Chartered Accountants Association, Surat has made a Representation to Finance Minister of India on Untimely release of GST forms and utilities.

Text of the Representation is as given below-

Chartered Accountants Association, Surat

Ref: CAAS/Representations/2017-18/01 Date: 25/08/2017

The Finance Minister,
Ministry of Finance, Government of India, 134, North Block,
New Delhi – 110001

Respected Sir,

Subject: Re: Untimely release of GST forms and utilities

We would like to introduce Chartered Accountant’s Association, Surat, as a non-profit organization with the object for the betterment of Chartered Accountants fraternity, dissemination of proper information amongst the stakeholders of economy, and government representations at appropriate levels and times to remove hardships faced by the stakeholders.

This is with reference to the CGST Rules, 2017 which were notified well before a month ago. Yet cardinal forms and utilities required for submission in its electronic form is not yet made available to the stakeholders.

Stakeholders in the current context means:

1. ALL the dealers whether big or small, supporting GST implementation;

2. Accounting staff of big dealers who have to do the actual additional work of accounting as per newly imposed “Universal GST Accounting Standards” by your Ministry;

3. Tax Consultants, Cost Accountants & Chartered Accountants who finalize the submission of various GST forms. They are the biggest stakeholders, since on account of the release of overnight notification based laws, which also get sunset on a fly-by-night basis, these professionals have to do a real, but futile and painful work of answering, educating and settling issues arising out of ignorance amongst masses created by garbage of notifications which has become the real work of Boards of Department of Revenue (DOR) within your Ministry.

Our Representation:

1. GST is only 54 days old law, but 107 Notifications have been released till date, shows that implementing the intricacies of a well written law, is being done without application of mind. Please stop legal garbage generation.

2. Deliberations relating to GST are being done since last 16 years by GOI. Its Modus operandi was also very clear. Forms were also notified well in time. As stakeholders and Financers of your IT Infrastructure cost, we want to know why online utilities are not made available to stakeholders on time. If basic utilities for filing like GST Returns, Transition Forms, Export Forms are not available on GSTN Portal, managed by IT Giants, it is rather shameful and we feel like Unproud Indians. The world is witnessing this historical paradigm change, and a wrong message is being sent amongst In that case, perhaps you would like to give a try to the brainstormers and Partners in Nation Building viz. Chartered Accountants, who have a record of keeping up to the tight deadlines. In a nutshell, if these basic utilities are not yet ready, it is requested to defer the compliance processes to be done online as stated in subsequent paragraphs, except for mandatory collection of GST Tax on monthly basis, which may serve to replenish your exchequer.

3. There is an utter chaos in the industry, relating to record keeping, since you have even not given a window for adaptation to the software vendors as the law, on the basis of which software was to be coded was passed a couple of weeks before its implementation. Today, no one is at rescue of the stakeholders. The so called push button softwares and GSP (Goods & Services Suvidha Provider) advertized by your Ministry are non-existent and even if there are some, they have started charging exorbitantly. The API (Application Programming Interface) required by the GSPs is also not made available. Hence, the nation wants a moratorium of 6 months to adapt to the newly imposed requirements. And not only nation, by your own GSTN requires time to adapt.

4. We are hopeful that GST would bring prosperity, transparency and growth to Indian But, Sir, lets simplify as we all have families waiting to share our time at home (which is the real prosperity), instead of sharing our time on GSTN portal and no one shall compensate for loss of such time. GST may be good, but GST procedures seem all messed up. We demand a review straight away. Form GST3B need to be scrapped, since we all signed up, trained people, staff and clients for a chronology of GSTR1 then GSTR2 and then GSTR3, but never signed up for loosely made forms like GSTR3B, which prima-facie looks to be prepared without application of mind. Your goodself is again requested to differ filing process online for 6 months, in Lieu of which the nation would not mind self-assessing GST and paying it within time, instead of invariably falling within the definition of criminals or violators, even though when the citizens want to abide by law, but infrastructure like GSTN does not support.

