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Most of the Traders were registered with respective State VAT authorities in Pre GST period and they did not possess any Central Excise Duty paying documents for the stocks held on the appointed date i.e., 01.07.2017. Government has given option to the Traders to declare these stocks held by filing GST Tran– 1 and facilitated the claim Credit of CGST by filing of GST TRAN-2 on monthly basis for a period of six tax periods (Rule 117 (4) of GST Rules).

Theoretically, it sounds good. However, in practice the GST Portal is not flexible enough to accommodate the requirements of Trade and Business and their practices.

While filing Monthly GST TRAN-2, in Sl.No.4 of the Form concerning “Details of inputs held on stock on appointment date”, it is made mandatory to furnish the details of “Outward Supply made” during the month.

For eg., if a Trader got certain quantity of a particular item as Opening stock (OB) in the month of July, 17 but sales were made only in September’ 17 and there were no sales of it during July’17 & Aug’17, the GST Portal is not allowing to furnish the details of OB of that particular item in GST Tran – 2 for the month of July, 17. At the same time, the GST Portal is also not allowing to furnish the details in the GST Tran -2 for the month of Sept, 17.

Thus a Trader made to lose his claim of CGST if there are no sales of the items in the month of July, 17. Thus, filing of Tran-2 for July, 2017 for all the opening stock became crucial for claim of CGST. To avoid this complication, one may consider filing all the details of Opening Stock of each and every item and consider showing a small token quantity of each of them as sale in July, 17 for making a successful claim of CGST.

However, If a Supplier mistakenly files the GST Tran-2 for July, 17 without aware of these rigidities, GST Portal do not allow him to revise the GST Tran -2 for other stocks. In the process, Traders are bound to heap huge loss of claim of CGST.

It may be noted that there is no Law or Rule mandating that the Supplier shall sell the stock held on appointed date during the month of July, 17 compulsorily for making a valid claim of CGST.

In view of these issues, it is requested to remove the “mandatory field” in the “outward supply made” and also allow filing the opening stock though there is no sale in the month of July’17. Further, it is requested to allow editing the filed GST Tran – 2 by giving “Reset” option.

The Authorities shall keep in mind that a flexible accommodative system is crucial for success of any Scheme particularly when it is affecting the revenues that too when the whole process is to be discharged by E- Governance. Hope, the Government and Authorities realize and resolve the issues to everyone’s satisfaction.

(Content is merely for sharing knowledge.  Author is Superintendent of Customs, Central Excise & Service Tax (Ex), Hyderabad and can be reached at contactgstplanner@gmail.com or 9440551266)

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7 Comments

  1. MD Ramjan says:

    The problem is only for those who have already filed TRAN2 for the month of july.

    Appreciate contents and advisory on issue of ITC through Tran 2.I am not able to add any new commodity in Form GST TRAN – 2 of August, 2017

    waiting for reset option or revising return atleast for JULY.

  2. p sharma says:

    now while filling TRAN2 for August 2017 we are unable to fill details of other items sold, as TRAN2 for July opening stock of other items missed inadvertently.

  3. p sharma says:

    Appreciate contents and advisory on issue of ITC through Tran 2.I am not able to add any new commodity in Form GST TRAN – 2 of August, 2017

  4. PRAKASH MARBLES says:

    GST TRAN 2 has provided the facility to mention ‘zero’ if stock is unsold in the month of july…
    now the problem is only for those who have already filed TRAN2 for the month of july.

    waiting for reset option or revising return atleast for JULY.

  5. Varun Jain says:

    Sir i am facing a problem in submitting GST Tran-2. Each time when i try to submit the form with DSC it shows a error msg of “SaveDSCData”. Pls Can you help.

  6. Manjit singh says:

    It is very appreciable that you being a superintendent has realized the problems of professionals & businesses and raised a voice against the deficiencies in GST portal. In fact there are so many other problems which are being faced from the very beginning of GST portal from Nov 2016 to till date and no body is hearing & solving the issues. It is merely a irresponsible Gov’t.

  7. Surrinder Kumar Moudgil says:

    Appreciate contents and advisory on issue of ITC through Tran 2., but sorry to say the GST setup is not so satisfactory.

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