10 SUGGESTIONS FOR SIMPLIFICATION OF GST LAW, PROCEDURES & FORMS to provide ease of business to dealers & to make GST simple.

1. FOR LATE FEES Refund of all late fees for all GSTR 3B filled upto period March 2019. It was anyways waived for some very late fillers lately. Otherwise it will be injustice to those who have been late in filling only few days & paid LATE FEES.

2. FOR CASH LEDGERELECTRONIC CASH LEDGER should be one basket. CASH ledger should be made with NO MORE TAX HEADS like IGST, CGST, SGST, CESS AND also NO MORE SUB-TYPES like TAX, INTEREST, FEES, PENALTY & OTHERS.. As of now, 20 baskets when one pays challan on GST portal. Only one single cash balance approach. This was also decided in One GST meeting.

3. FOR RCM RCM should be only applicable to REAL ESTATE industry.

4. FOR INTEREST ON LATE PAYMENTS in GSTR 3B – Let system do calculations of Interest payable on GSTR 3B late filling. Same like it calculates Late fees. Of course Interest on NET Liability. & retrospectively this provision should be amended so as to make Interest liability only on NET tax liability.

5. FOR REVERSAL OF ITC IF NON-PAYMENT in 180 DAYS –Delete the provisions of Reversal of ITC in case of non payment to Creditors within 180 days and interest thereof if late reversal. Or make it applicable to only Dealers having Turnover more than 100 Crores.

6. FOR MAXIMUM LATE FEES –The late fees for late filing of Returns should not be more than NET Tax Payable. (Moreover, Late fees should be only from 2019-20. Please Refund late fees collected for FY 17-18 and 18-19).

7.FOR PENDING ITC OF PREVIOUS YEAR – The Dealers should be allowed to take eligible ITC before filing the Final Return (Annual Return) for every coming FYs.

8.FOR MONTHLY/ QUARTERLY RETURNS – Instead coming with old formula of GST returns with new names, Please continue with GSTR 1 and GSTR 3B. Also Allow to upload ITC details in a new simple self- declared Form Same like Outward supplies we upload as of now. Let system makes GSTR 3B automatically from All self declared OUTWARD & INWARD supplies.For, ITC matching, Let system do matching just like Gujarat VAT website used to have ITC Profile.

9. FOR GSTR 9 & 9C –Table 8, 17, 18 of GSTR 9 should be removed. Table of HEAD WISE ITC Presentation in GSTR 9C should be removed.

10. FOR PORTAL – The capacity and speed of GST website should be increased. State wise Portal can be made to have smooth functioning. Also change in User interface to allow to view more than 5 line items on one screen and Able to see all invoices even if more than 500 invoices.

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