5. It is estimated that assessee base in GST would be much higher as compared to Income Tax, Excise and VAT combined together. The expertise of government till date was seen and well appreciated in managing Income Tax E-filling & TRACES Portal, as well as Excise and Service Tax Portal. The digitalization in Income Tax, ROC, Excise etc, was carried out in a phased and planned manner by your efficient Ministry and its hard-toiling government machinery, considering the Info-tech literacy of assessees. However, in the current scenario it is felt that if would be hard for the IT Infrastructure of GSTN to be able to cope up with the ever increasing assessee base and complexities of the law. Hence, to shed the IT Infrastructure load, we request to spread the routine reporting window for return filing to a more rational – Quarterly basis (with 45 days compliance window to file returns from quarter end), so that GSTN server can efficiently handle the assessee base. Besides, the same should be coupled with routine monthly tax payments by assessee on self-assessment basis. This will also enhance the atmosphere of trust amongst the businesses as well as towards the government, and ultimately it would result into Ease of Doing Business.

We hope, our representation would have appraised you in light of various hardships faced by the stakeholders, and are also hopeful, that you would do justice to our grievances.

Thanks & Regards,

For Chartered Accountants Association, Surat.

President Secretary

Download Representation on Untimely release of GST forms and utilities

Also Read- Why time Limit for filing IT Return (44AB Audit Cases) must be further extended

More Under Goods and Services Tax



    Excellent sir, How can a born baby to walk, talk and interact for all? GST like a born baby and Tax practitioner community needs time to understand the methodology of the GST. The Honorable Prime Minister assured that GST is a Good, Simple Tax System and no penalty will be leviable up to 3 months. Accordingly, we promises our client’s to “ACCHE DIN AGAYA”. But, the way GST is software has been untimely implemented and Late fee being posted as liability for Sept’17 in case Aug’17 filing is late of Rs 200/- per day is burden to small dealers. So, how we can expect the acche din sir, I had contacted Local GSTN Excise, Commercial Tax Officers, and sent mail to GSTN help desk till date no reply. Finally, It is my humble request to The GOI Secretay Sri Hashmukh Adhia Sir, please to take the proper action in the next GST council meeting to safe guard the interest of the people of nation.

  2. CA. nitin Bharadwaj says:

    Bravo!!!. At least CA’s from Surat have the guts to say that the government is should have implemented GSt correctly. Day in and day out we are thinking and doing GST. All other Tax practice has stopped.Even then new notifications are coming in and increasing the stress and burden. Where is the ICAI ???
    The PM can call us **** ( censored ) on ICAI day and now this . We are doing gadhaa majuri and the ICAI is doing nothing.

    1. CA Sameer Valia says:

      Very rightly said CA Nitinji.. since the introduction of GST, the whole practice has gone time to complete Income Tax returns.. no time for anything except GST..It’s really gaddhamajuri..I really wonder why ICAI is not doing anything on this..Can it not represent to Govt about the hardships faced by SME CAs like us…SME CAs practice will take a huge beating if this continous like this..

  3. GALA ASHWIN says:

    All Tax practioners have lot of to say on inefficiency & untimely implementation of GST. You have given a very good start. Hearty Congrats.
    Some very Important issues also need to be highlighted.
    1. Amendment utility not yet made functional
    2. Online submission of LUT not yet made functional.
    Due to many such inefficiencies in the GST portal the tax payers are in great trouble. They feel harrassed.

    GSTR1 final submission / Return filing for JULY 2017 will b allowed only from 1.917 to 5.9.17. In this 2nd & 3rd are saturday , sunday. 5 th is Ganesh Visarjan Holiday. ACTUALLY ALL 1 to 5 are Ganesh Festival days.
    Many people are on holidays.

  4. Sainath says:

    Very much thankful to the Surat CA Asson. for making ths repn to our FM. We all (tax consultants and Professional) are very much tired in getting the updates and answering our clients. Also, most of us are not yet fully understanding the exact provisions. Our humble request is to defer the filing process for atleast 2 to 3 months. we also request to give us one or two month’s extension for filing the Income Tax Tax audit reports and extension of due for Income tax filing. Pl understand our position.
    Thanking you for your efforts.

  5. S.prakash says:

    Sir excellent representation.. Just a few days back I had made a representation to PMO and the entire commercial tax department officials and and also few trade body representative opposed me and stood up to the support of the department. I really feel sorry for the same.According to my personal opinion if all the officials of commercial tax department would have worked for the GST implementation and it’s IT infrastructure testing before 1/07/2017 the present situation would not happened.But no one is ready to accept the truth as it will be bitter


    Thank you very much, this is the voice of all tax-professional persons, Tax Professionals are going toward mental illness, how can We expect morality and good work from ill-mind.

