Hasmukh Adhia,
IAS Revenue Secretary
Government of India
Ministry of Finance Department of Revenue

3rd October, 2017

Dear Commissioner,

As per the latest figure, about 53 lakh taxpayer (out of 57.57 Lakh) seem to have filed 3B return for the month of July 2017. While only 42 lakh taxpayers (out of 68.20 lakh) have so far filed 3B return for the month of August 2017. It is understandable that in the initial months, taxpayer did not have full knowledge of how to file return and that is why there is a delay. However, we need to exactly find out the reasons for taxpayers not filing return.

2. I would be grateful if the Commissioner of CBEC as well as Commissioner of Commercial Tax in every State carry out a sample study of 200 cases of taxpayers who have not filed 3B return and ask them the reasons for not filing, so that we would get to know some underlying cause.

3. 1 would, therefore, suggest you-to-carry out such a survey as early as possible and to send the results to Member, GST, CBEC.

Yours faithfully,

(Hasmukh Adhia)

All Commissioners, CBEC
All Commissioner of Commercial Taxes in every State

Draft questionnaire for sample survey of taxpayers who have not filed GSTR-3B return



Questions to be asked, in sequence, to taxpayer who has not filed at least one of the GSTR-3B returns for the months of July and August, 2017


1. Which GSTR-3B return(s) have you not filed?

a. Only for July, 2017

b. Only for August, 2017

c. Both July and August, 2017

2. Are you aware that GSTR-3B has to be filed by every registered person by the 20th day of the next month?

a. Yes

b. No

3. If answer to Question 2 is Yes, then did you try to initiate the GSTR-3B return filing process?

a. Yes

b. No

4. If answer to Question 3 is No, then why did you not try to initiate the GSTR-3B return filing process? (Tick all that are applicable)

a. I did not have the user and and password for logging in.

b. I thought that I could not do It Myself (i.e. needed professional help)

c. I knew that system was not working, and I would be unable to file return.

d. I did not have sufficient funds to pay tax.

e. The electronic cash ledger did not update oven after deposit in bank.

f. I deposited money in the wrong head, i.e CGST, SGST, IGST or Cess.

g. I faced problems in filing of TRAN-.

h. I could not avail transitional credit and did not want to GST in cash

i. I want to cancel my registration because I am not liable to be registered

j. I wanted to opt for the composition scheme.

k. I missed the deadline and did not want to file after the last date.

I. Any other point as may be deemed fit

5. It answer to Question 3 is Yes, then why were you not able to file GSTR-36 after initiation of the return filing process? (Tick all that are applicable)

a. The site was not functioning when I tried logging in.

b. I did not know how to initiate the return filing process on the common portal.

c. The return filing process was too complicated

d. I could not save the details that I had filled.

e. The system kept logging out during the return filing process.

f. I was unable to submit my return.

g. I could not preview the return details before submission.

h. I made mistakes while submission and did not want to file.

i. The system did not allow me to file a NIL return.

j. I did not want to pay the late fee.

k. I did not have sufficient funds to pay tax.

I. The electronic cash ledger did not update even after deposit in bank.

m. I deposited money in The wrong head, i.e. CGST, SGST, IGST or Cess.

n. I faced problems in filing off Tran

o. I could not avail transitional ‘credit and did not want to GST in cash.

p. I want to cancel my registration because I am not liable to be registered

q. Any other point as May be deemed fit

6. What are your suggestions for improving the. Returns filing process?

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  1. Akhil Mehra says:

    Is it correct that Cancellation on GST portal for Migrated assessee is still not working. If not please advice how to apply for cancellation.

  2. Shanmugam Sadasivam says:

    Thanks for allowing Quarterly Returns. But the same may be modelled like Service Tax Returns. Also, the defaulters for the months of July and August, also to be allowed to file their pending Returns in the new format, Quarterly Return in the month of October, without penalty proceedings.

  3. Phani kumar YS says:

    Only One positive aspect of GST is One Assessing Officer. Rest of All the rules and procedures are not at all Pro Business. It seems that the aim of the political government and admin govt is to collect and Enjoy the Taxes with out any difficulty to them. Let the business people quarrel each other but taxes are to be paid to the governments…..

  4. Tarunkumar D Trivedi says:

    Multiple steps of filing return is not understandable,
    1st upload,2 than save, 3 than submit, correction is not allowed, 4 after submission massage comes your request is under process.Thereafter we have to wait. Before submission off-setting liability is not allowed, 5 after off-setting liability file return with DSC or EVC. This process is to much lengthy. Liability register should 1st displayed. If any error or omission is found it should allowed rectification. Maximum 3 steps should be there. Return filing process must be simple easy.



  6. rajiv mangrulkar says:

    It is unfortunate that the basic/core issues are not getting covered for solutions in the survey- draft, :-

    01.The gst rate on work contract services reduction from 18 or 12% to 5% for govt projects and private projects for civil works projects.

    02. purchase of goods and services from unregistered dealers:-(Rs.5000/day limit is waste)
    threshold limit of Rs. 20 Lacs not required to register, what is is the legal basis for the receiver of goods and services to bear the gst burden for purchase/inward supplies taken from such remote/rural located suppliers for govt. road and irrigation projects works of public utility. the govt may have separate survey to increase awareness for more and more registrations encouraging under gst but shifting burden to receiver of goods/services is counter productive to business.

    03.reversal of rcm on transport, hire and labour charges, since resulting in double tax on output as well as input covering entire debit side of the profit & loss account.

    04. web based controlling of business and commerce and its revenues and taxes, allow manual filing as well for better complaince.

    05. Payment of GST along with gstr3b return which does not have any legal acceptability. the returns is not getting filing for part payments of gst liability hence unless funds for full liability are available the gst returns will not get filed. this is blunder and not allowing business to run smooth.

    06. delays in getting bills from govt projects based on mmile stones and not on monthly pattern of gstn portal to follow, the subonctractors and suppliers bills , theri payments and inputs credits on portal all is very complicated and tedious process and does allow focus of the business man on operations and work progress but entire time of all staff upto top management gets exhausted on gst portal data entry and complaince of gst online portal demands for fear of penal and prosecution clauses. this is biggest deterrent to us fear of punishment for compliance of gst, which will ruin entire rural economy.

    7.it is comman sense that, sources of revenue are kept confidential and secret and no one is interested in transparency of their financial affairs. the revune minsitry and gst council shoudl trust the commissioner systems of commercial taxes and cbec working for decades together and leave the process of revenue recovery, complaince of gst provisions and assessments etc to them aswell so that with freedom provided from gstn online portal filing the application of knowledge of business intelligence of tax reforms and tax systems of entire fraternity gets applied. now it seems only gst council, revenue secretary and mr,. arun jaitely- fin, ministe rare only handling the entire gst burden of the nation. hence lopsided.

    hope for better sense to prevail in interest of survival of gaon-wala enterprenuer.

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