WMTPA has written a letter to FM and said that they are Highly Disappointed with GST Audit Extension Press Release dated 30th Dec 2020, when delay is due to fact that Department / GSTN was not ready upto 30th Dec 2020. Full text of their representation is as follows:-


Date: 1st Jan 2021


Smt. Nirmala Sitharaman

Hon’ble Union Minister of Finance and
Chairman, Goods and Service Tax Council
Ministry of Finance, Government of India,
North Block, New Delhi — 110001

Subject: Highly Disappointed with GST Audit Extention Press Release dated 30th Dec 2020, when delay is due to fact that Department / GSTN was not ready upto 30th Dec 2020

Respected Madam,

The Western Maharashtra Tax Practitioner’s Association (Known as ‘WMTPA’), Pune, (formerly known as The ITSTP Association) was formed in 1980 with the object to assist the professionals and resolve common problem faced by the tax professional. WMTPA is one of the largest associations of Tax Practitioner in Maharashtra state and having about 1500+ members consisting of Tax consultants, advocates, chartered accountants & cost accountants who are practicing in taxation, corporate and other allied laws. Association’s primary objective is, to help the member to get acquaint with changes in various laws as well to help the government, by representing, issues faced by taxpayer as well as professionals

On time-to-time basis, our association WMTPA is submitting representation to your office on various aspects. Initially government was very positive with issues faced by professionals under GST and provided relief, as GST being new levy.


a) Professionals are Financial Pillars of Government- When government is able to collect monthly GST Revenue of R 1 lakhs crore approx, it is day and night efforts of all professionals in ensuring timely filing of GST Return from all taxpayers and needless to say, under GST, returns can not be filed without payment of tax.

b) GST is still unstable lawEven though, government is brining various notification on mid night, it is we professionals ensuring its implementation to all taxpayer. We are able to digest around 927 Notification/Circulars/ROD till date in last three years, which might be “world record” for any Tax Levy. This shows how much GST is unstable till date.

Notifications/ Circulars/Order 2017 2018 2019 2020 Total
Notifications: CT + CT Rate 122 109 107 100 438
Notifications: IGST + IGST Rate 62 35 32 11 140
Notifications: UTGST + UTGST Rate 64 45 31 7 147
Notifications: Cess + Cess Rate 8 3 4 0 15
Circulars: CGST + IGST + UTGST + Cess 29 56 50 14 149
Orders: CGST + UTGST 12 4 2 1 19
ROD: CGST + UTGST 1 4 13 1 19
Total 298 256 239 134 927

c) Professionals are bridge between Government and Taxpayer – We are bridge between Government and Taxpayer. We are also not interested in demanding any Extension, but when things are not in our control, businessmen finding it difficult to run the business and provide information to professionals, already due dates givens are impossible, we left with no option to approach to you for Extension.

d) Extension Demand is not for us but for Taxpayer – When we are demanding Extension, it is not for us but it is for taxpayer, who don’t understand GST Law fully.


a) GSTN opened window for GST Annual Return (GSTR 9) for F.Y. 2019-20 on 10th Dec 2020

Hone; News and Updates

GSTR-9 of FY 2019-20 is available now


Facility to file annual return in Forth GSTR-9 for FY 2019-20 is now available. The Form is enabled for taxpayers whose table 8A computation has been completed. Computation of the table 8A of the said return for auto population from returns is under progress which is likely to be completed soon. Please ensure that all applicable returns of  the said year have been filed before attempting to file the said return.

b) GSTN opened window and provided excel tool, for GST Audit/Reconciliation Statement in Form GSTR 9C for F.Y. 2019-20 on 31St Dec 2020

c) GST Annual Return and Audit/Reconciliation Statement (Form GSTR 9 and GSTR 9C) for F.Y. 2019-20 was amended on 15th Oct 2020 vide Notification No 79/2020 CT dated 15th Oct 2020

d) All professionals and Taxpayers were doing day and night efforts, for compliance of filing GST Annual Return for F.Y. 2018-19 and compliance under other acts (which was extended/stopped due to Covid lockdown), upto 31st Dec 2020.

e) Due date of 28th Feb 2020, is impossible to even God, but still government came with it. During Jan 2021 and Feb 2021, almost 20-25 days will be spent by all professional in doing monthly GST Compliance and implementation of other important changes in GST and other acts. How is it possible to complete GST Annual Return work in remaining 20-25 days for lakhs of taxpayers?

