OCIs through SNRR or NRE accounts are covered. NRO money must pass through a repatriable account first.
  • Netting of export receivables against import payables, where the RBI permits it.
  • Reinsurance brokers who keep their commission out of the premium, with no separate remittance.

A bonus for goods exporters. The time allowed to bring money home follows the RBI's Master Direction, including extensions. If your AD bank writes off an unrealised amount, the refund cannot be clawed back under Rule 96B.

Need this applied to your own case?

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This article is general information, not professional advice. Tax law changes frequently — please confirm your position with us before acting.