☐ Has cash ledger been adequately funded? ☐ Has credit ledger been managed accurately? ☐ Has utilisation order been observed? ☐ For above Rs. 50 lakh monthly turnover, has Rule 86B been applied? ☐ For Rule 86B exceptions, has framework…
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☐ Has cash ledger been adequately funded? ☐ Has credit ledger been managed accurately? ☐ Has utilisation order been observed? ☐ For above Rs. 50 lakh monthly turnover, has Rule 86B been applied? ☐ For Rule 86B exceptions, has framework…
Section 49 compliance — checklist (19 items)
Section 49 compliance — checklist (19 items)
☐ Has cash ledger been adequately funded?
☐ Has credit ledger been managed accurately?
☐ Has utilisation order been observed?
☐ For above Rs. 50 lakh monthly turnover, has Rule 86B been applied?
☐ For Rule 86B exceptions, has framework been verified?
☐ For inter-Government cash transfer, has PMT-09 been used?
☐ Has coordination with s. 50 interest been done?
☐ For excess payment, has refund framework been engaged?
☐ Has Bharti Airtel substance-over-form discipline been applied?
☐ Has Mafatlal procedural-fairness framework been observed?
☐ Has Mohit Minerals constitutional framework been applied?
☐ Has Vatika prospective-operation been applied?
☐ Has Modern Dental proportionality framework been applied?
☐ Has documentary trail been preserved?
☐ Has coordination with broader compliance framework been done?
☐ Has Whirlpool framework been considered for disputes?
☐ Has Maneka Gandhi procedural-fairness been applied?
☐ Has the file been reviewed for audit-defensibility?
☐ Has coordination with State / UTGST parallel framework been done?
Worked examples — five live scenarios
Example 1 — Standard ledger management
Facts: Taxpayer makes timely tax payment using credit ledger 80% + cash ledger 20%.
Analysis: Compliant payment framework. Utilisation order observed. Standard discipline.
Result: Compliant.
Example 2 — Rule 86B 99% cap
Facts: Taxpayer monthly turnover Rs. 80 lakh. Attempts 100% credit ledger payment.
Analysis: Rule 86B — 99% cap. 1% must be through cash ledger. Practitioner advice — split payment.
Result: Rule 86B framework operates.
Example 3 — Rule 86B exception (Income-tax)
Facts: Same taxpayer; paid Income-tax > Rs. 1 lakh in last 2 years.
Analysis: Rule 86B exception applies. Full credit ledger payment permitted.
Result: Exception framework.
Example 4 — PMT-09 inter-Government transfer
Facts: Excess CGST cash ledger balance. Transfer to IGST cash ledger needed.
Analysis: Sub-s. (10) + PMT-09 framework. Inter-Government transfer permitted.
Result: Operational flexibility.
Example 5 — Excess payment refund
Facts: Excess tax payment. Refund framework engaged.
Analysis: Section 54 + Mafatlal unjust-enrichment framework. For passing-on of incidence, Consumer Welfare Fund.
Result: Refund + unjust-enrichment framework.
Planning and litigation strategy
Litigation defence
Cross-references