prpri All India Common Representation on GST Amensty & Revocation Issue All India Common Representation on GST Amensty & Revocation Issue


SUBJECT To Increase Government GST Revenue and giving True Benefit of recent Amnesty Scheme

SYNOPSIS OF ISSUE  Recently in 43rd GST Council, Government has announced GST Amnesty Scheme for filing Tax Return from July 2017 to April 2021 with reduced late fees of Rs 500 / Rs 1000. However many taxpayer wish to pay the tax for past period and file GST Return. However, their GST registration is cancelled and time limit for revocation is over. Due to which, even though taxpayer wish to pay tax for past period and file return, then are unable to do so. This hardship is impacting government’s GST Collection too.

Representation Conceptualised, Initiated & Drafted by CA SWAPNIL MUNOT

Representation Supported By

Name of Association State
Maharashtra Tax Practitioners’ Association Maharashtra
GST Practitioners’ Association, Amritsar Punjab
Jaipur Tax Bar Association Rajasthan
Jamshedpur Chartered Accountants Society Jharkhand
North Maharashtra Tax Practitioners Association Maharashtra
A. P. Tax Practitioners and Consultants Association Andhra Pradesh
Chartered Accountants Association, Surat Gujrat
Tax Practitioners’ Association Nashik Maharashtra
Devbhoomi Tax Bar Association Uttara Khand
Tax Practitioners’ Association Nashik Maharashtra
Tamil Nadu Goods & Service Tax Professionals Association Tamil Nadu
All Odisha Tax Advocates Association (AOTAA) Odisha


Shri Narendra Sonawane CA Swapnil Munot Adv G Y Patwardhan Shri Manoj Chitalikar Shri Sharad Suryawanshi

(Formerly know as The western Maharashtra tax Practitioners’ Association)

Address : Yadav Vyapar Bhavan, Shivaji Road,
602, Shukrawar Peth, Pune 411 002
Phone No:- 022-2447 0237

Date: 29th June 2021


Smt. Nirmala SitharamanChairman, Goods and Service Tax Council and Hon’ble Union Minister of Finance
Ministry of Finance, Government of India, North Block, New Delhi – 110001
Shri Ajit Pawar

Member, Goods and Service Tax Council, Dy CM and Finance Minister of Maharashtra
Mantralaya, Mumbai – 400032


राष्ट्र को आगे बढ़ाना है। GST को सरल बनाना है

Subject: Representation to increase Government GST Collection (Tax Augmentation) and giving True Benefit of recent Amnesty Scheme announced in 43rd GST Council Meeting.

Respected Sir/Madam,

We, Maharashtra Tax Practitioners’ Association (MTPA, formerly known as The Western Maharashtra Tax Practitioners’ Association), was formed in 1950 with the object to assist the professionals and resolve common problem faced by the tax professional. MTPA represents 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.

We are thankful to your office and GST Council, for taking various measures in Covid pandemic for GST relief in 43rd GST Council meeting. We appreciate that government has reduced GST Late fees permanently and also announced GST Amnesty Scheme for July 2017 to April 2021, by reducing GST Lates to Rs 500 and Rs 1000 as per applicable.

This GST Amnesty scheme for period July 2017 to April 2021 is applicable only if, GST Returns with Tax payment is filed upto 31st Aug 2021.

Details of Issue and Representation:

Many taxpayers whose GST Return and Tax Payment was outstanding for past period, wanted to file their pending GST Return with Tax Payment, but due to heavy GST late fee (which was coming in lakhs) were unable to file (as under GST, returns cannot be filed without late fee payment).

Now with GST amnesty scheme, many taxpayers – a) wants to file their outstanding Tax Return. b) want to make Tax Payment to government and c) want to come on the path of compliance.

However, issue with such taxpayer is that, their GST Registration is cancelled by GST  officers/department due to non-filing of return and time limit of 90 days for revocation of such cancelled registration is also over. Due to which said taxpayer are not able to activate  GST Registration and make payment of pending tax liability to government.

This is causing hardship and impacting all stake holder (including government) as per below:

  • LOSS OF TAX COLLECTION TO GOVERNMENTTaxpayer wants to make taxpayment and file pending returns, but due to expiry of 90 days, said taxpayer are not able to activate their cancelled GST Registration and Government is losing Tax collection in such case.
  • IMPACTING MSME TO DO BUSINESSThis issue is peculiarly with MSME. Such people, who did mistake and wants to correct their noncompliance and start the new innings, but unable to do so, as their GST Registration is cancelled and now it can not be activated. This is stopping the person from doing the business (Impacting Self employed / small entrepreneur taxpayer).
  • TAX PAYER ARE DEPRIVED OF “TRUE BENEFIT OF AMNESTY” DUE TO EXPIRY OF TIME LIMIT TO ACTIVATE GST REGISTRATIONWith positive action, government came with GST Amnesty scheme, in order to help small taxpayer to file their pending GST Return and make payment of tax. However due to cancelled GST Registration status, they are not able to do so. Also, in many taxpayers’ case, time limit of 90 days, to reactivate such cancelled registration is over. This directly impacting, rather stopping, taxpayer to avail this Amnesty scheme.

Therefore, we request to kindly allow all taxpayer whose Registration is cancelled for any period (From July 2017 to April 2021), to reactive their GST Registration, Make Payment of Taxes to government, file their GST Return and Come on the path of compliance “

♦ With this representation, we are not supporting taxpayer who are defaulter. However, we request government to –

√ Give them one chance to reactive their GST Registration where time period of 90 days is over.

Taxpayer wants to make payment of their outstanding liability. Help such taxpayer to make tax payment to government

v’ Help such MSME to make new good start. Help such MSME to come on the path of compliance.

♦ We are sure, if our this “All India Common Representation” on recent amnesty , if accepted, will benefit to

  • Government → By getting tax from the taxpayer who wish to but unable to do so
  • Taxpayer → By starting new inning of Tax Compliance
  • Overall Economy → By encouraging taxpayer who stopped their business due to registration cancellation and

We request you to kindly consider and give relief for above mentioned points. Hoping for early relief / action from government. Since GST Amnesty scheme is valid upto 31st Aug 2021, it is important to consider above representation at earliest.

For Maharashtra Tax Practitioners’ Association

Mr. Manoj Chitalikar
Mr. Narendra Sonawane
CGST L & R Committee
CA Swapnil Munot
CGST L & R Committee


1) Shri Narendra Modi ,The Prime Minister of India
152, South Block, Raisina hills, New Delhi 110011

2) Shri Anurag Thakur, The Minister of State finance and Corporate Affairs
North Block, New Delhi – 110 001

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

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

5) Commissioner, GST Policy wing
North Block, New Delhi – 110001

6) The Principal Chief Commissioner of Central Tax,
GST Bhavan, Sassoon Road, Pune 411001

7) The Additional Commissioner of State Tax,
GST Bhavan, Yerawada

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