Sales Tax Bar Association has made a Representation requesting for extension of the date of filing of Forms GSTR 9, Form GSTR 9A and Form GSTR 9C by atleast three months i.e. from 31.01.2020 to 30.04.2020.

Full text of the representation is as follows:-

Sales Tax Bar Association
IInd Floor, Department of Trade & Taxes,
Vyapar Bhawan, Indraprashtha Estate,
New Delhi-110002

Ref No.: STBA/2020/13

January 27, 2020

The Hon’ble Finance Minister
Ministry of Finance,
Govt. of India, North Block,
New Delhi-110 001.

Sub.: Representation requesting for extension of the date of filing of Forms GSTR 9. GSTR 9A and GSTR 9C

Respected Madam,

Sales Tax Bar Association (Regd.), having been established on 30th March, 1957, is one of the oldest and the largest Association of Tax Professionals in the country. The Bar represents majority of the Tax professionals practicing in Direct & Indirect Taxes. We believe that State is entitled to the taxes which are just and due to the State to be spent for the welfare of its citizens. In this direction, Sales Tax Bar Association (Regd.) plays a major role in revenue collection by the Department. Present membership of our Bar Association is more than 1650 comprising of Advocates, CA’s and Tax Practitioners. Some of our members were elevated as Judges of the Hon’ble Delhi High Court and of the Hon’ble Supreme Court. Some of our members were also selected for appointment as Member of the Income Tax Appellate Tribunal. The Sales Tax Bar Association is the only Bar Association in the country which—

i) regularly holds Study Circle Meetings every month in which eminent speakers deliver lectures;

ii) hold Conferences in which speakers and delegates from all India participate;

iii) holds Group Discussions every month in which queries of the members, particularly the young members, are answered on the spot;

iv) is regularly imparting knowledge to the younger members of the fraternity by way of a programme called “Grooming the Young”.

v) is regularly publishing its own law journal — Delhi Sales Tax Cases for the last 62 years;

vi) is successfully running Benevolent Fund Scheme since 1975 under which financial assistance is provided to the family of a deceased member;

vii) is committed to and rendering Social Service.

Sales Tax Bar Association (Regd.) has been instrumental in educating its members on various aspects of GST since its advent and has been conducting workshops on latest developments and concerns for its members. This Bar has Conducted many workshops on Annual returns and Audit. It has also undertaken to educated members on the dew Annual returns and Audit forms. It has also tried to highlight concerns of its members it/4e filing of these new forms before all forums of government.

We write to your goodself on behalf of our members and registered persons of Delhi and other stake holders. We highlight the calamitous need of extending the last date of filing of forms GSTR 9, GSTR 9A (annual return forms) and GSTR 9C (Audit form) for reasons stated hereunder for your kind consideration.

Madam, we are conscious of the fact that last date for filing these forms have been extended several times but equally important is the fact that extension of date was NOT for reasons attributable to registered persons but for reasons solely attributable to framers of Forms and managers of portal. The difficulties faced by the persons required to file these forms have been stated to be simplified by notification on 14.11.2019 but portal was modified on 08.01.2031. During the period after this day, registered persons were busy with several time barring compliances.

One of the reasons for non-filing of these Forms upto the date fixed was non availability of credit in the accounts of registered person. A drive was launched by the Government to allow the registered persons to file Form GSTR-1 to enable the purchasing registered persons to get credit of Input tax. This was being done till 17.01.2020. After the last date of filing of GSTR-1, time available for filing the forms is only 13 days which by no means can be called adequate. Some other factors which contributed for non-filing of these forms are:

1. This is first filing of these Forms. It requires comprehension of various figures. Filling of the Forms has to be smooth. Portal is not designed for it.

2. The formats prescribed for GST Annual Returns and GST Audits are not only voluminous but confusing as well. The confusion all the more rises when GST Portal itself malfunction giving two information from the same source of data.

3. Auto populated data of 3E in GSTR 9 differs from the actual data uploaded in monthly GSTR 3B. This type of technical errors happens on both sides i.e. outward supply as well as inward supply.

4. GST website is passing through numerous technical glitches nowadays. The issue is persisting since more than 10 days.

5. The error “Received but Pending” appears as and when we try to upload GSTR 9C.

6. We are unable to upload JSON file in One attempt. It requires multiple attempts to upload the same. It kills time.

7. GSTR 9C latest utility 1.6 is made available on 08/01/2020 only. The time left after this is very short.

8. GST Portal is having multiple issues with OTP sending. We are not getting OTPs on Domains. Even on Regular E-Mails, OTP is coming after 2-3 hours which is of no use. It gives frustration and anxiety to filers.

9. Professionals are determined but are girdled with simultaneous amendments in different laws

9.1. With the intent of good governance and a clean system, your government has brought many changes on different fronts. Our members are happy to embrace the changes as we are of the firm belief that Government must get what is due to it. Even then for the larger good of the economy, professionals are toiling hard day and night to provide requisite information of their clients to different departments including GST. However we are pained to face the glitches of the system which require immediate correction.

