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Ahilya Chamber of Commerce and Industry has made a representation to The Chairperson, GST Council, Ministry of Finance requesting extension of availing ITC for F.Y. 2019-20 till Mar 2021 return, Continue relaxation in RULE 36 till 31.03.2021 which says that (Taxpayer can avail ITC (+10%) what is reflected in GSTR-2A) and Extend due date of Annual Return in form GSTR 9 & GSTR 9C for Year 2018-19 till 31.03.2021. Full Text of the representation is as follows:-

To,                                                                                                                                                          Date : 29/09/2020

The Chairperson
GST Council, Ministry of Finance

Dear Sir,


Subject : Taxpayer seeks Extension of following Due Dates till 31st March 2021

COVID – 19 has given big dent to economy and it has affected all types of taxpayers in Income Tax and Indirect Taxes. Situation in India is not favourable. Taxpayers are facing new problems due to this pandemic. We are again writing you to extend the due dates for following compliance till 31st March 2021 or “End of CORONA”, whichever is later.

1) Section 16(4)(Availing ITC till Sep 20 Return for FY 2019-20) :

As tax payers are still grappling with numerous issues in compliance of GST, taxpayer may have committed some mistakes by way of not availing available ITC credit. This section allows a taxpayer to rectify such errors and Taxpayer can avail ITC for previous FY till filing of September return of succeeding year. Present situation is making it difficult for Taxpayer to run business. Economy will need time to recover. C.A and Tax practitioners are also facing heavy load of previous returns due to COVID 19. Taxpayer needs time to reconcile all data of previous year, need to get it verified with Tax practitioner and avail ITC on previous year’s mistakes. Looking at time constrains, we request GST Council for extension of availing ITC for F.Y. 2019 – 20 till Mar 2021 return. We need to stress on point that, government has already received TAX on those supplies. This is only adjustment of ITC and is revenue neutral.

2) RULE 36 (Taxpayer can avail ITC (+10%) what is reflected in GSTR-2A) :

Due to large amount of Tax evasion and erroneous GSTR3-B along with false ITC , government has introduce Rule 36 in GST LAW to plug in this loophole. This Rule directly links Taxpayer ITC with GSTR-2A. Taxpayer is allowed ITC of amount equal to GSTR-2A + 10% over and above ITC shown in GSTR-2A. GSTR-2A data is directly reflected from GSTR-1 data filed by Supplier. We need to understand that government has taken proactive action in giving relaxation for filing of GSTR-1. As per normal practice, GSTR-1 is to be filed first and then GSTR-3B is filed. But due to COVID-19, it is seen that for few category of taxpayers, GSTR-3B is filed in advance and after that GSTR-1 is filed. There will be large amount of mismatch in data, which will result in unnecessary compliance issues. Presently this rule is relaxed till Sep 20. Looking at present situation of COVID 19, it should be relaxed till Mar 2021.

3) EXTENSION OF ANNUAL RETURN GSTR 9 & 9C for Year 2018 – 19:

With great difficulties, taxpayers have filed Yearly return 9 and 9C for Y 2017 -18. GSTN did not solve problems which taxpayers have faced while filing Y 2017-18 returns. While filing Y 2018 -19 returns, many of AUTO POPULATED fields not displayed. Multiple error relating to Offline utility and Server are being faced. These problems are faced till 29 Sep 2020. Looking at these problems, we need to extend the dates. GSTIN should be guided to take cohesive action on this front and test the utility and server rigorously. Portal should be closed for maintenance and should be live only when all problems are solved. As such, last date of filing returns should be 31st March 2021, subject to proper working of portal.

We fully trust that the issues raised by us will be found most justified, all of them being without any revenue implications, and the Council will take a positive view on the same.

Thanking you,

Very truly yours,

For Ahilya Chamber of Commerce and Industry

Sushil Sureka
General Secretary

Download Representation in PDF Format

Also Read:-

S. No. Dated Made by Link to View the Representation
1. 27/09/2020 Tax Bar Association, Guwahati Extend due date for filing GSTR 9, 9A & 9C for year 2018-19
2. 19/09/2020 Independent Tax Research Analysis Association Relax GST Annual Return & Audit dates for FY 2018-19
3. 19/09/2020 Confederation of GST Professionals and Industries Extend Implementation of E-Invoicing to April 1, 2021
4. 17/09/2020 Confederation of GST Professionals and Industries Extend due date for GSTR 9 & 9C of Financial Year 2018-19
5. 16/09/2020 Baroda Tax Bar Association Request to extend due date of GSTR 9 & 9C for F.Y. 2018-19
6. 10/09/2020 The Institute of Chartered Accountants of India Representation on difficulties in filing GSTR 9 for 2018-19
7. 10/09/2020 Institute of Chartered Accountants of India Permit availment of ITC under GST pertaining to FY 2019-20: ICAI
8. 10/09/2020 Institute of Chartered Accountants of India Request to devise mechanism to receive part payment of GST
9. 10/09/2020 The Institute of Chartered Accountants of India Extend due dates of filing GST Annual return & Audit Report
10. 27/09/2020 Karnataka State Chartered Accountants Association Extend due date for filing GSTR9 & GSTR9C for FY 2018-19
11. 24/09/2020 Bombay Chartered Accountants’ Society Extend dates for various provisions under GST: BCAS
12. 14/08/2020 C.V.O. Chartered & Cost Accountants’ Association (CVOCA) Representation on hardship under GST Laws on account of pandemic
13. 07/09/2020 C.V.O. Chartered & Cost Accountants’ Association (CVOCA) Representation on 7 GST issues & hardships faced by taxpayers
14. 10/09/2020 National Association of Tax Professional (Haryana) Extend Filing Date of Annual GST returns GSTR-9 & GSTR-9C
15. 24/08/2020 The Institute of Cost Accountants of India Request to extend due date of filing of GSTR 9 & GSTR 9C
16. 29/09/2020 Ahilya Chamber of Commerce and Industry Extend ITC availment, GSTR-9 & 9C Due dates till 31.03.2021

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  1. Mani says:

    1. In September 2018 return there was a sales invoice included by mistake in GSTR 1. GSTR 3 B has been correctly Filed. How to delete the entry now in September 2020 return. GSTR 9 has not yet been filed.
    2. In the same month sales invoices of one firm (under B2B) has been uploaded in another firm’s
    Name and GST number. Now only the original purchaser complained to us, regarding non-availability of the Purchase in their GSTR 2A. How to rectify this mistake in Sep 2020 return?

  2. Nitesh Gupta says:

    Extension for Only 1 months ……… !!!!!!!!
    Government is making mockery of Taxpayers. We were expecting extension till 31st March 2021 … !!!

  3. RD says:

    Why isn’t to the department declaring extension. It’s creatiing pressure and we as professionals cannot filed audit reports with unsatisfactory data.


    1 ) It should be extend till march 2021 for filling of annual Return for the period 2018-19 instead of 30th Sept 2020 and
    2 ) ITC availment for the F.Y 2019-20 till extent March 2021 instead of Sept 2020 all these causes only Corona.



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May 2024