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January 29, 2021

76 Issues and Recommendation in GST, 28 in Income Tax and 9 In MCA for Today Protest by 200 Associations to FinMin

by CA Shivam Jaiswal in Circular and Notifications

76 Issues and Recommendation in GST, 28 in Income Tax and 9 In MCA for Today Protest by 200 Associations to FinMin

The Western Maharashtra Tax Practitioners’ Association has given call for All India protest against issues in GST, Income Tax, MCA. 130+ National, State, Regional and Parent Association from All Parts of Country joined the Protest Call, to address the problem of members of all said association. Our Association has also joined it to address the issues of our member.

This Recommendation Memorandum is prepared to convey the problem of Trade and Professional along with solution desired. This memorandum is prepared by committee from All Parts of Country – Delhi, Gujrat, West Bengal, Karnataka, Maharashtra. For any clarification in this regards Kindly contact to:

  • Shri Narendra Sonawane – +91 98226 01617
  • CA Swapnil Munot          – +91 90212 65137

Annexure I – Issues under GST along with recommended solutions

A) Issues in Input Tax credit

Sr. No.GST IssueDetails of IssueRequired Solution
1Time Limit to claim ITC appearing in GSTR 2A/2BAs per Sec 16(4), ITC can be claimed only upto due date of Sep month return of next financial year. This is causing lot of inconvenience and loss to small tax payer who don’t have proper account staff. When said tax is paid to government and appearing GSTR 2A/2B, restricting said ITC to taxpayer is big hardship under GST.ITC is statutory right and there should not time limit to claim ITC which is appearing in GSTR 2A/2B
2ITC denial if Payment is not made to supplier within 180 daysSec 16 requires, reversal of ITC (with interest) if payment is not made to supplier   within   180  days,   from the date of invoice. However, it’s reclaim is allowed after payment to supplier.GST  Law  should  not  specify  time limit for      payment          to         supplier.          Sometime supplier  himself  allow  credit  period  of more than 1 year. There is other law to govern payment compliance (MSME Act) and therefore GST law should not specify any time limit for payment to supplier. Also Interest should not be asked for this.
Sr. No.GST IssueDetails of IssueRequired Solution
3Compulsory 1% Tax Payment in cashRecently government made mandatory 1% tax payment in cash, for certain class of taxpayer, inspite of ITC balance. Such provisions are making GST more complicated.said provision should be removed, as it is ultra-virus to concept of ITC.   Also, we suggest, such complicated provision should not be introduced in future.
4Time Limit for RCM ITCThere is confusion and different practices with regards to time limit for claiming RCM ITC. Whether it should be considered from ‘date of invoice’ or from ‘date of its payment’.There should not be time limit for claim of ITC under RCM (once RCM liability is paid) or it should be linked from ‘date of payment’ of RCM liability.
5ITC on Business Promotional ExpensesIt is common practice that, business is required to give samples to its customer and distributors. Also, on some occasion’s gifts are given to stake holders by business. All these expenses are done in order to promote the business only. As per Sec 16, All ITC is allowed, if it is for furtherance of business. However Sec 17(5)(h) is restricting ITC on gift and sample, which is without any rationale.ITC on All Business Promotion expenses should be allowed including Gift / Physician Sample, since without this, business cannot be done.
6Delinking of ITC of CGST and SGST in GSTR 3BWhile filling GSTR 3B, if CGST ITC is mentioned, then SGST ITC is populated automatically. (example  –  wrongly  taxpayer utilised excess SGST ITC from DRC 03, and now  he  want  to  reclaim  only SGST portion of ITC in GSTR 3B, but it is not possible)Filling of ITC of CGST and SGST in GSTR 3B to be delinked or edit to auto populated tax should be allowed.
Sr. No.GST IssueDetails of IssueRequired Solution
7ITC Restriction under Rule 36(4)Rule 36(4) is introduced to restrict ITC with cape of additional 20% ITC as compared with auto populated ITC. Then said rule is amended to restrict it to 10% and then further amended to restrict to 5%. Reduction in restriction is creating financial stress to taxpayer and also will attract future notices.Also It is very difficult (rather impossible) to keep track of limit on monthly basis.It should be restored to original additional 20% limit.   Also, limit should be checked on annual basis and not on monthly basis.
8Transfer of ITC/Cash ledger balance between Distinct PersonsSometime Business situation may arise that, one GSTIN will have huge ITC accumulation and other will have GST liability cash. Since both GSTIN as under same PAN, they should able to transfer the ITC from one state to another state. This is creating financial stress to taxpayer.Since GST is one nation one tax, it should allow for transfer of ITC/Cash ledger balance between GSTIN under same PAN.
9Blocking Of ITCBlocking of credit is unconstitutional as GST is already discharged on it to the Government. Also, said power are getting misused as there is no proper SOPIt is requested to Remove said provision or else should be applicable only in case of taxpayer whose track record is not good. Thus, proper SOP is to be given.
10Very High Rate of InterestIn case of wrong availment of ITC/delayed payment of tax or any other reason, Interest is demanded at 24%/18%. This is very high. Due to financial crisis, tax payer is not able to make payment of tax and such higher interest rate, is very harsh and demotivating the compliance.Rate of interest should be rational to recover government loss. It is recommended that interest should be equal to interest rate on refund or 1.5 time of interest rate on refund.

B) Issues in E Way Bill

Sr. No.GST IssueDetails of IssueRequired Solution
11Reduction in Validity of PeriodNotification 94/2020 dt 22.12.2020 has  changed  Eway  bill  validity  from 100 kms to 200 kms for 1 day. If validity is expired and vehicle is caught, then penalty is demanded of 100% tax amount. Sometimes due vehicle failure, road condition, traffic congestion and other unforeseen contingency, vehicle cannot travel 200 km in one day. Asking taxpayer to go for   Extention   in   such   case   is not suitable every time.Original Time limit of 100 km per day should restored again which was applicable upto Dec 2020. Also, it is recommended to policy drafting team, to kindly consider practical problems, before coming with such harsh provisions just because, you are finding some bogus Traders. We also recommend, Validity should not be kept for E way bill.
12Relaxation of E Way Bill in case of E InvoiceNow E Invoice is made applicable to all Tax payer having turnover more than 100 Crore. E Invoice and E Way bill contain 99% same information. However, still both the document is required to be complained with, resulting in increase of compliance. Government intention of stopping bogus billing is now to large extend taken care by E Invoice.For taxpayer to whom E Invoice is made applicable, for him E Way bill should be relaxed, since both the document is serving the same purpose. Revenue Secretary in Dec 2020 has given statement that, government is thinking on relaxing E way bill, if E invoice is prepared. We recommend government should implement it at earliest.
13Minor Discrepancies in E way Bill causing penalties in lakhs and coresSec 129 of CGST Act levies very high penalty, if there is minor discrepancies observed in e way bill. This lead to increase in corrupt practices as well. Circular No 64/38/2018 GST dated 14.9.2018 issued to levy Rs 500 penalty for some discrepancies, however it doesn’t cover all clerical mistake.1) Scope of said circular to be increased to cover below: Error in invoice dateExpiry of e way bill (but still vehicle was on road and travelling)Tax rate is wrongly selected in E way bill but description, value and HSN is correctly mentioned on E invoice and E way bill2. Also, maximum penalty should be levied in other clerical error, should not exceed 10% of tax amount or Rs 10,000/- whichever is lower. (presently same is 100%)   On initiating penalty proceeding, when tax is paid on goods, provision should be made for availability of its ITC to customer. Currently for releasing the goods from officer, tax is required to be paid and same is again required to be paid in monthly return to show its ITC to customer. This amount to double taxation.
Sr. No.GST IssueDetails of IssueRequired Solution
14Requirement to furnish details of RCM supply Transporter in GSTR 1Since all big/MNC customer wants supplier to be registered under GST, transporter have obtained registration. In such case, transporter are not charging GST and supplying under RCM. While filing GSTR 1, transporter is required to mention, each supply line item wise details, even though no tax is payable by transporter. This is increasing unnecessary compliance to all transporterGovernment has understood this issue and  in  ANX  1  [  RET1,  RET2,  RET3 Return system which planned to implement but never got implemented], government has removed requirement of line-item wise supply made under RCM. However, since ANX 1 is not implemented and GSTR 1 is continued, we request for removal of line item wise details   in   GSTR   1   for   supply made under RCM from supplier point of view
15Extention of Validity of E Way bill – Practical challengeValidity of E way bill can be extended only within 8 hours after it is expired. E Way bill expires at midnight at 12.00, it means practically validity can be extended only upto 8.00 am in the morning. This makes practically difficult as office staff are not available at morning 8.00 am always.Generation of E way bill, is itself proof that supplier is tax compliant. Therefore, we recommend There should not be validity for E way bill. (Part B should be there but no validity). It should be valid till the delivery without any time limit. (OR)Revalidation of expired E way Bill should be allowed either before 24 hours or after 24 hours of its expiry (excluding Sunday or holiday)
Sr. No.GST IssueDetails of IssueRequired Solution
16Amendment in Part A of E Way billAfter preparing of E way bill, if it is observed that, if by mistake any details are incorrectly filled in Part A of E way bill, same cannot be edited. In such case, another invoice is required to be generated and new e way bill. Resulting Increase in documents and complianceAmendment in Part A of E Way bill should be allowed
17Blocking of E Way BillIf GST Return is not filed for 2 months, then E Way bill portal is blocked. Since portal is blocked, business gets held up and it result into further financial stress. Two months is very short.a) E Way bill blocking should be started, if returns are not filed for past 6 months. Or else allow filing of GST Return without payment of tax. B) Also, Supplier (who is regular in filing GST Return) is restricted from prepared E way bill for, customer whose e way bill portal is blocked. Tax compliant supplier, here is sufferer for problems at customer end. Tax compliant supplier should be allowed to generate E way bill in all cases.
18Goods stored/held up at Transporter godown/wareh ouseWhen goods reach to destination city, some time, due to some reason, delivery cannot be made immediately and goods are required to be stored at transporter godown/warehouse. [ this time period may extend to 5-10 days. Sometimes, customer ask for delivery after 5-7 days.] In such case, there is no solution provided in law for ‘temporarily storing of goods in Transporter godown and expiry of validity of e way bill in such case’E Way bill validity “Pause” concept, to be introduced, if goods are stored for temporary period of 5-7 days at transporter godown. (OR)   Small fees of Rs 50 may be charged for revalidation of e way bill, in case validity of e way bill is expired and stored at transporter warehouse.

