Interaction with Members of BCAS Author : GSTN Team Date : 8 th - - PowerPoint PPT Presentation

SLIDE 1

Interaction with Members of BCAS

Author : GSTN Team Date : 8th August, 2018

SLIDE 2

GST IT Strategy

• Core Services

– Registration – Returns – Payments

• Helpdesk support
• Information on Inter-State supply

and cross-credit utilization

• Analytics
• IGST Settlement

Common & Shared IT Infrastructure Harmonization of Business Processes and Formats Centre/States Tax IT Systems

Aut Autonomy of

• f back

back-end syste ystems of

• f

St Stat ates and and Ce Centre

• Approval of Registration
• Assessment
• Refunds
• Audit and Enforcement
• Adjudication
• Internal workflows to support

above functions

• Recovery
• Analytics and BI

St Statutory ry Func Functions

Non-Statutory Functions

IT T Inte nterfaces

Front-end Back-end

SLIDE 3

A Complex Software like GST is like a High Rise Building

Attributes High Rise Building Complex Software Architecture

√ √

Detailed planning

√ √

Grounds up

√ √

Minor changes Possible Possible with less cost and time Major Change as after thought Not possible Possible but with lot

• f cost and time

Can more workers and machines expedite work Marginally Marginally Visibility as it gets constructed Yes No

SLIDE 4

The Journey of GST

June 2016 Publication of First Draft of Model GST Law Sept 2016 Publication of Rules for Registration, Return, Payment, Invoice and Refund 13th Jan ‘17 Removal of deficiencies in Composition and Registration Rules May 2017 Soft launch of Registration, Payment and Return 28-30 Dec 2016 Revisit of Registration, Payment, Composition and Refund Rules 4th March ’17 CGST and IGST approved by GST Council April 2017 6 Rules finalized, remaining 5 to be finalized by 10th May End June 2017 Final Rules/ Formats were made available 26th Nov ’16 Publication of Revised Draft of Model GST Law v 25th Jun ‘17 Rollout of GST Portal – New Registration and Payment

8th Nov 2016 Migration started

1st July 2017: launch

• f GST

SLIDE 5

GST System – Overall Stats (7th August 2018)

Functionalities Counts

Number of Returns Filed till date

13.76 Crore

Number of Invoices Processed

412.9 Crore

Number of Payments Transactions

4.7 Crore

Number of Migrated Taxpayers (net of cancelled) 63.07 Lakh New Registration Approved 50.31 Lakh Taxpayers Opted for Composition 17.7 Lakh GSTP Enrolled so far on GST Portal (applications filed) 87,636 Highest Return Filing in one day (20th Nov ‘17 and 20th July ‘18) During the peak load, the server utilization was 27% only. 18 Lakh Highest number of Payment transactions in one day ~800,000 E-Way Bill Issued 16.5 Crores (since 1/4/18) Maximum number of e-way bills in a day (13th June) 19.77 Lakhs

SLIDE 6

GST System – GSTR-3B Filing Compliance Stats

Returns Filing Eligible Filed till Last day of Filing % on Last date of Filing Filed till 2nd Aug 2018 % of Filing till 2nd Aug 2018 Jul-17

74,61,214

38,34,877 51.40%

63,47,445

85.07% Aug-17

75,32,807

27,25,183 36.18%

68,84,809

91.40% Sep-17

79,25,831

39,34,256 49.64%

71,95,036

90.78% Oct-17

81,54,303

43,68,711 53.58%

69,55,070

85.29% Nov-17

79,92,517

49,13,065 61.47%

69,92,107

87.48% Dec-17

81,82,277

54,26,278 66.32%

70,36,793

86.00% Jan-18

83,63,437

53,94,018 64.50%

70,89,031

84.76% Feb-18

85,45,661

54,51,004 63.79%

71,39,288

83.54% Mar-18

87,08,493

52,83,962 60.68%

71,22,257

81.79% Apr-18

88,17,798

56,38,813 63.95%

70,51,766

79.97% May-18

91,22,309

56,18,925 61.60%

70,21,817

76.97% Jun-18

93,16,710

58,39,034 62.67%

67,54,169

72.50% Jul-18

94,70,282

N.A. N.A.

