Chapter XVI - Liability to pay in certain cases
Section 92
Section 92: Liability of Court of Wards, etc.
Section 92 addresses GST recovery from specified controllers or managers of a taxable person’s estate and business.
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Need advice on Section 92?
This article is for general information. Refer to the Central Goods and Services Tax Act, 2017 official text for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
Where the estate or any portion of the estate of a taxable person owning a business in respect of which any tax, interest or penalty is payable under this Act is under the control of the Court of Wards, the Administrator General, the Official Trustee or any receiver or manager (including any person, whatever be his designation, who in fact manages the business) appointed by or under any order of a court, the tax, interest or penalty shall be levied upon and be recoverable from such Court of Wards, Administrator General, Official Trustee, receiver or manager in like manner and to the same extent as it would be determined and be recoverable from the taxable person as if he were conducting the business himself, and all the provisions of this Act or the rules made thereunder shall apply accordingly.
Introduction
When a taxable person’s business estate is managed under the listed legal arrangements, the managing body or person can face GST assessment and recovery.
Key takeaways
Covered control
Court of Wards, Administrator General, Official Trustee, and a court-appointed receiver or manager are listed.
Business manager
The provision includes a person who in fact manages the business, regardless of designation.
Extent
Dues are levied and recovered as they would be from the taxable person conducting the business.
Covered control
Court of Wards, Administrator General, Official Trustee, and a court-appointed receiver or manager are listed.
Business manager
The provision includes a person who in fact manages the business, regardless of designation.
Extent
Dues are levied and recovered as they would be from the taxable person conducting the business.
Practical checklist
Do
- Identify the order or arrangement transferring control.
- Document management period and business transactions.
- Maintain GST records and liabilities for that period.
Avoid
- Assume a private contract, merger date or restructuring automatically removes statutory GST liability.
Frequently asked questions
Can a de facto manager be covered despite another title?
Yes. The section expressly includes a person who in fact manages the business.
Need help applying this provision to your situation?
Contact BizeneedLast updated 10 October 2026