C) Issues in GST Monthly / Quarterly Return

Sr. No.GST IssueDetails of IssueRequired Solution
19Job Work Return ITC 04 – Duplication of WorkFor movement of goods for Job work, supplier is required to prepare Delivery Challan + E Way Bill + file ITC 04 Return, (ITC 04 contains details of all goods sent to job worker and received from job worker). ITC 04 is duplication of compliance, since E Way bill is also prepared. Also, ITC 04 has number of issues for preparation, uploading and filing which makes it impossible/extremely difficult to file. This issue is faced by all taxpayer in India.ITC 04 is causing duplication of work, as delivery challan + E way bill is already prepared. Therefore, compliance of ITC 04 should be removed.
20Revision of Return – GST Law assume Human cannot make mistake in ReturnIf any mistake happens in Sales, ITC details in GST Return, its revision is not allowed. Circular No 26/2017 dt 29.12.2017 issued to deal with such case and asked to make correction in subsequent GST Return. However subsequent return may not have said details and in such case, circular ask to do it in next-to-next return. This is cumbersome to followTo Err is Human. Income Tax Act allows multiple revision of ITR.   GST Law should also provide for “Revision of Returns” till the filing of Annual Return. If there is any mistake in GST Return of (Jan 2021), then revision of Jan 2021 return should be allowed.
21Correction of ReturnCurrently if any mistake happens (example wrong GSTIN in Mar 2020 GST Return), same can be corrected only upto next financial year Sep GST Return (in such case, it can be corrected upto Sep 2020 GST Return). Some time, mistake is observed after 1-2 years. Therefore, time limit of 6 month is very lessTo Err is Human. GST Law should provide for “Correction of Returns” without any time limit. (Correction in GSTIN Number, Invoice Number etc)
Sr. No.GST IssueDetails of IssueRequired Solution
22Huge Late fee is chargedHeavy late fees in GST causing “BIG Financial Strain / Trouble” to all small taxpayer. Many times, it is observed, amount of late fees is more than tax payable.Late fee should be maximum Rs 1000 per monthly/quarterly return, where tax is payable and Rs 100 per nil return. [ Under Income Tax, maximum late fee for one year is Rs 10,000, whereas under GST, one year late fee comes to Rs 1,20,000 ( 10,000*12) ]
23QRMP should be changed QRQPGovernment has introduced QRMP but small tax payer finding is very difficult to file (Form IFF, PMT 08, GSTR 3B, and GSTR 1).Government should implement this scheme in true spirit and ask for quarterly payment only. Most of taxpayer is covered under this category but still they can’t get true benefit of this scheme. Therefore, we recommend to have “Quarterly Return and Quarterly Payment Scheme” QRQP
24Filing of GST Return without payment of TaxGST Return cannot be filed without payment of Tax. Sometime supplier is under financial stress, his customer is not making payment and due to this he may not have adequate fund temporarily to pay the tax.Government should allow filing of GST Return without payment of Tax, atleast for 3 months (After 4 months, you can ask for payment with return) [ Please note, when you don’t allow filing of return, without payment of tax, government itself block submission of information from taxpayer who is in financial crunch]
25Negative amounts in GST ReturnSometimes Sales-Return will be more than sales during the month. In such case, GSTR 3B does not accept negative figures. In proposed GST RET 1 (ANX1/2/3), negative figures were allowed. However, said return was not implemented.In GSTR 3B , negative figures of ‘supply value/Tax amount’ should be allowed to inserted.

D) Issues in GST Annual Return and Reconciliation FORM (GSTR 9 /9C)

Sr. No.GST IssueDetails of IssueRequired Solution
26ITC bifurcation not requiredAnnual return requires bifurcation of ITC in to input, capital goods which is difficult to capture Also, credit is entirely available on inputs, capital goods and input services for GST payer (subject to fulfilment of conditions) irrespective of such classification.The bifurcation of credit should be done away with. (For FY 2019-20 relief is given for not providing bifurcation of input and input services. ITC of Capital goods is still asked. However, We, recommend to remove the said bifurcation from the GSTR 9, so that in future same issue will not come)
27HSN wise Purchases and Sale details should not be askeda) HSN wise details of Purchase – Sometime Capturing of HSN wise summary requires GST payer to determine whether the HSN of the procurements In the aforesaid exercise, even simple question like what is HSN of furniture, stationary becomes tricky one. Many time supplier don’t show HSN on invoice, as he is relaxed by governmentRequirement of HSN wise sales and purchase details should be done away with. (For FY 2019-20 relief is given for not providing said details. However, we recommend to remove the said tablefrom the GSTR 9, so that in future same issue will not come)
  b) HSC wise details of Sales – HSN details are already provided in monthly GSTR 1. Therefore, asking same in annual return increases compliance. 
28Liability Payment should be allowed from ITC BalanceThe taxpayer has to pay GST liability in cash irrespective of credit balance at the time of GSTR-9 and 9C This is creating hurdles to many industries having accumulated credit balance.Payment of Liability should be allowed from ITC in GSTR 9 and 9C
Sr. No.GST IssueDetails of IssueRequired Solution
29Pending ITC should be allowed in Annual ReturnGST Law prescribe September of the subsequent FY as a last date of availment of ITC, however till the date books not get finalised.   In Annual Return, pending liability can be paid but pending ITC is not allowed. This is dual approach.   Annual Return should provide one chance to pay pending liability and avail pending ITCThus pending/additional ITC should be allowed to be availed in Annual Return.
30There is no proper flow in Annual ReturnAnnual    Return    has    below    major issues: It     doesn’t     provide     any    tax calculationIt should be rational and logicalTax paid voluntarily through DRC 03 is not linked with Annual ReturnAnnual Return should provide tax calculation. It should also consider Tax paid voluntarily earlier through DRC 03 If form become easy, its compliance will be simpler. [ We request to refer Maharashtra VAT Audit Report Form 704. It was having some flow and easy to fill]

E) Issues in GST Composition Return

Sr. No.GST IssueDetails of IssueRequired Solution
31Interstate supply should be allowed for compositionIf person makes interstate supply, he is debarred from composition scheme. This restricts small business to do interstate supply.Interstate supply of goods and services should be allowed for all category of Composition dealer
32Input Details in GSTR 4Details of Inputs are to be submitted in the return GSTR 4 for no reason. This makes compliance of GSTR 4 complicatedNo Input details may be asked in GSTR 4 since composition dealer is not eligible for ITC
33Same Turnover limit for Composition Scheme for Goods and ServicesGoods composition has Rs 1.5 crore and  Service  composition  has  Rs 0.5 crore turnover  limit.  Also, the scheme for goods as well as services has different type of conditions & prescribed limits. (Example – 10% service restrictions in the composition for goods has also no logic)Common turnover limit of Rs 1.5 crore should be kept for composition of Goods and     Services,     without     any     10% limit/logic
Sr. No.GST IssueDetails of IssueRequired Solution
34Time for ITC Reversal in case of person opting Composition SchemeIf some Registered Person wants to opt composition scheme, he has to reverse the ITC on the stock as on the date of opting. Since this reversal amount becomes heavy for him, he avoids to go in composition.Suitable time period of 6 months may be given for payment of reversal of ITC without interest.

F) Issues in GST Refund Provisions

Sr. No.GST IssueDetails of IssueRequired Solution
35Refund of ITC on Input ServiceIn case of Inverted duty structure, refund of Input Services is not allowed without any rationalRefund of Input Service should be allowed    in    case    of    Inverted    Duty Structure.
36Refund of ITC on Capital GoodsRefund of ITC on capital goods is not allowed, causing disincentivise the capital investment and blocking of funds.Refund of ITC on capital goods should be allowed in case of Export under LUT as well as under Inverted Duty Structure
37Provisional RefundGST Law provides for 90% of provisional refund on Export under LUT within 7 days. However, said refund is not granted within specified time and follow up required to be madeInstruction to be issued to officer for strict adherence of said provisions
38Refund of ITC for SEZSEZ unit has been denied refund of ITC on inputs. This is hardship and against the spirit of SEZ PolicySEZ unit should be allowed refund of ITC. This will promote export
39Deficiency Memo for RefundIf deficiency memo is issued for refund application, then fresh application is required to be submitted.    If    fresh    application  is submitted  after time  limit, then refund is denied, even though first application was made within time limit. In such case, time limitation for refund is calculated till the date of fresh accepted application, instead of counting till original refund application.
This result in denial of refund in some cases.
a) If original refund application is filed within time limit , it should be considered that refund is filed within time limit. (Irrespective of whether it is accepted or deficiency memo is raised)
b) In fact, only deficiency should be complied with and there should not be requirement of filing fresh application in case of any query/deficiency.