2,02,945

2.14%

10,00,000 20,00,000 30,00,000 40,00,000 50,00,000 60,00,000 70,00,000 80,00,000 Jul-17 Aug-17 Sep-17 Oct-17 Nov-17 Dec-17 Jan-18 Feb-18 Mar-18 Apr-18 May-18 Jun-18

GSTR3B Return Filing Compliance

Filed till Last day of Filing Filed till 2nd Aug 2018

SLIDE 7

GST System – GSTR-3B Filing Compliance Stats

0.00% 10.00% 20.00% 30.00% 40.00% 50.00% 60.00% 70.00% 80.00% 90.00% 100.00% Jul-17 Aug-17 Sep-17 Oct-17 Nov-17 Dec-17 Jan-18 Feb-18 Mar-18 Apr-18 May-18 Jun-18

GSTR 3B Filing Compliance Last date of filing vs as on date

% on Last date of Filing % of Filing till 2nd Aug 2018

SLIDE 8

GST System – Filing of GSTR-1 Compliance Stats

* Last date of July GSTR-1 was extended till 31st Dec

Returns Period GSTR-1 Eligible GSTR-1 Filed % GSTR-1 Filed July'17 74,61,214 57,98,006 77.7% August'17 32,60,937 23,46,532 72.0% September'17 79,25,831 63,24,130 79.8% October'17 34,38,891 23,87,357 69.4% November'17 31,26,495 23,99,718 76.8% December'17 81,82,277 61,98,977 75.8% January'18 32,29,377 23,08,524 71.5% February'18 32,74,028 22,63,381 69.1% March'18 87,08,493 58,40,908 67.1% April'18 44,96,316 21,56,890 48.0% May'18 46,82,345 20,75,267 44.3% June'18 93,16,710 28,08,442 30.1% July'18 47,75,626 88,815 1.86%

10,00,000 20,00,000 30,00,000 40,00,000 50,00,000 60,00,000 70,00,000 80,00,000 90,00,000 1,00,00,000

GSTR-1 Return Filing Trend

Eligible Returns Filed till 5th Aug., 2018 Linear (Returns Filed till 5th Aug., 2018)

SLIDE 9

Refund

Export with IGST Paid, as on 7th August, 2018 Data Transmitted to ICEGATE IGST CESS Invoice Count GSTR Count

1 Total Transmission to

ICEGATE 34102.13, Cr 197.57 Cr 18,74,251 77,240 Data Not Transmitted to ICEGATE IGST CESS Invoice Count GSTR Count

2 Due to Negative Balance

2213.07 Cr 2.15 Cr 1,79,834 12,003 Due to Transmission Error 2.47 Cr 293 13

SLIDE 10

Some Observations

• 1. There are taxpayers who are consistently filing returns late
• 2. 2.52 lakh migrated taxpayers have not filed any return
• 3. Many are still showing different liability in GSTR-1 and GSTR-3B
• 4. The gap between ITC claimed in GSTR-3B and that accruing from GSTR-2A still

persists

• 5. GSTR-1 filing is behind GSTR-3B
• 6. ITC utilised lower than ITC availed. Why is it being kept? If it is ineligible ITC, it

should be declared so that it can be settled.

• 7. Compared to the count of Composition taxpayers (18 lakhs) the cash paid by them

is small.