9.2. Despite their good intentions, Professionals are finding themselves in a state of lackadaisicalness as they have to handle evolutions on many fronts including GST, Companies Act, MSME etc. Recently, a lot of forms were required to be filed by Companies Act even for long existing companies. Similarly, a lot of compliances are increased on MSME front. Similarly, PF and ESI acts also brought out certain compliances for existing subjects. Keeping all these in view, due to Glitches and complications in GST portal, filing of these forms suffered.

9.3. Thus, considering the fact that information required by different departments of Government, which were never there in past, it is inevitable in the interest of the professionals of the country that compliance date for Annual return and Audit forms be extended suitably.

9.4. We are sure that your goodself is aware of the unlimited and unwarranted stress through which the tax payers and professionals are undergoing because of difficulties being faced in completing compliances under the new law.


To conclude, we say that if the taxpayers are to file the annual returns and audit forms in haste, this shall not only be detrimental for their assessments, but it shall equally fail to fulfil the purpose with which these forms were devised. The forms aim to provide to the taxpayers an opportunity to present their compliance of taxes payable and paid for the FY 2017-18, and if the forms are not properly comprehended and are not filled with proper details, they shall fail to fulfil their purpose and shall result in unnecessary litigations arising out of data filled in a state of unscholarly discernment of the forms. Thus, it is humbly requested that considering the fact that the filing of FY 2017-18 is the first filing by all taxpayers and professionals and considering the above points, date for filing the said forms be extended by atleast three months i.e. from 31.01.2020 to 30.04.2020.

The review of the time frame by your good self, requires kind consideration of the fact that between these three months, there are multiple other compliances required to be made by the taxpayers prime amongst there being filing of monthly GST returns, TDS returns and numerous other compliances as required under different laws.

We are hopeful that your goodself shall be generous to consider our request and shall take necessary action for extension of the requested dates. This would save all stake holders including Government from unnecessary litigation.

Thanking you,

Yours faithfully

For Sales Tax Bar Association (Regd.)
Neetika Khanna, Advocate

Recent Representation on GSTR-9 & GSTR 9C due date extension Published till date on Taxguru

S. N. Date Association Link
15 30/01/2020 1) The Gujarat Sales Tax Bar Association
2) National Action Committee
3) All Gujarat Federation of Tax Consultant
4) Chartered Accountants Association, Ahmedabad
5) Income Tax Bar Association, Ahmedabad
6) Tax Advocates Association Gujarat
Request to extend due date of GSTR-9, 9A & 9C for F.Y. 2017-18
14 NA Taxation Bar Association, Modinagar Letter for GST Portal issues and GSTR 9 & GSTR 9C Date extension
13 26/01/2020 Central Gujarat Chamber of Commerce and Baroda Tax Bar Association Extend due date of GSTR 9 & GSTR 9C to 31.03.2020 for FY 2017-18
12 27/01/2020 The Goods and Services Tax Practitioners’ Association of Maharashtra Extend dates for filing Form GSTR-9 and Form GSTR-9C for FY 2017-18
11 27/01/2020 Tax Bar Association, Guwahati Request to extend due date of GST Annual Returns for year 2017-18
10 27/01/2020 Sales Tax Bar Association, New Delhi Extend date of filing of Form GSTR 9, GSTR 9A and GSTR 9C
9 27/01/2020 Association Of Tax Practitioners, Ernakulam Extension of due date for filing GSTR-9/9A & GSTR-9C for F.Y. 2017-18
8 27/01/2020 Haryana Chamber Of Commerce & Industry Extend GSTR 9 & GSTR 9C Return Filing due Date For Year 2017-18
7 22/01/2020 Ahilya Chamber of Commerce and Industry GST Portal Issues | Problems in Forms | GSTR 9/9C due date extension
6 27/01/2020 Kerala Tax Practitioners’ Association (KTPA), Kochi Extend due date of GSTR-9 & 9C for further one month
5 27/01/2020 District Tax Bar Association Sonipat. Extend due date of GSTR-9 & GSTR-9C for FY 2017-18
4 26/01/2020 Central Gujarat Chamber of Commerce and Baroda Tax Bar Association Extend due date of GSTR 9 & GSTR 9C to 31.03.2020 for FY 2017-18
3 24/01/2020 Jamnagar Chamber Of Commerce & Industry Request for extension of GSTR-9 / GSTR-9C report for year 2017-18
2 24/01/2020 The Southern Gujarat Commercial Tax Bar Association, Surat Extend due date of GST Annual returns / Audit of 2017-18 to 31/3/2020
1 24/01/2020 Tax Bar Association, Jammu Extend due date of GSTR-9 / GSTR-9C for year 2017-­18 for UT of J&K

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