G) Issues in GST registration prvisions

Sr. No.GST IssueDetails of IssueRequired Solution
41Time limit for physical verification should be reduced to 7 days from 30 daysIn case Aadhaar authentication cannot be carried out then the physical verification of the business is made compulsory and time for granting of registration is extended to 30 days in these cases.Intimation of Visit for verification should be given – Considering the present pandemic situation where in many sectors offices are kept open only for short periods or on alternate days, such physical verification should be made after due intimation to the authorized signatory so that they can show all required papers and supporting submitted at the time of application for registration.Time limit for verification – Moreover the 30 days limit may need to reduce to 7 days so that businesses can raise GST invoice at the earliest.
42Effective date of GST RegistrationGST Portal treats, Date of GST Registration Certificate, as Effective date of GST RegistrationEffective date of GST Registration should be the date of original application and not the date of issue of registration certificate. (GST Portal restrict, entering all supply details, before date of GST Registration as per certificate.)
Sr. No.GST IssueDetails of IssueRequired Solution
43Deeming Effective date for cancellationCancellation applications not given effect, even after passing of 6 to 7 months from the date of application because of which the closure of the business is incomplete in many cases.Provision for deemed cancellation within 7 days should be incorporated (from date of application for cancellation) Note – Department can proceed for recovery    /     notices     /     audit     post cancellation as well.
44Standard list of Cancellation documentIn case of cancellation applications, different type of documents like indemnity, banks statements, balance sheets of last 3 years are being sought for apart from a report of physical verification. Since this is not standardized, it is creating unnecessary confusion in many cases and so taxpayers are not sure as to the set of documents required which is creating wastage of time for the proper officer as well as for the tax payer.Just like standard set of documents for refunds are defined under Circular 125 of 2019 CGST, a standard set of documents required to be filed along with cancellation applications be issued so that same set of documents can be uploaded and verified by officer
45Excessive Authority for cancellation of GST Registration – For ITC issues (Inspector Raj)Rule 21(e) – Where a taxpayer avails Input Tax Credit (ITC) in violation of the provisions of Section 16, even for minor differences or unintentional errors, a taxpayer may have to face cancellation proceedings, leading to suspension of GSTIN and business in the meantime.The proceedings for cancellation should be initiated only if there is sufficient evidence available on record that, the violation was with fraudulent intend to evade taxes.
Sr. No.GST IssueDetails of IssueRequired Solution
46Excessive Authority for cancellation of GST Registration – For difference in GSTR 3B and GSTR 1 (Inspector Raj)Rule 21 (f) – Where the liability declared in GSTR 3B is less than that declared in GSTR 1 in a particular month the department can move for suo moto cancellation. Since revision of GSTR 3B is not allowed, many corrections Or Omissions are given effect through process enumerated in Circular 26/26/2017 CGST. Due to this there if liability is shown in excess in say January 2021 , the same may be adjusted in 3B of February 2021. This will lead to liability in GSTR 3B being lesser than GSTR 1 for the month of February 2021. This would unnecessarily increase litigation for genuine taxpayers without giving them opportunity to make correct the errors as per circular.Power for cancellation of GST Registration for difference in GSTR 1 and GSTR 3B should be removed. GST Law doesn’t have provision for revision of return and therefore there is bound to have difference in GSTR 1 and 3B. If government keeps on increasing power of authority, we feel, we are going to Era of “Inspector Raj”. This power should be removed.
47Excessive Authority for “Suspension” of GST Registration     Rule 21 (2A)On a comparison of output tax payable as per the GSTR 1 and  GSTR 3B or the ITC available as per GSTR3B and GSTR 2B, if there are significant differences or anomalies indicating contravention of the provisions of the Act his registration shall be suspended. However, this suspension prior to Cancellation will be effected without providing any opportunity to taxpayers to offer their reasoning for the anomalies. This   is   infringement   of   the   basic principle of Natural Justice and may lead to unnecessary challenges being faced by recipients. For example, a taxpayer avails credit of 1,00,726 in place 1007.26, it will be anomaly which can be rectified by the taxpayer in the next return itself. Here suspension will only lead to litigation and impact of business.Government intention for this appears to be good, to restrict bogus taxpayer. However, this power is likely to be misused against Genuine Taxpayer. We recommend that Government should give opportunity of being heard before initiating suspension of registration.
Sr. No.GST IssueDetails of IssueRequired Solution
48Time limit for Revocation of CancellationIn case of cancellation of registration on the motion of the Proper officer, the tax payer has to apply for revocation  of  the  cancellation  within 30 days. However, at times the cancellation order is available to the taxpayer after a time gap. Also, funds are not readily available which also leads to delay in filing of application for revocation of cancellation. If the revocation can’t be filed and approved, the tax payer is also not able to raise tax invoice which impacts the business where a large portion of the supply is made after cancellation.The time for application for revocation be extended to at least 90 days from the date of cancellation so that the tax payer can arrange the funds, pay the taxes, file the returns and then apply for revocation of cancellation.
49Revocation of cancellation on account of application made by taxpayerDue to various reasons the taxpayer may decide to shut the business or discontinue with the business and so may apply for cancellation on his own. However suddenly he may receive a huge order and so he may want to revoke the cancellation. However, since revocation is allowed only in case of cancellation initiated by the proper officer, revocation in case of cancellation  application  made  by tax payer  is  not  allowed.  Due  to  these small businesses are losing business at times as the customers are not ready to give the order to a recently registered entity.Revocation application be made available for all types of cancellation – whether by officer or the tax payer. This would also help in the governments vision of Atmanirbhar Bharat wherein business may revive at times even after applying for cancellation.
50Automatic Activation of cancelled Registration if return filedIn case registration is cancelled by department for non-filing of return, the taxpayer is required to – file Returns + file revocation application.Once all pending returns are filed, registration should be activated ‘automatically and immediately’, without requiring filing application of revocation.

I) GST Issues in Documentation

Sr. No.GST IssueDetails of IssueRequired Solution
51Credit Note for Service CancellationSec 34 – It can be observed that the situation of ‘cancellation’ of service is not covered under section 34 of CGST Act.We request suitable clarification that cancellation of service contract is also covered under the ambit of section 34 of CGST Act. In case of sectors like real estate sector, software etc. the customer may cancel the flat even after 2-3 years and thus, clarity should be provided as per section 34 of the CGST Act that either refund of GST to said customer/ Developer or credit of GST paid to Developer is available.
52Time Limit for Credit Note should be removedGST law should not put condition for sales return. It is business need and therefore time of six month for sales return is very cumbersome. •Additionally, it is pertinent to note that, this may not be practical in some of the industries like real estate sector, software etc. In case of real estate sector, the customer may cancel  flat  even  after  3-4  years.  In case   of   pharma   company, expired goods are returned after expiry, period of return in such case, can be more than 2 years.Time limit of issuance of Credit note should be removed.
Sr. No.GST IssueDetails of IssueRequired Solution
53Requirement of Payment Voucher to be deleted in case of RCMSection 31(3)(g) read with Rule 52 of the CGST Rules – A payment voucher is required to be issued for the expenses liable to RCM. This increases the compliance.Maintenance of payment voucher in case of RCM Should be withdrawn
54Requirement of RCM Invoice to be removedSection 31(3)(f) read with Rule 36 of the CGST Rules – RCM ITC is available based on RCM Self Invoice. This is unnecessary document requirement.RCM ITC should be allowed as per payment and requirement of additional invoice should be removed. This is increasing compliance.   Make GST simple

J) Issues in place of supply

Sr. No.GST IssueDetails of IssueRequired Solution
55Definition of Export of ServiceIt has been observed in some cases that the transaction between the holding company (foreign company) and its subsidiary company (Indian company) or vice versa, is not qualified as export by the tax authorities. The export is rejected on the grounds that both the companies are not distinct person and does not satisfy the condition for export of services as per Sec 2(6) of IGST ActSuitable and Trade friendly clarification should be issued for meaning of term as per Sec 2(6)(v) of IGST Act 2017.
56Discouraging the Export of intermediary ServicesAs per sec 13(8)(b) of IGST Act, if supplier from India provides any services to person outside India, (which is the nature of arranging supply between two person) is taxable under GST, even though India supplier is receiving amount in foreign currency.  This  is  discouraging Big Amount of Export from India. Due to this many businesses are changing business location from India to other country.In case of intermediary, if amount is received in foreign currency, said service should be treated as Export of Service and no GST should be asked on it.   This will make Export Service from India, competitive in international market and also India’s Export will increase to larger extend.