• 8. Taxpayers have prepared eway bill but have not filed GSTR-3B

SLIDE 11

Taxpayer Segmentation 2015-16 Vs 2017-18

0.00% 10.00% 20.00% 30.00% 40.00% 50.00% 60.00% 70.00%

Upto 20 Lakhs 20 Lakhs to 1.5 Crores 1.5 Crores to 3 Crores 3 Crores to 5 Crores 5 Crores to 10 Crores 10 Crores to 100 Crores 100 Crore and above

Percentage of Total (GST) 2017-18 Percentage of Total (VAT/ST/CE) 2015-16

Turnover SLAB Percentage of Total (GST) 2017-18 Percentage of Total (VAT/ST/CE) 2015-16 Upto 20 Lakhs 52.24% 60.40% 20 Lakhs to 1.5 Crores 31.12% 26.69% 1.5 Crores to 3 Crores 6.57% 4.58% 3 Crores to 5 Crores 3.36% 2.58% 5 Crores to 10 Crores 3.05% 2.37% 10 Crores to 100 Crores 3.28% 2.91% 100 Crore and above 0.39% 0.47%

SLIDE 12

12

e-Way Bill System – Overall Stats

Functionalities Counts Total e-Way Bills generated till from 1st April till 10th July, 2018 16,41,99,397 Count of Inter State e-Way Bills 8,27,58,983 (50.40%) Count of Intra State e-Way bills 8,14,40,414 (49.60%) Highest number of e-Way bill generated in a day 21,77,002 (on 31st July) Number of Tax payers registered with e-Way bill system as on Date 22,89,271 Number of Transporters registered with e-Way bill system as on Date 29,385

April, 2018, 2,79,96,004 May, 2018, 3,72,31,666 June, 2018, 4,67,65,199 July, 2018, 4,42,10,436 Aug, 2018, 79,96,092

• 50,00,000

1,00,00,000 1,50,00,000 2,00,00,000 2,50,00,000 3,00,00,000 3,50,00,000 4,00,00,000 4,50,00,000 5,00,00,000 April, 2018 May, 2018 June, 2018 July, 2018 Aug, 2018

Monthwise e-Way Bill generation

Intra State Inter State Total

SLIDE 13

Hourly Filing of E-Way Bill

0.90% 0.76% 0.63% 0.54% 0.48% 0.43% 0.43% 0.62% 0.95% 2.09% 4.56% 6.50% 7.36% 6.41% 6.94% 8.61% 10.20% 10.93% 10.08% 8.23% 5.71% 3.40% 1.95% 1.28%

0.00% 2.00% 4.00% 6.00% 8.00% 10.00% 12.00% 01:00 Hours 02:00 Hours 03:00 Hours 04:00 Hours 05:00 Hours 06:00 Hours 07.00 Hours 08.00 Hours 09.00 Hours 10.00 Hours 11.00 Hours 12:00 Hours 13:00 Hours 14:00 Hours 15:00 Hours 16:00 Hours 17:00 Hours 18:00 Hours 19:00 Hours 20:00 Hours 21:00 Hours 22:00 Hours 23:00 Hours 24:00 Hours

April: Hourly Generation of e-way Bill

SLIDE 14

14

e-Way Bills Generated – Top 10 States

Top 10 States on Total Number

• f EWB

Top 10 States for Inter-State EWB Top 10 States on Intra-State EWB Maharashtra Gujarat Maharashtra Gujarat Maharashtra Karnataka Haryana Haryana Uttar Pradesh Karnataka Tamil Nadu Haryana Uttar Pradesh Delhi Tamil Nadu Tamil Nadu Karnataka Gujarat Rajasthan Uttar Pradesh Andhra Pradesh Delhi Rajasthan Rajasthan Punjab Punjab Punjab Andhra Pradesh West Bengal Kerala

SLIDE 15

Challenges Faced

• 1. Capacity building of multiple stakeholders (mammoth task of Change

management)

• 2. Getting stakeholders to align the business processes with technology

solution and remove redundant processes and steps.

• 3. Workflow driven return system, which was not accepted by the

taxpayers and tax consultants

• 4. Paradigm shift in working of taxpayers: Huge resistance in going from

paper + electronic mode to 100% electronic mode.

