Open Letter to the Honourable Prime Minster of India

My Experience with GSTN:  

I am a small-time professional chartered accountant in field of Taxation practicing since 21 years. Have seen massive transformation of manual to fully automated system of filing the returns be it be Income Tax(CPC), Be it be TDS(TRACES), Be it be VAT (MAHAVAT), be it be Service Tax(ACES), be it ROC Filing (MCA) etc.

 All these systems took off gradually and day by day matured and were made user friendly day by day. E.g. Initially TDS System Traces was rigid about payment of the taxes and does not allow adjustment intra Codes, between the years etc. but as the administrators realised that When the tax paid belongs to the deductor why he shouldn’t be allowed to adjust as per his wishes, and subsequently the system was made more user friendly and rigidity was done away.

When the GST was implemented with big bang we thought Government have huge experience and best expertise (as claimed) of implementing such automated system, and GSTN will be best of system and a illustrative model (So that US Govt will inherit from us). The life of taxpayer will be more easier as far as filing is concerned (as termed by our Hon PM Goods & Simple Tax.) .The GSTN system was supposed to be front office of tax administration eliminating all chances of red tapisim, and all sort of corruption. Also, I heard that GSTN System is being developed and maintained by one of most reputed Software company of India.

But after passage of almost two months after launch of GST, it can be concluded that GSTN is massive failure and worst ever system implemented by supposed to be best government (as claimed).

With very little IT knowledge I can prove that system has all kinds of shortcoming and seems that there is no co-ordination between administrators and system developers. The Developers are not aware of the coded GST law. Just to quote a few Shortcomings:

  1. Being a new user there is every chance of error and omission, but the system is made so rigid with no room for revision or modification. Why not such facility provided to the users, when automated system can keep the trail of every addition and modification done by the user.
  2. The law allows and have provision to opt-out of Composition scheme by filing form CMP-04 ,if the conditions for opting composition u/s 10 of CGST Act does not fulfilled or breached. The GSTN does have such option till date. Needless to point out that option to opt for composition was provided very lately, by that time taxpayer had made lot of blunders by issuing Tax invoices. Also GSTN network has no facility of verifying dealer composition status by third party which can lead to huge evasion of taxes.
  3. The Enrolment application (migration / New registration) has provided option (compulsion for few Category) to submit the application online with Valid DSC but most of user system was found incompatible with signer software used by GSTN. Users have wasted lakhs of hours in struggling to make their system compatible for signing on GSTN. (Thanks to Chinse UC-browser which allowed some system to use GSTN signer utility.)
  4. The Enrolment process require Submission of Supporting Documents. The system displays 1 MB sizing requirement which is reduced down to 100 KB when uploaded. If GSTN feels that documents can be uploaded with all clarity with size of 100 Kb , the users earnestly request them to provide such utility.
  5. Existing Taxpayer which are not liable for registration under GST was legally entitled to cancel their registration. But again, system though allows to cancel but never accepts cancellation and those registration continue to be active making them liable for all sorts of compliances under GST Law.
  6. The GSTN system though an artificial brain which does not require any shutdown except in case of technical glitches or maintenance for a short period. But GSTN use to sleeps whole night, even if programmed to wake up to @ 6.00 Am, sometime sleeps up to 10.00 Am., Sometimes sleeps for days together. During the Day, the system is very busy to respond the users. As a results lakhs of skilled man hours were lost.
  7. The very basic concept of GST was seamless flow of credit and with that in mind Transition credit was to be allowed to the taxpayers by way of online return Trans1, Trans2 & Trans3. The return was to be submitted within 60 days , which was extended to 90 days after request made by various forum. But what happened facility to upload Trans1 was provided after 50 days that too when the administration was reminded by the Taxpayer that we need to adjust our credit of opening stock carried forward in GST regime. Shame on administration that Trans1 return was made online without any bulk filing utility knowing that thousands of entries has to be punched by the users. With a very little knowledge a small-time professional like me can design the Bulk filling utility. than how such a reputed developer cannot make it available till today. 
  8. The GSTN System supposed to be very intelligent, flexible should have adjusted the credits laying in cash ledger & credit ledger as per law. But contrary, the system was made rigid again with no scope of adjustment. The payment should have been allowed to be made on consolidated basis to be adjusted by taxpayer to various taxes head viz SGST; UTGST; CGST; IGST; CESS; FEES; INTREST;PENALTY ( 8 under forward charge & 2 under Reverse Charge or may be more than that). Many Taxpayer have lost valuable working capital due to this system. Only a big corporate like ACC Limited managed to bring to notice of MOS Finance such inconsistency in system. GSTN need to learn and inherit existing system from TRACES which seamlessly allows adjustment of Tax paid in Cash.
  9. The GSTN supposed to provide online application(RFD-11) for Export without payment of duty or against bond, but no such facility provided and exports were left on mercy of corrupt official for availing the facility without payment of the duty. In some case even after one month of time lag the Letter of undertaking was not accepted by the official. Why not systems were designed well in advance before the GST implementation to provide facility to exports to apply online for getting approvals without payment of duty.
  10. Technical Glitches like System errors; system failures; System not responding; down for maintenance; does not have enough bandwidth to support the users were daily and routine slogans on site.
  11. No effective system is in place for timely redressal of problems faced by the users. The helpdesk is inexperienced and have no solutions for most of the issued raised by the users. The Twitter handle and email respond rarely and that too incorrectly.

The above shortcomings are only illustrative and many more can be list down, but sheer waste precious time, as we know that deaf Government is busy in praising themselves (single way communication).

We Ask the government for fair treatment of tax paying citizens. Don’t treat them as dog but treat them as horses. Be accountable, responsive & assertive to the citizens. Don’t make mockery of Taxpayers by making contradicting statements on social media. Realise economy is suffering due to business closures, Loss of Skilled resources in understanding such systems. Forget Anti-profiteering, and pursue the real Loss to economy. Be responsive and design self-compliant and transparent system by way of wider referendum and involvement of Tax Professional who are real link between taxpaying citizens and Government.

People are using the social media peacefully to awake the government, and if government fails to react in right way, in no time taxpayers will be become tax evaders and will forced to be on road which will gain bring down the GDP (much higher than prediction of Silent but diligent Ex-PM).