K) Technical GST portal issues [ GSTN ISSUES]

Sr. No.GST IssueDetails of IssueRequired Solution
  57 When authorised signatory leaves the organization, change of credentials is not given unless the old person allows the change. This put business in to hardshipsUse of Director DSC to change the Authorised signatory details to be permitted
58 It is frequent issue with GST Portal since last 3 years that, it doesn’t perform properly on last due dates.   This leads to lot of wastage of valuable time of professional person of taxpayer.   This is big worry, issue of all taxpayer. When complaints are filed that there is issue on portal, GSTN come with tweet that, “     ” returns are filed. They should accept that capacity of server is not upto the mark and therefore taxpayer find is very hard to file return on due date.When there are 1.25 crore + taxpayer under GST, we recommend to kindly extend capability and capacity of users to be dealt by GST system to atleast 20 lakhs at a time.   This will save lot of valuable time of taxpayer and professionals.
59 Unable to add more than 10 partners in registrationSystem is required to be changed for the same.
60 GST Annual Return in Form 9 is allowed to fill online but GSTR 9C online filling is not allowed by portal. Taxpayer has faced many issues with GSTR 9C excel utility.GSTR 9C online filling should be allowed, in addition to excel utility of GSTR 9C
61 Post upload of the Json system takes
upto 15 minutes to validate and share the errors
A Json Validation utility shall be provided offline which saves users time and travel to portal and slowness in portal is saved. The off-line validation should be same as validation for online
Sr. No.GST IssueDetails of IssueRequired Solution
62 While submitting return, validity time of the OTP is 5 minutes. Many times, this doesn’t get delivered.OTP validity time should be increased to 1 hour. If that OTP screen is closed again, new OTP need not be generated and old OTP should be accepted
63 If in a month B2C Section is not filled and submitted one cannot go and amend the B2C section in subsequent months.System should allow to amend all fields as per laws, whether it is filled or not in earlier month.   Also, unnecessary validation should be removed from all Types of GST Return forms. It increased GSTN Helpdesk work as well.
64 Export details (Copy of Shipping bill d) sometimes are not available with taxpayer, while filing GST ReturnExport details should be automatically populated from ICE gate to GSTR 1, to eliminate data entry errors and ease of refund, or better taxpayer compliance (Similar to update of import of Goods in 2A)
65 Auto Refund of Exports, with payment of tax, is accepted/processed only when SBN Value, GSTR 1 Value and 3B value matches. Even a minor error in paise the refunds are on holdPaise errors to be ignores and round of to Rs.100 can be considered and auto refunds to be initiated
66 In some of refund case, (export on payment of tax), refund is kept on hold since last 2-3 years. No solution for the same is given by ICEGATE or GSTIN or custom officer.Government should issue guideline to local custom officer, give him power to deal with such case, so that he can release refund after due verification.
67 Portal consider same interest amount of CGST and SGST. Interest component auto populated with same amount for SGST when a value is entered for CGST column in Form 3BAt times correction in only one liability arise these facilities shall be provided
Sr. No.GST IssueDetails of IssueRequired Solution
68 Currently GSTR 2A / 2B download is available for one month at a time.Option to download GSTR 2A for a period (For example – FY for 2019-20, Oct to Dec) be made available.
69 E Invoice report (in GSTR 1 functionality) for Users who are uploading GSTR 1 data through Einvoice, are not available for view / download.Whatever submitted by the supplier a view + Download report feature should be available to recipient, so that , if required taxpayer can check details of portal with books, for any difference if any.
70 Some time, GST Returns can not submitted due to DSC issue, which takes some time for resolution. For corporate taxpayer, OTP facility for return submission is not allowed.Return submission by OTP should be allowed to all taxpayer in addition to DSC.
71 In large entity with multiple GSTIN, there would be one person who does the approval of transactions. Common error that comes is “Certificate already registered with another authorized signatory”Within the same PAN multiple persons being authorised signatory to be permitted.
Sr. No.GST IssueDetails of IssueRequired Solution
72One Chance to Rectify Mistake of 2017- 2020Every new attempt will have some mistakes and errors. GST being New Law is not exception to this. Even government is also learning under GST and due to which number of notifications, circular are issued, some forms are designed but scraped.   Taxpayer is also not exception to this and he has also made many such mistakes, which caused him for financial loss as well. Some are just clerical mistake but taxpayer is required to bear cost in lakhs. Therefore, “GST Amnesty Scheme to be introduced for 2017-2020 transaction” as one time relief for all mistake and errors by taxpayerGST Amnesty Scheme 2017-2020 should provide for: Availment of all pending ITC, if it is appearing in GSTR 2AAmendment in GSTR 1Adjustment of Credit notesPayment of RCM Liability and ITC Reduced rate of interest for delay in payment of outstanding tax under amnesty Waiver from penaltyZero Late fees for filing pending GST ReturnCondonation from non-submission of LUT, if other export condition is fulfilled.Solution should be provided for mistake of wrong tax paid (example – CGST/SGST paid instead of IGST) Refund Application should be allowed even if time limit is over.

M) Issues in criminal offence provision under GST

Sr. No.GST IssueDetails of IssueRequired Solution
73Section 132(1)(a) of the CGST ActThe supply of goods or services without issue of any invoice with an intention to evade the tax is cognizable and non-bailable offence (above specified tax amount threshold).However, if such income is already disclosed under any of the Act (like Income Tax Act, Company’s Act) then the same should not be treated at par with the supply which is not disclosed at all and thus, may be decriminalized irrespective of tax amount threshold.
74Section 132 (1) (d) of the CGST ActThe offence of collection of taxes however failure to deposit to Government beyond the period of three month is cognizable and Non bailable offence if covered under subclause (i). Within the amid of COVID-19 everyone is struggling with the huge financial crunch. Thus, some of the customers pays properly however some of the customer may not make payment towards such supply. GST is payable  in  due  basis  irrespective of receipt of amount due. Further, GST portal does not allow part payment of GST liability. In such scenario sometimes it becomes difficult to pay the GST liability to the extent of amount received even in case of genuine taxpayer.while prescribing the punishment in case of said offence the person who is of good track record for prior period should be differentiated from the person who is not having good track record for prior period instead of time of three month.
75Section 73,74 and 76Pre-consultation     is     not     provided before issuance of SCNPre-consultation should be provided before deciding case unlike in Service Tax

Immposible due date target, leading to many extention (EXAMPLE: GSTR 9/9C FOR F.Y. 2019-20)

Sr. No.GST IssueDetails of IssueRequired Solution
76GSTR 9/9C due date for FY 2019-20On 13th Dec 2020, GSTR 9 for FY 2019-20 is opened. On 31st Dec 2020, GSTR 9C for FY 2019-20 is opened. GSTR 9/9C Form is amended in Oct 2020.   All professionals and Taxpayers were doing day and night efforts, for compliance of filing GSTR/9C for F.Y. 2018-19 and compliance under other acts (which was extended/stopped due to Covid lockdown), upto 31st Dec 2020 However, still after knowing this, government specified due date for GSTR 9/9C for FY 2019-20 to 28th Feb 2021. This due date target is impossible and not possible to even god. Now government force all people to cry for Extention.  We don’t need Extention. We want should government give due date after considering all issues.   GSTR 9/9C due date for FY 2019-20 should be immediately extended to 31st May 2021.   Also, if future as well, create such trust among all professionals and trade, that, there should not come any requirement of extension.

