Extension for date of Trans 1 to be understand very carefully –
As per CGST Rule, 2017 Rule. No. 117, 118, 119 & 120 Trans 1 has defined it’s timings for submission to the Govt. i.e. within 90 days from the appointed date = 28th Sep 2017.
Now a new Rule 120A has been introduced vide Notification No. 34/2017 dt. 15/09/2017 in which under clause 3 it is described as under:
3. In the principal rules, after rule 120, the following rule shall be inserted, namely:-
“120A. Every registered person who has submitted a declaration electronically in FORM GST TRAN-1 within the time period specified in rule 117, rule 118, rule 119 and rule 120 may revise such declaration once and submit the revised declaration in FORM GST TRAN-1 electronically on the common portal within the time period specified in the said rules or such further period as may be extended by the Commissioner in this behalf.”;
Now by empowering u/s 120A an Order No. 02/2017 dated: 18/09/2017 has been issued as under:
“In exercise of the powers conferred by rule 120A of the Central Goods and Services Tax Rules, 2017 read with section 168 of the Central Goods and Services Tax Act, 2017, the Commissioner , on the recommendations of the Council, hereby extends the period for submitting the declaration in FORM GST TRAN-1 till 31st October, 2017.”
Therefore it is to be noted date for REVISION OF TRANS 1 which has been filed timely has been extended not the time of “ORIGINAL DATE FOR FILING TRANS 1” extended.
THEREFORE, TAKE CARE, IN MY OPINION YOU HAVE TO FILE TRANS 1 UP TO 28TH SEPTEMBER 2017.