EXTRAORDINARY

No. 2

GOVERNMENT OF GOA

Department of Finance

Office of the Commissioner of Commercial Taxes

Circular

Subject: Clarification regarding jurisdiction in cases involving migration/transfer of taxable persons

from one jurisdiction to another jurisdiction—reg.

Ref.: Circular No. 255/01/2026-GST dated 25th June, 2026 issued under Central Goods and

Services Tax Act, 2017 by the GST Policy Wing, Central Board of Indirect Taxes and

Customs, Department of Revenue, Ministry of Finance, Government of India, New Delhi.

CIRCULAR

(No. 01/2026-27 – GST)

The GST Policy Wing, Central Board of Indirect Taxes and Customs, Department of Revenue,

Ministry of Finance, Government of India, New Delhi has issued the above referred Circular.

For the uniformity in implementation and in exercise of the powers conferred under Section 168 of the

Goa Goods and Services Tax Act, 2017 (Goa Act 4 of 2017) it is hereby directed that the Said Circular

issued by the GST Policy Wing, Central Board of Indirect Taxes and Customs, Department of Revenue,

Ministry of Finance, Government of India shall be applicable, mutatis mutandis, in implementation of the

Goa Goods and Services Tax Act, 2017 (Goa Act 4 of 2017).

A copy of the above referred circular is attached herewith as Annexure.

Difficulty, if any, in implementation of this circular may please be brought to the notice of the

undersigned.

Given under the seal of this office.

S. S. Gill, IAS, Commissioner of State Taxes, Goa.

Panaji.

CCT/26-4/2026-27/H/1471

Date : 06-Jul-2026

Suggestions are welcomed on e-mail: [email protected]

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Reg. No. RNP/GOA/32/2024-2026

RNI No. GOAENG/2002/6410

Panaji, 06th July, 2026 (Ashadha 15, 1948)

SERIES I No. 14

PUBLISHED BY AUTHORITY

ANNEXURE

Circular No. 255/01/2026-GST

F. No. CBIC-20010/11/2026-GST

Government of India

Ministry of Finance

Department of Revenue

Central Board of Indirect Taxes and Customs

GST Policy Wing

***

New Delhi, Dated, the 25th June, 2026

To,

The Principal Chief Commissioners/Chief Commissioners (All)

The Principal Director General/Director General (All)

Madam/Sir,

Subject: Clarification regarding jurisdiction in cases involving migration/transfer of taxable

persons from one jurisdiction to another jurisdiction– reg.

References have been received from field formations seeking clarification on the validity of action

taken, and on the authority competent to act, at various stages of proceedings under the Central Goods and

Services Tax Act, 2017 (hereinafter referred to as “CGST Act”) in cases where the jurisdiction of the

taxable person has changed on account of change in Principal Place of Business of the taxable person.

2. Clarification has been sought on the following:

(i)

whether an action undertaken by the transferor jurisdictional authority, at a given stage of

proceedings, before such migration/transfer of the taxable person to another jurisdiction, remains

valid and applicable on the transferee jurisdiction authority;

(ii)

whether the transferor jurisdiction authority can take any action or initiate proceeding against the

taxable person, after he has migrated/transferred to another jurisdiction (transferee); and

(iii)

who would be the authority competent to give effect to, implement, or act upon any such action

already taken, and also to act upon any consequential action arising from the antecedent

proceedings, including representing, defending, or otherwise conducting proceedings, filing of

appeals before the appellate authority or appellate tribunal, in cases involving migration/transfer of

the taxable person.

3. The matter has been examined in consultation with the Union Ministry of Law and Justice. In order to

ensure uniformity in the implementation of procedure in such cases involving migration/transfer of taxable

persons from one jurisdiction to another, the Central Board of Indirect Taxes and Customs (hereinafter

referred to as “the Board”), hereby, issues the following clarifications in the matter.

4. The core issue, common to all the proceedings under the GST framework referred to in para 2 above, is a

conflict between the validity of action already taken by the erstwhile (transferor) jurisdictional officer, and

the need for the present (transferee) jurisdictional officer to have control over the proceeding once a

taxable person has migrated/transferred to a different jurisdiction. The governing principle, applicable

uniformly across all stages of actions or proceedings, is that jurisdiction to exercise a statutory power is

required to be assessed as on the date on which the power is actually invoked. A subsequent

migration/transfer of the taxable person does not retrospectively vitiate a proceeding already validly

initiated or concluded by the erstwhile (transferor) jurisdictional officer, though it does affect who should

conduct matters from that point forward.

