Institute of Charted Accountant of India
10th September, 2020
Shri S K Rahman,
Goods and Services Tax Council,
5th Foor, Tower II, Jeevan Bharti Building,
Janpath Road, Connaught Place,
New Delhi-110 001
Subject: Mechanism for accepting part payment of taxes and/or adjustment from cash ledger to boost revenue during COVID-19 time
Greetings. The Institute of Chartered Accountants of India (ICAI) has been proactively supporting the Government by providing its suggestions, creating awareness and disseminating knowledge of GST among various stakeholders.
Under the present system, the taxpayer is required to file return in GSTR-3B and make the payment through input credit, and short fall, if any, is met from the cash ledger. Only after filing the Return in GSTR-3B, it is presumed that payment has been made by the taxpayers and there is no relevance of the balances lying in the cash ledger of the registered person, although payment has already been credited to the Government.
It has been observed that many taxpayers are not filing their Return in GSTR-3B on timely basis because they are facing difficulties in paying full taxes and managing their working capital as they are receiving late payment generally over a period of 4-6 months from their customers especially in B2B supplies more so because of epidemic Covid- 19 and law demands payment on accrual basis. Therefore, it is suggested to devise a mechanism for receiving part payment of taxes till the industry recover and stabilises from the effect of Covid-19, which could be a win-win situation for both the Government, as they will receive early payment of taxes and at the same time taxpayers will not be required to pay interest on the part payment made by them. One of the ways could be treating payment in cash ledger as payment towards taxes. Other way could be developing a new mechanism for accepting part payment towards return for a particular month/period.
Hoping that our suggestions would be considered positively in the interest of taxpayers and suitable mechanism for accepting part payment would be devised. We shall be glad to provide any further input as may be required and your office may reach us at firstname.lastname@example.org or 9310542608.
CA. Rajendra Kumar P
GST & Indirect Taxes Committee
|S. No.||Dated||Made by||Link to View the Representation|
|1.||27/09/2020||Tax Bar Association, Guwahati||Extend due date for filing GSTR 9, 9A & 9C for year 2018-19|
|2.||19/09/2020||Independent Tax Research Analysis Association||Relax GST Annual Return & Audit dates for FY 2018-19|
|3.||19/09/2020||Confederation of GST Professionals and Industries||Extend Implementation of E-Invoicing to April 1, 2021|
|4.||17/09/2020||Confederation of GST Professionals and Industries||Extend due date for GSTR 9 & 9C of Financial Year 2018-19|
|5.||16/09/2020||Baroda Tax Bar Association||Request to extend due date of GSTR 9 & 9C for F.Y. 2018-19|
|6.||10/09/2020||The Institute of Chartered Accountants of India||Representation on difficulties in filing GSTR 9 for 2018-19|
|7.||10/09/2020||Institute of Chartered Accountants of India||Permit availment of ITC under GST pertaining to FY 2019-20: ICAI|
|8.||10/09/2020||Institute of Chartered Accountants of India||Request to devise mechanism to receive part payment of GST|
|9.||10/09/2020||The Institute of Chartered Accountants of India||Extend due dates of filing GST Annual return & Audit Report|
|10.||27/09/2020||Karnataka State Chartered Accountants Association||Extend due date for filing GSTR9 & GSTR9C for FY 2018-19|
|11.||24/09/2020||Bombay Chartered Accountants’ Society||Extend dates for various provisions under GST: BCAS|
|12.||14/08/2020||C.V.O. Chartered & Cost Accountants’ Association (CVOCA)||Representation on hardship under GST Laws on account of pandemic|
|13.||07/09/2020||C.V.O. Chartered & Cost Accountants’ Association (CVOCA)||Representation on 7 GST issues & hardships faced by taxpayers|
|14.||10/09/2020||National Association of Tax Professional (Haryana)||Extend Filing Date of Annual GST returns GSTR-9 & GSTR-9C|
|15.||24/08/2020||The Institute of Cost Accountants of India||Request to extend due date of filing of GSTR 9 & GSTR 9C|
|16.||29/09/2020||Ahilya Chamber of Commerce and Industry||Extend ITC availment, GSTR-9 & 9C Due dates till 31.03.2021|