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CMA Intermediate · Direct and Indirect Taxation · Exemption from Tax

A notification dated 1 July 2026 exempts a specified service absolutely. Within one year, on 15 March 2027, the Government inserts an Explanation in it to clarify its scope. From which date does the Explanation have effect?

The Explanation takes effect from the original notification's date, as if it had always formed part of it. Section 11(3) gives this retrospective effect when the Explanation is inserted within one year of issuing the notification.

  1. AFrom 15 March 2027, the date of the Explanation
  2. BFrom the date of the first notification, as if it had always been part of itCorrect
  3. CFrom 1 April 2027, the start of the next financial year
  4. DFrom the date on which it is laid before Parliament

Explanation

Under section 11(3), an Explanation inserted by notification within one year of the original notification has effect as if it had always been part of the first notification. The date of insertion (15 March 2027) is therefore not the effective date.

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