Annexure II – Issues under income tax along with recommended solutions

Sr. NoIncome Tax IssueDetails of IssueRequired Solution
1Actions ultra- vires the Citizen’s CharterThe Citizen’s Charter recently unveiled in the year 2020 states as follows: The Charter commits to provide fair, courteous and reasonable treatment to the tax payers, while expecting the tax payers to be honest and compliant.However, we feel that either we have failed to comprehend the meaning of fair, courteous and reasonable treatment of the tax payers or the Income Tax Department’s actions are ultra-vires the Citizen’s Charter. Your good self needs to take corrective action for the same.
2Complicated Tax returns emerging each yearEvery year the tax return forms are changed, adding new items each year, making them more and more complicated, year by year. We can easily recall when we used to file IT Return in 2010 and today, more schedules have been added in ITR Forms. Numerous items have been added to the IT Return forms since 2010, making it more and more complicated.The forms applicable to the trade and industry are ITR-3, ITR-5 and ITR-6, and on a comparison of changes made since last 10 years in the ITR, it is found that the following items were added over the decade. (Details of changes in Income-tax return forms are attached in Appendix-A)Tax returns should be amended to accommodate only meaningful information, after consultation with the stakeholders. Certain details like matching GST with P&L as required in Schedule GST is not only impractical, but also a futile exercise. Tax returns should be simplified further, encouraging more and more tax payers to increase the base of tax payers.
3Simplifying Tax Audit ReportDuring the last decade, the reporting requirements in the Tax Audit u/s 44AB are highly escalated. Around 27 Paras have  been added resulting  into increased complexity and higher consumption of time of the auditor. Further it has also  increased the efforts required to be given by the members of trade and industry in preparing the details before submission for audit. (Details of Changes in Tax Audit reports are attached in Appendix-B). From Appendix-B it is clear that Clause No.13(e), 13(f), 17, 28, 29, 29A, 29B, 30A, 30B, 30C, 34(b), 34(c), 36A, 41, 42, 43, 44, have very much complicated the tax audit process, requiring  substantial  time  and  energy for both the auditors and the auditees.Tax Audit report should be simplified to the best possible level. If certain details are required by the Income Tax    department,    sufficient    time should   be   allowed   for   the   audit process
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
4Insufficient timeline of due-dates for MSMEsBack in the 1990’s and 2000’s all audited assessees were given ample time up to 30th November, 31st December for compliance with a relatively easier tax audit report and Simple/Saral income tax return. However, even after introduction of newer complexities in Tax Audit Reports, Income Tax Returns and other compliances, the due dates have been shortened by at least 3 months. The  period of filing Non-Audited IT Returns upto 31st July and Audited Cases upto 30th September are in first place quite short. Although the level of complexity of Income Tax Returns and Tax Audit Reports which has increased over the last decade as specifically described in Appendix A and Appendix B attached to this submission, the time given for compliance is still 30th September    (for    audit    cases)    of  the assessment   year,   instead   of  providing additional time for compliance.Due Date for non-Audited Income Tax Returns be fixed upto 31st August and for Audited Cases by 31st December each year.
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
5Cumbersome and avoidable provisions of TCSRecently unveiled wef 1st October 2020 provisions of TCS (Tax Collected at Source) u/s 206C(1H) are highly cumbersome and full of fault, and implemented without taking the stakeholders into confidence. Those have been notified in a haphazard manner with quite less clarity. The trade and industry at large are putting much effort for practically implanting it. Most businesses end up paying the TCS amount out of their own pockets instead of collecting it from the customers / clients, thinking of the amount as trivial. In fact, the amount of TCS is recoverable from the deductee,  which itself is an issue of dispute between the deductor & deductee.Retract the cumbersome and futile provisions of TCS u/s 206C(1H) with immediate effect. Most of the businesses becoming liable for aforesaid TCS are already under the tax net either under GST or Income Tax. Therefore, the compliance of this section is an additional burden on the assessee.
6Presumptive Income Scheme really not presumptiveSmall tax payers, while opting for the presumptive Income Scheme: u/s 44AD: 6% / 8% of Turnover / Gross Receipts for Businesses u/s 44ADA: 50% of Gross Receipts for Profession u/s 44AE: Rs.1000 per MT / Rs.7500 per month for Transporters are allowed to pay tax on the presumptive income calculated above and as a part of the scheme are not required to maintain books of accounts. However, the IT return form as well as the software requires mandatory information on key figures of Cash on Hand, Sundry Debtors and Loans and Advances of these small tax payers.  Thus, forms and softwares asking the above details are ultra-vires the Scheme declared under the statute.Forms for Income Tax Returns should not require the tax payer to mandatorily furnish details of Cash on hand, Sundry Debtors and Loans & Advances, which defeats the purpose of the scheme. Updated forms should remove the said anomaly.
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
7Identification of CA’s and Tax Professionals as an entity in Income TaxMCA has long back recognized the role of professional as distinct and identifiable from the other stakeholders on the MCA portal. Accordingly any filing required to be done by any company is also allowed to be done from the login ID of the professional. However, on the Income Tax Portal as well as the GST Portal, the tax professionals have to use User IDs and Passwords of the respective businesses or assessees. Infact, this is not a proper manner of tax compliance, when it is a settled fact that the filing of Income Tax, GST or MCA are all done by professionals having requisite skill sets, after due authorization from respective businesses.E-filing of all existing forms should be enabled for filing through the Professional IDs, and the delegation should be authenticated through Aadhar based OTP of the owner/authorized signatory of the respective business. It would also give a statistical idea of how many returns are being filed by assessees and how many are filed by the tax professionals.
8Stop Bombarding of unidentifiable emails & SMS after office hoursNumerous unidentifiable emails and SMS with marked PAN, GST or Return filing numbers are bombarded by the department (both CPC under Income Tax and GST) in the evening after office hours, at night, midnight, in the early morning and even on public holidays, on the registered email and mobile numbers. Such communications are highly undesirable in similar fashion as official calls to government officials after office hours.Emails requiring the assessee to take any action or responding on to the portal should be made only during working hours and at no other time also not on public holidays.
9High Cost of Compliance for MSMEsMost MSMEs operate at a low level of profitability and seldom have enough resources   to   innovate   and  modernize. However,  on the other  side,  departments like GST, Income Tax and MCA levy hefty penalties, interest and late fees for submissions of trivial importance. The growth potential of these MSMEs is thereby curbed and instead of positive change, theentities undergo a negative change. Numerous entities have been wound up and thrown out of the business, just due to the excessive and abnormal levy of late fees. At times, this results into evading of compliances and loss of taxpayer base by the department. Cost of existing compliance schemes is affordable for the large tax payers, however, for the small and medium tax payers, the same is not affordable. Putting both categories of tax payers is not an advisable comparison keeping in view the principle of “Equality among Equals”.Interest, Penalty, Late fees, extra costs like procurement of digital signatures,       etc       should       be rationalized  for MSME’s  so that  the cost of compliance for this level of tax payers is bearable and can be accomplished without substantial hardship. It is gut feeling of all the taxpayers that the government does not recognise the popular phrase “To err is human”.
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
10Removal of Late Fees for filing returnsHefty late fees have not only broken the back, but also the morale of the tax payer community. While the late fees charged for late compliance under TDS provisions u/s 234E (Rs.200 per day), were already undesirable for the timely compliance of TDS provisions by the trade and industry, new provisions u/s 234F were introduced by Finance Act 2017 for levy of late fees of Rs.10,000/- on late filing of Income Tax Returns after December of relevant assessment year. These provisions of Sec.234F were introduced without adequate        consultation        with      the stakeholders and at a time when the whole nation was busy migrating itself to the new indirect tax structure. Not only are the provisions of 234-F illogical, but also detrimental to the Citizens Charter more aptly described in Appendix A attached . Those tax payers who were filing Income Tax returns upto 2017-18, even in the month of March, duly paying taxes and interest on validly allowed belated returns, suddenly became violators and offenders from 2018-19.When a whole year is given as an assessment year, filing must be allowed at any time during that assessment year. The concept of asking for late fees is totally against the concept of assessment year. Also, when an assessee is filing his return late, he is charged interest u/s 234A which is already penal in nature. Non bis in idem (Double jeopardy) is never allowed for the same act. Hence, the provisions of late fees for both TDS Returns u/s 234-E  and Income Tax Returns   u/s 234-F  are  required  to  be  removed immediately. Non / late filing of TDS returns & Income – tax returns has its own consequences to the assessee. Therefore, no assessee will avoid filing of these returns unless for the genuine reasons must be considered. The name late fees take the character of penalty & hence required to be removed.
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
11Punctuality and Stability in providing return filing utilitiesIncome Tax Forms, Schemas and utilities (either for returns or for Audit Reports) should be made available by the department at the beginning of the year. Needless to mention that it has to be an implied and assumed action by your department to provide the stakeholders  the necessary documentation like forms, its schemas and utilities at the start of the assessment year. Also, needless to remind your department, the various instances in past, wherein various courts had to intervene into the matter for directing extension of time limits and the subsequent apologies from the top officials of the Finance Ministry, promising to ensure timely release of forms, schemas and utilities. One such Tweet is reproduced below for refreshing the memories of 2015-16: Further, during the whole year, ITR utilities undergo revision on  an  average  for  6-13  times.  What are the  afterthoughts  that  give  rise  to   such frequent changes in IT Return filing utilities? (Tweet made by Dr. Hasmukh Adia, Finance Secretary, Govt. of India on 01.10.2015 in this respect is attached herewith as Appendix-C)ITR Forms should be notified well before 31st March to the ensuing year. Adequate time for testing and deployment should be given to the technology provider. Finally, utilities should be delivered in a time bound manner not later than 1st day of relevant assessment year. The department has sufficient time to prepare these utilities of 10 plus months after assent of the President on Union Budget.
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
12Lifting service standards of Websites and PortalsThe world watches India, for the level and standards of its e-Governance, the Government websites and portals, the level of comfort it offers for ease of doing business, the service turnaround times and the average downtime of the key portals. Amongst other benchmarks, the above forms key part which drives their decision making process of external investors. When compared to other developed countries as well as developing countries, these benchmarks are not upto the mark.There is a dire need to increase the service standards of the website for their continuing availability. For this a thorough benchmark test needs to be set. Rigorous tests are required to be cleared, and a lot more to explain as to why frequent outages occur, when world’s leading technology provider handles these portals?
13Issuance     of certificate u/s 197 and / or sub     section (9)    of         Sec 206CForm No.13 is provided vide Rule 28 and Rule 37G for non deduction or deduction at lower rate of TDS / TCS. Presently, such applications are mechanically processed without application of mind by ITO resulting in denial of benefit. Presently this benefit is not available for deduction of TDS u/s 194N. Particularly for regular ITR filers and for those having very less amount of profit margin (Like commission agents etc) due to 2 % of TDS large amount of profit margin is blocked.Presently benefit of concession is either   wholly   denied   or   application   is processed much late resulting in  nullifying the benefit.The said provision is for benefit of small taxpayers whose income is otherwise not taxable or under basic exemption limits. For example small pigmy agents, postal commission agents, Co-op Societies (availing benefits of Sec 80P), Trusts (claiming exemption u/s 11 & 12) etc.It is required that such certificate shall be processed considering facts in each case separately. In case if income in previous year is not taxable or is below basic exemption limit condition may be waived. Exact time limit shall be given for processing of Form 13. Benefit of Form 13 shall be extended for TDS u/s 194N particularly for regular return filers.
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
14Stay            of Demand particularly in high    pitched assessmentPresently IT department, relying on departmental directives forcing to pay at least 20% of demand. Coercive actions are being taken on nonpayment of 20% of demands. This is resulting in great injustice particularly in cases of high pitched assessments.Stay of demand on payment of 20% of demand is departmental directive only. Supreme court in various cases has categorically mentioned that application of stay of demand shall be considered judiciously. Particularly in case of high pitched assessments courts have directed that CIT being a quasijudicial authority shall apply his mind in granting stay of demands. In view of losses suffered by society in COVID Pandemic coercive actions like attachment of bank a/c shall be in very selective cases only.
15Processing of application u/s            154 Rectification application in timely mannerProblem of non processing of Applications u/s 154 (Rectification application) in timely manner is becoming severe. This has resulted in rising of non-existent demands, non issuance of due refundsProblem is becoming more severe where  ASK centers are not operating.In spite of specific provisions/ Instructions about disposal of application u/s 154 within 6 months, many applications have remained pending, unattended. Some specific instructions be issued to remove this difficulty for once. ASK centers must become functional all over the country.
16Appeal effectsPresently  appeal  effects  are  pending  in large number at ITO level resulting in non- existent demands, non issuance of due refunds etcExact timelimit shall  be provided  for disposal of appeal effects.  One time limit shall be given to IT department for clearance of all pending appeal effects.
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
17Filing of TCS returnPresently after introduction of TCS on sale of goods TCS returns are being processed by NSDL.Previously TCS returns can be filed with DSC using validation tool provided by departmentValidation tools shall be provided at earliest to facilitate compliance in time without hassles.
18Late        filing fees           u/s 234E                  for periods before 01/07/2012Fee u/s 234-E was introduced for late filing of TDS returns. However, after various judgments from courts a change was madein Sec 234E so as to levy such fees only for periods after 01/07/2012. However, in many cases demands raised for earlier periods are still shown as due in TRACES. Levy of late fees for periods before 01.07.2012 is not only illegal but also not intended by law makers.As department possess all data regarding such pending late fees for periods before 01.07.2012, all such demands shall be waived and removed from TRACES without any compliance required to be done by stakeholders.
19Non display of TDS / TCS paid under his TAN by AssesseeIn 26-AS presently all tax credits are shown under one PAN. However there is no system where assessee can know and verify the details of TDS / TCS paid collectively under his TAN.Department possess data of payment of TDS / TCS under single TAN. Sharing of such data with deductor / collector will avoid duplication of payments, payments under wrong TAN, payment for wrong period etc.
20Non display of Income Tax refunds in 26-AS from A Y 2020-21In 26-AS till A Y 2019-20 Income – tax refunds made during the year were reflected along with interest on refund if any granted to the assessee However, from A Y 2020-21 these details are not available in 26-AS resulting in great inconvenience to the assessee.Whatever Income tax refund has been granted must be reflected in 26-AS of the assessee along with bifurcation of interest granted on refund.
2144-AB audit Provisions should be simplifiedPresently, the provisions of Section  44-AB of  The  Income  Tax  Act  are complicated having 3 different categories. Those are also not applicable to below taxable income assessee & loss cases also. Resulting in wrong / misinterpretation by the stakeholders & suffering unnecessary consequencesThese     provisions     need     to     be simplified.
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
22234-A interest on extended due datesThe department is charging interest u/s 234-A of The Income Tax Act, 1961 on extended due dates u/s 139 (1).When a due date is extended charging of interest u/s 234-A is illegal & hence we demand not to charge the interest on extended due dates.
23Window for changing Bank details is not available in present formsIn present income tax return forms window for changing the details of bank account particulars is not available.In Income tax return forms window for changing the details of bank account particulars be made available.
24Banks asking for Income tax passwordMany banker’s while granting loans do not rely on the Income Tax return acknowledgements produced by the assessee.Suitable instructions to the banker’s may be given in order to avoid any wrong acts to the e filing account of the assessee.
25TDS / TCS payment & filing returns to be clubbedIn respect of TDS / TCS presently payment thereof & filing of returns are 2 separate procedures. It results in non-filing / late filing of returns & consequently credit thereof  is  hampered  resulting  in  various issues.A procedure while making payment of TDS / TCS be laid down so that a separate return will not be required to be filed.
26Under Presumptive Tax for firms deduction of Partner’s Remuneration & interest on Capital be allowedUnder presumptive tax system, taxable income was considered before allowing deduction of Partner’s remuneration & Interest on Capital. However, it is not allowed by Finance Act 1997 w r e f 1.4.1994.Partnership firms be allowed to be taxed under presumptive tax after allowing Interest on Capital & remuneration allowable to partner’s.
Sr. NoIncome Tax IssueDetails of IssueRequired Solution
27CPC using excessive powers u/s 143 (1) (a)Central Processing Centre is using excessive powers in making addition in respect of late payment of PF, ESI etc. paid by assessee on before due date of filing returns but late after the dates prescribed under the respective Acts.In no. of court cases before Bombay High Court & various tribunals the addition made on this account were set aside & the deduction were allowed for the respective assessee. Then why CPC is using this tool to harass the assessee & raising unnecessary demands.
28Wrong demands conveyed to CPCIn case of many assessee wrong demands (which were never conveyed to assessee) were conveyed to CPC in past. These demands are being asked to be paid to the assessee or are being adjusted from subsequent refunds u/s 245.All such demands be taken back immediately from the records of CPC.

