F. No. 450/36/2018-Cus IV
Government of India
Ministry of Finance
Department of Revenue
(Central Board of Excise & Customs)
New Delhi, 28th March, 2018
All Principal Chief Commissioners/Chief Commissioners under CBEC.
All Principal Commissioners/Commissioners under CBEC.
Subject: Problems encountered in sanction or IGST refund Non-transmission of data from GSTN to Customs—reg.
As you are aware that numerous steps have been taken to resolve errors in the refund claims held up with Customs system However, various representations have also been received from the trade that the refunds are held up due to non transmission of data from GSTN to Customs system. Such refund claims have not come to Customs System due to incorrect or insufficient information filed by exporters on the GST portal.
2. Wherever information provided in GSTR I is incorrect or insufficient, exporters have been given the option to rectify the same through Table 9A of GSTR 1. The modification done through Table 9A have been transmitted by GSTN to Customs EDI system. However, there are large number of cases wherein data has still not been transmitted by GSTN to Customs EDI system due to failure on account of other validations at their end. One of the checks done by GSTN is to ensure that the refund claimed is not more than the IGST paid by the exporter. In other words, the aggregate IGST paid amount indicated in Table under column 3.1 (b) of GSTR 3B of the corresponding month Such validation failure is due to the following reasons
I. Issues pertaining to declaration of Cess amount
(a) Table 6A under Table 6 of GSTR 1 requires feeding of details with regard to Integrated Tax mainly the rate, taxable value and amount on account of exports.
As there is no column to declare Cess amount separately, some of the exporters have declared the total of IGST and Cess paid amount in the column meant for IGST amount only. The declaration of IGST and Cess amount, in the manner, as above, has resulted in mis-match of IGST amount figures declared in Table 6A of GSTR 1 vis a vis figures shown in Table 3.1 (b) of GSTR-3B, resulting in data not getting transferred from GSTN to Customs EDI system as amount of IGST paid reported in Table 6A of GSTR 1 is higher than the IGST amount indicated in table 3.1 (b) of GSTR-3B.
(b) For non-transmission on account of failure of above validation, the matter has already been taken up with GSTN and Principal CCA for resorting to system based solution.
II. Export Supplies has been declared as domestic supplies in GSTR 3B
(a) It is also observed that some or the exporters have provided correct details in Table 6A of GSTR 1 but while tiling GSTR-3B, particulars of exports have been furnished incorrectly by not declaring the entire export data in Table 3.1 (b) of GSTR-3B, meant for data concerning exports. In these cases, the data relating to Table 3.1 (b) has been shown in Table 3.1(a) or in other words export supplies have been shown under domestic supplies.
(b) For cases where validation failure is due to above reason, it has been decided that wherever it is not possible to compute the correct value of 3.1(b) using system/logic, the GST field officers need to be deputed in the Custom Houses in order to specifically scrutinize the returns and seek necessary clarification from the exporters wherever necessary
(c) In such cases the exporters have filed details or export supplies in domestic supplies i.e. instead of providing details under Table 3.1 (b), the exporters have filed in other Tables like 3.1 (a) or 3 (d). The GST officers would reconcile the data submitted by exporters in GSTR 1 and GSTR 3B so as to enable those cures to be processed further.
(d) The officers would compare the aggregate data of inter- state supplies declared in Table 4. 5., 6A and 7B along with amendments, if any declared in Table 9, 10 and 11 of FORM GSTR-1, with the aggregate data of interstate supplies declared in Table 3.1(a), 3.1(b) and 3.1(d) of FORM GSTR-3B. Thereafter, if the aggregate value get matched, then the officer would calculate the notional value of Table 3.1(b) on the basis of reconciliation.
(e) The notional value of Table 3 has so arrived after calculation at (d) above should be greater than IGST amount declared in Table 6A of GSTR 1. While reconciling the data, the officer shall also take into account the amount of IGST paid as shown under Table 6.1 of GSTR 3B. In no case, the notional values of IGST in Table 3.1 shall exceed the value of IGST paid in Table 6.1 of GSTR 3B. In no case, the notional values of IGST in Table 6.1 of GSTR 3B. The purpose of the above check is to ascertain whether details pertaining to export supplies are actually filed under domestic supplies or not.
(f) Only in cases where it can be established that the mistake is only on account of feeding details as above, the officer may send the reconciled data to Customs System for further processing.
3. The reconciled data of GSTR 3B would be sent to Customs Systems in the format as per Annexure- A
4. Field limitations may take in writing form the exporters about the errors made while filing Table 3.1(b) of GSTR 3B. The officers have to ensure that revised values submitted by exporters in Table 6A of GSTR 1 shall be less than or equal to that in 3.1(b) of GSTR 3B. These documents must also be preserved best they be required subsequently for any investigation or otherwise.
5. In cases, where the errors committed by exporter arc not restricted to declaring export supply as domestic supply, a letter from exporter explaining the error and the correction to be made in GST return shall be taken. In such eases, exporter may also provide a certificate from Chartered Accountant that the IGST has been paid on export or goods for which IGST refund is being claimed.
6. It has been decided that the GST field formations shall provide sufficient number of officers to be stationed at the designated Customs Houses in their jurisdiction for such verification/ scrutiny. The Chief Commissioners of CGST may co-ordinate with Chief commissioners of Customs. wherever required. Customs Houses will provide necessary infrastructure support to all such GST officers deputed to carry out such verification/ scrutiny of GST returns.
L. Satya Srinivas
Joint Secretary (Customs)
The format for data to be sent after verification/reconciliation with respect for interstate supplies
(To be filed in Excel Sheet only)
|Sr. No.||Information||Data as per Original GSTR 3B||Reconciled Data after Scrutiny/ Verification|
|1||GSTIN of exporter|
|2||Period of Return (in MM/YYYY)|
|3||Taxable Value shown in 3.1(a)|
|4||IGST paid shown in 3.1(a)|
|5||Cess paid shown in 3.1(a)|
|6||Taxable Value shown in 3.1(b)|
|7||IGST paid shown in 3.1(b)|
|8||Cess paid shown in 3.1(b)|
|9||Taxable Value shown in 3.1(c)|
|10||IGST paid shown in 3.1(c)|
|11||Cess paid shown in 3.1(d)|
|12||Taxable Value shown in 3.1(d)|
|13||IGST paid shown in 3.1(d)|
|14||Cess paid shown in 3.1(d)|