• 5. Complexity of law and operations.
• 6. Flexibility, scalability and security -System has to be flexible to meet the

ever changing requirements and needs. At the same tine secure and scalable

• 7. Peoples behavior: to do things at the fag end of period.
• 8. Building the ship while it is sailing.

SLIDE 16

GSTN is not mandated to provide clarification on Law

• matters. The clarification to questions asked are with

respect of GST Software designed and its functionalities CAVEAT

SLIDE 17

• 1. While making core and non-core field amendment application, system is rejecting application because
• f pan mismatch of existing directors. Even if we modify existing director details system will still show

the same error. Thereby creating a loop.

Ans: While performing non-core/core amendment (Name of Director/Name of Authorized signatory/Legal Name as per PAN) need to be provided as per CBDT (Central board of Direct Tax) database to avoid PAN mismatch error. In this context, it is relevant to mention that Change in PAN can be done through core amendment (add/delete) while change in other details are editable through non- core amendment.

Registration

SLIDE 18

2. Authorised signatory related issued:

(i) Death of proprietor: When GSTIN is to be cancelled, submission of application happens through DSC of proprietor or OTP sent on EVC through registered mobile or e-mail id of proprietor. In such a case to accept application as e-signed by deceased proprietor is legally wrong. If cancellation application is to be submitted, it has to give drop box for sign of proprietor [in case business is discontinued] or legal heir [in case of death]. ANS

• 1. In case of death of sole proprietor, legal heir has to visit office of the proper officer (jurisdiction officer) and submit the death certificate of the sole

proprietor along with the succession certificate before the proper officer as documentary evidence.

• 2. Proper officer will add legal heir as the authorized signatory on the GST Portal.
• 3. Username and Temporary password reset will be communicated to the e-mail address of the newly added authorized signatory as entered by the tax officer
• f your jurisdiction. Next, the newly added authorized signatory need to login to the GST portal available at https://www.gst.gov.in/ and login using the first

time login link. He/ She will be forced to change his/her username and password after first time login with the username and temporary password that was emailed on the newly added e-mail address of the Primary Authorized Signatory.

• 4. Legal heir has to apply for new registration on the his/her PAN.
• 5. Once the new registration is approved, legal heir has to apply for the transfer of ITC by filing FORM GST ITC–02 to new entity.
• 6. Legal heir or his/ her authorized signatory has to submit the application for cancellation in Form GST REG-16 (ref step 3 GSTIN) and select the “Death of

Proprietor” as reason of Cancellation of Registration and attach sufficient proof.

• 7. Also refer paragraph 4(c) Schedule –II appended with the Act.

SLIDE 19

• 3. Resignation of authorised director.

In second instance, When GSTIN data base is to be deleted/ amended due to change of Board of directors; amendment takes place only through DSC of retired/deceased director. This situation like one above has to be avoided. GSTN: In case of single director as authorised signatory, the necessary updation can be done by the jurisdictional officer as mentioned below:

Ans

Authorized signatory has to visit office of the proper officer (jurisdiction officer) and submit the documentary evidence related to addition of new authorized signatory (Authorization letter) Proper officer will add new authorized signatory on the GST Portal. Username and Temporary password reset will be communicated to the e-mail address of the newly added authorized signatory as entered by the tax officer in your jurisdiction. The newly authorized signatory so added need to login to the GST Portal available at https://www.gst.gov.in/ and login using the first time login link. He/ She will be forced to change his/her username and password after first time login with the username and temporary password that was emailed on the newly added e-mail address of the Primary Authorized Signatory. Post Login, please Go to My profile->register/update DSC for performing further activities related to registration/return etc.

SLIDE 20

• 4. Amendment to Registration - PAN Validation issue:

Sometimes when application for amendment is submitted, it gives error that PAN of promoter/one of the promoters is mismatch with Name in PAN data base. It directs the applicant to correct the error and then proceed. But, when application is opened up for correction, then it does not allow editing the Name of promoter. One has to compulsorily delete the name, then only application proceeds. It also does not allow simultaneous correction to be made. As soon as same PAN and correct name with

• ther details is keyed in, on attempt to save the data, it gives error that same PAN is

already on the record.