Long live our Nation… Jai hind….

CA. Mohammed LakkadshaCA Mohammed Lakkadsha

05th September ,2017

mohdLak@gmail.com

Also Read- My Experience with GSTN- An Open letter by a CA to PM of India- Part II

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126 responses to “My Experience with GSTN- An Open letter by a CA to PM of India- Part I”

  1. srinivas says:

    i am a fan and admirer of modi, but these 2 suicidal blunders like demoniterisation & GST introduction has made me rethink. this GST filing is very complicated , it does not allow u to rectify ur wrong filings and submissions, there is no scope for revised returns. most of the vat officers are not trained, no workshops conducted, technical snags are routine,
    these returns have to be made very very simple and bussiness friendly. jaitly is a man in too much hurry. he just jumped on to introduce GST without checking the ground realities as was done in case of demonetisation. i dont know where modi & jaitly are taking us. our bussiness is already dead

  2. rajiv mangrulkar says:

    sir,
    request following clarifications:-
    01. what is the relevance of threshold limit for registering under gst of Rs. 20Lacs since the person not required to register is treated as an unregistered dealer and incidence of tax from 5 to 28% is on receiver of the goods or services

    02. what is need for payment of gst liability along with the return, when it is not necessary that in construction industry the ra bill will get certified and remitted in same month and depends on govt approvals of budget etc for work contract bills.

    03. getting gst registered suppliers and subcontractors for construction industry working at remote areas is not practicable and also the hapazard rcm on receiver of goods and services for gst payment from 5 to 28% will be huge burden on cash flows since sources of funds are limited and do not follow monthly pattern but milestones
    it is desirable to remove rcm

    04. why the dealers should trust on gst portal for input and rcm payment input credits and matching and mis matching of inputs of suppliers and subcontractors and date deadlines of the gst system may result in destroying the entire infrastructure, agro based rural economy the root of financial system of bharat. this may not be the vision of atal bihari vajpayee for gst execution.

    05. will the govt. make part payments of ra bills for gst remittances or the govt takes the responsibility of remittance of gst on behalf of contractors in construction of roads, irrigation, power, mining projects which attract 12% gst. the onus of remittance of tds may be on the receiver of work contract services instead of provider of service, keeping in view huge volume of resources/funds.

    06.the rate of works contract although revised to 12% from earliar 18% the same is not updated in
    most of web sites including cbec.gov.in
    “Composite supply of Works contract as defined in clause 119 of section 2 of CGST Act 18%”

  3. MOHINER PAL GIRDHAR says:

    THERE SHOULD BE A PROVISION FOR REVISED RETURNS FOR AT LEAST TWO YEARS SO THAT THE TRADERS AND GST PROFESSIONALS CAN UNDERSTAND THE GST LAWS

  4. J R Holla says:

    I feel, The Govt should have carried the Vat model further with a little improvemant and modifications and then slowly should have evolved to full fledged GST model, could have neen more acceptable system it would have been.
    The RMC, Reverse Mechnism charging of GST will put almost all small enterprises and self working group out of Job. As any voucher payment for small jobs like gardner, Printer, Cleaners , Watchmen doing duties on contract job will be liability under GST RMC. This will increase the Unemployment of small people.

  5. D Khasnabis FCA says:

    All the negative inputs of practicing professionals are not tenable since Govt is aloowing extension of time from GSTR 3B onwards. If one does not adapt to changes he / she should leave profession, which now requires constant updation together with extensive computer applications by self. Dependence on others seems to be the root cause for all the problems.

  6. sumaiya Daruwala says:

    very rightly described the problems faces by various CA’s Tax professionals.
    All this things takes our lot of time and energy without involving in any productive work.
    In near future no CA wants to do his personal practice as its lost their daily ability to attached his soul with his body

  7. Ram says:

    Only because of comments like this by CA s, the govt is making an opposite comment that CA s are involved in money laundering through fake companies. In other words people who comment on the govt are called anti nationalists.

  8. Mukesh Parmar says:

    Hi Friends
    As an interim relief let the Government decide to collect the taxes on monthly basis by filing GSTR3B till the time the software is fully ready. Government has enough live data to test the software. In the meantime they can work on simplifying the forms and formats so that they are dealer friendly. And the returns from July can be uploaded then. A frame work of schedules to file return be made out. This will save lot of time of the Businessmen and professionals. September is Navratri and Dasera. And October is Deepvali. The staff will go on leave for their exams. Hence, completing the audits also is a question mark.
    So here is a request to Prime Minister, Finance Minister, Revenue Secretary, Chair Man of GST Council and all involved to act on practical ground. We are all with you in this journey of GST but let us walk peacefully and abide by our words n statements. Keep all fines, penalties and interest aside and let there be amicable situations and circumstances.
    It is a long way to go and only fruitful path is to walk together in co-operation.
    The Goods & Service Tax can really become Good & Simple Tax in the days to come. Let us all strive together and reach the goal.
    https://www.youtube.com/watch?v=HfYAdkKGOxs

  9. Prashant A Salunke says:

    Dear sir,
    Thanks a lot for writing a letter. You have covered almost all the issues. I have never seen online utility for filing returns. It will never work with such a huge no of entries. We are wasting our so many hours to upload a single GSTR return. Dates are extended without understanding holidays.

  10. Ram says:

    Our beloved PM/FM was in mad rush to implement such a huge Economical Reform – Post Independence, they never even thought that it was wasted 17 years on their (politicians) plate itself. But citizen and trade to take all nasty for no rhyme on reason. Their own so called bureaucratic set up is under dark. God has to save assessee.

  11. Vikas Gupte says:

    Absolutely agree with it.
    The concerned government authorities need to take some drastic measures.
    Otherwise a system which is being touted as a great success will be rejected by the business establishment, which is suffering the utmost in terms of man hours lost and stress due to failure to comply to the rigid system.

  12. SANJAY GUPTA says:

    yOU CANT PRAISE ANYONE UNTILL YOU GET COMPLETE FOOD IN YOUR THAALI. NOW JUDGE WHO IS WRONG. ALL ARE WRONG AND CARELESS IN SUCH SITUATION.

