GST Gains & Pains on Rates
Gains
Goods and Services of basic necessity are either exempted or charged to lower rates Standardized GST rates across all States Government open to consider representations from industry.
Pains
Multiple tax rates (12 including cess) as against the expectation and vision for a simple tax regime Classification issues due to multiple tax rates.
GST Gains & Pains : Registration
Gains
Majority of the taxpayers under various Indirect tax regime were successfully migrated to GST and the process of obtaining new GST registrations was also fairly smooth
Pains
No centralized registration option for service providersNo composition scheme for service providersFunctionality for registration by non-resident OIDAR service providers still awaited
Gains & Pains : Transitional Credit
Gains
The GST law allows transfer of entire eligible credit from previous law to GSTThe law also enable certain taxpayers to claim credit of goods in stock procured in past one yearFor ease of taxpayers, the due date for filing of TRAN-1 is extended up to 30 November 2017 and the taxpayers are also allowed to revise the transitional form once
Pains
Taxpayers faced cash flow issue during the first month of GST implementation due to delay in release of transitional formsThe facility for filing of TRAN-2 to claim deemed credit is not available yetFrom law perspective, there is ambiguity over carry forward of credit pertaining to various cess discharged under previous regimeSimilarly, taxpayers are not allowed to claim transitional credit of stock older than one year. This has been challenged and the writ petition is pending with Gujarat High CourtThe most upsetting aspect has been the letters issued by the tax department for verification of transitional credits
Gains & Pains : Compliance
Gains
Extension of due dates for return filingOption to file a simpler GSTR 3B (which will be followed by detailed return) in initial period of GST implementationValidations on GSTN portal to ensure sanitization of data to be filed prior to filing of return. This would help reduce lot of rectification and correctionsAuto population of data in GSTR 2A based on GSTR 1 of supplier; GSTR 3 based on GSTR 1 and GSTR 2 of the registered personNo late fee or penalty in case of delay in filing of first quarter GSTR 3B returnSingle interface and portal for all GST related activitiesFacility to upload data through various sources i.e. the offline utility, GST Suvidha Providers or manuallyReal time matching of inward and outward details for input tax credit
Pains
Significant increase in monthly compliances especially for service providersRequirement to upload invoice wise data in the returnLimit in file size and number of invoices that can be uploaded at a time (offline utility only works with maximum of 14 to 15k invoice entries even though the prescribed limit is 19k)If a return for a particular month is not filed, then taxpayers cannot file returns for all subsequent monthsLimited access to the GST Suvidha Providers (GSP)Site crash / downtime and automatic and unexpected log-offFunctionality for certain registrations (OIDAR etc.), advance ruling applications etc. still not available
Note –
Compliance has been time consuming and a major worry for the industry during the initial months GST Network is the IT backbone of Government and hence, the success of GST is entirely dependent on preparedness and functioning of GST Network
