ALL INDIA JOINT REPRESENTATION COMMITTEE FOR GST
An alliance of 44 DST and Trade Associations for partnering Government in GST issues resolution
Wednesday, 16 October 2020
Honourable Prime Minister of India
Prime Ministers Office
South Block, Raisina Hill
This representation was hosted on http://chng.it/8rbfnbcqNh and 6205 signatures were received from 07.10.20 till 16.10.20 till 9.51 a.m. ( Screen shot annexed)
Respected PM Ji,
44 GST and Trade Associations all over India have come together to submit this joint petition to your good self along with signatures of professionals, like lawyers. chartered accountants, cost and management accounts and GST practitioners, as well as taxpayers and their employees from all over India. We are writing to you in connection with the decision of the Government of India to extend the due date for submitting the annual return (GSTR-9) and audit report/reconciliation statement (GSTR-9C) for FY 2018-19 from 30.9.2020 to 31.10.2020. We have also organised a signature campaign from 7th October, 2020 to 15Ih October 2020 in order to garner support for this petition on www.change.org. The list of signatures is appended to this petition.
The nation is going through a great and unprecedented turmoil. A raging and deadly virus, known as the coronavirus, is on the loose. The Government of India has been encouraging the people to work from home as much as possible and to avoid An alliance of 44 GST and Trade Associations for partnering Government in GST issues resolution
stepping out of the home However, in the midst of this pandemic, the Government has taken a decision which, with respect, is not only causing a great hardship to various stakeholders, but is also puffing the health of many professionals and employees of businesses at risk.
As you are well aware, the forms and utilities for filing the GSTR-9 and 9C for FY 2018-19 were not available till 1s‘ week of March, 2020. This is acknowledged by none other than the GST Council itself. However, immediately the lockdown struck and for the next three months, till 31.5.2020, the nation was in a lockdown mode.
Thereafter, the Government of India had started the unlock phases. However, many states did not allow private offices to work at full strength. For example. in the State of Maharashtra, only 10% of the employees or 10 persons (whichever is higher) were allowed till end of August, 2020. Only from September,2020, 30% of the staff strength is being allowed. Even today only 30% of the employees are allowed.
Businesses in India are not entirely paperless, even the big corporates. Audit and the compilation of the annual returns requires large amounts of data to be checked and made available to the professionals who are conducting the audit or compiling the return. There are confidentiality issues also: data cannot be shared seamlessly over the internet with auditors and consultants, and specially with employees of auditors for work from home. Furthermore, there is a staff shortage at both client’s end as well as the professionals’ end and even if the paper records are to be scanned and sent to the auditors etc., there is a serious shortage of manpower to carry out these functions. In the city of Mumbai, which has the largest tax base for GSTR-9/9C purposes, the local trains are not working. Staff has to travel for 3 to 4 hours on buses to reach office. It is just not possible to comply with the annual return and annual return/audit deadline of 30.10.2020 in this scenario.
In normal times, the Government extends the time limit on the last day This is obviously done so that there is no complacency and to achieve maximum compliance. However, the times today are different. This short extension has caused widespread panic amongst businesses and professionals and waiting for the last day to extend time limit will only cause more harm than good. With such severe limitations and panic, the only outcome from this short extension will be that the professionals and their staff and staff of the taxpayers will have to put their health at risk and run from pillar to post to compile the data and then to complete the audit and annual return work.
Sir, the annual return and audit report are methods of voluntary compliance by the assessees. The audit by a private agency ensures that any discrepancies or shortfall in payment of tax is brought to the notice of the taxpayer as well as the Government. This acts as a motivation to taxpayers to resolve these discrepancies on their own and pay the deficit tax voluntarily instead of risking recovery and penal action from Government. However, if the audit assignments are completed in a hurried manner. who is going to benefit? The Government will end up being the biggest loser from botched up audit reports and wrong data being sent to it.
As our Prime Minister, you are in the position of the father of the family of this entire country. We are therefore requesting you to take notice of our difficulties. This is a matter of our health and the health of our families, staff and their families. The public health cost of this decision to give only a short extension will far outstrip whatever benefit the Government derives from this short extension
Kindly therefore extend the due date for submitting the GSTR-9 and GSTR-9C to at least 31.12.2020. We do not want to completely ignore our obligations and ask for unending extension. We are committed to partnering the Government in nation-building, We only want more time to cope with the extra-ordinary times.
The President of the Confederation of GST Professionals and Industries is formally signing this petition on behalf of all the 44 associations since taking individual signatures from all the representatives of these associations on this petition is not possible. The Confederation is having the necessary letters of support of these associations joining this petition as well as signature campaign We are also marking all these association representatives in “cc”
Thanking you in anticipation.
ON BEHALF OF ALL 44 ASSOCIATIONS
CA Sujata Rangn kar
Confederation of GST Professionals and Industries
1. The Hon’ble Finance Minister of India
Rajpath Marg. E Block.
Central Secretariat. New Delhi.
Email: fmoanic.in; appointment.fmactovin
2. The Honourable Chairman,
Office of the GST Council Secretariat
5th Floor. Tower II. Jeevan Bharti Building, Janpath Road.
Connaught Place. New Delhi-110 001
3. The Chairman, CBIC.
Govt of India, North Block
New Delhi -110001
LIST OF JOINT SPONSORS OF THIS PETITION
Confederation of GST Professionals and Industries
Maharashtra Chamber of Commerce and Industry
Western Maharashtra Tax Practitioners Association
Western Maharashtra Chamber of Commerce, Industries, Agro & Education
North Maharashtra Tax Practitioners Association
Rajarampuri Merchants Association
Tax Consultants Association (Sangli)
Tax Practitioners Association (Yavatmal)
The Tax Practitioners’ Association (Aurangabad)
Nag Vidarbha Chamber of Commerce
Goods & Services Tax Bar Association (Nagpur)
The Tax Practitioners’ Association, Nanded
Tax Bar Association (Amravati)
Jalgaon District Tax Practitioners’ Association
Hingoli Tax Practitioners’ Association
Tax Practitioners Association Nashik
Goods and Services Tax Practitioners Association of Sindhudurg
Ratnagiri Tax Practitioners’ Association
Tax Consultant’s Association of Kolhapur
Bhiwandi Tax Practitioner’s Association
Karad Tax Practitioners Association
Tax Practitioners’ Association Thane
Tax Friends Association (Mumbai)
Tax Bar Association (Akola)
Malad Chamber of Tax Consultants (Mumbai)
Kolhapur Chamber of Commerce and Industries
Gujarat Sales Tax Bar Association
All Gujarat Federation of Tax Consultants
The Southern Gujarat Chamber of Commerce and Industry
Taxation Consultants’ Group
Tax Advocates Association Gujarat
Foundation of Tax and Accounting Professionals
Association of Finance and Tax Professionals
Rajasthan Vitta Salahkar Samiti
Jaipur Chartered Accountants Group
Tax Consultants’ Association Jaipur
Peer GST (Jaipur)
District Tax Consultants Association, Chittorgarh
Tamil Nadu Tax Consultants Association
Telangana Tax Practitioner’s Association
Belagavi Chartered Accountants’ Association
Tax Bar Association
All Goa Tax Practitioners’ Association
The Goa State Industries Association