  13. Shubham Kumar says:

    Lot of Confusion under GST Regime.. Many Small Dealer/Taxpayer/Professional not understand this GST Regime till now like ITC Adj, Trans Form, RCM Treatment, Expenses ITC, Etc Etc. and Help Desk is also inexperienced person.

  14. SHARNABASWA HARWAL says:

    THANKS SIR , YOU ARE RIGHTLY REVIEIV ED ACTUAL PROBLEM FACING MANY PROFESSIONALS AND MANY PRACTICAL PROBLEMS

  15. Amit says:

    Well stated, This has become complicated, ill&sick system of taxation. Wasting lot of valuable time of professionals & creating space for lot of errors, which will be never solved. Govt. is standing totally irresponsible.

  16. venu gopal madishetty says:

    Very good representation

  17. SHYAM MAHESHWARI says:

    It is really horrible to see that the voice of millions of people with facts and figures are just being ignored by the govt. There seems to be no one in sight from the govt who can help us in the matter now. As the things stand today, the only way out for the professional fraternity involved in the job is “Satyagrah”, just to bycott GST altogether for the time being and witness whatever is going to happen. Any losses due to this is going to be much less than otherwise.

  18. Jose M.P says:

    These are genuine comments intended to support the government and the people of India.
    I fully share the same concerns.
    Let us request the government not to be anti national. It should not be people Vs the government, rather government of the people. Please incorporate this spirit into the Government, particularly when dealing with tax collection. It is the people who make the tax, you only collect them. Appreciate the hard efforts of the people.

  19. prabhakar says:

    Yes it seems the writer has suffered and lost his valuable time in encountering with GST . For this whom to blame whether the govt or the GST admn or the software developer who will take the responsibility for loss of such skilled time . Just a simple example for the idiot brain of the developer is — at the time of submission of Trans 1 the software will not validate it, only thing it will warn you telling that it can not be rectified later. Accepting the risk if one files, it will show filed with errors in process. It will ask you to generate error report. ones you opt for error it will give after 24 hours. At this stage by seeing that error report one will get such an irritation that if the developer is standing in front, one would like to slap like a teacher to the student. Because the error report will not show what errors you have done. Instead it will show you what entries you have done correctly. That means leaving those correct entries you have to struggle yourself in finding the errors. May be some GSTIN mistakes which can be noticed those things can be identified on trail and error basis. But what about other errors, how many types of errors are there, how to resolve them. It will be like a situation who has lost his way back in a deep jungle. Over and above all these the local LVO staff calls and why you have not filed. When we tell them about the problems simply they keep down the phone.

    When the professionals express all their grievances the FM instead of assuring the solution, he tweets in a different voice by warning the prof organisations pointing about the past illegal activities done by few scrupulous fellows, as if all these politicians have landed from heaven . Without listening to any public appeals and requests they have implemented GST in hurry as if there is no tomorrow and for that again the same public is suffering as in demonetization period. What is the end of these dictatorial atrocities. Please PM sir and FM sir watch the ground reality instead of roaming in dream heavens.

  20. chandrashekhar chinchapur says:

    Many many thanks for your good suggeation &once again thanks

  21. Mukesh Parmar says:

    i have written to Dear Prime Minister, GST Council, Revenue Secretary follows:
    Namaste
    GST though a significant change for country is a compound of all the subsumed acts and has become mix of this subsumed taxes. A very clear and simple tax was expected unlike the present complicated tax structures which are in state of multiple fractures.
    Though every one wants to walk with the change, they too want to breath easy and be in peace. It is most welcome that our Beloved Prime Minister launched GST from 01-07-2017 which was very simple but the Good (GUD) part did not follow. This is evident from the past two months where business & consultants struggled to cope with GST.
    There are several experts in the country who can really help to make this Good & Simple Tax even now, with modification to existing GST. One Truth of GST is that whatever tax is charged is vatable ( ITC is allowed). This reduces the cascading effect of taxes. Based on this simple principle, make the law friendly.
    For Eg: The following can be suggested for ease of doing business.
    1) All supplies of goods and services be made liable to get registered under GST with link to thie PAN.
    2) There will be only TWO schedules ~ Exempted categories of goods and supplies and Taxable category of Goods and supplies @ 18% (with ITC allowed till the end, whre it reaches consumer). And the rate can be reviewed for reduction.
    3) Registered persons can file single page return every month and discharge their tax liabilities. ( Karnataka Vat has simple return and tax payment methods. The return is hardly 3 pages ~ it has also facility to upload the sales and purchases details, with matching facilities). The sales return should be evidenced by Tax Invoice only and for corrections in invoice Debit/Credit Note be used. Single rate of GST be charged in the bill and in the return the same can be split into 50: 50.
    4) Exports are zero tax and imports can be monitered seperately as it is done at present.
    5) Registered persons with turnover below Rs.20,00,000/- lakhs to pay annual fee of Rs.5000/- and file one annual return in a year.
    6) E Way bill can be continued as at present. (Karnataka has e sugam at present )
    7) The reverse charge mechanism can be done away as there will be no unregistered dealer.
    8) The composition scheme also can be done away as the person with turnover of Rs. 75 lakhs can claim entire input of tax.
    These are the few suggestion and may be the GST council take call on this in consultation with the Prime Minister and Finance Minister, Finance Secretary.
    Aab ayenge Achhe Din.
    Thanking you all in advance.
    Lots of Love n Take Good Care of Yourself.

    BIO ~ I am accounting Technician working as freelance accountant in Bangalore for nearing 36 yers.

  22. Vinod Burde says:

    Very rightly said sir, may it reaches FM and steps should be taken on this.

  23. ajit jain says:

    Sir, there should be a provision in all TAX Laws for accountability for each officials for his act such as Tax payer is punished aggrieved tax payer should have right to questions there actions they should be restrain from saying go to Appeal because we know this right. One thing l yet know are we to follow the enacted Law Developed System . As I feel my life is for the Govt.Not for me.

