URGENT STEPS NEEDED  TO MAKE GST COMPLIANCES EASIER

Business community is still not able to cope up with the GST Compliances due to various complicated and irrational provisions. Based on the feedback received from various stakeholders I have listed some of the suggestions  which will be helpful with respect to :

a) ease of doing business ,

b) reducing the administrative energy and cost of assesseess as well as government ,

c) revive the Economy ,

d) Better compliances of law.

A) GST REVERSE CHARGE AND TDS PROVISIONS SHOULD BE REMOVED

GST reverse charge and TDS are mostly  Revenue Neutral . It unnecessarily increases the administrative work of assesses as well as administration. In some Industries where final products are exempt/partially exempt there is a loss of credit. Also in some seasonal industries like Cotton Ginning & Oil Industries there is a time lag between raw material procurement and production resulting in blockage of working capital.

B) GST PAID ON COMMERCIAL CONSTRUCTION SHOULD BE AVAILABLE FOR CREDIT

GST Input Tax Credit should not be blocked on Commercial Construction (Factory Buildings, Warehouses, Godowns, Offices etc). Otherwise GST rates on Cement and Steel should be brought down to 12%. It will have following benefits :

1. It will reduce the construction cost . Current GST rates on Cement is 28% and on Steel it is 18%.

2. It will boost the real estate sector  which is reeling under depression.

3. Economy slow down can be checked.

4. Infrastructure development will get a boost.

5. GST avoidance can be checked.

C) INPUT TAX CREDIT MATCHING SHOULD BE REQUIRED QUARTERLY ONLY

The reason being there are Monthly/Quarterly return filing system. It will remove to some extent the monthly transitional face, reduce monthly mismatches , reduce the monthly workload.

D) E-WAY BILL BLOCKING

Before blocking of E-way Bill at least a 15 days notice should be given and in cases of genuine reasons grace period  should be granted.

E) E-WAY BILL SYSTEM SHOULD NOT BE APPLICABLE TO INTRA CITY MOVEMENT

It is unnecessarily increasing the compliance burden of assesses.

F) THERE SHOULD BE UNIFORM THRESHOLD LIMIT FOR E-WAY BILL

For example in Maharashtra  the threshold limit is Rs.100,000/- for Intra State Movement however for Inter State Movement it is Rs.50000/- only.

G) THERE SHOULD BE A SINGLE CASH LEDGER FOR ALL THE 3 GST

It will help the assessee in utilising the funds in a better way. It will also reduce the mistakes done while making GST payments under various heads.

H) TDS ON GST SHOULD BE ALLOWED FOR MAKING PAYMENT OF IGST ON IMPORTS

Currently if someone is sourcing raw material from imports and supplying to government then Govt. deducts TDS which can not be utilised to pay IGST on Imports. Resulting in accumulation of credit and blocking of funds.

I) IF ANY WAIVER FOR LATE FEES/PENALTY IS GIVEN THEN IT SHOULD ALSO BE GIVEN TO ASSESSEES WHO HAVE HONESTLY PAID THE LATE FEES/PENALTY FOR THE SAME PERIOD

For example : A waiver for late fees is announced on 15th December  for the returns not filed for a period from April 19 to Sept 19. Now anyone who has filed returns for this period on 10th December with late fees feels cheated.

J) INSTEAD OF ANNUAL RETURNS AND AUDIT (GSTR 9 AND 9C) THERE SHOULD BE A CONSOLIDATED RETURN FOR THE PERIOD FROM JULY 2017 TO MARCH 2020 . 2020.

Already due date for Annual Return and Audit return (9 and 9C) have been extended so many times. Still there are so many complications due to various reasons , that is why a big percentage of assesses are yet to file these returns. Even government also waived filing of GSTR 9C for a specific segment. As this was the initial stage of GST implementation it will be better to have a consolidated return for a period from July 2017 to March 2020.

K) DEPARTMENT SHOULD NOT CALL FOR HARD COPIES OF GST FORMS FILED FOR VERIFICATION / AUDIT ETC.

Department is unnecessarily calling for hard copies of returns filed from the assesses for verification, when the same is easily available on portal.

These are some of the measures which can reduce the compliance burden of assesses and administrative burden of Department without hampering the revenue collection at all.

(Author is a Practicing Chartered Accountant and Past Chairman of Nagpur Branch Of ICAI and can be reached at satishsardanagpur@gamail.com)

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