21 Suggestions for Simplification of GST

Suggestions for Making GST, Sweet & Simple.

Contents at a Glance:

1. Registration for All Traders & Service Providers, with Exemption, for Small Scale Suppliers from Collecting & Remitting GST:

2. Exemption (Threshold) Limit May Cover Inter-State Sale also

3. Abolition of Casual Trader Category

4. Single Point Registration and One GST Regn. No. for PAN-India Operations.

5. Free Billing Software from GSTN and Invoice Format

6. Free Purchase Register Software From GST Network & Register Format.

7. Composition Scheme should be extended to Service Providers and for Inter-state Supplies also.

8. Input Relief should be extended to all Supplies, except Sin Goods & Services:

9. Tax Payment Under Single Head can be done by Dealer and Classification under various sub-heads may be done by GSTN:

10. Simplification of GST Returns & Matching/ Reconciliation System:

i. The Dealer must be made to file only a Simple Sales / Supply Statement and Purchase Statement and a Response Statement on Monthly or Quarterly basis. The remaining things (analysis) should be taken care of by the GSTN System.

ii. Dealer may file a Single- Tile Worksheet for Sales/ Supplies in GSTR1 (Provisional) Format &

iii.  A Single- Tile Purchase Return (GSTR2- Provisional) Format.

11. Both Provisional Returns may be filed by 10^th of the following Month/ Qtr.

12. Matching & Reconciliation by GST Network:

i) GSTN System may generate GSTR1 M (Mis-match Statement, based on comparison with Counter-parties’ GST Returns.

ii) Dealers to submit Response Statement by 25^th, based on which Finalised GSTR 1 & GSTR2 statements would be generated/ Uploaded by GSTN.

13. The Consolidated GSTR3 Return may be filed by the 30^th of a Month, based on Figures Auto-populated by GSTN from Finalised GSTR1 & 2.

The Other GST Returns can also be suitably brought on these lines.

14. Electronic Ledgers to be maintained by GSTN:

i) Electronic Cash Ledger,

ii) Credit Ledger,

iii) ITC Ledger

iv) GST Liability Ledger &

v) Interest/ Penalty Ledger, for each Dealer and make available these for viewing.

15. Penalty/ Interest Debits may be generated by GSTN System.

16. GSTN can generate a Tax Statement every month, like Credit Cards Statements. & Extract of GST Liability Ledger: (Formats Given) and this would serve as “Tax Demand/ Tax Status Report”.

17. Dealers to pay Self- Assessed GST on 20^th of a Month and square off the difference liability, based on the Tax Statement of GSTN.

18. For Purchase From Unregistered Dealers, PAN may be insisted upon.

19. Reverse Tax Mechanism –Exempt Services may be excluded from levy of Reverse Tax. Reverse Tax would be added to Liability by GSTN and auto- Reversed by GSTN in the following month.

20. GSTN may cover Real Estate, Petroleum Products as well:

21. GST Rates; Some Suggestions.

GST- Suggestions for Simplification

GST is a landmark legislation in independent India and every Indian should be proud of it. This has brought the concept of “one Nation- One Tax” in our country. The Convergence of multiplicity of taxes (about 17) and harmonizing the varying interests of several States & Union Territories is a phenomenal achievement, to say the least. To enact a law, that takes care of several concerns is a herculean task and a bold initiative has resulted in the enactment of this masterpiece legislation.

While the idea is great and laudable, still if it should meet with success and get willing acceptance of the Traders & Public, it should be simple, convenient & easy to operate.

This Goods & Services Tax can really become a Good & Simple Tax, as described by our Honourable Prime Minister Shri Narendra Modi, if the Compliance is rendered easy, avoiding needless complications. The Govt. has taken measures to improve ease of doing Business. in this context, it is very important that the Compliance burden should be considerably reduced, and our energies conserved for greater things than in carrying out routines. Both at Concept level and Compliance level, there is scope for a lot of simplification to make GST, a sweet pill. One of the ideal canons of taxation is “Simplicity” and we can work towards that.