  7. Kishor says:

    Traders and Manufacturers will not get any break in busy schedule of gst formalities, Every Government Staff and other salaried person gets leave, vacation, holidays etc but traders are working for government revenue without reward and with big responsibility

  8. ASHOK KUMAR says:

    Sir, thanks for your real representation, we are Exporter and When we prepare Export Bill, we came to know from Clearing Agents that we have to Put IGST Invoice for Cotton yarn and the same will be refunded to us after shipment.

    We have made the Exports on 21.07.17, till such time no refuds of IGST received. When we contacted our C&F, they are telling that GST Portal is not ready and Customs Portal are ready.

  9. Mityel says:

    Where is Mr. President of ICAI.??? Aafter CA Day in which Mr Prime Minister Slapped indirectly but yes directly in a Fora full of Mininsters and Chartered Accounatants for which I understand Huge Cost was incurred.. Jst to insult the fraterenity on OUR OWN Auspicious Day!!!!!
    Why not a single representaion by ICAI is made in this regards to the MOF or GST Council??

  10. Rajesh Shukla says:

    Good Representation,
    The following line is very important which is used in repsresntaion “lets simplify as we all have families waiting to share our time at home (which is the real prosperity), instead of sharing our time on GSTN portal and no one shall compensate for loss of such time”

  11. sudheesh says:

    GOI Share for imparting law to dealers is Zero.Its the consultants and professionals done for GOI.Still we professionals are hit by GOI by their unplanned unsystematic and moreover unrealistic tax introduction to the country. GST says betterment for the country, is there any glimpse of betterment. Betterment is not at all money only,countrymen physical and mental health too be considered

  12. Rajnikant Raja says:

    it is the demand of the time that the government should differ in filing of online returns for at least 3 to 6 months or until the complete availability of all necessary forms and uninterrupted working of website of GSTN. the government has nothing to loose by allowing additional time in return filing.

    further we are not getting reply of our mails posted through GSTN website. we can not connect on the helpline phone numbers.

  13. harendra khira says:

    nice and good to show the face in mirror to mainly official staff of excise department who doing major roll in this gst law they think all indian traders is chor and we are the cops of that all indian public and harrasing will start soon to traders to service provider
    every buddy who involved in gst rule.

  14. yashwant mali says:



  15. K M Panchal says:

    Congratulation for such bold representation instead of professional. Very few have such daring to show mirror to the authority who always speaking to make public fool.

    Congrats once again and hoping such act always.

  16. Vipul says:

    Thank you very much, this is the voice of all tax-professional persons, Tax Professionals are going toward mental illness, how can We expect morality and good work from ill-mind.

  17. Mukund says:

    I feel this representation should go from each an every association of CA and business partners from all over the country so the Ministry will know the seriousness of the situation…


    sir good letter, social life of professional as well as of our businessman be nil. no time for family ,time for gst only as per GST LAw

  19. S.Alvares says:

    Thanks for sending this letter. I welcomed GST and purchased software in advance as I file my own returns. But the absence of a planned timeline for updating software based on these ambiguous notifications and specifications for input and reverse credit has left us all in hanging garden especially where admin. expenses incl. of GST have been paid via credit card.
    The manual entry of GSTR3B is risky and prone to error due to tension while filing, even if you have a printout in front of you. There is no auto-feedback like Form 231. There too we had a scope of revised return which helped if you still made errors. If the system is does not provide a scope for justified revision it will only promote inconvenience and irregular adjustments.

  20. Vijay K. Malik, Advocate says:

    Sir, Every line of the petition is from the core of the heart of every professional who is in this field of taxation practice. Govt has made every thing mass with their non practical approach and hasty decision. Thanks for your effort to prepare this petition.
    Thanks and regards,

  21. Surendra Kumar Varshney says:

    Nice and we’ll drafted letter we expect a letter like this from our President
    Anyway keep writing thanks again for writing

  22. anilkumar says:

    Every human being do mistakes. There is no revised return option in GST then how to file rectify mistakes. Ministry has to re think this.

  23. JAYAN says:

    The sugetion is the right thing to do immidiatly and and hoping that the finance minisnister will take appropriate decision for the smooth transision to GST

  24. HARIOM SHARMA says:

    Thanks Sir,
    It is really true,If our Government need not to invest ANY money that job may be allowed. The season of so many returns is going on.

