Rajkot Chamber Of Commerce & Industry has made a representation to Finance Minister on some of the procedural issues on GST, which includes issues related to 3B Return submission / Revision, Extension of Due date for filing 3B for the Month of September 2017, Filing of GST 2, Cancellation of GST Registration, Trans-1 Return and Extension of Composition Scheme.
RCCI/242 Dated: October 16, 2017
Shri Arun Jaitley
Hon. Finance Minister & Chairman GST Council,
Government of India,
Sub : A request to revise some of the procedural provisions under GST.
We are an apex institute, representing the entire region. Recently our Association Member “Tax Bar Association” has submitted a representation on some of the procedural issues on GST. They are the consultants & rendering their professional services to the business communities. They have felt some genuine problems under GST & we believe that when any expert body on the issue represent the problems, then the issues are genuine in nature.
Therefore, we are submitting the following points for consideration please.
(1) While submitting the return 3B, there must be provision of submission after offsetting the liabilities, at present submission is prior to offsetting liabilities.This provision to offset line will give clear picture on rightness of return.
(2) Each returns should allowed to revise, the present provision is very harsh as revision of Return is not allowed. The Act is new & still it is under setting process & neither experts nor businessmen have understand it properly. Mistakes bound to happen, so to file revised return must be allowed.
And most essentially Return 3B must be allowed to get revised. There should not be any time limit for such revisions.
(3) There should be an extension of final date for Sept. 17-3B from 20-10-17, as the festive season is on & the biggest festival of Dipawali is 19-10-17, therefor, 20-10-17 is a new year day. Looking to all these the 20-10-17 should be extended.
(4) There is always a mis-match between the declaration on any modified provisions & notifications thereupon. This causes a lot of problems for business communities. Therefore, the press release must be the date of notification. The notification must be released on the day of any declaration.
(5) To ease the procedural process all the three monthly returns must be allowed to get uploaded at the same time & there should be a time of at least 45 days after the completion of month to file the returns. In addition, the date of filing returns & to pay tax should not be same. This will give advantage, as un-necessary waste of time of the professionals will be cut. The user friendly programme is the need of the hour.
(6) GSTR-2 must be allowed to get up-loaded & there should be no need to reconcile (matching provision) so that the waste of time can be reduced.
(7) Those units who want to cancel its GST No, don’t have on line form available on the portal. So this cancellation form should be made available on the portal at the earliest.
(8) Still there are so many issues to be resolved & therefore, any punitive provisions must be held back till Mar-18. There should not be any late fee or penalty for any late filing. Those who have paid late fee must be given back late fee by crediting their ledger.
(9) The TRANS-1 return must be allowed to get revised & even format need to modify as there is no need of any details on Form “C” therefore, the details of form “C” must be removed from the format. There is no need of any details of “Statutory” form in theTRANS-1 & such issues can be cleared through local authorities.
(10) There should be extension of “Composition Scheme” so that those who are not having taken the advantage, can avail the benefit of the scheme.
Hope that this letter will be viewed in a proper context and due steps will be taken.
V. P. Vaishnav
Copy to : (1) Shri P. D. Vaghela Saheb, Commissioner GST, Government of Gujarat, Ahmedabad.
(2) The PMO Office, Government of India, New Delhi.