Ans: While performing non-core/core amendment (Name of Director/Name of Authorized

signatory/Legal Name as per PAN) need to be provided as per CBDT (Central board of Direct Tax) database to avoid PAN mismatch error. In this context, it is relevant to mention that Change in PAN can be done through core amendment (add/delete) while change in

• ther details are editable through non- core amendment.

SLIDE 21

• 7. We have opted Quarterly filing option for GSTR-1 for F.Y. 2018-19 as

company's turnover is below 1.5 Cr. at the beginning of the filing of GST returns for F.Y. 2018-19. Accordingly, GSTR-1 return was freeze in the month of April, 2018 and May, 2018. But now suddenly without intimating to the company, GST site showing monthly GSTR-1 return filing option instead of quarterly filing option for F.Y. 2018-19.

ANS: Option to opt Quarterly/Monthly filing option can be changed as many times till the time none of the return has been filed for the same FY. Post filling option which has been selected earlier cannot be reverted for that FY. System does not change the option at its own.

RETURNS

SLIDE 22

• 8. Multiple month data amendment in GSTR 1 for B2C. There is no such restriction in the Act
• r Rules, yet, portal allows to amend GSTR 1 related data for only one month in any

particular return. ANS: Amendment in table 10 for B2C amendment has no such restriction to amend information reported in earlier months.

• 9. GSTR-3B should allow negative entries. For instance, if in a particular month, there is only

credit notes in outward supplies, the portal does not allow input of negative value in GSTR- 3B. ANS: The credit notes can be adjusted with the liability of current month. If there is no liability in current month, the liability can be adjusted in the next month. Allowing negative amount has also the same effect i.e. to carry the excess credit forward for adjustment in the next month’s liability.

RETURNS

SLIDE 23

• 10. If an B2B billing is shown as B2C billing in GSTR3B and also in GSTR1, how the

said error can be rectified if receiver of supply wants to claim the input credit. In current months, the B2C is not so much that we can adjust the same in GSTR3B. 1) Is there any option/way by which one can reduce the B2C amount to B2B AMOUNT. 2) How will the receiver of supply get the Input credit as it will never appear in their GSTR2A. 3) What is the implication on my client’s liability if they accept the invoices uploaded by the B2B clients in GSTR2. Please throw light on same. ANS: In GSTR-3B, liability is reported in a consolidated manner for B2B and B2C in table 3.1. B2C transactions reported in table 3.2 of earlier month can be adjusted with the subsequent months, in GSTR-1, B2C (large) are reported invoice wise, therefore, it cannot be converted to B2B. For B2C (small), there is no check in the system.

RETURNS

SLIDE 24

RETURNS

1.What is the mechanism to rectify the mistake while filing the returns specially if any mistake has been done in the last return of the Financial year. ANS: The return mistake done in last return of FY can be rectified in any subsequent month of Next FY till September.

SLIDE 25

RETURNS

GSTN: (i) Amendment of information can be done in the returns of next financial upto Sept or filing of annual return whichever is earlier. Allowing payment with Annual return is a policy matter and may be taken up with Govt. accordingly.

• 12. Clarity in respect of transactions which were not recorded in the returns of financial year 2017-2018:

Under the existing GST provisions, revisions of returns are not permitted and hence, if any error or omissions taken place during the filing of returns have to be rectified in the next / succeeding months return. We seek clarification in respect of following eventualities – (i) Outward or Inward supplies are not recorded in the returns filed for F.Y. 2017-18, whether such transactions need to be recorded while filing returns in the F.Y.2018-19? (ii) Section 44 of CGST Act, 2017 read with Rule 80 of CGST Rules, 2017 provides for filing of “annual return” by taxable person on or before 31st December following the end of such financial year. Whether omission / mistakes as pointed out in sub clause (i) is required to be disclosed in “annual return”? (iii) Section 37 (Furnishing details of outward supplies), Section 38 (furnishing details of inward supplies) and Section 39 (Return) that any

