The central government's clarification on the 2 per cent equalisation levy on foreign digital operators in the Budget, which considerably expands the scope of the levy, might be challenged in court, with several companies contemplating filing a writ petition in the coming few weeks. The writs might be filed on the grounds of the levy's alleged extra-territorial overreach, as it aims to cover those entities that do not have a physical presence in India, going against international taxation rules.

It is likely to be a stormy affair with divergent views on market borrowing. Centre will likely press states to borrow to make up for the shortfall, but states want either the Centre or the GST Council to do so.

A slew of challenges that are yet to be resolved include the lack of consensus between the Centre and states over the GST exemption threshold limit, dual control over scrutiny and assessment