CA Vinod Kaushik
As per Wikipedia the Harmonised Commodity Description and Coding System, also known as the HSN (Harmonised System Nomenclature) is an internationally standardized system of names and numbers to classify traded products. These codes are basically used to fix rate of tax on various products at the time of export and import. In Indian context it is proposed to use HSN codes at invoice level to make taxation system of international standard. Under GST supply invoices will be made by capturing hsn codes in case of goods and service accounting codes in case of services.
Though internationally HSN code is of 6-8 digits but in our context HSN code of 4 digits will be mandatory initially for taxpayers having turnover more than 5 crore. Turnover will be taken on self declaration basis for IST year and afterwards turnover of previous year shall be used. In return form rate of tax shall be auto populated based on the HSN codes used in furnishing invoice level purchase or sale information. After completing first year under GST the turnover for previous year will be considered as yardstick for using HSN codes of 4 digits. The use of HSN codes below its standards is to make GST systematic and globally accepted.
For taxpayers with turnover between Rs 1.5 Crores and Rs 5 Crores in the preceding financial year, HSN codes may be specified only at 2-digit chapter level as an optional exercise to start with. From second year of GST operations, mentioning 2-digit chapter level HSN Code will be mandatory for all taxpayers with turnover in previous financial year between Rs. 1.5 Crores and Rs. 5.0 Crores. HSN code at 2 digit will be little easy for taxpayers and make GST an international compatible tax.
HSN codes at 08 digits will be mandatory in case of export and imports. The GST law has to be compatible with international standards. The concept of HSN codes was invented outside India and same is used by various member countries. The above parameters with respect to HSN code for goods and Accounting Code for services will apply for submitting the information in return relating to relevant invoice level information for B2B supplies (both intra-state and inter-state) and inter-state B2C supplies (where taxable value per invoice is more than Rs. 2.5 lakhs).
In case goods and services are identified through their unique codes i.e. international too the chances of misinterpretation are very low. Again the taxpayers are not required to submit description of goods and services tax in return as the same is to be obtained from invoices which are made on the basis of HSN codes and accounting code.
Though certain limits have been fixed for mandatory use of HSN codes and service accounting code but any taxpayer can use these optionally if he desires. The small classes of dealers who have opted composition scheme are even not required to use HSN codes of 2 digits. The HSN code will be used in case of goods and accounting code will be used in case of services.
For all B2B transactions (Inter-state and intra-state) invoice level specified details will be uploaded i.e. every invoice issued by the taxpayers will form part of GST return. For all B2C transactions it will be mandatory to upload invoice wise information if it exceeds 250000/-. The level of compliance proposed in GST law seems very systematic but required enough preparation for professionals and taxpayers. At last in my personal opinion the national impact of Bihar assembly election (Defeat of PM Modi) will be little negative for rollout of GST from 01-04-2016.
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