  24. CA.S.Balaji FCA says:

    Excellant one. This is nothing but the views of all CAs in India.
    CA.S.Balaji FCA

  25. Surendra Kumar says:

    Very rightly said and agreed with all the points. Can any professional / GST officials pl. help me on following issue ” – 1. While applying for new registration applicant mendaterorly require to select
    SAC – Service accounting code . As per GST sac starts from 99 like 9995 related to RWA cooperative Society – but same is not available fin drop down list – selection bar – instead service tax code like – 004144180 has been given .In absence of any such list available in GST portal – Lay man is helpless . if proper SAC code as provided in GST list has been given in selection bar very useful and save applicant from unnecessary hassel.
    2.Application made on 31.08.2017 online – while on registration was granted on 06.09.2017 . it should be from the date of application .
    3.How applicant shall avail input credit of services availed by him in Aug 17 if reg. was granted w.e.f.06.09.17. even our juris. officer in Noida unable to clarify the issue and help us .

  26. Surendra Kumar says:

    Very rightly said and agreed with all the points. Few more things i wish to brought into the notice of GST officials and our professional Colleague : –
    1.While applying for new Registration On GST portal , a service provider is supposed to chose 5 main services offered by the business and a search opyion was given as – “Search SAC” – service accounting code – very surprising SAC starts from code – 99 – like 9995 – related to RWA Co operative society is not available in selection bar list and a lay man could not able to find the code available in list like service tax codes – 00441480 – other services . How a lay man can find out a fill correct code . No such list was provided in GST system . If any one of u / gst officials able to provide these codes compatible with GST portal SAC – it shall be very useful for the public at large .
    2.GSt application was made on 31.08.2017 online but gst registration was granted w.e.f.06.09.2017 – how the applicant get the benefit of input credit for services availed by him in the month of August 2017 . Registration must be effective / valid from the date of application not with the date of registration . No GST offiicials in jurisdiction AC Noida office was ready to rectify the error . can any one help us very greatful .my mail id is – surendradelhi71@gmail.com . Thanks in Advance for help .

  27. R Saravanan says:

    He is absolutely right, as every tax payer and dealer are facing difficulties in handling GSTN. Let us wait for the outcome of the decision of the Honorable Rajasthan High Court

  28. Uday says:

    Rightly mentioned and good to see the glitch had mentioned in detail. Government waving penalities , interest etc.is secondary . In my view it’s completed dislink with other provision. We are CA professional not machine.

  29. KAMAL says:

    Rightly said. Even after lapse of two months, the system is not properly functioning. In pre GST regime, we were able to complete most of the Audits, around 70%, but during the current year, we have been able to complete only 30% audits. Whether, we use offline tool or online preparation, the system is taking around 2 days to update the data. After updating, many fields are missing, like HSN wise summary, number of documents. In case of discounts received or paid, or rebate allowed during a particular month, it is asking for the invoice number against which the discount is given or received. A large number of documents are required to be maintained like invoices, revised invoices, receipt vouchers, payment vouchers, debit notes, credit notes etc etc. If the govt can not trust there citizens, why don’t the govt take over all the businesses and run them and we are ready to work as an employee to the govt. At the time of asking for the votes, Sri Modijee had told that he will control the inspector Raj, but now we feel, the proper Inspector Raj. Tax terror will vanish, now we feel what is tax terror.

  30. Ramesh kumar Singh says:

    Finance ministry is doing blunders like double Taxation , irrational tax rates and cess.Take example of Car Lease rental agreements. Pre GST 14 % VAT was the rate , all of sudden it went to 43% even deck was cleared to charge 53% GST on Cars below 1500cc .From 14% to 53% on Honda City Car. Is it not lunatic act by GST Council ?
    No doubt GST Council is managed by group of people with little knowledge of trade and industries . The Finance Secretary Mr.Adhia himself admitted that he does no how to solve the problem of Double Taxation on un expired
    Car lease agreement .

  31. Prajesh Purohit says:

    RCM is also a big hadeck for all of us, it must have withdrawn with immediate effect. Why GST liability imposed on receiver those whose turn over are below 20 lacs? This has increase unproductive work tremendously.

  32. Harsh says:

    Sir,
    I suggest,
    Be postive, Be optimise and Be gracefull.
    I am not favour govenment. our country is very with population and culture.every problem has it’s solution. whether your open letter is related to problem in GSTN / GST regime or challenging system ?

  33. K.T.Jadhav says:

    Sir, thanks for bold letter. In fact the contents of Laws and Forms are so complicated that even tax experts are finding difficult to guide and follow to comply legal requirements. It appears that those, who drafted laws and prescribed forms are not having practical and business experience. They have read case laws and made effort to incorporate pronouncements without thinking usefulness and compliance. The different rates, different GST Acts and so many Notifications within 2 months indicates non application of mind at initial stage.The period for demand is increased, rate of interest is increased No.of forms are increased then law and compliance should have been simple and easy following cannons of taxation.Even wording in laws is so clumsy to understand. Let us hope Members of GST council and officers, who are involved would realise that taxes are coming from business, which will increase if businessman concentrate on business rather than tax compliance and penalties there under. ..

  34. jitendra thacker says:

    Really all should request the government to give only one expert from the finance ministry who handle and fulfill the compliance of dealers in only 1 ca or tax consultants firm’s client so all the so called GST class will be proved practically.
    This should be our challenge to the GST law makers.

  35. jitendra thacker says:

    Very true, your comments and remarks on the GSTN system are valued and valid. You have rightly raised the issue of the wastage of precious time. The helpline do reply with layman’s language and not showing any professional approach. And most the dealers are totally depended on the tax consultants and CA but govt. and dealers both seems that not going to understand the basic problem what we are going to suffer.

  36. SCPL says:

    The Government slogan of 1 tax 1 nation has totally failed with multiple tax rate system. There are many nations where only one rate of tax prevails and they have better economy than us.

    What was the necessity of harassing people and increasing the paper works and man working hour losses. Actually the administration has no ground knowledge, never they have consultations with the regular working people in the very streamlines.

    This Government has just imposed the burden of its preplanned ego only to show that they have completed their commitments, whether people and nation suffer / loss they have no botheration at all.

    We are talking about digitalisation whereas there seems no ease in working environment. People from every walk of life are struggling at their level and every stage a cost has to be paid, and our govt is telling things will be cheaper, How? can any one explain! At every step of life cost has increased. Sales are getting affected.

    Just Failure, No Worth of wasting nations’ money and man hours in such a crumbling way could be justified at any level. Before such mass changes in the system one should have hardcore ground level knowledge from every walk of life and prevailing system.

    This government is utilizing public power, as its own VITTO power.

