Indirect Tax Laws · Miscellaneous Provisions (GST)

Transitional Provisions: Section 142 of the CGST Act Overview

Updated 5 October 2026

Section 142 of the CGST Act is the catch-all transitional section. It covers pre-GST matters not handled elsewhere: price revisions under old contracts, goods returned after 1 July 2017, refunds, and pending assessments, appeals and recoveries under the existing law. To solve a question, fix the dates, identify the event, and apply the matching rule.

Understand Transitional Provisions: Section 142 Overview

GST started on 1 July 2017, called the appointed day. Many transactions began under the old laws (Central Excise, VAT, Service Tax) and ended after GST began. Sections 139 to 141 deal with credit, migration and stock. Section 142 handles everything else that straddles the date.

Think of section 142 as a bundle of separate rules. Each rule answers one question: what happens when a pre-GST contract has its price changed, goods sold earlier come back, a refund was claimed under the old law, or a case is still pending?

The main groups are these:
- Price revision of old contracts. For a contract entered into before the appointed day, an upward revision made on or after that day leads to a supplementary invoice or debit note. It must be issued within 30 days of the price revision, or such further period as the Commissioner may allow on sufficient cause. A downward revision leads to a credit note, issued under the section's conditions. The credit note relates to supplies made before the appointed day. It reduces the supplier's output tax liability only if the recipient has reduced his input tax credit by the corresponding amount.
- Goods returned (s.142(5)). Goods removed before the appointed day and returned within six months from it. If a person other than a registered person returns them, no tax is payable. If a registered person returns them, he is liable to tax as on a supply. The original supplier may reduce his tax liability only if the goods are identifiable to the satisfaction of the proper officer.
- Refunds under existing law. Refund claims for tax paid under the existing law are disposed of under the old law. This covers claims filed before the appointed day (s.142(3)) and claims filed after it for the pre-GST period (s.142(6)(a)). The sanctioned amount is paid in cash, unless the existing law provides for refund in another form. Any rejected amount lapses. It is not credited to the electronic credit ledger.
- Pending proceedings. Assessment or adjudication proceedings relating to the earlier period continue under the existing law (s.142(6)(b)). So do appeals, reviews and revisions (s.142(7)). An amount found recoverable that is not recovered under the existing law is recovered as an arrear of tax under GST (s.142(8)).

The key idea is that the old law governs the old tax, and GST governs the new documents. For example, a debit note issued for a pre-GST contract after the appointed day is treated as an outward supply under GST. A refund of old tax is not paid as GST credit. It is paid in cash, unless the existing law provides another form.

The detailed rules on refunds and recovery, returned goods and contracts, and pending assessments and appeals are each covered in separate topics. This page gives you the map. Learn it first, then learn the detail.

Key rules to remember

Appointed day: Appointed day = 1 July 2017; Every section 142 question turns on whether an event falls before or after this date. Mark it first.
Upward price revision of a pre-GST contract: Contract entered into before 1 July 2017 + price revised upward on or after 1 July 2017 → supplementary invoice or debit note within 30 days of the revision (or such further period as the Commissioner may allow on sufficient cause); The 30-day rule applies only to upward revisions of contracts entered into before the appointed day, where the revision is made on or after it. The Commissioner may allow a further period on sufficient cause, so do not call the limit absolute. The document is treated as an outward supply under GST. Count the 30 days from the date of price revision, not from the original invoice.
Downward price revision of a pre-GST contract: Supply made before 1 July 2017 + revision on or after the appointed day → credit note issued under the section's conditions, and the supplier's output tax liability is reduced only if the recipient has reduced his credit accordingly; The credit note relates to supplies made before the appointed day. The supplier's output tax liability reduces only if the recipient has reduced his input tax credit by the matching amount. Check this condition in every answer.
Refund claims under existing law: Refund claim for tax paid under the existing law, filed before the appointed day (s.142(3)) or filed after it for the pre-GST period (s.142(6)(a)) → disposed of under the existing law; sanctioned amount paid in cash; The amount is paid in cash unless the existing law provides for refund in another form. Any rejected amount lapses. It is not credited to the electronic credit ledger, and it is not paid as GST credit.
Pending proceedings: Assessment or adjudication for the pre-GST period (s.142(6)(b)), or appeal, review or revision (s.142(7)) → continues under the existing law; amount found recoverable but not recovered under the existing law → recovered as an arrear of tax under GST (s.142(8)); Assessments, adjudication, appeals, reviews and revisions continue under the existing law. An amount found recoverable which is not recovered under the existing law is recovered as an arrear of tax under GST, as provided in s.142(8). Do not say that every recovery is a GST arrear.
Goods returned after the appointed day: Goods removed before 1 July 2017 and returned within six months from 1 July 2017 (s.142(5)) → if returned by a person other than a registered person: no tax payable; if returned by a registered person: he is liable to tax as on a supply, and the original supplier may reduce his tax liability only if the goods are identifiable to the satisfaction of the proper officer; The result depends on the removal date, the six-month period and whether the returner is registered. For a return by a person other than a registered person, no tax is payable. The identification condition belongs to the case of a return by a registered person: the returner is liable to tax as on a supply, and the original supplier may reduce his tax liability only if the goods are identifiable to the satisfaction of the proper officer.

How to solve Transitional Provisions: Section 142 Overview questions

Use the same method for any section 142 question. It keeps your answer in provision-facts-conclusion form.