Frankly, some sweeping Changes are required to make the present GST Law, sweet and simple.

Let us look at some aspects where we can attempt this simplification.

1. Registration for All Traders & Service Providers, with Exemption, for Small Scale Suppliers From Collecting & Remitting GST:

As in the case of Income Tax Permanent Account Number, GST Registration can be extended to all willing persons.

Just as every PAN Holder need not pay IT, so also, every Registrant need not charge GST or remit the same. Only if the Turnover crosses the threshold Limit ( now Rs.20 Lacs in general  & Rs.10 Lacs. in Specified Territories like the North East), GST  should be charged and remitted. Those within the threshold Limit may be named “ Small Scale Suppliers”. It can even be insisted that they have to  prominently state on their Invoice “ Small Scale Suppliers”.

Returns Filing may be made “Optional” for those within the threshold Limit. (Only if any Notice is issued by the Dept., they need to reply the same). The Reasons are :

i. Since they would not collect GST, no GST would be collectable from them .

ii. They would neither avail Input Credit on their Purchases, nor pass on Input Credit to their Buyers.

If at all required, they may be asked to file Annual Return. Besides Tax Professionals, the Govt. can also train GST Tax Preparers, who can assist Small Scale Dealers for filing GST Returns at nominal Fees.

Besides Tax Professionals, the Govt. can also train GST Tax Preparers, who can assist Small Scale Dealers for filing GST Returns at nominal Fees.

Advantages:

i). Even Small Traders (below the threshold Limit) would able to remain in business and supply to big Dealers, without forcing the latter to pay Reverse Charge.

ii) Small Traders need not have to collect Tax and pay it, but remain hassle- free.

iii) Since Small Traders also have GSTIN, they would be under the GST Umbrella and their Transactions can also be kept track of.

2. Exemption (Threshold) Limit May Cover Inter-State Sale also:

Presently, if a Dealer makes even a single Inter-state Sale, he is not entitled to avail the benefit of threshold Limit and Composition Scheme.

This impediment can be removed. Whether local Sales or Inter-state Sales, there should be no discrimination. If, in aggregate, the Inter-state & Intra-state turnover is within the threshold Limit, they should be treated as “Small Scale Dealers” and should be entitled to the concessions available to similar Intra- State Dealers.

Moreover, whether it is Supply of goods or Services, they should be in the same footing.

3. Abolition of Casual Trader Category:

If any Trader can apply for and get GST Registration (as per Suggestion 1 above), there is no need for a person to get Registered as a Casual Trader and specify the time limit for his trading activity. So, a separate Categorisation as casual Trader may be dispensed with.

4. Single Point Registration and One GST Registration Number for PAN-India Operations.

Presently, a Dealer having his presence in different States has to get registered separately in each State. This can well be avoided. There can be a Single GST Registration No., that can apply for the whole of India. If we can have one Currency, One Aadhaar No. & one IT PAN, Can’t we have one GSTN for a Dealer, wherever he operates within the Country? If felt necessary (for analysis purposes), the State Code / Union Territory Code may be suffixed to the common GSTIN.

5. Free Billing (Invoicing) Software from GSTN & Billing Format

GSTN can provide an Optional Billing Software, which can be adopted especially by Small & Medium scale operators. The Required Columns may be provided for filling relevant data. Facility for both off-line & On-line Billing may be given.

 If on- line Billing is selected, the GST Rate can be automatically displayed (auto-populated) against the HSN Code/ SAC., by GSTN, by accessing the GST Rates Finder. (If possible, the GSTN System itself can auto-populate the HSN Code/ SAC for the Item Specified, but sometimes, this can pose problems as the Item Descriptions may not match. So, the Dealer may be asked to furnish the HSN Code/ SAC.)