  37. D RANADE says:

    I totally agree with issues raised in the open letter.
    While implementing any new system we suggest a parallel run for 6 months to check system stability and then only old system is scrapped. Therefore Government should allow physical/excel submission for first six months and then switch over to new system.
    Let us wait for Honourable rajasthan High Court order

  38. K.S.SALDANHA says:

    Such a time consuming excercise filling in the
    Returns. SME’s are put to loss over GSTN.
    This is a most cumbersome tax enactment
    introduced. in India. The penal provisions for ordinary genuine omissions are draconian.Revert to the simpler Sales Tax VAT.Sooner the better.

  39. krishnamoorthy Naidu says:

    Nice bold step after 25.08.1947 independence
    Hope, it is a good lesson to the BJP Govt. at least another two years Modi will think 100 times before becomming once again !!!!!!!!!!!!

  40. K K G NAIR says:

    thanks for commenting the original problems

  41. Arvind says:

    भारत सरकारने कोई तयारी करे बिना इसे लागु किया है. छोटे बेपारी को यह समज में आताही नहीं. साईट में एरर आतेही रहती है.
    आज GSTR-2 फ़ाइल् डाऊनलोड किया तो पूरी फ़ाइल् ख़ाली है.
    ईमेल id व् मोबाईल नंबर Edit/ Change करने के लिए कोशिश बेकार गई. हेल्पडेस्क, Feedback,और Tweeter पर कम्प्लेन किया कोई जवाब नहीं.
    यह कानून सिर्फ सरकारने अपनी जिद पूरी करने कोई तयारी करे सिवाई लागु किया है.

  42. Veenkatasubramanian says:

    Still there are dealers who are not understood GST properly.It may be due to that the GST is not simple as said by the Govt. Some more time should have been taken to educate the dealers,service providers and Tax practioners.

  43. The officers working in GST common portal have to help all stake holders in completing the work of filing of returns on the due dates.Finance Minister has to exercise control over them in instructing them to attend the queries sent to Help Desk / State Computer system heads to solve the problems then and there in order to complete the process of making payment and filing returns,It should be remembered there are lakhs of small GSTIN holders who were filing the returns in the earlier State tax regime with help employees who are not conversant with new GST though two months have passed. Once. first return is filed i.e. for July 2017,everybody can manage thereafter. Till such time instant help from Govt.side is needed.

  44. MOHD AHMAD says:

    Thank God, some one is here for raising an alarm for issues which we are facing in return filings.

  45. VIJAY SHETTY says:

    Sir, We appreciate your initiative on behalf of crores of assessees on GST-Returns.It is big blunder of Government of India that inspite of knowing that this is new chapter there is no provision for revision of Return or Modify the details before submitting.It is also blunder that digital signature was made compulsory to Ltd and pvt ltd and partnership with LLP.

  46. SIDHES says:

    Completely agree, if govt didn’t react early we can see n number of tax eveaders and no Bhai or beheno will work then.

  47. The system Managers of GST COMMON portal are only real guiders for smooth filing of returns and allied matters and not P.M. Any mail sent to the Help Desk or any other nominated agency / authority should be answered at least in 24 hours. Then only, further steps can be taken by the Return filers or GSTIN holders to complete the process of the returns within stipulated time.

  48. Nagaraj says:

    Every citizen of India should not forget, what Modi at SIRC on 30th June 2017 told the nation at Bangalore attending CA conference. I invite you great Chartered Accountants for ” Festival of Honesty”. Because they are the biggest problem creator for the nation.

  49. anil shah says:

    Very nice effort. There is sudden fall in GDP due to the reason that small and medium Businessmen and enterpreneurs are devoting all their time in preparation of multiple GST returns in place of devoting time to their business.

  50. Tousif says:

    Sir,
    i am totally agree that you have observed the GST portal while filing return…

  51. YASHWANT MALI says:

    YES SIR, U R POINTED RIGHTLY.
    AND,IF GOV. SAYS ONE NATION ONE TAX ,THEN WHY THIS THREE TAX SGST,CGST,IGST?
    BY THIS THREE TAX SO MAY ACCOUNTING ENTRIES, CALCULATION’S, PAPERS, ARE CREATED,
    CENTRAL AS WELL AS STATE GOVT. TAKE WHATEVER SHARE FROM TAX,IT IS YOUR DISTRIBUTION PROBLEM BETWEEN CENTRAL AND STATE GOV, BUT WHY THIS HEDAK FOR TRADERS,SALERS ?
    WHY THIS GSTR 1,2,3. IF GOOD AND SIMPLE TAX WE SAID, THEN WHY NOT ONE MONTHELY SIMPLE RETURN FOR GST?

    WHY THIS REVERSE TAX?

    THANKS.

    • Frightened Businessman says:

      Very nicely stated that Only one rate of Tax should be paid and payable. How to distribute it to Center, States, UTs etc. is your problem. Don’t you have enough Accountants and Calculators in the Ministry to decide on how much should go to which State etc. My important suggestions are as follows :
      1. Because of your Portal and many other problems if somebody defaults on anything upto 6 months, there should not be any Interest and Penalty chargeable. All honest tax payers making some mistake due to Portal problem etc. should not be penalised. To avoid penalty, honest tax payers also will start finding loopholes and will be forced to become tax evaders.
      2. There has to be a provision for rectification, revision of all Forms to be filed.
      3. The Finance Minister has to keep in mind that he is running the Economic ministry of the County. He is not standing in the Court for pfofessional argument in favour of his client. As economic affairs minister, his main priority is economic upliftment of each and everybody in India and not only the tax (revenue) collection.
      Modi Govt. is concerned with how India is shining in front of USA, UK, Japan etc.etc. This India shining gave good lessons to Vajapayee Govt. in 2004. If Modi decides not to learn any lesson, Honest people of this country will teach a lesson in 2019. If Modi decides to label every body standing in Queue for exchange of Notes, as dishonest tax-evader, the Chingari of humiliation caused to honest people can turn into Big flame.

  52. Adv.Anil Kumar says:

    We all have placed variety of problems from which I have also come across. I would appreciate if solution is also proposed by us. This will help them to modify the modus operandi for mass utilization.