Issues under income tax along with recommended solutions

Appendix -ADetails of Changes in Income Tax return forms:

Sr. No.ITR TypeScheduleAY 2020-21
1ITR-6GeneralTotal 23 Changes
2ITR-6Balance SheetDetailed information in Balance Sheet schedules
3ITR-6Part A ManufacturingNew Schedule with detailed information (New)
4ITR-6Part A TradingNew Schedule with detailed information (New)
5ITR-6Profit LossDetailed information in compare to 2010 ITR
6ITR-6Part A PLReceipt and Payment account of company under (New)
7ITR-6ESRExpenditure on Scientific Research ( Deduction under section 35 or 35CCC or 35CCD) (New)
8ITR-6CGDetailed Information in compare to 2010
9ITR-6112AScript wise Capital Gain (New)
10ITR-6115AD(1)(b)(iii) provisionScript wise Details (New)
11ITR-6OSDetail information
12ITR-6ICDSICDS compliance Detail (New)
13ITR-610AADetail information
14ITR-6RADetails of donations to research associations etc. [deduction under sections 35(1)(ii) or 35(1)(iia) or 35(1)(iii) or 35(2AA)] (New)
15ITR-6MATComputation of Book Profit (New)
16ITR-6MAT CMAT Credit Details (New)
17ITR-6BBCby back of share (New)
18ITR-6TPSASecondary adjustment in Transfer price (New)
19ITR-6FSIDetails of Income from outside India and tax relief (available only in case of resident) (New)
20ITR-6TR FASummary of tax relief county wise (New)
21ITR-6SH 1 and SH 2SHAREHOLDING OF UNLISTED COMPANY (other than a start-up for which Schedule SH-2 is to be filled up) (New)
22ITR-6AL 2Assets and liabilities as at the end of the year (applicable for start-ups only) (New)
23ITR-6DIDetails of investments (New)
24ITR-6GSTGST Turnover Detail (New)
25ITR-6FDBreak-up of payments/receipts in Foreign currency (to be     filled     up     by     the     assessee     who      is not liable to get accounts audited u/s 44AB) (New)
26ITR-3GeneralTotal 12 Changes
27ITR-3Balance SheetDetailed information in Balance Sheet schedules
28ITR-3Part A ManufacturingNew Schedule with detailed information (New)
29ITR-3Part A TradingNew Schedule with detailed information (New)
Sr. No.ITR TypeScheduleAY 2020-21
30ITR-3Profit LossDetailed information in compare to 2010 ITR
31ITR-3HPDetailed information
32ITR-3ESRExpenditure on Scientific Research ( Deduction under section 35 or 35CCC or 35CCD) (New)
33ITR-3CGDetailed Information in compare to 2010
34ITR-3112AScript wise Capital Gain (New)
35ITR-3115AD(1)(b)(iii) provisionScript wise Details (New)
36ITR-3OSDetail information
37ITR-3ICDSICDS compliance Detail (New)
38ITR-310AADetail information
39ITR-380DNew Schedule with detailed information (New)
40ITR-3RADetails of donations to research associations etc. [deduction under sections 35(1)(ii) or 35(1)(iia) or 35(1)(iii) or 35(2AA)] (New)
41ITR-3AMTComputation of Book Profit (New)
42ITR-3AMT CAMT Credit Details (New)
43ITR-3EIDetail information
44ITR-3AIR ITOther    Information    (Information   relating    to    Annual Information Return) [Please see instruction number-9(iv) for code] (New)
45ITR-3GSTGST Turnover Detail (New)
46ITR-3FDBreak-up of payments/receipts in Foreign currency (to be     filled     up     by     the     assessee     who      is not liable to get accounts audited u/s 44AB) (New)
47ITR-5GeneralTotal 13 Changes
48ITR-5Balance SheetDetailed information in Balance Sheet schedules
49ITR-5Part A MfuringNew Schedule with detailed information (New)
50ITR-5Part A TradingNew Schedule with detailed information (New)
51ITR-5Profit LossDetailed information in compare to 2010 ITR
52ITR-5HPDetailed information
53ITR-5ESRExpenditure on Scientific Research ( Deduction under section 35 or 35CCC or 35CCD) (New)
54ITR-5CGDetailed Information in compare to 2010
55ITR-5112AScript wise Capital Gain (New)
56ITR-5115AD(1)(b)(iii) provisionScript wise Details (New)
57ITR-5OSDetail information
58ITR-5ICDSICDS compliance Detail (New)
59ITR-510AADetail information
60ITR-5RADetails of donations to research associations etc. [deduction under sections 35(1)(ii) or 35(1)(iia) or 35(1)(iii) or 35(2AA)] (New)
61ITR-5AMTComputation of Book Profit (New)
62ITR-5AMT CAMT Credit Details (New)
63ITR-580PDeduction u/s 80P (New)
64ITR-5AMTComputation of Book Profit (New)
Sr. No.ITR TypeScheduleAY 2020-21
65ITR-5AMT CAMT Credit Details (New)
66ITR-5EIDetail information
67ITR-5Sch PTIPass Through Income details from business trust or investment fund as per section 115UA, 115UB (New)
68ITR-5TPSASecondary adjustment in Transfer price (New)
69ITR-5FSIDetails of Income from outside India and tax relief (available only in case of resident) (New)
70ITR-5TR FASummary of tax relief county wise (New)
71ITR-5DIDetails of investments (New)
72ITR-5GSTGST Turnover Detail (New)
73ITR-5FDBreak-up of payments/receipts in Foreign currency (to be     filled     up     by     the     assessee     who      is not liable to get accounts audited u/s 44AB) (New)

