Key 21 suggestions on Draft GST Return Formats

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The GST Council in its 28th GST Council Meeting held on July 21, 2018 under the Chairmanship of Shri Piyush Goyal, Union Minister for Railways, Coal, Finance & Corporate Affairs had approved the new return formats. The Council had earlier approved the basic principles of GST return design and directed the law committee to finalize the return formats and changes in law. In pursuance thereof, the CBIC has placed Note on draft GST simplified returns and return formats in public domain on July 30, 2018 for perusal and feedback of stakeholders.

Following suggestions were compiled by Mr. Bimal Jain, Chairman, Indirect Tax Committee, PHD Chamber of Commerce towards making Return system and formats simplified for all taxpayers, which have been submitted to the Government for their kind consideration:

I   Date of implementation and mock drill

We understand that the government is expected to roll out the revised return frameworks from the beginning of the next calendar year i.e. January 2019. Implementing the new framework in the mid of the financial year is likely to create hassles for the taxpayers in terms of performing reconciliations.

Suggestion(s):

  • Implementation from next financial year – It is therefore humbly requested to kindly consider roll out of the new system from the beginning next financial year i.e. with effect from April 1, 2019. Further, new system of return may be introduced as trial option for 3 months if the Govt. is willing to introduce the new framework effective from January 2019.
  • API for system configuration – Please release the Return API by October 2018 so that sufficient time is available for system configuration and sync with ASP/GSP.
  • Selected companies for mock return filing – Further, it is requested to kindly consider for providing opportunities to certain selected companies to undertake a mock return filing under this new framework, sufficiently before being implemented.  This would give an opportunity for industries to practically experience the practical aspects in the framework and to understand the finer aspects in the whole process and also give an opportunity to the GSTN to have a check over various technical and validation issues and take necessary rectifying measures well before the new return filing framework is getting implemented.
  • Offline Utility of New Return format to be released by September for practical training of the tax payers on new return formats with SOP and guidance note of its usage.

II   Non-editable tax amount field

The new formats provide for system-based auto-computation of tax amount basis the taxable value and tax rate. It is also provided that that tax amount so computed will not be editable except in case of credit/debit notes issued.

Attention is drawn towards the fact that there can be genuine mistakes on the invoices where the multiple of taxable value and taxes have not been charged on the invoice and debit/credit notes have been issued for the differential. If the tax amount is auto-calculated by the portal, there would exist mis-matches in the invoices issued by the suppliers and the information uploaded on the portal.

Further, depending upon the rounding off logic of various IT Systems, the auto calculated figure may not be equal to the amount considered in books of accounts of dealers and therefore, can lead to infinite validation errors in data upload through ASP – GSP. In past, this issue has already been experienced which caused a huge unrest amongst the dealers and GSTN.

Suggestion(s):

  • Tax amount field to be made editable – It is humbly submitted that this field should be made editable so as to allow actual invoice reporting and no validation/tolerance limit be imposed on the assessees.

​To access full list of suggestions, please click: http://www.a2ztaxcorp.com/wp-content/uploads/2018/09/Suggestion-on-GST-returns.pdf

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