  53. Shridhar says:

    Dear Sir I fully agree with you. My observations are
    There are some contradictory provisions in the GST law.
    For Eg. : Supply to SEZ unit is zero rated. But the RCM provisions are contradictory to the main provision ( i.e. zero rated )

  54. Hari Baldawa says:

    I completely agree with what is said. I am a technocrat running small technical firm and it is nightmare to follow formalities. It is suicidal. Is this what we have to do run business in India?. Govt. thinks we have no other work or business other than compliant with GST and blah blah blahs.

    This is absolute shame on leaders who big boast of digital India,who Implement without proper planning and take citizens for granted. Inefficient insensitive leadership will drag country back, forget about being world leaders.

    No proper planning is made for trades done by registered person with turnover within 20 lakhs. Getting GSTIn number is like getting khaidi number of jail who has to follow brainless insensitive monthly formalities. The requirement for leadeship in digital India requires super boost to innovation, creativity and efficiency, rather than wasting country’s resources and citizens time with exploiting dumb brainy thoughts.

    I suggest, under 20L trades turnover should be left free from filing formalities and whatever total amount of trade he does, so much turnover setoff has to be given to the buyer.

    I suggest collect reasonable tax amount every month but make quarterly reporting for organisations can’t comfortably afford additional expenses to have CA or accountant. I don’t think implementing this is difficult at all, but needs some creative positive thinking heart, rather than assuming all citizens are thieves and cheats.

  55. G S SRIRAM Auditor & Tax Consultants says:

    Each every points quoted sir very nice letter
    as per my 20 years experience very worst soft ware
    for GST. Why not alter vat soft ware by NIC
    Vat soft very nice easily understand everybody
    Now also no problem please change the worst soft ware

  56. Ram says:

    What is the merit in point 3,4,7,8 and the para’s after point 11…Its a new system and like every system introduced before it too have technical issues, which will be corrected like the systems implemented before…Rome was not built in a day lads…It is unfair to term a initiative as farrago and fiasco based on its performance in initial days…

  57. Mounika says:

    Yeah, there is no use of tutorial they had provided.. ,there is no proper awareness programme on the filling..

    main Disadvantage is no facility to revise r modify.

  58. KRISHNA JASTI - Tax Consultant says:

    having 25 years of experience I always proud to be a part of bridge between Tax payers and government. we wholeheartedly put our valuable time to create positive approach and tried our level best to adopt GST System for our clients (all are small business people). after seeing day by day due date system we are helpless to proceed further.

  59. S K SINGAL says:

    1. There is no button on gst.gov.in for generating way-bill which is said to be must for txn above 50K ?
    2. For interstate B2B, we are shown intra-state in GSTR-2 resulting in calculation of CGST/SGST instead of IGST ?

  60. yeshuachild says:

    I am thinking of shutting down my business. I am a small time retail shop and the paperwork involved and the difficulty in finding out proper details and HSN Codes is unbelievable.
    I am only trying to upload everything and am not able to attend to my business.
    this is one of the worst nightmares of India. My business has also practically no customers due to the combined effect of demonetization and GST> If you want to shut down the economic growth of India and throttle all Indians … this is the best way to do it

  61. Kingshuk Das says:

    I have successfully applied for enrolment as GST Practitioner on 28th July 2017 but yet to get the certificate. I found that the service of processing applications is not yet started. By the time it is started lakhs and crores of pending application will be there on the list.

  62. Prakash says:

    Sub Modi ji ki copy cat hai. from which angle it is good and simple tax. Modi ji please lets us put the bureacrates in practical to demonestrat how it is good and simple. Eek GST Tran-1 fill up karke bate da how much time it takes.
    GST law provides 90 days time but babu logo ko Tax ki credit dene me pet dukhta hai as if unka ghar ka paisa yeh tax payer le lenge. completely foolishness. This time limit is reduced to just 7 days. how miserable is tax payer?

  63. Mayur Prajapati says:

    Very true Gst portal not working well. Time period is very less

  64. Prakash says:

    Agreed with all the points. Helpdesk is hopeless. Still bureacrats are living in earlier era of taxation systm. there is no change in their mindset. “khud ko kam ni karna hai aur tax payer/professional logo ki jina haram karna voh unki purani adaat hai” best example is RCM liablity on URD purchases. fixing per day limit of Rs.5,000/-etc. only social media me statement dene me sub mahir hai” Lagta hai Modi ji ko eski kimmat bhare padgi.
    Our professtion bodys/bunsiness chambers remains silent on the issues instead of raising voices. sub apani apani roti sekane me lage hai at the cost of there members life. sahi me kutta nahi subko Gaddhe ban die hai es logone.

  65. Heena Gupta says:

    Well Written sir, I completely agree with your each n every word…….

  66. kmd says:

    Hello,
    i think acceptance is better than blaming the government. Every change take some time to be stable,

  67. Satish Patankar ( Tax Consultant) says:

    Very nice observation sir,it’s true facts.
    my self is fully supporting to this article. As a well wisher of P. M. of India I would like request to Our H’ble P M. Modiji please look into the matter personally, and keep in mind that our whole economy and total Govt.system run only from these taxpayers.
    Thanks

  68. govind agrawal says:

    i agree with you

  69. CA Srinivasa H, Bangalore says:

    We never find this kind of poor, weak and hopeless technical and IT support which is used in so called GST portal, besides it made all professionals and tax payers life horrible.

  70. GALA ASHWIN says:

    Congrats Very well drafted. Is it submitted on PGportal ? Direct to PMO office ?

  71. Krishna Kumaran Nair.T.R says:

    The article is good.Since the system is in its infant stage, such shortcomings are natural.It is true that precious man hours are lost. The Government should assure that, no penal interest, late fee, penalty etc are levied till the system is made fool-proof.

  72. Prerna Soni says:

    So rightly stated. Thanks for taking efforts to highlight the misery undergone by all practising professionals and businesses…….

  73. CA Ashok Rathi says:

    The article specifies real pains of business and professional community. But surprised to notice that no media is raising voice against this, No business or professional forum is forcefully representing to Govt. The media was very active in demonetisation but slept in GST.

  74. prabhakar rao k says:

    Though i am a post graduate in commerce in 1986,I felt very difficult to submit returns. What stated in the above letter is quite correct.

