Filing of GST TRAN – 1 Forms is mandatory for anyone to carry forward the Balances of Tax Credit lying unutilised in the erstwhile Central Excise/Service Tax/VAT Regime and to claim the unavailed credit either on Capital Goods or Inputs lying in stock.
These Forms have become available from 21 st August, 2017 in the GST Portal and the Notification No. 23/2017 – Central Tax dt 17.08.2017 made it compulsory to file GSTR TRAN -1 in the cases of any Registered Supplier wishes to pay the GST from the earlier Tax Credit Balance. The last date for filing of GSTR – 3B for the month of July, 2017 is 28.08.2017. Therefore, these Registered Suppliers have effectively got 7 days to file the GST TRAN -1 Form for claim of the Transitional ITC. Infact, GST Act has provided the time for filing these Forms for 90 days and on the Other hand the Government effectively curtailing this to Just 7 days.
These forms require the entry of the details of Unutilised ITC balance of Central Excise/Service Tax/VAT in the existing Laws and the details of Inputs and Capital Goods Invoice Wise. These forms also require the entry of details relating to various pending C – Forms, F – Forms, H/I – Forms. Further, they also call for about the details of stocks sent to Job Worker and the details of goods held by/as Agent.
If the operations of any Small to Medium scale manufacturer/ Trader/Service Provider is examined, the Operations are continuous and at any given point, they will be holding many no of invoices relating to Capital Goods and Inputs /Job Work Challans/ C, F, H/I Forms easily running into Hundreds. In the cases of Large Scale Operators, it is safe to assume that these documents may run into High Hundreds if not Thousands.
Unfortunately, GST Portal has not provided EXCEL Upload Facility to upload the bulk data available with the Suppliers at One Go. It has only given the provision for entry of details of each Single document seperately and there are 10 Nos of data fields to capture each detail. After feeding the details of One Document, these Forms are allowing the data entry of another Document. As the matter involves money, nobody wants to forego their legitimate Claim of ITC. Thus, it is putting humongous task on the Supplier to make the data to be fed in the Portal for entry of each Line Wise Item. In addition to this huge task, frequent Hanging of Portal is becoming Nightmare to the Accounts Personnel.
The GST Portal should have included an EXCEL Upload Utility for bulk uploading the data available with the Suppliers instead of making the Suppliers to sit in front of the Computer Systems to file the data, document wise, in the Portal Online. At least, the designers should have foreseen these issues and should have come up with a remedial measure. It also warrants the inclusion of Edit Option to edit the data submitted in case of corrections and mistakes. As the last day to file GSTR – 3B is approaching fast, the Suppliers who wish to discharge the tax by filing the Transitional Forms are at trouble.
It is high time for the Government or Higher authorities of GST Administration to be proactive and responsive to the needs of the Trade for smooth transition into GST regime and offer ready solutions for each such Problem. The Co-operation extended by the Trade shall not result in fleecing them for payment of Interest/Late Fees/Penalty. Hope, Good Sense Prevails and the Government or Higher Authorities to take up these issues for resolution.
(Content is merely for sharing knowledge. Author is Superintendent of Customs, Central Excise & Service Tax (Ex), Hyderabad and can be reached at firstname.lastname@example.org or 9440551266).