When GST was implemented, it was advertised as Good and Simple Tax, however reality is very different from what was promised to the millions of taxpayers of the country. Almost every business is spending unnecessary time and effort in order to comply with GST, even after so much efforts businesses are not able to calculate their tax liability and eligible Input Tax credit correctly. We need procedural correction in GST so that Business houses as well as tax practitioners can save their valuable time and efforts.

With my limited exposure in GST and the problems I faced in return filing and reconciliation of Data, I have compiled few suggestions which if implemented will provide Relative Ease of compliance to Businessmen.

GST Return

I am listing my suggestions as below:

1. Scrap GSTR 3B & GSTR 1, instead launch a Consolidated Form which captures details of outward and inward supplies simultaneously.

2. Automatic calculation of Interest in return on net tax liability basis.

3. Scrap the system of auto population of input from GSTR 2A, instead allow Taxpayers to upload details of inward supply invoices.

4. Allow option to revise all returns at least twice before the due date of filing of Annual Return. Present system of amendment is creating unnecessary confusion.

5. Monthly Tax Payments and Quarterly Return filing for all types of Regular Taxpayers irrespective of their turnover.

6. Decrease the time taken in generation of JSON summary & error report on portal.

7. Allow people to upload Party wise Sales details as opposed to current Partywise + Invoice wise+ Rate wise sales in GSTR 1.

8. Allow Claim of ITC in Annual return.

9. Annual Return Form GSTR 9 need to be revised, current form is serving no purpose. Annual return should be drafted in such a manner that taxpayers should be able to calculate Tax payable and ITC correctly.

10. Provide option to revise annual return.

11. In case of GST audit, Audit should be conducted before filing of Annual Return.

12. Scrap GSTR 10 and incorporate the details required in GSTR 10 in GST Registration Surrender Application.

13. The concept of “Submitted” and “Filed” should be scrapped and direct filing of return should be allowed.

14. Taxes should be considered as paid from the date of challan instead of set off date.

15. Single GST number for service providers instead of multiple registrations

16. Remove the condition of compulsory registration in case of Inter State outward supply.

17. Single GST Tax Instead of current three types (IGST CGST SGST). Centre and states should share revenue on the basis of place of provision of supply.

18. Rationalize blocked credits; it is hurting the concept of Seamless flow of credit. In case, Taxpayer has wrongly availed blocked credit, no interest & penalty should be levied.

19. Late fees should be capped at Rs. 500 per return in case taxpayer made outward supplies and nil in a case of no transactions.

20. Interest rate in case of delay in payment of Taxes and Delay in granting refunds should be at par.

21. Notices for mismatch in ITC should be sent after the expiry of Due date for Annual return.

22. Grant of Professional Tax Registration automatically along with GST registration application.

I firmly believe that if these suggestions are implemented it will provide instant relief to many taxpayers and tax practitioners and will promote ease of doing business as well as decrease the compliance cost drastically.

(The author this article can also be reached at [email protected])

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  1. CA Kaladhara Saralaya says:

    Excellent suggestion. But, whether the bureaucracy will accept these suggestions is the big question. From day one I was always suggesting to implement the Karnataka Vat software in GST, which I was always advocating and suggesting for GST. Unfortunately the GST regime didn’t bother to understand the real problem. Instead created more and more problems. Simply put , the GST software is totally blamed for the entire mess. In my opinion, this software needs to be scrapped totally and should be given to NIC, which has developed VAT Returns. If the GST allows revision of returns, most of the problems are solved. Main problem in GST is it is too slow and non revisable. Also staggering of purchase details among the dealers is another problem. If every one uploads the sales invoices, debit, credit notes, the entire problem is solved. Annual consolidation can be auto populated therefrom automatically and hence is not required to be filed again. By 10th, let all upload their sales. Between 10-20th people can approach their suppliers to make any corrections or uploads pending to be done. By 20th, everyone will, know their Output and Input taxes. and can pay tax and pay the taxes. Or for every one, make GSTR 1 quarterly. Tax should be allowed to be paid monthly in advance as the dealers will know their liability. For any shortfall interest can be automatically and collected during quarterly filing. As of now, there is no provision for correcting the monthly returns, which has lead to so many problems of reconciliation with the books of accounts.

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May 2021