  75. Satya says:

    Very rightly said and agreed with all the points.
    waiting for response from FM.

  76. M.M GULATI says:

    Sir,it seems that total trade is puzzled due to change and govt is also in fog and enjoying. Due to lack of coordination between ministries and other authorised agencies schemes are failed and delayed.
    Now our PM & God can save all this.

  77. Mithilesh says:

    Nicely written..

    I think one more important thing.. RCM provisions under Sec 9(4) should be deferred for atleast six months. How can you expect each and every data entry accountant to understand such tediuos provision. Practically near to impossible to follow.

  78. ADV V M MALPANI says:

    i agree

  79. VIMAL KUMAR V G says:

    Due date for filing of GSTR-6 is 8th Sep 2017, but till 12.15 pm on 7th Sep. the system not provided with any utility offline or online for filing. When they will provide the facility god knows …….

  80. ADV V M MALPANI says:

    I AGREE . IN A COMING DAYS TRADERS MAY NOT RESPOND THE LAW AND THERE WILL BE MASS DIS OBEYANCE OF LAW.THERE SHOULD BE 9 DAYS TIME FOR PROFESSIONAL TO UP LOAD THE RETURNS.

  81. CA Vijay Kumar says:

    I am not understand the all existing Tax system are option to Revise the Return and correct the particulars but why not given in this GST all the professional and businessmen are human being some mistake happen at the time of the issuing invoice and at the time of filling the data

  82. manoj poddar says:

    Our Govt. has become very arrogant actually. As per FM all tax professionals are a big tax evaders. We are working under tremendous pressure and in between that wastage of time due to GST is not at all acceptable. we cannot plan any work due to GST. Just wondering, how the Tax and Company audit will be done,,,, GST is now :-
    “GOD SAVE TAX PROFESSIONALS”
    “GALTI SAARI TUMHARI”
    “GHANO SARO TAX”

  83. Naresh Chander says:

    The Govt. has compelled to follow their laws without any completion of their Home Work

  84. Vijay Kumar says:

    There may be around Ten Lac or more Registered GST Dealers now.
    1. What GSTR3B is required?
    2. It is required of all dealers to file GSTR-1, GSTR-2 and GSTR-3, as a registered dealer is required to file even NIL report.
    3. In the event of non filing of GST forms, a minimum of Rs. 200/- per day penalty is applicable.
    4. The site is not operative at all times, it is getting crashed again and again.
    5. It is not understood, why Government is extending the due dates by 5 days at a time?
    The filing of GSTR-1 even with 1 to 4 bills is taking around one hour.
    The whole thing needs to be reviewed.

  85. CN Tilgulkar says:

    Best Observations. Even working in IT for years, I find difficult to understand logic behind vast reports and lengthy procedures. Further , system itself was getting revised on regular basis. If developers are not clear what they want, how one can expect common man to respond ? What measures are taken to reduce corruption is still a very very big question mark. And this is pro claimed clean and efficient government.

  86. Santosh says:

    Thank for your review. 85% of Indians are for reforms. We cannot go back to 1600 years now. Bharat mata ki jai. You never voted to him neither support his vision so don’t misguide people. Resistance to change will happen & sometimes it would be rigid.

  87. prasanna says:

    GST was implemented in a hurry burry due political reasons and nothing else.

  88. Ashok says:

    We are struggling to add another DSC in place of primary one. But it’s not possible till date. GST-14 is always showing validation errors. No help from helpdesk as well.

  89. RAJESH MANGAL AGRAWAL says:

    VERY NICELY QUOTED THE PROBLEM OF THE TAXPAYERS & CONSULTANTS.

  90. Jagdish patidar says:

    Sir,
    very nice observation & noticed to gov.
    our expreiance on the same.
    a most related to software of GST i fined that i was filed trans- 1 in gst portal. in 5A, 7a, 7b. 6A coloum fullfil details .& filed 23.08.17. but Electronic Ledger Show Credit in Twice (just Double) helf desk ask & mail but no responce. some days ago gst portal Also reflect re-Submissition with DSC I have Second time filed.but till dt Electronic ledger show credit .twice.

  91. Ranjith Jain says:

    I Completely agree with what he written in letter.

    But Rather than just saying what is not good, he would have gave some suggestion by which GST Can be made Simple for Tax payer.

  92. Ganesh Vishwanathan says:

    I am a small time professional who registered for GST though not required based on request from PM. The system is a nightmare. Now I am thinking of going out of business altogether. Is there no accountability at the government level?? Is the tax payer only responsible for everything??

  93. CJR Sankar Rao says:

    Sir,
    U rightly said, no body responding the problems, where ever Infosys enters, there will be 100%problems, like u know in MCA v2 version how the professional suffered still lot of problems exists, law saying something, system saying something.

  94. Ramesh Patel says:

    I am totally agree with you. Even I wrote to helpdesk why they need DSC to upload return in case of Company and LLP. This can be done with OTP. I think the law and software is made by people who sits in AC cabin and have no practical experience of operation of business

  95. CA Premchand Kadmawala says:

    very true ,if they have no full proof and according to act and rules system ,the have no right to force the implication and penalizes for the fault of the Govt.govt allowing extension of time for there mistake and insufficient preparation of software not for the problems of the business men.
    CA Premchand Kadmawala

  96. DARSHAN SHETH says:

    Yes another Technical Issue.

    if the invoice is Issued in the Month of July while having Registration Under Process, GST Number allocation done in Aug by Department, But Now system is not allowing users to file returns as well payment for July-17,

    This is also technical snag, As per provision if any person falls under GST within 30 day from he has to take GST registration, but Department had allocated GST Number in the Month of Aug then what about July Months Returns and payment of GST as the Customer have already taken credits based on the invoice issued.

    This needs to be corrected in system.

  97. K P Bhanu says:

    Each and every word and observation is correct.
    It is right time to act and bring parity at all levels.
    T & R
    K P Bhanu

  98. Sanjeevkumar Kabra says:

    I have also send message to Shri Arun Jetly FM on this issue and other issue also, I am also of opinion that if Hon PM takes this issue with office of the FM to work on grievances.

