(Set up by an Act of Parliament)


Date: 10th January, 2018

Smt. Vanaja N Sarna

Central Board of Excise & Customs
Department of Revenue,
Government of India,
North Block,
New Delhi 110001

Subject: Issues in filing of GSTR-1 & Enabling Transitional Credit to assessee, who could not file TRANS-1 due to system glitches

Reference : Our earlier representation ICAI/IDTC/2017-18/Rep/26 dated 29th December, 2017


Your goodself is aware that the Institute of Chartered Accountants of India (ICAI) is working towards the smooth implementation of GST. The ICAI, being the accounting regulator, has been proactively supporting the Government in creating awareness and disseminating knowledge of GST among various stakeholders. The ICAI has organized more than 3000 programmes across the country, attended by more than 2.5 lacs participants. We are glad to note that more than 125 of our suggestions have been accepted by the Government for the smooth implementation of GST.

We would like to bring to your notice that assessees across the country are facing difficulties in filing Form GSTR 1, which includes the following:

1. System is not generating summary within 5 minutes. Sometimes it takes around 12 hrs. due to which assesses are not be able to proceed.

2. Even though assessees are generating json file in the Latest version of Offline Tool, on uploading such file system shows it as generated in old version.

3. In B2B sheet, assessee round off the tax dues, bill wise. But the System is finalising without rounding it off to rupees.

4. The filing of refund claims manually defeats the fundamental premise of GST being paid for supplies by exporters. In the interim till matching is firmly in place, it is suggested that the 90% be paid provisionally subject to verification within next 2 months.

As the last date of filing Form GSTR 1 is today, 10th January, 2018 but due to such system errors assesses are finding it difficult to file the return before due date. Accordingly, your goodself is requested to give relief to the assessees by extending the date by one month after proper testing of system. Further, it is important to note that waiver of late fees vide Notification No. 64/2017 Central Tax dated 15th Nov, 2017 provided in case of Form3B return filing only, which may also be extended for GSTR 1 return also.

Also, we refer our communication dated 29th Dec, 2017 wherein we bought to your notice that some assessees who were required to file TRAN 1 before the due date i.e. 27th December were unable to submit due to website issues, as before due date on saving data, website was showing ” Some uploaded record are in progress, Kindly submit once it is processed” due to which such assesses would not be able to claim TRAN 1 transitional credit. Your good self is requested to resolve the issue of such assesses to enable them to claim transitional credit.

It is a genuine hardship to the assessee because of delayed functionalities and system failure. Accordingly, your good self is requested to resolve the issue related to TRAN 1 to enable such assesses to claim transitional credit and extend the due date of GSTR-1 return appropriately.

We as ICAI, is always at support to the Government for smooth implementation of GST. In case of any queries you may contact CA. Sharad Singhal, Secretary, Indirect Taxes Committee at or 0120-3045954 / 9310542608.


CA. Madhukar Hiregange


Indirect Taxes Committee

CA. Sushil Goyal


Indirect Taxes Committee


More Under Goods and Services Tax


  1. vijayalakshmi says:

    we have closing stock of itc value as on 30.06.2017 approximately 9.5 lakhs. but we have not submitted some technical issues in gst potral on 27.12.2017. next day it is showung date is over. we are waiting for reopen trans -t . now showing not able to submit trans 1. please help us what i can do.

  2. Ishu says:

    Not Able to file 3B since two months its showing ” You Had Submitted TRAN 1 but have not filed it ” but i have never submitted any TRAN 1 form. Help desk told us to send Grvience. Since one month no resolution.Please Help SOS

  3. DT says:

    Trans1 does not provided maker and checker in the filing process. After entering the transition credit data it does not allowed to check and verify by our internal audit requirement. Preview or the details of transaction could only be taken only after submission. but after submission it does not allowed to any modification. It hardly give the reconciliation trial to check for what we input the datas are correct or not. It was very absurd for any large tax payer to check and verify the transition credit uploaded.

  4. Bipradas Chakraborty says:

    I submitted TRAN 1 but could not file it due to technical error. On 19.01.18 when I tried to file
    GS TR 3 B for December I find a massage “You have submitted TRAN-1 form but have not filed it. You are requested to file the same before submitting this return”. I contacted the local Central Exise , State Sales Tax Authorities and also to GST Help line but none could resolve the issue and told me to wait. Similarly I could not file the GSTR 3B for January and the massage has come “GSTR-3B is not filed for previous period”. Now I am affaraid that I will not be able to file GSTR 3B in future. Kindly save me and treat this as S.O.S.

  5. says:

    I have filed Trans-1, have acknowledgement and arn number of the same, however now it is showing status as submitted and unable to File return 3B because of the same. Written on helpdesk, submitted greviance on online portal and still not able to file 3B. Dont know who is this world will solve this problem.

  6. jagjit sehgal says:

    You have SUBMITTED TRAN-1 form but have not FILED it. You are requested to FILE the same before submitting this return.

    facing this problem any remedy?

  7. Lawrence says:

    Dear Sir,
    We were not able to file TRAN1 before the due date ( 27tth Jan 2017) due website did not responded.
    Kindly help us file TRAN1.


  8. Raj kumar says:

    Cannot file GSTR 3B as tran 1 is submitted but not filed

    please help I have submitted the GSTR-3B but I cannot file. Once I enter OTP for filing 3B, I get a message which says “You have SUBMITTED TRAN-1 form but have not FILED it. You are requested to FILE the same before submitting this return” I have already file TRAN – 1 form 20-12-2017 status – FILED showing. When I go to again file Tran 1, it shows The filing of declaration in TRAN-1 is not available now as the due date is over.
    What shall I do now?

  9. ARJUN says:


  10. P.sivadasan says:

    It seems council not touched above issue of filing Tran 1 by left out assessees may be due to Act amendment. This needs to be corrected at the time of budget presentacion

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