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suggestions in regard to the draft report

suggestions in regard to the draft report

Here in the proposed system monthly return GSTR-1, GSTR-2 and GSTR-3are proposed which will be time and  manpower consuming. Also proposed are three different datelines? One return by 10th, next by 15th, and final return by 20th. This will be extremely time consuming and will discourage people to get into Business.

In the proposed GSTR-1 & GSTR-2 supplier need to mention the Invoice No, date and HSN/SAC. However, one invoice may have multiple goods of same or different HSN and invoice may have run into several pages. Further, one invoice may have goods as well as freight which is a service. In the circumstances how assessee will fill the multiple HSN/SAC code in a single line and if the system allows several lines for one invoice, return may run into several pages. In view of above, it appears that the system is extremely time consuming and will result in only mismatches and will make return filing as most difficult and there will be very difficult of doing Business.

In the proposed GSTR -1 supplier need to mention the Transaction id (A number assigned by the system when tax was paid advance received) for adjustment of tax paid on advance received. However, adjustment of advance tax may have different invoices raised, as whole advance may not be applicable for one invoice. And filling same transaction id for different invoices in the same return or in subsequent return will result in mismatches and will make return filing as most difficult and there will be very difficult of doing Business.

Thus it seems that the compliance burden may increase substantially on account of filing of monthly returns and submission of invoice level details for B2B and inter-state B2C supplies

At present non payment of tax liability of seller imposes no liability on purchaser. In this proposal, purchaser is fully liable for the tax payment of seller. It appears that revenue wants to put entire burden of tax collection on purchasers. Tax collection from any supplier should be the responsibility of tax authorities. The present proposal is extremely faulty. Collection of Tax from any assesses is the responsibility of Tax Authorities.

While it is proposed that the input tax credit balance will be auto- populated at the end of the tax period in the ITC ledger, the issue relating to treatment of credit balance during the transition will need to be addressed

In proposed GST, Sales Tax Practioners (STP) who are present doing most of the compliance under the STATE VAT acts are not recognized to issue Annual Return GSTR-8 in respect of assesses covered by Tax Audit U/s 44AB of Income-Tax Act, even though the returns are proposed to be filed by STP/TRP.

suggestions in regard to the draft report

Gujarat VAT department has issued circular

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