Sl.
No.
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Subject/Module
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Issue
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Suggestion
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Rationale for suggestion
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1.
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HSN wise details
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The HSN wise tax on taxable sales details should tally up to paise
otherwise it does not end the task at present since the figures in Form GSTR-3B are up to rupees resulting into mismatches in turnover and tax as per GSTR-1 and GSTR-3B.
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It is suggested to provide the figures of turnover and tax in rupees only, in GSTR-1 and
GSTR-3B. This would also be in line with the provisions of
section 170 of the CGST Act, 2017 which requires rounding off of tax, interest, penalty, fine or any other sum payable, and refund or any other sum due to the nearest rupee.
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This will avoid irrelevant mismatches.
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2.
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Tables 4A,4B, 4C, 6B, 6C – B2B
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The outward supplies under RCM are currently required to be entered in the tables 4A,4B, 4C, 6B, 6C – B2B. Tick box is to be filled if the supply is in RCM. The summary of value of supplies and output tax payable on the face of the table are inclusive of RCM liability, if any. It makes it difficult to verify the actual output tax payable & RCM supplies from the face of the table. It is difficult to identify RCM supplies from the face of the table as it is clubbed with other supplies.
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It is suggested to put up a separate table exclusively for
RCM supplies so that it is not clubbed with other supplies. So that it will be easy to directly verify the RCM supplies from face of the table.
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The above change will reduce errors in the data entry
regarding RCM as it can be identified immediately from summary shown on the face of the table.
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3.
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HSN summary
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Auto-population of HSN summary in GSTR-1 not available for taxpayers who are eligible for e-invoicing.
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It is suggested to provide the facility of auto-population of
HSN summary in GSTR-1 for e-invoice eligible taxpayers.
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It will facilitate ease of compliance for the taxpayers.
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4.
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GSTR-1: B2C Sale
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Portal does not allow change of B2C sales more than once.
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It is suggested that some sort of a facility which would allow
conversion of B2C sale to B2B sale should be given.A lot of times, due to absence of GSTN, inadvertently B2B sales are reported as B2C and the recipient does not get input tax credit. If some sort of ledger confirmation utility is given so as to convert these B2C sales to B2B akin to what is available in VAT Regime in Maharashtra a lot of these problems would be solved.
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The genuine buyer should not be prejudiced because of a
minor mistake of the supplier.
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5.
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Amendment of
B2B invoice
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In Form GSTR-1 of March 2021, sale invoice dated 31/03/2021 included as 31/03/2020 and return was filed. After few days the mistake of date came to notice but we are unable to amend the B2B bill as for the FY 19- 20, it was freezed by the GSTN.
Similar issue is also faced at the beginning of any new year, mostly in the month of January when it takes time for a taxpayer to get accustomed to the new date. So if by mistake he puts date of previous year, he is deprived of the facility to amend the GSTR-1 thereby depriving the ITC to the recipient.
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It is suggested that GSTN should also allow to amend B2B invoices within 6 months period from the date of uploading of invoices in case of freezed financial years.
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This is a clerical mistake. Even after few days of uploading, we are unable to amend the
invoices. It will cause injustice to the taxpayers.
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6.
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Issues in GSTR-1, 2A, Integration, New Tools Required
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1. Downloading of details pertaining to GSTIN from GSTR-1
2. Bulk details of PAN based turnover in order to integrate with section 194Q of the Income-tax Act
requirements
3. Bulk verification tools for GSTR-1, GSTN status under GST, E-way Bill
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It is suggested to provide bulk verification tools which is being offered by GSP’s. If the same are provided in the GST portal, the necessity to depend upon GSP will be reduced.
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7.
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GSTR-2A / 2B for whole year
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No facility to download GSTR-2A / 2B for the whole year.
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There should be a facility to download GSTR-2A / 2B for the whole year or quarter.
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For refund application, GSTR-2A needs to be downloaded. For a whole year of refund, 12 GSTR-2A / 2B need to be downloaded. With this facility, time can be saved.
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8.
