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Complete Analysis has been made of Recommendation and Presented in 3 Table:-

Proposed Change

Present Scenario


There would be a single cash ledger for each tax head.

Currently there are multiple heads like Tax, Interest,Fees,Penalty,Other.

  • It will create less confusion among taxpayers.
  • Identification of Correct head is a major Problem for some Small Taxpayers.

Late fees for late returns is sometimes shown in Penalty head leads to creation of Wrong challan and blocking of Working Capital.

A scheme of single authority for disbursement of the refund amount sanctioned by

either the Centre or the State tax authorities.

Currently Refund is given by both the Authority. CGST part is refunded by CG and SGST part by State Govt.

  • It will ease the Process of Refund,  As for refund same process have to be followed before both the Authorities.
  • Single Window for Refund will remove the Cascading Process.

The new return filing system shall be introduced on a trial basis from 01.04.2019 and

on mandatory basis from 01.07.2019.

Currently 2 returns are filled GSTR1 & GSTR 3B.

  • Govt is in talk to Introduce Single Return for a Period in place of Several returns creating a unnecessary burden on Professionals & Wastage of Productive Hours.

ITC cannot be availed through FORM GSTR-9 &FORM GSTR-9C.

There was confusion that if ITC not taken up to specified date can it be claimed in Annual Return?

Govt has made Clarified that No ITC can be claimed in Annual Return.

ITC in relation to invoices issued by the supplier during FY 2017-18 may be availed by

the recipient till the due date for furnishing of FORM GSTR-3B for the month of March,


Currently last date to claim ITC pertaining to FY 17-18 was due date of Furnishing of GSTR3B for the month of SEP 2018 i.e. 20 OCT, 2018.

Council has extended due date to Claim ITC till furnishing of FORM GSTR-3B for the month of March,


Subject to specified conditions.(Let’s See what condition are to be complied for claiming ITC)

The due date for furnishing FORM GSTR-8 by e-commerce operators for the months of

October, November and December, 2018 shall be extended till 31.01.2019

  • GSTR 8 is to be filled by E-Commerce Operator till 10th of Next month.
  • Sec 52 talks about TCS provision which has been made Effect from 01 OCT 2018.
  • Due date has been extended as GSTN has not provided the portal to file GSTR 8.

Late fee shall be completely waived for all taxpayers in case FORM GSTR-1, FORM

GSTR-3B &FORM GSTR-4 for the months / quarters July, 2017 to September, 2018, are

furnished after 22.12.2018 but on or before 31.03.2019.

  • Late fees of Rs 50 or Rs 20 Per /Day is charged for late filling of GSTR 3B.
  • Previously Late fees is not charged on GSTR 1 but as per notification issued by CBEC returns after OCT will be liable to late Fees but Portal is not showing late fees for GSTR  1.
  • Here Govt has played a game with Taxpayers.
  • Late fees for only those taxpayers will be waived who will file after 22-12-2018.
  • What about the taxpayers who have already filled their returns with late fees.
  • Less than .1% taxpayers will be covered under this as mostly taxpayers have filled their  return with late fees.

Taxpayers who have not filed the returns for two consecutive tax periods shall be

Restricted from generating e-way bills.

Currently there no Trail between Filling of return and Generation of E way bill.

  • CBEC is going to create a functionality which will barred the taxpayers from generation of E-waybill if they have not filled their return for 2 Consecutive period.


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