f) By specifying date of 28th Feb 2021 for GSTR9 and 9C of F.Y. 2019-20, you have shown great disrespect to efforts of all professionals, demand of all associations and request of many Members of Parliament.

g) Recommendation for due date of GST Annual Return of 2019-20: We Trust, Modi Government — “Sabka Sath, Sabka Vishwas”. Kindly keep trust on our efforts and suo moto make correction to (Notification No 95/2020 CT dated impossible date of 28th Feb 2021 and make it to 31st May 2021.


a) Your office was kind enough to extend due date for GSTR 9 and 9C for FY 2018-19 to 31st Dec 2020, due to write petition in Bombay high Court.

b) All professionals and Taxpayers work hard to achieve due date of 31st Dec 2020 for GST, Income Tax and Companies Act. However, due to effect disruption/unavailability of staff, when all associations in India and Member of Parliament has requested for one more last Extention of GSTR 9 and 9C for F.Y. 2018-19, your office has not considered said request.

c) We failed to understand, why government don’t Extend or relief from penalty, when the demand is due to genuine reason.

d) When forms are not filed in time, professionals feels so much of stressed and overloaded.

e) Recommendation for due date of GST Annual Return of 2018-19 – We request your good office to kindly give 1-2 more last extension for GST Annual Return GSTR 9 and 9C for F.Y. 2018-19 or at least given relief from Rs 200 per day penalty


  • When there is delay from Government in issuing Notification/circular (Numerous example can be quoted — on 30th Sep 2020, Govt issued notification for applicability of E-Invoice to Exporter from 1st Oct 2020, It took government almost one year to make basic changes effective of Finance Act 2020 and issued notification finally on 22nd Dec 2020 and keeping Taxpayers/professionals in between in confusion of its applicability) or when there is delay from GSTN to make change effect on Portal ( Numerous example can be quoted — On 10th Dec 2020 and on 30th Dec 2020 GSTN provided GSTR 9/9C of FY 2019-20, ITC 04 always have issues on GST Portal, It took GSTN 1.5 years to de-link Debit Note/Credit Note on portal, when law already amended ), time is automatically extended
  • But when it comes to genuine demand of professionals and taxpayers, government don’t give respect to it. This is nothing but double standard approach.

V. COMPLETE U TURN/HUGE DELAY FROM GOVERNMENT, STILL WE ARE SUPPORTING GOVERNMENT: When any new law is introduced and it is not full proof, it is expected that said law will be flexible. However, this is not case of GST. Due to detection of number of GST fraud, government is making GST Law complicated and strict day by day, which hit hard to honest tax payer. GST Is supposed to be simple tax system but unfortunately it is moving toward complex hard system.Below are few incidences, where government took complete U-Turn / Huge delay from government and still we supported government:

  • Implementation of GSTR 1,2,3 postponed and then suspended
  • Implementation of GST RET 1/2/3 never saw light of the day
  • It took, government 15 month to notify GST Annual Return Form after 1st July 2017 and too, form was corrected many times after that.


a) We appreciate huge efforts taken by government machinery for making GST successful and Easy Tax System, however this will not be possible without active participation and consideration of view of all Professional and Trade Bodies. We are with the Government and wish to make GST Easy Tax System and thereby making India as USD 5 Trillion Economy and World Leader.

b) Kindly keep GST little flexible and address demand of professional who are actually implementing the GST and all time to time changes

c) Kindly Extend time line for GST Annual Return GSTR9 and 9C for F.Y. 2019-20 to 315‘ May 2021 and for F.Y. 2018-19 by 1-2 more month or waive of penalty for 2018-19

d) Allow us to meet you and re-present various issue in GST and all officers of policy wing, so that we will be able to communicate is properly.

We are with Government and want government to be with us. Let make GST Successful by “Sabka Sath — Sabka Vishwas”. We shall be glad to provide any further inputs as may be required in this regards. Your office may reach to us on thewmtpa@gmail.com/munotswapnil@gmail.com/sonawanenarendra@ymail.com. We are hopeful that government will understand concern explained by us in this document and will come out with positive action on urgent basis.