• mission / mistakes happened while filing returns, rectification can be done after furnishing of the return under section 39 for the month
• f September following the end of financial year to which such details pertain, or furnishing of the relevant annual return, whichever is

earlier. Accordingly, tax payers who had not rectified errors while uploading the returns for the F.Y. 2017-18, he has an option either to rectify such errors before 30th September 2018 or in the annual return which needs to be filed on or before 31st December 2018, off course by paying tax and interest. Such correction of mistakes / omissions in the next years return will create lot of problems in reconciliation of turnovers in the financial statements.

SLIDE 26

• 13. Correction of selection of periodicity for filing return of outward supply:

For the financial year 2018-19, GSTIN portal have provided facility to select an option to file the return of outward supplies either monthly or quarterly, in the month of April

• 2018. Many tax payers have committed an error while selecting the option of monthly

and quarterly options leading to a circumstance that though they are eligible to cover under quarterly, because of error in selection, they are now mandatorily file monthly

• returns. How to resolve this issue?

Usually this mistake is realised when dealer goes to upload quarterly return. Thereafter, when monthly returns for first two months of quarter are uploaded, they are late and would attract late fee just for simple clerical error. ANS: Edit option has been given for change in quarterly to monthly if no return has been filed for the originally selected option.

RETURNS

SLIDE 27

RETURNS

14. System driven Auto email of Full Return Filed: A copy of the Full GST Returns filed by the assessee should be emailed automatically by the GSTN System to the registered email id of the assessee within 30 days of filing. The 30 days window is suggested so that the system is not clogged on the deadline dates. This will be helpful for the company, its Auditors and for submission to income tax and other

• authorities. Further the automatic emails will reduce the load on GSTN as

assessees will not login to view the filed returns. Incidentally, in the Income Tax e-filing system, the ITR and Tax Audit Report filed is immediately available for download as a PDF with Government watermark. ANS: Return under GST is also available as PDF download. The taxpayer can download the same. Benefit of return being sent by email is not clear.

SLIDE 28

RETURNS

15.

Extract of GSTR1 for particular GSTIN: A report should be available from GSTN System which gives an extract of GSTR1 filed with respect to a particular GSTIN. If the assessee has not received the input credit in GSTR2A, there is no way in which he can verify that the vendor has filed GSTR1 with his invoice details. The GSTR1 can have voluminous data which a vendor may not be willing to share with assessee. In such cases the GSTIN-wise / Vendor-wise reports of GSTR1 can be evidence and can be used by the assessee to file credit mismatch error on GSTN. A GSTIN-wise / Vendor-wise extract of GSTR1 on an annual basis could be useful for Audit and other purposes also.

ANS: Will be considered for feasibility to make the information

• available. Some more info on format will be needed. Other way is to

match GSTR-2A with Purchase Register

SLIDE 29

• 16. Many times, error reports generated after uploading data for filing returns are not clear and

does not say/indicate what is wrong or what needs to be done. The error report should generate specific errors and suggest action to be taken.

ANS: The errors related to upload data can be rectified and corrected through below steps: Step 1 – Login on to the GST Portal Step 2 – Then, go to ‘Services’ > ‘Returns’ > ‘Returns Dashboard’ Step 3 – Select the Month and Year from the drop-down. Step 4 – Click on ‘Prepare Offline under GSTR 1 Step 5 – Under ‘Upload’ tab and click on ‘Generate Error report’. This request takes around 20 min. Step 6– Now, click on ‘Click Here’ to download link. A ZIP file will be downloaded. Step 7 – Open the file using the GST offline tool by clicking on OPEN under Open Downloaded Error file from GST portal Step 8 - Navigate to corresponding section By Clicking on Hyperlink Step 9 – Error related to data will be available in column “Error Message” Step 10 – Do the correction accordingly, generate the JSON and upload the same to GST portal

RETURNS

SLIDE 30

• 17. In case of exports without payment of tax, refund is to be

claimed by filing a Refund application. However, claim of refund is restricted to ITC of that particular month only. Thus, in cases where there have been no exports in a particular month, portal does not allow claim refund of ITC for said month. Para 11.2 of Circular 37/11/2018 mentions that consolidated refund application can be filed by the assessee but same facility is not available on portal as of today. Reply: The provision for filing multi tax-period refund application is under testing and is expected to be made available on the portal in next two weeks.