Appendix -B: Details of Changes in Tax Audit reports:

Sr. No.FormClauseNew Clauses added during the last decade
13CA / CB5In our opinion and to the best of our information and according to explanations given to us, the particulars given in the said Form No.3CD and the Annexure thereto are true and correct.
2Form 3CD4Whether the assessee is liable to pay indirect tax like excise duty, service tax, sales tax, customs duty, etc. if yes, please furnish the registration number or any other identification number allotted for the same:
3Form 3CD8Indicate the relevant clause of section 44AB under which the audit has been conducted
4Form 3CD8(a)Whether the assessee has opted for taxation under 115BA/115BAA/115BAB?
5Form 3CD13(e)ICDS Requirement
6Form 3CD13(f)ICDS Annexure
7Form 3CD17Where any land or building or both is transferred during the previous year for a consideration less than value adopted or assessed or assessable by any authority of a State Government referred to in section 43CA or 50C, please furnish:
8Form 3CD217 new sub clause added
9Form 3CD28Whether during the previous year the assessee has received any property, being share of a company not being a company in which the public are substantially interested, without consideration or for inadequate consideration as referred to in section 56(2)(viia), if yes, please furnish the details of the same.
Sr. No.FormClauseNew Clauses added during the last decade
10Form 3CD29Whether during the previous year the assessee received any consideration for issue of shares which exceeds the fair market value of the shares as referred to in section 56(2)(viib), if yes, please furnish the details of the same.
11Form 3CD29AWhether any amount is to be included as income chargeable under the head ‘income from other sources’ as referred to in clause (ix) of sub-section (2) of section 56? (Yes/No)
12Form 3CD29 BWhether any amount is to be included as income chargeable under the head ‘income from other sources’ as referred to in clause (x) of sub-section (2) of section 56? (Yes/No)
13Form 3CD30AWhether primary adjustment to transfer price, as referred to in sub-section (1) of section 92CE, has been made during the previous year? (Yes/No) ( 7 sub clause)
14Form 3CD30BWhether the assessee has incurred expenditure during the previous year by way of interest or of similar nature exceeding one crore rupees as referred to in sub- section (1) of section 94B? (Yes/No) (7 sub Clause)

Appendix -C: Tweet of Finance Secretary, Mr. Hasmukh Adia dated 01.10.2015:

Appendix -D: Additional fees payable for MCA compliance:

Period of DelayAdditional Fees payable Rs.
Up to 30 days2 times of normal filing fees
More than 30 days and up to 60 days4 times of normal filing fees
More than 60 days and up to 90 days6 times of normal filing fees
More than 90 days and up to 180 days10 times of normal filing fees
Beyond 180 days12 times of normal filing fees

Capping the late fees as above shall have a stimulus effect on various business entities on shifting towards the corporate formats.

Annexure III – Issues under MCA compliances with recommended solutions

Sr. NoMCA IssueDetails of IssueRequired Solution
1Stability in providing form filingMCA Portal filings are to be made in PDF fillable forms with inbuilt programmed validation facility. These forms are released as version numbered utilities with periodic updates. At most time it is seen, that the required version on the portal is upgraded to a higher version rendering all the ready to upload documents and the efforts put by the users in a total waste.Newer versions of PDF Utilities need to be released only at specific point of time i.e. at the beginning of the financial year, after adequate testing and correction, and not to be changed throughout the year.
2Simplification of filing processThe process of filing on MCA is plagued with too much technicality that it is quite tough for the members of trade and industry firstly to access and secondly to upload documents on the portal. The meticulous requirement of a particular version of Adobe Reader, Java Run Time Environment (JRE) and EMSigner (Proprietary Digital Signing Software) is required to accomplish intended tasks.PDF Forms are highly unstable and require particular versions of Adobe Acrobat Reader. These should be replaced by Excel Utilities similar to Income Tax E-Filing Portal generating XML and supporting documents can be uploaded directly on the website. Requirement of JRE and EMSigner is for digitally signing and submitting forms can be avoided with the implementation of measures described in Para D3.
3Extension of Amnesty SchemesThe trade & industry was looking towards the Company Fresh Start Scheme and the LLP Settlement Scheme as game changer amnesty schemes. Accordingly, many companies/LLPs had opted for to regularize their filings with minimal penalties under the scheme. Many members  of  the  trade  and  industry  had made extensive preparation of filing for the same. However, due to the frequent outage of the MCA website and  the version of Annual Filing form was changed at the eleventh hour on the last day i.e. 31stDec 2020, rendering all the ready to upload files with the CS, CAs and other professionals obsolete, and the same also resulted in a non-compliance compelling the stakeholders to pay hefty late fees.Renew and extend the Company Fresh Start Scheme (CFSS) and LLP Settlement Scheme (LLPSS) up to 31st March 2020 in the interest of trade and industry.
Sr. NoMCA IssueDetails of IssueRequired Solution
4Encouraging Industry for switching to Corporate formatThe Government is keen on onboarding number of businesses into the corporate formats viz. Companies and LLPs instead of the proprietary formats and partnership firms. It is expected from every business to be as transparent as possible in their operations and adopt the corporate format for future growth. However, no such encouragement works when it is coupled with discouragement in the form of late fees and penalties for filings of trivial importance. The new scheme of late fees was introduced with the Companies (Amendment) Act, 2017, without consultation with the stakeholders when most of the stakeholders were busy with the GST roll out. Post implementation, the per day additional fees of Rs.100 per day is back breaking and highly demotivating for new corporate entrants.Roll back the late fees provisions of Companies (Amendment) Act, 2017 and restore back the earlier late fees structure as per Appendix-D attached herewith. Capping the late fees as per Appendix-D shall have a stimulus effect on various business entities on shifting towards the corporate formats.
5Avoiding unproductive compliancesExamples       of       such       unproductive compliances under MCA are as follows: a) MSME-1 filing, b) DPT-3 filing, c) Director E-KYC. The above is only an illustrative list. These filings require reporting in a short time, when the required details are even not available on hand. Also, these periodic    filings    are    unproductive    and results in duplication of work. It is shocking that, a non-compliance of Director E-KYC would result into late fees of Rs.5000 whereas obtaining new DIN No. costs only Rs.500. However, obtaining multiple DINs is an offense. Having said that, the public is inspired by the very acts of the ministry to do wrong. Also, is it justifiable that Rs.5000/- per director, be charge for updating of KYC, which is an annual requirement?These forms should be immediately depreciated     from    use.     Alternate means for the required details can  be obtained as follows: MSME-1: Udyam Database already available with the Ministry of Micro, Small and Medium Enterprises. DPT-3: Annual Filings under MCA portal Director E-KYC: Income Tax filing status (whether the director is alive or deceased and is there any change in address of the director) There are various other filings with MCA   which    are    either    repetitive, redundant or unproductive. The same should be identified and depreciated from      use,      so      that       genuine stakeholders do not have to suffer by way     of     paying     late     fees     for unproductive compliances.
Sr. NoMCA IssueDetails of IssueRequired Solution
6Increasing the number of banks in Payment Gateway of MCAIt is pertinent to note that even the smallest e-commerce vendor has shifted to multiple banks for accepting payments through merchant payment gateway, due to his drive to increase his business. However, MCA seems to lack the drive to increase its filing. Presently the portal for MCA accepts    payment   only    from   4    banks through net-banking. Recent payments are also accepted in a staggered manner i.e. one payment from one user ID, after which the account is lockedA serious thought on increasing the banks that accept payments from MCA should increase, so as to allow any person to make payment through any bank. Also, the issue of blocking of accounts post-payment should be resolved immediately.          
7Reducing the downtime of MCA PortalOn the day of writing this letter, more than 30 days have elapsed since the MCA portal is not working, or working inconsistently. It is also frequently observed that the portal crashes on key due dates. Is it the structure of heavy-duty forms, or the low quality of IT infrastructure to be blamed? Such outages result into heavy late fees which have to be borne by the stakeholders. This is not a fair treatment of stakeholders due to the fault in the IT Infrastructure.When huge costs of monies are being spent on O&M of the MCA portal, usability of portal by the end users should be ensured. Additional hardware infrastructure to scale up the filing requirements is now highly affordable with the unplanned revenue generated from the late fees collected from the stakeholders.
8Increase in Suit Filing limits under IBCMCA has amended the section 4 of Insolvency and Bankruptcy Code, 2016 vide notification no. S.O. 1205(E) dated 24th March, 2020 and has increased the minimum amount of default from 1 lac to 1 crore for application of IBC, 2016. Such action of MCA and Central Government has already impacted thousands of operational and financial creditors. Such 100 times increment in minimum amount  of default is absolutely arbitrary and it has ruined the rights of small and medium creditors to initiate the Corporate Insolvency Resolution Process although there is intentional default. On other hand, it is an open license to Corporate Giants who are Corporate Debtors to crush the small and medium creditors.The issue should be  reconsidered and the notification should be annulled, repealed or cancelled to restore back the former limit again for application of IBC, 2016 in the interest of creditors and the economy at large.
Sr. NoMCA IssueDetails of IssueRequired Solution
9Relaxation in Banning of Unregulated DepositsAs per Sec.3(b) read with Sec.2(4) of The Banning of Unregulated Deposit Schemes Act, 2019, restricts members of public at large to give or take unsecured loans and advances from unrelated parties. This law was introduced without adequate consultation with the stakeholders and is resulting into drying up of money stream from the market. Businesses are already facing shortage of money, but with introduction of the ordinance and then followed by the law, is creating great hardship in meeting the liquidity requirements in the businesses.The provisions of this Act were introduced with an intention of Banning the Unregulated Deposits Schemes like that of Mandalis. However, the interpretation of the existing statute results in a wider meaning thereby illegitimating the giving and accepting of unsecured loans. Hence, a suitable amendment be made to add, the providing of unsecured loans even between the non-relatives.