Thanking you with Warm Regards,

For The Western Maharashtra Tax Practitioner’s Association
Mr. Vilas Aherkar
Mr. Narendra Sonawane
Chairman, SGST Committee
CA Swapnil Munot
Convener, SGST Committee


1. The Chairman of Central Board of Indirect Tax and Custom, North Block, New Delhi – 110001

2. Hon’ble GST Council Secretariat 5th Floor, Tower II, Jeevan Bharti Building, Janpath Road, Connaught Place, New Delhi-110 001

3. The CEO, Goods and Service Tax Network, East Wing, 4th Floor, World Mark 1,Aerocity, New Delhi 110037

4. Hon’ble State Finance Minister, Maharashtra State Mantralaya Mumbai — 400032

Download Representation in PDF Format

Also Read:-

S. No. Date Association Particulars with link
1 9 Dec 2020 Western Maharashtra Tax Practitioners Extend due dates of Tax Audit & ITR for AY 2020–21
2 12 Dec 2020 Gujarat Sales Tax Bar Extend GSTR-9/9A/9C due date for FY 2019-20 to 30/06/2021
3 12 Dec 2020 Chamber of Tax Consultants Extend due dates for Tax/Transfer Pricing Audit & ITR for AY 2020-21
4 12 Dec 2020 Tax Practitioner’s Association, Indore Extend due dates for filing Tax/TP Audit Report & ITR for AY 2020-21
5 14 Dec 2020 AGFTC, ITBC and CAA Extend due dates of Tax Audit Reports/ITR for A.Y. 2020-21
6 15 Dec 2020 BCAS, CAA (Ahmedabad), CAA (Surat), KSCAA & LCAS Request to Extend Due dates under GST & Income Tax
7 15 Dec 2020 Tax Bar Association, Bhilwara Request to extend Due Date of filing of Tax Audit & ITR
8 15 Dec 2020 Direct Taxes Professionals’ Association, Kolkata Extend due date of ITR & Tax Audit for AY 2020-21
9 16 Dec 2020 Lucknow CA Tax Practioners’ Association Extend Due date for filing Tax Audit Report & ITR
10 16 Dec 2020 Jamshedpur Chartered Accountants Extend Due Date of filing Tax Audit & ITR to 31.03.2021
11 13 Dec 2020 Direct Taxes Committee of ICAI ICAI requests for extension of various Income-tax due dates
12 10 Dec 2020 Udaipur Tax Bar Association Further extend due dates of ITR & Tax Audit Reports for FY 2019-20
13 15 Dec 2020 CA Social Affiliation (CASA) Extend Tax/TP Audit Report & ITR filing due date for AY 2020-21
14 19 Dec 2020 Chartered Accountants Association, Jalandhar Extend Due Dates for Tax Audit and Income Tax Return Filing
15 19 Dec 2020 All India Federation of Tax Practitioners (CZ) Request for extension of due dates of Tax Audit Reports/ITR
16 19 Dec 2020 Vyyapaar Mandal Association, Nagore & AIMTPA Extended Income Tax & GST Audit/Return/Compliance dates
17 17 Dec 2020 Emerging Businesses Chamber Of Commerce Extend due dates for Income Tax Audit & Returns for AY 2020-21
18 Dec 2020 The Uttar Pradesh Tax Bar Association Representation for Extension of time for Tax Audit & Return
19 19 Dec 2020 Tax Bar Association, Guwahati Extend Tax Audit/ITR due dates for AY 2020-21
20 21 Dec 2020 Tax Bar Association, Guwahati Extend due dates of GSTR-9/ GSTR-9C for FY 2018-19 & 2019-20
21 17 Dec 2020 Karnataka State Chartered Accountants Association Waive Late Fees for Delayed Filing of GST Returns
22 15 Dec 2020 Direct Taxes Professionals’ Association Extend Vivad Se Vishwas Scheme due date to 15.03.2021
23 15 Dec 2020 Direct Taxes Professionals’ Association Extend due date of AGM to 31st March 2021
24 15 Dec 2020 Association of Tax payers & Professional, Agra Extend due of GSTR-9, GSTR-9A & GSTR-9C
25 08 Dec 2020 Tax Bar Association (Regd), Allahabad Extend due date of ITR/Tax Audit/GSTR-9/GSTR-9C
26 08 Dec 2020 Tax Consultant & Practitioners Association of Kerala Extend due of ITR, GSTR 9, 9A & 9C for FY 2018-19 & 2019-20
27 21 Dec 2020 Tax Bar Association, Guwahati Extend CFSS 2020 & LLP Settlement Scheme 2020 to 31.03.2021
28 22 Dec 2020 Income Tax Bar Association, Lucknow Extend Time for filing ITR & Audit Report for A.Y 2020-21
28 22 Dec 2020 53 GST and Trade Associations 53 Associations requests Extension for GSTR 9, 9A & 9C
29 16 Dec 2020 Chandigarh Chartered Accountants Taxation Association Extend Income Tax & GST Return & Audit due dates
30 22 Dec 2020 Bhayander CA Social Group Request to extend Due date of Annual GST Return & Audit
31 22 Dec 2020 Luminaires Accessories Components Manufacturers Association Extend due dates for Tax Audit & Income Tax Return filing for AY 2020-21
32 22 Dec 2020 All Professionals, Tax Payers and Stakeholders Open letter for extension of Due dates under Income Tax and GST
33 22 Dec 2020 Punjab Accountants Association Extend due date for filing ITR & Tax Audit Report- AY 2020-21
34 22 Dec 2020 Bhayander CA Social Group Extend Income Tax Audit & ITR Due dates for AY 2020-21
35 23 Dec 2020 The Tax Bar Association, Odisha Extend due dates of Audit Reports, ITRs, GST Returns, VSV Scheme
36 21 Dec 2020 Sales Tax Bar Association, Delhi Extend Tax/TP Audit & ITR Due dates for AY 2020-21
37 23 Dec 2020 Direct Taxes Professionals’ Association Extend Income Tax, Companies & CGST Act compliance due dates
38 24 Dec 2020 ICSI Extend due dates of CFSS, LLPSS, Charge Forms, Meetings
39 24 Dec 2020 All Odisha Tax Advocates Association Extend due date for filing TAR/ITR/GSTR9/9A/9C
40 25 Dec 2020 BJP Economic Cell, Rajasthan Extend Income Tax, GST, LLP, Company Law due dates
41 23 Dec 2020 Hyderabad Chartered Accountants’ Society Extend Due date under GST and Income Tax
42 22 Dec 2020 A. P. Tax Bar Association, Vijayawada Extend date of filing of GSTR 9, GSTR 9C and IT returns
43 03 Jan 2021 National Company Law Tribunal Bar Association Representation for further extension of CFSS 2020
44 25 Nov 2020 Merchants Chamber of Uttar Pradesh Request for extension of Company Fresh Start Scheme 2020
45 04 Jan 2021 Adv. Anuj Bhatt Request to President to take Suo-Moto cognizance of GST Issues
46 03 Jan 2021 The Chamber of Tax Consultants Extend Income-tax due dates with humane approach
47 01 Jan 2021 WMTPA Highly Disappointing GST Audit Due Date Extension
48 01 Jan 2021 The A.P. Tax Bar Association, Vijayawada Extend due date of Form GSTR 9 and 9C for year 2018-19