  25. prabhakar says:

    It is nicely presented from the angle of GST only but what about the other work of Tax audits, ROC work etc., which is waiting for September to take the professionals in to task. When time is totally taken away by the GST where do you find time for the other work. Considering all these things all the forum and associations should go for a petition against the finance dept. What happened to other states associations who are silent, that means they are capable of doing this foolish work. Pl. all of you come out like this and show your strength.

  26. Anil Rao says:

    E filing of Income Tax introduced in 2006 for companies has taken a long time to stablise. It was over a period of 11 years of trial and error that we have reached the stage where we are today. Even now there are certain procedures which are yet to be get completed.

  27. S Vanaja says:

    All the dealers are supporting the Introduction of GST as ONE TAX One Nation Policy. But the Way of implementation is Irking due to answering of Different kinds of Forms & mode of ITC Adjustment is not in favour of Assesses for the simple Reasons that GST to Be Adjusted only in GST & the IGST to Be Adjusted only in CGST. Afterall the Taxes are going into the Gove Exchequers only . The way in which the Rules are framed by Finance Minister goes to show that all the Trading Communities are not trust worthy & are deceivers. If the FM had faith & belief on the Business & trading Sectors to 100% there will not be any evasion of Tax . When once an unworkable & unmanageable rules and acts are passed naturally the trading sectors are put to lot of hardships 7 try a shortcut.

    1. M Gabriel says:

      You are right , trying to put impossible task to businessmen, comply with GST, Comply with IT, Comply with Tax audit, link with aadhar to PAN, Aadhar to Bank, If we keep on minding this alone, how do we do our business ?

  28. Krishnamurthy G.K. says:

    “1. GST is only 54 days old law, but 107 Notifications have been released till date, shows that implementing the intricacies of a well written law, is being done without application of mind. Please stop legal garbage generation.” – HOPE THE FM WILL UNDERSTAND THE DIFFICULTY OF THE BUSINESS COMMUNITY.

  29. Manish Shah says:

    This representation will be more effective if twitted to Prime Minister Sri Narendra Modiji on his twitter handle or MyGov twitter handle and in a short and concise form.

  30. T Sampath says:

    The best Suggestions to be & must be followed By the GOI in the Interest proper functioning of the GST Scheme. As suggested the Form 3B can very well be scrapped & further number of Forms to be reduced such as GSTR 1 2 3 etc by combining all in one or Two Forms. The Software Organizations can very well programme & give such a Form for the assesses . The Software Programmers must be given Ample time to Construct a Robust Software to handle the Loads . In my view more Importance were given only on Roll out Date instead of a proper Assessee friendly approach by the GOI. Having waited for more than 15 years waiting of another year or two will not Matter much

  31. Vijay Shetty says:

    Nice letter and perfect letter, further liberty of utilizing ITC option not allowed

    E.g. If a Company do not want to utilize full credit want to pay in cash, this is not allowed.

    Just because, we did not use IGST for payment of CSST we were not allowed to use IGST for SGST.

    1. Frightened Businessman says:

      If no resignation of Finance Minister comes in time then 2019 will give us a sure chance of getting resignation of Prime Minister. Jai Ho BJP – Party with a difference.

      1. S Prakash says:

        the party or the FM can not do anything as the law is well drafted and welcomed by all of us while introducing the same. The failure is on part of the GSTN net work and bad administration of the NEW ACT by the half trained commercial tax department and the no co ordination between the Central Excise and Commercial tax Departments, ie., no co ordination between the Center and State Governments. If any one highlight about this both the Central Government and the State Government officials say that they are working all the 24 hours for the success (FAILURE) of GST the ALL ARE putting the blame on the Government as like the opposition parties even by the professionals. The Professionals advise should be taken by the Government for the successful implementation of the NEW ACT and not just the IAS advise.

  32. M Gabriel says:

    Sir , thanks a lot for the well drafted petition. Let the Finance minister address to the points raised. Further, let the IT minister ensure good internet connectivity. Let both ministers ensure that the GST server is capable of taking a big load. I was trying for more than 3 days to pay my tax due. Who is going to compensate for this loss of time, my futile internet charges and wages for my staff ?

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