5. Where an action corresponding to particular stage of proceedings (i.e. investigation, conducting audit,

issuance of show cause notice, issuance of adjudication order, issuance of Order-in-review, filing of appeal,

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issuance of Order-in-Appeal, or any other proceedings under the CGST Act and the rules made thereunder)

has been validly undertaken by the officer having jurisdiction over the registered taxpayer at that time

(transferor), the action so taken remains valid, notwithstanding subsequent migration/transfer of the taxable

person to another jurisdiction (transferee). The conduct of the next stage of proceedings, and the

implementation of any directions contained in an action already taken or proceedings, is however to be

undertaken by the officer presently having jurisdiction (transferee) over the taxable person, and not by the

erstwhile (transferor) jurisdictional officer who, on account of the migration/transfer of the taxpayer,

ceased to have jurisdiction thereon.

6. Judicial treatment of post-migration/transfer actions, as held by the Hon’ble Supreme Court and Hon’ble

High Courts in various of judicial pronouncements, in tax related matters, shows that the past acts of a

competent authority remain valid, and enforcement and further proceedings must be taken over by the

officer, who has now acquired jurisdiction (transferee) subsequent to such migration/transfer. In such

cases, it has been highlighted that continuing or consequent proceedings to any action, must be exercised

by the authority currently having jurisdiction over the taxable person, after the said migration/transfer.

Moreover, there is nothing to prevent the transferee jurisdictional authority from acting upon an earlier

valid administrative or quasi-judicial action or proceeding initiated by the transferor jurisdictional

authority. This indicates that the present jurisdictional authority (transferee) should be the face of

proceedings at every subsequent stage after the migration/transfer and wherever any action or proceeding

had already been initiated by the transferor jurisdictional authority before the migration/transfer, the

transferee jurisdictional authority can rely on such action or proceeding already taken by the erstwhile

jurisdictional authority (transferor).

7. Therefore, it is hereby clarified that:

(a)

Where any action or proceeding under the CGST Act and the rules made thereunder has been

validly undertaken by the transferor jurisdictional authority having jurisdiction over the registered

taxpayer on the date such action was undertaken, the same shall remain valid notwithstanding the

subsequent migration/transfer of the taxable person to another jurisdictional authority. The

transferee jurisdictional authority shall act upon, give effect to, and proceed on the basis of such

earlier valid action taken by the transferor jurisdictional authority, as if it had itself initiated the

same.

(b)

The transferor jurisdiction authority shall not take any action or initiate proceedings against the

taxable person, after he has migrated/ transferred to another jurisdiction and any issue that comes to

the notice of the transferor jurisdictional authority should be intimated to the transferee

jurisdictional authority for any further action.

(c)

Where the taxable person migrates to another jurisdiction during the pendency of any action or

proceeding initiated by the transferor jurisdictional authority, the transferee jurisdictional authority

shall take over and conclude the same from the stage at which it stood at the time of migration/

transfer, and shall be competent to take all further actions, including consequential proceedings that

might arise therefrom. Thus, the transferee jurisdictional authority shall be the competent authority

to give effect to, implement, or act upon any such action already taken, and also to act upon any

consequential action arising from the antecedent proceedings, including representing, defending, or

otherwise conducting proceedings, filing of appeals before the appellate authority or appellate

tribunal, in cases involving migration/transfer of the taxable person.

8. Difficulty, if any, in implementation of the above instructions may please be brought to the notice of the

Board.

Yours faithfully,

(Gaurav Singh)

Commissioner (GST)

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Department of Planning

Directorate of Planning, Statistics and Evaluation

Notification

The following Notification No. S.O. 3472(E) dated 27/06/2026 issued by the Office of Registrar

General and Census Commissioner, Ministry of Home Affairs, New Delhi, is hereby published for general

information.

Vijay B. Saxena, Director.

Porvorim.

---------

MINISTRY OF HOME AFFAIRS

(Office of Registrar General, India)

Notification

New Delhi, the 27th June, 2026

S.O. 3472(E).— In exercise of the powers conferred by Section 17A of the Census Act, 1948 (37 of

1948) read with rule 6D of the Census Rules, 1990, the Central Government hereby extends the provisions

of the said Act for conduct of pre-test of second phase of Census of India, 2027 in the States and Union

territories, as under:—

(i) the pre-test of Population Enumeration in selected sample areas shall be conducted from 6th July,

2026 to 18th July, 2026, with a revisional round from 19th July, 2026 to 20th July, 2026.

(ii) there shall be an option for self-enumeration from 1st July, 2026 to 5th July, 2026.

[F. No. 9/8/2025-CD(Cen)]

MRITUNJAY KUMAR NARAYAN, Registrar General and Census Commissioner, India.

DPSE/IV/PopulationCensus-2027/1/2025-26/1078

Date : 06-Jul-2026

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