Similarly, considering the Place of Origin & Place of Supply, GSTN itself should flash the IGST or CGST/ SGST or UTGST element and amount of GST applicable for the transaction.

Provision can also be given for manual feeding of the Rates & Type of Tax, to take care of situations like Connectivity problems/ Network Failure, etc. But, later when GSTN System generates the Tax Demand Note (as suggested later), the System- generated Rate would form the basis of Calculations.

The Billing Format can be as under:

Name Of Supplier		Bill No.:
GSTIN of Supplier		Date :
Type of Supplier  (whether General or Composition):		State/ UT Code
Address;
Contact Ph. Nos.
Mail Id’s

 –

Sl. No.	Receiver	GSTIN of Regd. Receiver/ PAN, if applicable, of Unregd. Receiver	Place of Despatch (Origin)	Place of Supply (Destination)	State/UT Code of Destination	Description of Supply	HSN Code/ SAC	Value of Supply Rs.
Col. 1	2	3	4	5	6	7	8	9

–

GST Rate/ Special / Nil Rate, if applicable.	IGST Rs.	CGST Rs.	SGST Rs	UTGST Rs.	Cess Rs.	Others, if any	Total Rs.	Remarks, if any.
Col. 10	Col. 11	12	13	14	15	16	17	18

In Col 4, If PAN is not available, it may be left Blank.

If GSTIN is not there, it can be taken as Supply to Un-Registered Dealer or To Consumer (Bto C).

A Dealer having Supply Points/ Branches in Several States/ UTs., will have separate serial No. Sequence for each supply point.

Advance & Advance Adjustment? Early Shipment cases: Since GST Law provides that Advance, if paid earlier or Shipment, ahead of raising Invoice would be liable to GST at the point of their occurrence, these transactions can also be billed with a suitable suffix A/D, etc., and when the actual Invoice is raised, these entries can be reversed with a Minus Value Entry, with Narration in the Remarks Column.

For Export Sales/ Supplies abroad, or those to EOU (Export Oriented Units)/ Export Processing Zones, etc., a Separate Serial- Numbered Invoices may be generated and suitable Changes in the Billing Format may be suitably made. 

6. Free Purchase Register Software From GST Network & Format:

Similarly, for Purchase Register also, a Software can be provided by GST Network. The Suggested Format is as under: (This would facilitate generation and uploading of GSTR-2 (Purchase) Return by the Dealers.

Sl  No	Bill No.	Date	Supplier	Type of Supplier- viz. RR/C/UR	GSTIN of Regd. Supplier/ PAN, if applicable of Unregistered Supplier	Place of Dispatch (Origin) & State/ UT/ Country Code	Place of Supply (Destination) & State/ UT Code	Description of Supply	HSN Code/ SAC	Value of Supply Rs.
C. 1 C.	2	3	4	5	6	7	8	9	10	11

 – 

Rate of GST applicable	IGST Rs.	CGST Rs.	SGST Rs	UTGST Rs.	Cess Rs.	State/ UT Code	Total Rs.	Reverse Tax, if applicable.	Other Remarks, if any.
12	13	14	15	16	17	18	19	20	21

Col 5. – RR= Regular Regd. Dealers. C = Composition Dealers. UR= Unregistered Suppliers.

Debit Notes, Credit Notes, Sales Returns & Purchase Returns, etc:

No need for a separate Register for these. These can be recorded/ accommodated in one of the above two Registers, as appropriate. (Minus Values should also be admissible with a prefix of Minus Symbol). 

7. Composition Scheme should be extended to Service Providers and for Inter-state Supplies also:

There is no logic why Composition Scheme should be confined to Traders, Manufacturers & Restaurants and denied to Service Providers. By extending Composition Scheme to Service Providers, the Compliance may improve and moreover, the Service Receivers may not get Set- off benefit of the GST on the Services availed. So, from Revenue point of view also, the Govt. may not stand to lose.

