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March 8, 2021

13 Suggestions of Changes in GST by All India MSMEs and Tax professional association

by CA Shivam Jaiswal in GST

13 Suggestions of Changes in GST by All India MSMEs and Tax professional association

Copy of Letter of Request to FM from All India MSMEs and Tax professional association

Honorable Finance Minister,

Govt. of India, New Delhi.

Respected Madam

It has been more than 3 years since GST was implemented in India but still dealers and professionals are having so many problems with GST and related processes. It is still not a smooth taxation system as it was desired when GST was introduced in 2017 in the country.

Respected Madam GST was brought in India for simplification of indirect tax system and we Still under your leadership should continue to work for simplification of GST and we are hopeful that GST will achieve its simplified form during your tenure.

We are presenting following suggestions to you, which if you and under your dynamic leadership the GST Council implement then GST will become simple Tax and it will make positive and desirable contribution to India’s economy: –

1. An opportunity should be given to the dealers to rectify the mistakes and also give the facility to revise the returns.

2. Late fees should be waived and for future its limit should be fixed. It should not be more than the Net Tax Payable by the dealers.

3. All the penal provisions should be suspended except for penal provisions related to evasion of Tax.

4. There should be Lower rate of interest for delayed payment of Tax and other payments. The rate of interest of 18 percent and 24 percent interest is very high considering the economic conditions prevailing in the country at present and further current interest rate in force in the country in other sectors.

5. The number of changes, amendments and experiments should be kept in Limited number now. So many changes are creating lot of confusions amongst the dealers and tax payers.

6. If any facility like QRMP is given then there should be a scheme that if any dealer wants to go for the scheme can choose it instead of converting all the dealers in the scheme and then give dealers an option to opt out of the scheme. It is not a practical or natural way to introduce an optional scheme. It has created lot of confusions and lot of dealers has to follow the scheme without any intention and usefulness of the scheme for them.

7. Keep the practical date of e-invoicing 1 April 2021. Many dealers, especially those from far flung and remote areas and small towns have not been able to follow it and implement it with in time due to lack of practical knowledge and facilities available to them.

8. The checking of e- way bill should be done in a practical manner and the dealer’s side should also be taken care of for technical and clerical errors and defects in a-way bills. Further if other evidences and documents are properly available with the vehicle then these should also be taken care of before taking any action against the dealer.

9. GST Help desk should be made more helpful and equipped with the expertise to solve the problems. There should be a comprehensive and quick system to solve the dealers’ problems.

10. The burden of mismatch should be shifted to the Sellers side instead of blocking the ITC of purchaser if the Purchaser has proper Invoices and payment is also made by the purchasers.

11. The seller should be empowered to withhold ITC if payment is not received by him from the purchaser. At present it is the purchaser who has to reverse the ITC if he has not made the payments to the seller. This is not the practical solution.

12. Limit the number of circulars, notifications and changes. With constant changes, this law is becoming increasingly difficult to follow and making the situation more confusing.

13. 2021-22 should be declared as GST REFORM YEAR and all the Law-Making Machineries should work accordingly to achieve this goal.

Your Good self is therefore requested to please take care to implement the above suggestions so that Trade, industry and profession will faceless problems in following GST and it will give great relief to them.


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