1Mark the appointed day, 1 July 2017, and place every date in the case on one side of it.
2Identify the event: price revision, goods return, refund, pending assessment, appeal or recovery.
3Name the rule that fits the event, in plain words. State that section 142 applies as a transitional provision.
4Check the conditions: time limit (30 days or six months), who the person is (registered or not), and the recipient's credit reduction.
5Decide which law applies: the existing law for the old tax, GST for the new document such as a debit note or credit note.
6Compute any date or amount. For a 30-day limit, count from the revision date.
7Write the conclusion: what document to issue, who pays or gets the refund, and in what form (cash or credit).

Quickest way: Date, event, law: three-line check

When to use it: Use it for short MCQs and for the first line of a written answer when time is tight.

Date: is the key event before or after 1 July 2017?
Event: price change, return, refund or pending case? Match it to one of the four groups.
Law: old tax goes by the old law and cash refund. New documents (debit note, credit note, supplementary invoice) are GST documents.
Then test the one condition: 30 days for a debit note on an upward revision of a pre-GST contract, recipient's credit reduction for a credit note, six months for returned goods and whether the returner is registered.

Common mistakes in Transitional Provisions: Section 142 Overview

Counting the 30-day limit from the original invoice date.
Students link the limit to the invoice because most invoice rules run from the invoice date.
Fix: Count from the date the price is revised. The original invoice only tells you the contract was a pre-GST one.
Allowing a credit note for a downward price revision without checking the recipient.
The credit note rule in regular GST looks unconditional to students.
Fix: Always state that the credit note is allowed only if the recipient reduces his credit by the corresponding amount.
Applying GST to the tax on old supplies.
Students think that because the question is in a GST paper, GST law governs every part of it.
Fix: Separate the two. The old tax, its refund and its pending proceedings follow the existing law. Only the new documents, and recoveries where the section so provides, are under GST.
Giving a refund of old-law tax as ITC in the electronic credit ledger.
Students confuse carry-forward of credit with a refund claim.
Fix: State that the refund under section 142 is paid in cash, in accordance with the existing law. A rejected amount lapses and is not credited to the ledger.
Mixing up sections 139 to 141 with section 142.
All are under the transitional chapter and the headings sound alike.
Fix: Remember the split. Sections 139 to 141 deal with migration, credit and stock. Section 142 is the miscellaneous residue.
Writing section 142 sub-section details from memory without the conditions.
The section has many clauses and students cram the numbers.
Fix: Learn the rule and the condition in plain words. Give a sub-section number only when you are sure of it.

Worked examples

Example 1

A supplier who was registered under the existing law (migrated to GST) issued an invoice on 20 June 2017 for ₹10,00,000 under a contract signed in March 2017. On 10 September 2017 the parties agreed to revise the price upwards by ₹50,000. By which date must the supplier issue the supplementary invoice or debit note? How is it treated?

Show the solution

Provision: section 142 deals with upward price revision of a contract entered into before the appointed day, where the revision is made on or after it.
Facts: the contract and original invoice are before 1 July 2017. The price revision is on 10 September 2017, which is after the appointed day.
Time limit: the supplementary invoice or debit note must be issued within 30 days of the price revision.
Computation: 30 days from 10 September 2017 ends on 10 October 2017.
Treatment: the document is treated as an outward supply under GST.

Answer: The supplier must issue the supplementary invoice or debit note on or before 10 October 2017. It is treated as an outward supply under GST.

Example 2

A manufacturer supplied goods to a dealer and issued the invoice on 15 June 2017 under a pre-GST contract. After 1 July 2017, the price was revised downwards by ₹40,000. The manufacturer wants to issue a credit note. What must he check, and what is the conclusion if the dealer does not reduce his credit?

Show the solution

Provision: section 142 allows a credit note, issued under the section's conditions, for a downward price revision of a pre-GST contract made on or after the appointed day.
Facts: the supply and invoice are before 1 July 2017, so the credit note relates to a supply made before the appointed day. The price revision is after 1 July 2017.
Condition: the manufacturer's output tax liability reduces only if the recipient has reduced his credit by the corresponding amount.
Application: if the dealer does not reduce his credit, the condition is not met.
Conclusion: the credit note cannot be used to reduce the manufacturer's output tax liability.

Answer: The manufacturer must confirm that the dealer has reduced his credit by the corresponding amount. If the dealer does not, the credit note is not allowed for the purpose of reducing the manufacturer's output tax liability.

Exam tips

Scan every date in the case. If both dates are before 1 July 2017, section 142 is usually not the point being tested.
In MCQs, look for the 30-day limit and the recipient's credit reduction. Examiners use them as the trap.
In written answers, state provision, facts and conclusion in three short parts, and finish with the document or refund form.
Learn the four groups as a list: price revision, returned goods, refund and pending proceedings. A one-line mention of each earns marks in theory questions.
Practise with the three linked topics on refunds and recovery, returned goods and contracts, and pending assessments and appeals.

Practice questions from Miscellaneous Provisions (GST)

Transitional Provisions: Section 142 Overview: frequently asked questions

What is section 142 of the CGST Act in simple words?

It is the miscellaneous transitional section. It tells you how to treat price revisions, returned goods, refunds and pending cases that began under the old laws but were completed after GST started on 1 July 2017.

How is section 142 different from sections 139 to 141?

Sections 139 to 141 deal with migration of registrations, carry-forward of credit and treatment of stock. Section 142 covers the remaining matters, such as price changes, refunds, returns and pending proceedings.

Is a refund claim under the old law paid as credit?

No. A refund claim for tax paid under the existing law is decided under the existing law and the sanctioned amount is paid in cash. A rejected amount lapses and is not credited to the electronic credit ledger.

Do I need to remember the sub-section numbers of section 142?

Not necessarily. Examiners usually test the rule and its conditions. Quote a sub-section number only if you are certain of it. Otherwise write 'section 142' and state the rule in plain words.