As earlier stated, whether it is Inter-State or Intra-State Supply and whether it it is Goods or Services, there should be no differentiation or discrimination, and the Composition Scheme should apply evenly for all.

8. Input Relief should be extended to all Supplies, except Sin Goods & Services:

GST paid on some services like Motor Cab Rentals, Transportation of Passengers, Restaurant Services have been specified as ineligible for Input Relief. It is not known as to what will be greatly achieved by this. The Law should be simple and straight forward with minimum twists & turns, bends and bunds on the road. Just as Input Relief has been rightly extended to Capital Goods and Trading Goods alike, so also any service and any goods (except SIN goods or Services) should in all fairness be made eligible for Input Credit.

Exceptions should be bare minimum, easy to remember and logical to understand.

9. Tax Payment Under Single Head can be done by Dealer and Classification under various sub-heads may be done by GSTN:

The Taxpayer should not be saddled with the burden of Classification of Payment under different heads, viz. IGST, CGST, SGST, UTGST, Interest, Penalty, etc., but should be allowed to remit under one common head, “GST” and the allocation to different heads of account should be done by GST Network. This would avoid mis-classification, Surplus in one account & Deficit in another and remitting under Multiple heads, etc.  

10. Simplification of GST Returns & Matching/ Reconciliation System:

This probably would be the most vital Area where Simplification of procedures should be of utmost importance, The Tax Payer must be able to file with a smile, but not put into cumbersome and complicated procedures.

10.1. The Dealer must be made to file only a Simple Sales / Supply Statement and Purchase Statement and a Response Statement on Monthly or Quarterly basis. The remaining things (analysis) should be taken care of by the GSTN System.

10.2. The Dealer should be made to fill only the following Information in the Provisional GSTR 1 Return (Sales/ Supply Statement). This Return can be named as GSTR 1 P, with Suffix “P” indicating Provisional Return.

(In fact, the Free Billing Software that can be provided by GSTN, as suggested in Suggestion 3 above, can facilitate this and auto-populate the Data to this Return.)

Sl. No.	Bill No.	Date	Receiver	GSTIN of Regd. Receiver /PAN, if applicable, of Un-Regd. Receiver	Place of Despatch (Origin) & State/ UT/ Country Code	Place of Supply (Destination)& State/ UT/ Country Code	Description of Supply	HSN Code/ SAC	Value of Supply Rs.	Rate 0f GST Applicable
Col1	2	3	4	5	6	7	8	9	10	11

–

IGST Rs.	CGST Rs.	SGST Rs	UTGST Rs.	Cess Rs.	State/ UT Code
Col. 12	13	14	15	16	17

Presently in GSTR1, the Assessee has to analyse & tabulate his Sales under multifarious heads and fill in the details in the Appropriate Tile/Tab (Worksheet).

a). Invoice-wise details of all

i) Inter-state and Intra-State Sales made to all Registered Persons

ii) Inter-state Supplies made for Invoice Value Exceeding Rs. 250000 made to Unregistered Persons

b) Consolidated Details of all

i) Intra-State supplies made to Unregistered Persons for each rate of tax and

ii) State-wise Inter-state Supplies for Invoice Value upto Rs. 250000 made to Unregistered Dealers for each rate of Tax

c) Debit and Credit Notes, if any, issued during the month for Invoices issued previously.

All the above complications can be removed and a Simple, Single worksheet can make available all the relevant Basic Information. The Analysis part can jolly well be handled by GSTN System.

10.3. Similarly, The Dealer should be asked to furnish in a Simple way, only the following information in the Provisional GSTR2 Return- Purchase Statement. The Figures from the GSTN Software, as suggested in Suggestion 3 can facilitate generation & uploading of this Return.

This Return can be called “ GSTR-2 P”, with “P” indicating “provisional Return”.

