BJP CA Cell representation for one time GST Amnesty Scheme


BJP CA Cell representation for one time GST Amnesty Scheme



Date: 16/12/2022

Smt. Nirmala Sitharaman Madam, Honorable Finance Minister Ministry of Finance, North Block, New Delhi

Respected Ma’am

Sub: Suggestion an Issue on GST

The following issues to be considered:


  • GST APPEAL limitation one time Let due date of all Appeal for all orders passed till now be extended
  • For filing returns, mismatch & interest on the same
  • For 16(4) ITC
  • For availing Non genuine tax payers ITC
  • For GSTR10 Final Return
  • 2A vs 3B mismatch SCN’s to be dropped for 17/18 & 18/19
  • Waiver of 50% interests& Penalty for SCn’s 17/18 & 18/19 for genuine mistakes where tax is paid
  • Waiver of Late Fees for RTP with Annual TO less than 5 crores
  • E-way bill penalty should be dropped for selecting the wrong shipping address & while selecting branch A instead of branch B or godown

OTHER GST issues:

  • One GST return instead of multiple returns
  • Concept of ease of doing business requires more attention
  • GST notices to be sent thro’ RPAD/Speed post to dealers office address or by email to the proprietor/Partners/Directors/Tax consultant. All the email id’s are very well present on the GST portal itself & just mapping needs to be done on the portal to send the notices/intimations to every such person to avoid mis-communication/non- attendance/export orders and delay in filing rectification applications and Appeal
  • Condonation of delay for Refund/registration with small late fee
  • reaccredit of ITC along with interest in case supplier makes payment in the future
  • Allow corrections in GSTR1
  • Permit payments for inward supply of goods directly to supplier without tax and gst tax component thro cash ledger by recipients directly to the an option to This will help small tax payers in seamless tax claims instead of present complicated ITC
  • Not to levy interest for the cash deposit made in the electronic ledger but the same to be offset against the liability in GSTR3B at a later date
  • Assesses facing problem in cancellation of GST RC>Superintendent asking papers like he is going to complete audit & assessment or else he wants to disallow all ITC although fully seen in GSTR2A & wants us to pay full tax liability on outward
  • New provision of taxation of rent on residential property used for office purposes, needs some relaxation of up to 5 lakhs
  • New GST applications are rejected without any reasons or irrelevant reasons
  • Correction/Amendment in 9/9C be allowed
  • Revocation of cancelled Registration should be more lenient
  • Clarity on cross charges within Group Company should be done away with
  • Remove the provision of suppression from section 74
  • GST on stock broker’s brokerage is reduced to 8% so as to invite more participation from general public & reducing the cost of transactions
  • GST is killing small businesses & inspector Raj & suffocating compliances
  • Cut GST to 5% or NIL on Insurance premiums
  • Filed by supplier B2B erroneously under B2C from 2017 to date, rectification to be permitted
  • Allow cross utilization or transfer ECL balance among GSTN with same PAN to entity having multiple GSTN to Avoid fund block
  • GST Tribunals to be established on top priority
  • There are nearly 35% vacancies in each cadre of State GST dept. These posts should be filled on Most of these posts are filled up thro. MPSC which

requires atleast 1 year’sprocess. So time bound approach required.Modiji also promised to create 75 lakh jobs in 75th year of Indian Independence

  • As in SGST an internal circular is issued for 17-18 for ITC allowable by producing Ledger confirmations so same should also be issued under SGST
  • GST authorities should not ask the buyer to reverse ITC claimed in case the seller didn’t pay the GST to the dept. They should allow the ITC claimed with proof of payment of invoice of amount to the seller

Await your Appointment for personal Discussion.

You’re faithfully



BJP Professional Cell, Mumbai

ADV.C.B.THAKKAR                                                            CA MANISH GADIA

Former President                                             Vice President:BJP Professional cell, GST PAM                                                                                           Ex Chairmain:WIRC of ICAI


CA SUNIL KHUSLANI                                                                 ADV. PRAVIN SHINDE

President: GSTPAM                                                                          VP: GSTPAM

CA JANAK WAGHANI                                                              ADV.SURESH SHIVNANI

Secretary:BJP Professional Cell.                                               Sr.Councel:GST PAM Ex Editor:GST PAM.

CA TEKCHAND GUPTA                                               CA SANJAY GAJRA

Secretary: Professional Cell, Mumbai                 President:Mulund VidhanSabha

BJP Professional Cell.