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  1. Jignesh Kumar says:

    Hope some positive compliance from FINMIN for smooth and positive ambience at both side – from taxpayers and from government.

  2. Dinesh says:

    Well written representation to the Govt. Brings out the chequered history of GST in the country. This is something the Govt and it’s machinery should understand

  3. Neeraj Tandon says:

    We are hopeful that Govt. considered the same. After impose of GST the life of accounts pepole as well as professionals are so complicated. Everyday new notification takes place, they are so complicated in compliance, by which way Govt. expected that we do all the work on stipulated time frame. There is a basic difference in assumptions an practical.

  4. U.M.NATARAJAN says:

    Waiver of penalty given by the government during COVID19 is only an EYEWASH. If the government truely wants it to be used by the Tax Payer, it should extend the limit upto COVID19 compleation. Mere giving an opportunity at time of Peak COVID19 is not useful to the trade people. Govt. should Consider this


    We completely understand the hurried way of getting through the datelines for Return filing under different revenue garnering laws as the coffers are relatively lighter in this pandemic condition, but still Govt. can do its bit to ease the penalty provision to make both the Tax Practitioners and tax Payers life little easier.


    This sort of representation is also required for Income Tax Return filing date for AY 2020-21 which is 10th Januarty 2021 for non audit assessee.

  7. Chandrashekar Shetty says:

    Govt is hellbent on making professionals life miserable and GST procedures more complicated. MSME have a tough time. But Govt is adamant for unknown reasons.

  8. Manoharan s says:

    The policy makers and the gst officials think that they are lords have right to send notification amends without counsel with the tax payers team What to do no one come frward to object orfile suit against the dept. We may file suit that the amends to be made only at the time of budget

  9. Saatwik Jain says:

    I support word to word to this presentation given by the Maharashtra Association. I also urge to all the Associations to speak for our Rights and Problems, else nothing will going to change and we have to work always in a peer pressure. It also has a side effect on our Health and Social life as well. And after all we all know that we can’t rectify anything in GST which itself is Injustice.

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