Sl. No	Bill No.	Date	Supplier	Type of Supplier- viz. RR/C/UR	GSTIN of Regd. Supplier/ PAN, if applicable of Unregistered Supplier	Place of Despatch (Origin) & State/ UT/ Country Code	Place of Supply (Destination) &State/ UT Code	Description of Supply	HSN Code/ SAC	Value of Supply Rs.
1	2	3	4	5	6	7	8	9	10	11

–

Rate of GST applicable	IGST Rs.	CGST Rs.	SGST Rs	UTGST Rs.	Cess Rs.	State/ UT Code	Total Rs.	Reverse Tax, if applicable.	Other Remarks, if any.
12	13	14	15	16	17	18	19	20	21

Col. 5 Abbreviations:

RR=Regular Registered Person

C= Composition Dealer

UR= Unregistered Dealer.

Notes:

a) If Supply is received from a Composition Dealer or Unregistered Person or from a Registered Person within threshold Limit, GST would be NIL.

b)Only for Purchase from Unregistered Dealer, Reverse Charge would apply.

c)For Imports, Separate Serial Numbered Purchase Invoices may be generated and the Format may be suitably modified to enter Customs Duty, IGST & other levies and Particulars, etc.

d)For Reverse Charge Cases, the GSTN system itself can generate the Reverse Charge Demand. In the following month, GSTN itself can generate the Reverse Charge Reversal Credit and compute the Tax Liability accordingly.

11. Time of Submission of Returns ; Both the Provisional GSTR1 & Provisional GSTR2 Returns may be required to be submitted on the 10^th of the following month/ Quarter.

12. Matching & Reconciliation by GST Network :

Based on the Provisional GSTR1 & Provisional GSTR2 Returns,  GSTN can match the Sales & corresponding  Purchase by the Counter-parties , based on their GSTINs  and generate the Mismatch Statement and upload / mail it to both the parties. This Statement can be named “ GSTRM” to denote  GST Returns Mismatch Statement. This Statement can be generated by the  15th of each month. The Concerned Dealers have to mark “Accept/ Reject/ Keep on Hold “ for each case and submit by 20th of the month. This Statement can be called “GSTRMR” Statement ( Mismatch Response Statement).

Based on this Response Statement, GSTN should generate a Finalised GSTR1 & GSTR2 Statements by the 25th of a Month.

13. The Consolidated GSTR3 Return may be filed by the 30^th of a Month.

 For this also, GSTN system can auto- Populate the total figures of Sales, Purchase, Input Relief, Reverse Charge, etc. and the type-wise Total GST liability, Amount adjusted and Balance at Credit/ Debit. If Balance tax is payable, the Dealer can pay the same in Electronic Cash Ledger and square off the Liability, as otherwise it would be carried forward to Next month and would attract Interest for the delayed payment. 

The Other GST Returns can also be suitably brought on these lines.            

14. Electronic Ledgers to be maintained by GSTN:

i. Electronic Cash Ledger: Tax Remittances received from Dealers get credited here. The amount transferred to GST Liability Ledger gets debited here.

ii. Electronic Credit Ledger: Based on Finalised GSTR2, the Input Credit, in total, should be Credited here. The Amount transferred to GST Liability Ledger may be debited here.

iii. ITC Ledger: Based on Finalised GSTR2, detailed ITC Ledger may be generated by the GSTN System.

iv. GST Liability Ledger (GST Payable Register):

v. Penalty/Interest Ledger: GST Network should maintain these Ledger a/cs. electronically for each Dealer, GSTIN-wise.

a. Based on Finalised GSTR1 Return, the Tax Payable should be picked up and recorded here as a Liability (by crediting GST Payable a/c., giving category-wise break-up, viz. IGST, CGST, SGST, UTGST, Cess, Interest, Penalty, etc.

b. Based on the Finalised GSTR 2, the GSTN System can compute the Reverse Charge (for Purchase from Un- Registered Persons) and add it to the Liability. Correspondingly, in the following Month, the GSTN system itself can reverse this and reduce from the Liability.

c. Credit available in Electronic Credit Ledger may be automatically transferred by GSTN System to this Ledger to off-set the Liability (by debit to the GST Payable a/c.)

d. Similarly, Credit available in Electronic Cash Ledger may be transferred by GST System to this Ledger, by debiting GST Payable a/c.