List of associations joined this protest:

001All India Transport Welfare AssociationDelhi
002Association Of Tax Payers & ProfessionalsUttar Pradesh
003All India Cotton Seed Oil Industries AssociationMadhya Pradesh
004Federation of All India Vyapar MandalDelhi
005Confederation of GST Professionals & IndustriesMaharashtra
006The Goods and Service Tax Practitioners’ Association of MaharashtraMaharashtra
007Maharashtra Chamber Of Commerce, Industries & AgricultureMaharashtra
008Haryana State Tax Bar AssociationHaryana
009Tax Consultants & Practitioners’ AssociationKerala
010All OdishaTax Advocates AssociationOdisha
011Karnataka State Tax Practitioners’ AssociationKarnataka
012Karnataka Taxpayers AssociationKarnataka
013Association Of Tax Payers & Professionals – BranchMadhya Pradesh
014Association Of Tax Payers & Professionals – BranchChhattisgarh
015Chhattisgarh Sales Tax Bar CouncilChhattisgarh
016The Rajasthan Tax Consultants AssociationRajasthan
017H.P. Tax Bar AssociationHimachal Pradesh
018Punjab Tax Bar AssociationPunjab
019Chhattisgarh Chamber of CommerceChhattisgarh
020Vitta Samnvaya SamitiRajasthan
021Kerala Tax Practitioners AssociationKerala
022Tax Practitioners Bar AssociationJammu Kashmir
023Tamandu Goods & Services Tax Professional AssociationTamandu
024Federation of Chhattisgarh Income Tax Bar AssociationChhattisgarh
025Jaipur Tax Bar AssociationRajasthan
026The Income Tax Bar Association,Chhattisgarh
027Tax Bar Association AmbalaPunjab
028GSTCORNORMadhya Pradesh
029The Tax Practitioners’ AssociationMaharashtra
030Tax Consultants Association of RaigadMaharashtra
031The North Maharashtra Tax Practitioners’ AssociationMaharashtra
032Tax Practitioners’ Association NashikMaharashtra
033Nandurbar District tax Practitioners’ AssociationMaharashtra
034The GST Practitioners’ AssociationMaharashtra
035Dhule District tax Practitioners’ AssociationMaharashtra
036The Income tax & Sales Tax Practitioners’ AssociationMaharashtra
037Amaravati Chamber of Commerce & IndustriesMaharashtra
038Bombay Metal Exchange Ltd.Maharashtra
039Tax Consultants’ AssociationMaharashtra
040Wardha Tax Bar AssociationMaharashtra
041GST Practitioner Association of SindhudurgMaharashtra
042Chartered Accountants Association, SuratGujarat
043The Beed District CA & Tax Practitioners AssociationMaharashtra
044Gondia Sales Tax Practitioners AssociationMaharashtra
045Kishanganj District Tax Professional AssociationBihar
046Palej Industrial Estate AssociationGujarat
047The Poona Merchants ChamberMaharashtra
048Dhule Vyapari MahasanghMaharashtra
049Tax Bar AssociationMaharashtra
050Gir Somnath Tax Bar AssociationGujarat
051Una Diu Joint Tax Practitioner AssociationGujarat
052Ratlam Accountants AssociationMadhya Pradesh
053GST Bar AssociationChhattisgarh
054Tax Bar Association AmaravatiMaharashtra
055Bhubaneshwar Tax Lawyers ForumOdisha
056Tax Consultant AssociationMaharashtra
057Sikar Tax Bar Association, SikarRajasthan
058The Mysore Division Tax Practitioners AssociationKarnataka
059Nag Vidarbh Chamber of CommerceMaharashtra
060Dist. Tax Bar AssociationOdisha
061CREDAI SangaliMaharashtra
062The International Association of Lions Clubs (Faridabad)Haryana
063Tax Practitioners’ Association, OsmanabadMaharashtra
064Tax Bar Association, Sagar (M.P.)Madhya Pradesh
065The Karad Tax Practitioners’ AssociationMaharashtra
066Dhenkanal Tax Bar AssociationOdisha
067Zila Tax Bar AssociationUttar Pradesh
068Nandurbar CPE Chapter of WIRC of ICAIMaharashtra

069Sangali- Miraj MIDC Manufacturers AssociationMaharashtra
070Sangali Chamber Of CommerceMaharashtra
071Tumkur District Tax Practitioners’ AssociationKarnataka
072Vijayapur District Tax Practitioners AssociationKarnataka
073District Tax Bar Association FaridabadHaryana
074Tax Practitioners’ AssociationMaharashtra
075Lucknow Chartered Accountants’ SocietyUttar Pradesh
076Nandurbar District Chemist & Druggist AssociationMaharashtra
077Chandigarh Tax Bar AssociationPunjab
078Dhule Oil Seeds Crusher AssociationMaharashtra
079Income tax Bar AssociationMaharashtra
080District Tax Bar AssociationPunjab
081Chitradurga District Tax Practitioners’ AssociationKarnataka
082Tax Practitioners’ AssociationMaharashtra
083Tax Bar AssociationChhattisgarh
084Tax Practitioners’ Bar AssociationMaharashtra
085The Tax Practitioner AssociationMaharashtra
086The Belgaum District Tax Bar AssociationKarnataka
087Kalburgi District Tax Practitioners’ AssociationKarnataka
088Bangalore Rural District Tax Practitioners AssociationKarnataka
089Tax Advocates Bar AssociationUttar Pradesh
090Jalgaon District Tax Practitioners’ AssociationMaharashtra
091Ambajogai Tax practitioners’ AssociationMaharashtra
092Tax Bar AssociationMaharashtra
093The Cuttack Tax Bar AssociationOdisha
094GST Practitioners’ AssociationPunjab
095Tumkur District Chamber of Commerce and IndustryKarnataka
096Kolhapur Chamber of CommerceMaharashtra
097Tax Practitioner Association IndapurMaharashtra
098Indapur Trade AssociationMaharashtra
099Tax Practitioner Association WashimMaharashtra
100Kolar District Tax Practitioner AssociationKarnataka
101Haveri Jilla Terige Salahegarara SanghaKarnataka
102The Pune Wholesale General Merchand AssociationMaharashtra
103Karsallagar Association Ratnagiri ZillaMaharashtra
104The Mandya District Tax Consultants AssociationKarnataka
105Davangire District Tax Practitioners AssociationKarnataka
106Bagalkote District Tax Practitioners AssociationKarnataka
107The Bidar Tax Practitioners AssociationKarnataka
108Vidharbh Chamber of Commerce and IndustriesMaharashtra
109Kalamb Shahar Building Material AssociationMaharashtra
110Kalamb Taluka Medical Practitioners AssociationMaharashtra
111Kalamb Tax Practitioners AssociationMaharashtra
112Shimoga District Chamber of Commerce and IndustryKarnataka
113Hassan District Tax Practitioners AssociationKarnataka
114Tasgaon Taluka Chemist and Drugist AssociationMaharashtra
115The Nasik Saraf Association, DharmakataMaharashtra
116Satara Saraf Association, SataraMaharashtra
117Ambejogai Taluka Krushi AssociationMaharashtra
118Commercial Taxes Bar AssociationJharkhand
119Federation of State Association of PuneMaharashtra
120Builders Association of India – Satara CentreMaharashtra
121Machin Tools Marketing Association , MumbaiMaharashtra
122Chandrapur Chamber of CommerceMaharashtra
123Satara Chemist & Drugist AssociationMaharashtra
124Hingoli Dist. Tax Practitioners AssociationMaharashtra
125Tax Bar AssociationHaryana
126Sambalpur Tax Bar AssociationOdisha
127Jamshedpur Chartered Accountant SocietyJharkhand
128The Tax Bar Association, BerhampurOdisha
129The Jalna CA CPE Study CircleMaharashtra
130Jalna Jilha Vyavari MahasanghMaharashtra
131Income Tax Bar Association LucknowUttar Pradesh
132JITO – Pune ChapterMaharashtra

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