  99. Common Aadmi says:

    Why you are blaming the PM. The culprit is CBEC whose officers don’t want the system to succeed because then they will loose their importance. when the assessee himself doesn’t know under whose jurisdiction his regn falls, the CBEC officers are calling everyday asking for ‘REVENUE FIGURES ‘
    PM at the meeting of Rajasva Gyan Sangam has told that officers of CBEC should have minimum interaction with assessee, and that too through digital means, The CBEC inspectors of mofussil areas/rural areas like Katol/Gondia/Kalmeshwar/Butibori in Nagpur region, donning the uniform are threatening the small traders/dealers/service providers under 20 lacs turnover for registration. Complaints to higher ups falls on deaf years

    ONLY GOD CAN SAVE THE TRADE/PM FROM THE WRATH OF CBEC OFFICERS

    • Jayadev says:

      If we don’t blame PM then whom we should blame when every one said system is not ready he is the person who instead for July 1st Implementation
      Always don’t blame officials
      Even they don’t have enough training
      Bhakti aap ke pass raakho

  100. vinod kumar rana says:

    agreed with all the point sir ji

  101. DARSHAN SHETH says:

    Yes, Another addition is that
    No clarity as to how to take GST credit if the invoice received from PURE AGENT Service Provider specifically in IMPORT clearing consignment.
    The clarification should be covered with TDS provision as well.

    Still it is in ambiguity.

  102. ca Glen says:

    Well written .honest feedback of genuine practical problems faced.
    Issues May be taken note of and escalated by various associations /forums and complemented with other observations alongside so that it reaches all concerned forcefully and GSTN is suitably amended.

  103. Vibhor Sanghi says:

    Hi,
    Very rightly stated Sir,
    A complaint was recorded on GST portal after waiting for around an hour on the GST portal and after repetitive follow ups no reply has been received from there end.
    If this is how its going to change the nation, I think we are moving towards the worse..
    Regards,
    C.A.Vibhor Sanghi
    +91-8802032451

  104. CA V D Goley says:

    I do not understand why everybody is blaming PM, my questions to all of us in professional community
    1) How do you rate GSTN with your previous VAT/S Tax/Excise websites performance ? (Manual return vs GST return)
    2) If it was good or bad, have you ever complained to the respective PM or FM of that time ?
    3) After 21 yrs of practice how impatience we are ??? isn’t surprising ???
    4) If we get fail in CA exam, whose fault it is of student or ICAI for setting difficult exam papers.
    5) Any system need time to develop, (AAj ghee khane se kal kai gora nahi hota) it takes time ?
    So note that everybody is preparing and it will take some time to habitual with the new system ??

  105. V.Ramachandran says:

    It is a good effort at highlighting the difficulties everyone is facing.

    However, in an open letter to the PM, the last 3 paragraphs ( after point number 11) are unwarranted.

  106. Raj Thevar says:

    I am fully agree to the points raised by this gentleman. It is not user friendly like the earlier systems. very rigid. lot of skilled manpower time is wasted in running this system, Finally due to the Govt fault unnessarily assesees are targetted by the so call officers of the goverment for interest and penalty.
    Court should come in to the picture in future for any harassment by the govt authorities to business.

  107. CA. S.C.Podder says:

    I appreciate the Points raised ( failure on the part of Govt, system administrators / adviser ) by our one of the professional friend . But none will care ( PM and his associates ) including our beloved Institute’s MPs, MAs ( Central council and regional Council members )
    They may understand the difficulties but no voice before the Govt.
    I am not against implementation of GST. but detailed home work and impact on the businesses and others associated service providers .
    Complete mess .

  108. H A Vakharia says:

    Modi did only two things. One is demonization & other implemention of GST. Both are biggest blunders of Indian history. He just wasted both strong weapons. This man is over confident in his acts. God knows why he wants to do everything in so much haste. What he wants to prove ? I blame people more than him who are still singing ” modi chalisa” & living in fools’ Paradise.

  109. N D Shreenivaas says:

    Yes its the experience across India. Now Govt Dpet are asked to obtain GSTIN..no procedure in place and confusion galore..

  110. ANIL SHARMA says:

    it is really wastage of time by sitting hrs together for nothing. At the end you landed no where. No reply we are getting from GSTIN. There are numerous problems while doing work at GST portal.
    Amendments in Registration not done after spending so many hrs. We professionals are spending so many hrs for which no fee will be paid by the client .

  111. CA Archana says:

    Very well put up.

  112. samarth says:

    Very Good Observation. I am also trying to change
    Register No but there is no option.

  113. Ravi Mehra says:

    Very nice observation.
    I would also like to add one of my experience.

    “No option to change trade name”

    While doing GST registration for two of our clients the trade name get interchange mistakenly and now even after 2 month we have not get any solution of it. There is option to amend registration but no option to either change the trade name or cancellation.

    Ravi Mehra
    RG Cinsultants

  114. Narayan says:

    Hi,
    You guys are 100% correct, infact our Honble finsnce minister is suppose to be blamed for this blunder, who knows nothing than blaming others, if he is changed from current post & appoint new person with financial knowledge then only our country will improve, r else everything will be govinda.

    • manoj poddar says:

      Our Govt. has become very arrogant actually. As per FM all tax professionals are a big tax evaders. We are working under tremendous pressure and in between that wastage of time due to GST is not at all acceptable. we cannot plan any work due to GST. Just wondering, how the Tax and Company audit will be done,,,, GST is now :-
      “GOD SAVE TAX PROFESSIONALS”
      “GALTI SAARI TUMHARI”
      “GHANO SARO TAX”

  115. Sandeep Kothari says:

    Well written.

  116. Ravichandran says:

    I agreed 100%. Slow and study is always best in all.
    They may implement one by one (ie) Manufacturer, traders, exporter’s Wise in a phased manner. Over the period it’s become a great one.

  117. CA Shreyash Sheth says:

    Very rightly said and agreed with all the points.

  118. BSKRAO says:

    Rightly stated Sir, If Modi Ji personally sit in the office of Ministry of Finance, ask for details of grievance received & action taken, definitely, it will put pressure on learned officials in FM to work on grievances. In fact, Modi ji gave free hand to these bureaucrats to do what they feel, this has been misused by these people. These bureaucrats are living with the environment of house keepers for every job, they do not understand what is happening at gross root level. I suggest learned officials in Ministry of Finance to come and sit in our office & give compliance of return filing under GST.

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