15. Penalty/ Interest Ledger: Penalty/ Interest Debits may be generated by GSTN System and added to the Liability, by crediting the GST Liability a/c. Subsequent waivers/ Reversals may also be recorded by GSTN System itself in this Ledger. It is desirable, if these Levies are intimated to the Dealers and an opportunity for representation, given to them.

16. Tax Statement of GSTN:

GSTN can generate a Tax Statement every month. Like Credit Cards Statements, this can show the Month Opening Balance, Tax Liability for the month, Tax Receipts/ Credits and adjustments during the month & the balance at Credit/ Debit at the end of the Month. GSTN System can compile this Statement, based on Electronic Cash Ledger, Credit Ledger & GST Liability Ledger. An Extract of GST Liability Ledger may also be generated along with this & uploaded for viewing by the Dealers. 

16(i)TAX Statement Of GSTN Month:

Sl.  No.	Electronic Ledger Type	Month Opening Balance Rs.	Additions	Transfers/ Deletions	Month Closing Balance Rs.	Remarks
1.	Cash Ledger
2	Credit Ledger
3	Penalty/ Interest Ledger
4	GST Liability Ledger

NB: If the Specified Mode of Payment is Quarterly, then “Month” can be substituted by “Quarter” in all places, wherever applicable.

Remarks, if any.:(Here, Due Date for Net Amount Payable, if any, and Interest for delayed Payment, etc. can be indicated. Details of Penalty/ Interest Levied May also be indicated.).

16(ii) Extract of GST Liability Ledger:

Sl, No.	Description	IGST Rs.	CGST Rs.	SGST/ UTGST Rs.	State/ UT Code	Cess	Penalty/ Interest Rs.	Total Rs.
1	Month/ Quarter Op. Balance
2	Payable For the Period
	Reverse Charge Payable
	Transfers from Cash Ledger
	Transfers from Credit Ledger
	Earlier Reverse Charge Reversible
	Balance Payable – Net

Explanatory Notes for Tax Statement of GSTN:

Note 1: Tax Remittances received from Dealers should be credited in the Electronic Cash Ledger. As suggested earlier in Suggestion 9, the GSTN System should allocate the GST payment, made under single GST Head to the concerned Sub- Heads, viz. IGST, CGST, STGST, UTGST, Cess, Interest & Penalty, etc., depending on the amount remaining payable under each head. If no amount is payable, the amount can remain in the Common GST a/c., pending allocation in future. The Allocation to the Sub- Heads needs to be done only at the time of Transfer to GST Liability a/c. (GST Liability Ledger).

Note 2: As far as ITC Credit is concerned, the Classification would be already available, based on the Purchase Booking. The amounts in Credit would be transferred to the respective sub-heads in the GST Liability Ledger.

Note 3: ITC Credit should be permitted to pay off even Penalties & Interest. There is no logic in insisting that these payments should be made only through Cash Ledger. Cash or Credit, why there should be discrimination?

Note 4: After considering all these, if there is a Net Liability, then, that would figure as the Balance Amount payable in the Tax Statement. In that case, the balance in Cash Ledger & Credit Ledger would be NIL.

 If on the other hand, there is surplus balance in Cash Ledger or Credit Ledger, the Net Amount Payable would be NIL and so also, the Liability Ledger Balance would be NIL.

17. Time of Payment of GST by Dealers:

As at present, Dealers may be asked to pay GST on or before the 20^th of the following Month based on their own Calculations/ Estimation. On Generation of Tax Statement by GSTN, the Excess/ Short payments may be adjusted in the subsequent period. In case of short payment, Interest @1% per r month may be levied, if felt desirable.