REFUND

SLIDE 31

• 18. The portal should allow for filing of refund application for
• ther cases as well (for instance, where tax payment is under

protest, where tax liability was disclosed erroneously in GSTR 3B and hence, had to pay the same (before introduction of amendment facility) Reply: The other reasons basis which refund can be claimed, as mentioned in the notified form GST RFD-01, is also at advance stage of development and should be rolled out in a phased manner shortly

REFUND

SLIDE 32

• 19. Refund Application for Credit of ITC can be made Monthly or Quarterly
• r for any period, however on the site one can file only Monthly

Applications. Reply: This will get provisioned on GST Portal once multi tax-period refund filing is made available.

• 20. Whether all B2B Invoice details needs to be given Invoice wise even for a supplier

who is engaged in export of exempted goods only and for production of such goods he uses the taxable capital goods and other taxable input and wants to avail the taxes on input and capital goods as credit against domestic taxable supplies in GSTR-1 although he is not claiming any refund or he can give an aggregate figure in exempted interstate supplies? Reply: The refund form requires disclosure of invoice level details only related to refund

REFUND

SLIDE 33

• 21. Registered person has provided export of services with payment of Integrated tax under section

16(3)(b) of IGST Act, 2017. An application is required to be made in Form GST RFD-01A in order to claim refund of integrated tax paid under section 16 (3)(b) of IGST Act, 2017. However, while filing GSTR-3B, they have inadvertently depicted the transaction against column 3.1(a) instead of column 3.1(b). Due to erroneous depiction of the transaction as stated above, the GST portal is not permitting to make online application and displaying error as “No outward supply tax (Integrated Tax\Cess) filed for the selected return period”. Attention is invited to Circular No. 45/19/2018-GST issued in CBIC website on 30th May, 2018. The aforesaid circular states that while filing return in FORM GSTR-3B if registered person commits error by depicting their zero-rated supplies in column 3.1(a) instead of 3.1(b) then such registered person shall be allowed to file the refund application in FORM GST RFD-01A on the common portal. Till date effect of the above circular is not given in the GST portal. As a result, registered person is unable to file online application for refund even after issuance of above mentioned circular. Reply: We will get back

REFUND

SLIDE 34

• 22. Point 14.2 of Circular No.37/11/2018-GST issued on 15th March, 2018 provides for list of documents required

for processing the various categories of refund claims on exports wherein one of the documents is BRC / FIRC for export of services. Thus, in order to avoid rejection of refund application, registered person is filing refund application

• n receipt basis. Say for Example Registered person filing refund application for a particular period (say, March 2018)
• n receipt basis for which invoices have already been issued and shown in GSTR – 1 and GSTR – 3B of earlier periods

(say, July 2017 to February 2018). Thus, in the given case, refund amount of IGST shown in refund application of a particular period (say, March 2018) is in excess of IGST amount of GSTR – 3B of that period (say, March 2018). However, at the time of filing online refund application on receipt basis on the GST portal, error is appearing that “the Refund amount claimed (Integrated Tax/ Cess) should not be more than the amount of Integrated Tax /Cess mentioned in Zero-rated supplies of GSTR-3B item 3.1(b) filed for the period.” When contacted helpdesk for the above issue, it has been informed to us to file online refund application on invoice

• basis. However, if refund application is filed on invoice basis, then corresponding BRC / FIRC cannot be submitted

unless and until payment is received by us. Please suggest.

