GS/ADMN/2019 Dated
08.03.2019
To
The Chief Commissioner of Central Tax,
Central Excise & Customs
Thiruvanathapuram
Zone
Sir,
Sub: Undue pressure on GST field
formations and deficiencies in GST
backend
The
Association is constrained to highlight the unbearable pressure thrust upon our
members working in GST formations by overwhelming them with culling and
analysis of data on various mismatches and calling for immediate report and
realizations. The recent addition of DGARM data has further compounded the situation.
The Superintendents working in field formations are further burdened by the
lack of adequate staff. The compulsions for immediate verification reports puts
the officer at a high risk of disciplinary action at a later date when it comes
to notice that some mistakes have crept in due to the haste in implementing the
directions issued. It is apposite to mention here that the C&AG Audit
Parties have now started scrutinizing the TRAN 1 verification done by our
officers and there is every chance for the same being replicated on other
verifications. Hence, it is requested that sufficient time and manpower must be
given for completing these verifications.
2. We would like
to bring to your notice some of the practical difficulties in conducting these
verifications. The email id given in the application for registration is often
created merely for registration purposes and most often mails are not read by
the registrants. When the numbers of registrants to be verified are high, the
Range Officers are not in a position to place individual call to the
registrants, which are at times viewed as harassment also. You may recollect
that a question was raised in the Parliament regarding the phone calls to
registrants. It is hence suggested that the possibility of sending automated
messages and calls to the registered mobile number should be explored in order
to overcome this difficulty.
3.
Another major area of work is action against non-filers. Repeated emails
are not giving any result in many cases and non initiation of further action has
grossly discounted the worth of such emails. Automated GSTR 3A should be issued
to the Registrants. Suo-moto
Cancellation of Registration Option
may be incorporated in GST Backend Software in
respect of registrants who have not filed Return >= 6 Months, after
intimating the Tax Payer with a pre-defined
“As per Section 29(2) of CGST Act, 2017, Your Registration is liable for
Cancellation since you have not filed GSTR-3B Return for a continuous period of
6 Months” through e-mail and mobile no. with a due date (as a final chance) to
file the Returns and send a compliance report through online. The system may
cancel their registration after the due date, if no reply is received from the
tax payer and they still have not filed the returns even after the intimation. Amendment
may be required to change the word “proper officer” as “GSTN System/proper
officer” in Section 29(2) of CGST Act, 2017.
4.
A good number of verifications
required to be conducted pertains to ITC and one of the crucial documents in
this regard is the GSTR2A. Though the functionality to view GSTR2A has been
introduced recently, it is practically difficult to use. The GSTR2A cannot be
downloaded immediately and a request is to be placed. In a good number cases
the GSTR2A would not be made available. These requests are to be made
separately for each month and for each data field (B2B, B2BA, CDN, CDNA, ISD,
ISDA) and this becomes a time consuming exercise. The GSTR2A should be made
available on real time basis for a given range of months. It would be ideal if
the suppliers GSTR 3B status is also provided in the GSTR2A.
5.
We would also like to bring to your
kind notice, some of the inadequacies of the report functionalities available
in GST back end. Some of the reports in Reports Module can be generated only
for a single month. But most of the time, reports are being required for a
particular period i.e, in between periods (<= 12 Months). Hence it is very
difficult for the Range Formations to generate all reports for every month and subsequently
work out the same in MS Excel manually to compile a report for a particular
period, which is tedious and time consuming leading to wastage of time and man
power, although all data is available in the system itself. It is compulsorily
required to generate all reports for the period (From Month, To Month Options
and maximum for a period of 12 Months) at least for the Range Formations. If
possible “Values: Rs. in Crores/Rs. in Lakhs/Rs. in Actual” may also be included.
Also, the download option for the summary may be enabled so that all data can
be got in a tabulated form.
6.
In the HSN Report and Tax Offset
reports, the summary of various Taxes paid in cash and credit and the cash to
credit ratio is to be added. At present, these are to be calculated.
7.
Some of the reports when downloaded
do not contain the name of the formation or the period. The Non Filers of GST
Returns Report listing the Composition Levy Tax Payers also, who have already
filed GSTR-4 Returns which is required to be filed by them. Hence It is better
to have an Input Parameter during the report generation i.e., Type of GST
Return: GSTR-3B/GSTR-1/GSTR-4/GSTR-9/GSTR-10” to avoid this type of issues. It
is an urgent requirement since Suo-moto cancellation of Registration by the Tax
Officer is in the process based on the Non filers
of GST Returns for a continuous period of 6 months. It would be ideal if the
Non filers report also provides the email id and phone no of the registrant as
it would avoid the burden of identifying the data from the registration master.
8. It is also submitted that the Non filers data
are sometimes inaccurate causing embarrassment to field officers. Although the
GST Returns for the months filed by the Tax Payers are displayed with “Filed”
status, while verifying through “Search Tax Payer” Option in www.gst.gov.in, the Range
Officer is unable to retrieve the recently filed returns in the AIO. It takes 1
or 2 Days/1 Week time to view the recently filed returns through the AIO. The
Range Officer should be able to view the GST Returns in the AIO immediately
whenever the returns are filed. Only then the Report on Non Filers of Returns
will be correct while being generated from AIO.
9. An additional report comparing the revenue
trends of Top 100 taxpayers should be introduced. This should have data for
current month, upto month along with comparative figures of the previous year.
10.
As per the extant instructions,
application for cancellation of registration is allowed without looking into
the liability part. A report of cancelled registration should be made available
containing details of Registration Required Date, Registration Approved Date,
Cancellation Application Filed Date, Effective Date on which Cancellation is
required, Last Month for Which Return is Filed and Registration Cancelled Date.
11. In the downloadable tax payer details from
the registration menu, the details of the goods/ services supplied and the name
of the signatories may be added.
12.
The refund processing is soon expected to be completely online. In the case of
refund of ITC on zero rated supply, the prime concern is the correctness of NET
ITC declared. In the case of refund of ITC accumulated on account of inverted tax structure, the Statement 1A
required to be filed online contains the details of inward supplied which get
validated with GSTR2A before uploading.
Similar details are presently not required in Statement 3 pertaining to ITC on
zero rated supply. This detail is required to be filed online for smooth online
processing.
13.
The online learning management system
should be regularly updated to keep the trainers up-to-date.
Yours
faithfully
ARUN
ZACHARIAH.P
GENERAL
SECRETARY
Copy to
The Commissioner of Central
Tax & Central Excise,
Cochin/Thiruvanathapuram/
Calicut,
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