Advantages of the Suggested System:

1. The Cumbersome and complicated Procedures involved in calculations/ classifications/ analysis and tabulation by the Dealers would stand greatly simplified. The Dealer needs file a Simplified Purchase & Sales Register and pay tax in a Simplified way. The GST Network, with its vast technological capability would take a major burden of Analysis, Matching, Reconciliation, Input Relief and Reverse Charge calculations, etc. from the tax payer and make things simple for the Business Community as a whole and especially, for the Small & Medium Vendors.

2. The Rigours of calculation of Tax Payable, Input Relief Adjustment, Reverse Charge, application of Correct GST Rates and remittance under Right Sub-heads would all vanish and the GST network, on the other hand, would present the Dealer with Reliable Data and a Simple Tax Status Report.

3. Calculation Errors and Disputes would stand sizably reduced.

4. The present GST Returns have several Tiles/Tabs (Worksheets), since it contemplates the Dealer to classify/ analyse his Sale & Purchase Data under Several Categories. It is this that has made the GST compliance, a complicated one for the generality of Dealers. In a Computer assisted Environment, this data analytics may well be handled by GST Network and if Dealers are made to provide just the Basic Data alone correctly, then things would be a lot simpler. Anaysing transactions into several types, such as those above Rs. 2. 5 Lacs value, Purchases from Unregistered Dealers, Purchase From Outside State, etc. can all be avoided at the hands of the Dealers.

18. Purchase From Unregistered Dealers:

In case of Purchase from Unregistered Dealers, now Reverse Charge Mechanism comes into play. No doubt, this would discourage purchasing from Unregistered Dealers. But, this cannot help track the Unregistered Dealer. In such cases, if Dealers can be asked to quote the IT PAN of the Supplier, in the space provided for GSTIN in the Purchase Bill/ GSTR2 Return,  the Govt. may be able to track the Unregistered Supplier.

19. Reverse Tax Mechanism:

i)Where Service Providers like Advocates, cannot charge GST, there is no point in subjecting it to Reverse charge, at the hands of the Receiver, who eventually may take credit in the following month. The Exempted Cases may be exempted in toto without going through circuitous procedures.

ii) For Purchase from Registered Small Scale Dealers, (whose Turnover is within the Exemption Limit,), as stated earlier in Point No. 1, no GST would be payable on Purchase, But since they are also registered Persons, no Reverse Charge would be payable.

So, the Reverse Charge cases would be considerably reduced. If every Supplier comes under GST Net, the Reverse Charge can become “NIL’ and this would serve the object of discouraging purchase from Unregistered Dealers.

20. GSTN may cover Real Estate, Petroleum Products as well:

If full scale benefits of GST, as facilitator of One Tax- One Nation Concept, Transparency & avoider of Cascading Tax Effect, should be reaped, it should bring under its purview Sectors, which can contribute significantly to the exchequer, in terms of value, like Real Estate Transactions & Petroleum Products. The Stamp Duty and Registration Charges payable on Real Estate Transactions can be merged with GST.

21. GST Rates: While it would be ideal to have a Single GST Rate, practically it may be very difficult since the nature of Items vary very widely. There can preferably be four Rates, viz. Zero, 5% 12% & 18%. If desired, for SIN Goods like Cigarettes, etc, whose Consumption is sought to be restricted, in Public Interest, a Cess of 10% may be levied.

Conclusion: It is hoped that the suggestions would be given due consideration and the needful done, to improve ease of doing business and enhance public satisfaction.

(The author can be reached at gvmuruga26@gmail.com)

Gopalswamy Vaidyanathan 

B.Com, FCA, ACMA, ACS.,  ( FCA 19106). Chennai-600033. (M) +91 94444 56924.