Reply: Will be solved with multi-period refund application which is likely to be rolled out

this month.

REFUND

SLIDE 35

• 23. Supplies to EOU are deemed exports under GST on receipt of Form A

from EOU. In such cases there is an option for supplier to pay tax and claim

• refund. How should supplier of EOU file refund application? Manual

application is not accepted by GST officer in absence of ARN. Reply: The provision of filing refund application for AF-13: Refund for the supplier of deemed exports is under testing and is expected to be made available on GST portal in 2-3 weeks. Once available, taxpayers will be able to file refund application under this category.

REFUND

SLIDE 36

• 24. What is the remedy if one has shown zero rated supply on payment of IGST in

column 3.1.a instead of 3.1.b. GSTR 3B is not matched with GSTR 1 and thereby data is not pushed to customs database and hence refund of IGST paid on exports is stuck? Reply: As per customs circular 12/2018, the policy wing of customs is validating such cases by comparing the total IGST declared under GSTR-1 with total IGST paid under GSTR-3B. In case sufficient payment has been made, customs policy wing shall forward recommendation to process the held up invoices as per para 3A of this circular. In case there is a shortfall, taxpayer should fulfil the deficiency by paying the difference in next GSTR-3B and submit CA certificate to custom port officer as per para 3B of this circular, post which customs policy wing shall forward recommendation to process the held up invoices.

REFUND

SLIDE 37

• 25. Lots of issues in ITC 04 job work return. For Eg., Amounts inserted in offline utility and when uploaded online generates

abrupt summary with wrong totals at main page. Reply: This generally happens when summary generation of previous request is in progress. New summary takes anywhere between 1 min to 15 mins depending on the size of uploaded data or number of uploads in the queue. This is however, now corrected.

• 26. ITC-04 return is not yet stable. Data not filled in/keyed in by the dealers also appears when off line tool is uploaded. The data

which appears in sheet 4 and 5 cannot be viewed or edited. The returns are not getting uploaded due to this fault. Reply: This was an issue in the beginning when ITC04 was just enabled on GST Portal. This was fixed in a new release in Feb 2018. Please use the new offline tool made available on the portal. If there is a specific issue, may please send us individual details and we can investigate.

• 27. ISD Return - GSTR 6 does not include Tax paid u/s 9 (RCM). How to incorporate the same ?

Reply: GSTR-6 and GSTR-1 are getting delinked such that the invoices uploaded in either of the return will not auto- populate in each return. Taxpayers may declare their own respective invoice in their own return, including RCM invoice and claim ITC. Feature is due to be rolled out before end of this month.

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• 28. While filing ITR 1 it is observed that it takes lot of Time for uploading data. Many times data of Invoices uploaded is not visible or lost and one

has to wait for a longer to see the data already uploaded. Reply: When the GSTR-1 is uploaded, system performs series of validations such as duplicate invoices, validity of GSTINs included, taxpayer status etc. Later, system also updates many other audit data elements. Thus this process takes anywhere between 2 min to 20 mins. There are some specific failures scenarios where data uploaded blocks the processing of data. In such cases, after a specific time period, the status of uploaded data is set to

• error. We have been continuously improving the processing and such instances have now reduced. The average time taken for processing of uploaded

invoices has been around 6 mins.

• 29. Why the Portal related issues are not answered within a reasonable time frame ?
• 30. Somewhere from 21st-22nd July 2018, GSTN portal displays due date of GSTR-1. It does not differentiate periodicity and difference in due dates.

For June 2018, in case of Monthly return due date was 10/07/2018 and for quarterly Return filers it was 31/07/2018. But due date was displayed as 10/07/2018 generally across the board for all return filers. Reply: This is being corrected as we speak.

• 31. The effectiveness of Portal in last couple of days is a challenge and lot of time is taken to upload a Return. Please look into the same.

Reply: We had specific issues on particular days, like in January, March and July due to issues with Hardware and an external factor. We have taken corrective actions to ensure smooth filing experience for our taxpayers.

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