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Availment of ITC in GSTR-3B
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While filing Form GSTR-3B, portal raises warning that input availed is in excess of 105% of GSTR-2B. Sometimes, we avail that input
because we forgot to take it in previous month or previous year. So, we have no other option other than just ignore that warning & continue.
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It is suggested to make some changes in software (if
possible), which can detect that input availed in this month is due to short ITC taken in
previous months. Also, there should be a separate column in GSTR-3B which discloses ITC belonging to previous year, which is now availed this year before September return.
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This will remove the confusion faced because of the ITC which belongs to previous return period, availed in this return period.
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9.
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Outward Supply
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Sales returns are not shown separately in Form GSTR- 3B in Table 3.1 outward supply.
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It is suggested to add sales return row in Table 3.1 (Outward Supply) of Form
GSTR-3B.
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It will help in proper identification of comparative
figure of sales and sales return.
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10.
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Negative values be allowed
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Negative outward tax liability or inward tax credit are not acceptable. There may be many reasons for either negative tax liability or negative tax credit e.g., due to credit note/ debit note.
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It is suggested that with satisfactory explanation/
reason, negative tax liability or negative tax credit should be accepted.
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For e.g. credit note for IGST liability received during the
month and there is no outward supply during the month for IGST. In such case, we are unable to upload return due to negative tax liability resulting in mismatch between Form GSTR-1 and Form GSTR-3B.
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11.
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ITC
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Not able to bifurcate current year and previous year ITC at the time of reconciling Annual Return.
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It is suggested to provide separate column for current
year ITC and previous period ITC.
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To check previous year’s ITC.
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12.
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Acceptance of zero figure
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The form does not accept zero figures under IGST, CGST and SGST for suppliers whose supplies are under RCM.
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Zero should be allowed in tax even where there is some
taxable value. (or)
Incorporate a row for reporting a turnover, where the receipt is liable for tax under RCM.
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For suppliers under RCM, they have taxable value but there is no tax to be paid by them. So, the portal should either allow ‘zero’ figures in tax even when there is taxable value or have a dedicated row for reporting the same.
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13.
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No proper functionality to take and reverse proportionate Input Tax Credit as per rule 43
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There is no proper functionality to take and reverse proportionate
input tax credit as per rule 43. Firstly, entire ITC needs to be claimed and then ITC needs to be reversed for 60 months in 60 GSTR-3B forms and interest also needs to be paid making it very complicated.
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It is suggested that a separate column should be inserted for ITC to be availed in Rule 43.
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Present system makes it very difficult to calculate ITC as per Rule 42 and 43.
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14.
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Form number not given on
portal
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Closing balance of ITC is only reflected in its ledger & form number is also not reflected for any
application filed on the portal like when we apply for cancellation of registration number, form number in relation to the same is not given on portal.
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Closing balance of ITC in Form
GSTR-3B as at the end of the
month should be reflected &form number should be
reflected with the related form
for every application.
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ITC closing balance, if reflected like VAT in GSTR 3B will help in working to some extent and form number will also ease the working and will provide clarity.
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15.
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Return filing date
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Date of filing of return not available in the return.
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Date of filing of return may be provided in filed returns itself
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If we want to know the date of filing, we have to go to GSTN and search the filing status. If
the date is given in the return itself for all types of returns, it will be more convenient.
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16.
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GSTR 3B: ITC Table
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ITC claim more than GSTR-2B
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It is suggested to restrict the ITC claimed in Form GSTR-3B to 105% of GSTR 2B and any additional ITC claimed in the
GSTR 3B needs to be specifically mentioned with a description.So, for e.g., ITC of previous month although appearing in GSTR 2B but not claimed in
GSTR 3B as the goods were not received last month. When the same is claimed in current month, this would be specifically mentioned in a
separate row in GSTR 3B, along with the month to which the same pertains.
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This could be one of the specific mechanism to curb
excess/fraudulent claim of ITC.
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17.
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Export Invoice (with payment of IGST)
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Only one time amendment is possible in the invoice. After that nobody knows, how to get IGST refund with payment of IGST when there is error of ‘Sb 001’.
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Amendment be allowed in GSTR-1 for correction of invoice no., date etc. more than once.
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It is not justified to deny refund on account of human error while filing GSTR-1.
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