THE INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA
(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,
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 www.gst.gov.in 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 email@example.com or 0120-3045954 / 9310542608.
CA. Madhukar Hiregange
Indirect Taxes Committee
CA. Sushil Goyal
Indirect Taxes Committee