The Sales Tax Bar Association (Regd.) has raised key GST-related concerns in a representation to the Principal Chief Commissioner, CGST & Central Excise, Delhi. Major issues include a lack of clarity in documentation for businesses operating from shared premises, additional document demands beyond legal requirements, and the inability to withdraw or edit GST registration applications, causing unnecessary delays. The association also recommends a mandatory notice viewing system on the GST portal to enhance communication and compliance. Further, it highlights difficulties in availing the GST Amnesty Scheme due to the mandatory DRC-03A requirement, particularly in cases where appeals are partially accepted or direct payments are made through the Electronic Liability Register. Another critical issue is the delay in appeal disposals due to staff shortages, making it difficult for taxpayers to meet Amnesty Scheme deadlines. To address this, the association urges the government to deploy additional manpower and extend the scheme’s due date from March 31 to June 30, 2025.
SALES TAX BAR ASSOCIATION (REGD.)
Office:
2nd Floor, Department of Trade & Taxes,
Vyapar Bhawan, Indraprashtha Estate,
New Delhi-110002
EPABX : 23352310 to 14 | Extn. : 3666, 3667 | Ph. :23318682
March 26, 2025
Ref No ________
Dated________
The Principal Chief Commissioner
CGST & Central Excise Delhi
Subject: Grievance Redressal Committee (GRC) Meeting
Major Difficulties Faced under GST — Points for Representation
1. GST Registration
a) Lack of Clarity on Documentation for Shared Business Premises There is a persistent issue concerning the absence of clear guidelines regarding the documentation required for GST registration in cases where businesses operate from shared spaces such as co-working premises, 0Y0 workspaces, metro station shops, or similar space-sharing arrangements.
b) Officers frequently raise additional document requirements during registration processing, such as:
-
- Photographs, copy of PAN Card, Aadhaar Card of Proprietor/ Partner/ Director
- Geotagged photographs of the premises,
- Multiple ownership proofs beyond the rent agreement/ consent letter (electricity bill, property tax receipt),
- IDs of witnesses, etc.
Such demands often lead to prolonged delays, especially when these documents are not specifically asked in the application form itself. It is requested that:
-
- Either the GST Registration form should specifically include these requirements upfront, OR
- Proper guidelines be issued to the officers restraining them from raising unnecessary additional document demands that have no legal backing under the GST Act and Rules.
c) No Option to Withdraw or Edit Application
The portal lacks an option to withdraw or edit registration applications after submission, causing unnecessary pendency or rejection due to minor errors/ omissions
Enablement of the facility within a specified time frame will reduce unnecessary rejections, and ensure only genuine applications move forward for officer verification.
2. Mandatory Notice Viewing Before Portal Access – Suggested Mechanism for Effective Communication
Under the erstwhile VAT regime, taxpayers could access their login only after reading any pending notices, ensuring deemed receipt and acknowledgment of communications.
A similar feature should be introduced in the GST portal to make it mandatory for taxpayers to view notices before proceeding further. This will strengthen communication, reduce disputes over non-receipt, and ensure timely compliance.
3. Mandatory Requirement of DRC-03A in SPL-02 (GST Amnesty Scheme Application)
The Form SPL-02 requires mandatory furnishing of DRC-03A for availing the GST Amnesty Scheme (waiver of interest and penalty). However, in cases where:
- Appeals are partially accepted, resulting in liability less than the pre-deposit, or
- Direct payments are made through the Electronic Liability Register (ELR), submission of DRC-03A becomes practically impossible.
Clarity should be provided, and the system should allow alternate proof of payment or auto-adjustment of the liability to facilitate genuine cases and ensure compliance with the scheme’s intent.
4. Delay in Appeal Disposal Due to Limited Manpower Hindering GST Amnesty Scheme Benefit — Request for Extension of Due Date Numerous appeals remain pending due to severe staff shortage — currently, only two officers are handling appeals in the Delhi SGST office. This has resulted in delays in processing appeals, making it practically impossible for taxpayers to determine their final tax liability within the given timeline for availing the GST Amnesty Scheme.
Additionally, considering that the prescribed forms and necessary clarifications were made available on the GST portal much later after the scheme’s notification, taxpayers are left with inadequate time to comply.
Suggestion:
- Additional manpower should be deployed to expedite appeal disposals.
- The due date for making payments under the Amnesty Scheme (currently 31st March) should be extended to 30th June 2025 to provide taxpayers with a fair opportunity to avail the benefit of the scheme.
