Author: admin_gst

In Re: Assistant commissioner of Central Tax, Sankrail division (MEGA FLEX PLASTICS LTD.)
GST
2018 (11) TMI 663 – APPELLATE AUTHORITY FOR ADVANCE RULING, WEST BENGAL – 2018 (19) G. S. T. L. 159 (App. A. A. R. – GST), [2019] 63 G S.T.R. 80 (AAR)
APPELLATE AUTHORITY FOR ADVANCE RULING, WEST BENGAL – AAAR
Dated:- 25-10-2018
Case No. 06/WBAAAR/Appeal/2018
GST
RANDHIR KUMAR AND RAKESH KUMAR SHARMA MEMBER
Present for the Appellant: Mr. Nishant Kumar, Assistant Commissioner of Central Tax, Sankrail Division, Howrah CGST & CX Commissionerate
Present for the Respondent: Mr. Vinay Kumar Shraff, Advocate
This Appeal has been filed by the Assistant Commissioner of Central Tax, Sankrail Division, Howrah CGST & CX Commissionerate (hereinafter referred to as “the Appellant”) on 08.08.2018 against Advance Ruling No. 09/WBAAR/2018-19 dated 06.07.2018 = 2018 (7) TMI 391 – AUTHORITY FOR ADVANCE RULINGS, WEST BENGAL, pronounced by the West Bengal Authority for Advance Ruling in th

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peal against the above Advance Ruling requesting to set aside/ modify the impugned Advance Ruling passed by the Authority for Advance Ruling or pass any such further or other orders as may be deemed fit and proper in the facts and circumstances of the case on the following grounds:
i) The Respondent had themselves declared that they manufacture woven sacks of plastic materials of Chapter 39. The learned Advance Ruling Authority referred to Note 1(h) to Section XI of the Tariff Act which covers “textile and textile articles from Chapter 50 to 63 and does not include woven, knitted or crocheted fabrics of Chapter 39”, and hence the learned Advance Ruling Authority has erred in interpreting the true essence of this Chapter note;
ii) When every word in the above Chapter note is separated by comma then each word should be given equal weightage and from that perspective the word 'woven' should have been considered as an exclusion word in its own right. Hence the Advance Ruling is n

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ne Leno bags/ sacks containing 100 MT polypropylene granules” under ITCHS 39232990, the assessee decided to change the Tariff Heading for the same product, PP Leno Bags, to 6305 33 00 without citing any reasons for the same. The Appellant also submitted that the rule of estoppel by election is applicable in the matter as the Respondent themselves declared the item in question under Tariff Sub-Heading 3923 29 90 and enjoyed the duty draw back as per Duty Drawback Schedule of DGFT. The Appellant further submitted that the same product cannot be cleared for export and in DTA under two different Tariff Headings.
6. During the course of the hearing, the Respondent submitted the following:
(i) Manufacturing process includes manufacturing of polypropylene strips (tapes) which is woven to produce man-made textile material which is commercially known as Leno Fabric;
(ii) In terms of Chapter Note 2(p) of Chapter 39 of the GST Tariff (Plastics and articles thereof) if textiles or textiles prod

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uits and vegetables. The Standard IS 16187:2014 classifies such Sacks under the category of Textiles.
(vi) The respondent has been granted capital subsidy by the government of India under The Technology Upgradation Fund Scheme (TUFS) for making the textile industry globally competitive and to reduce the capital cost for the textile industry-
(vii) The polypropylene leno bags for packing of agricultural produce is internationally classified under HSN code 63053300.
7. The Respondent submitted copies of the reports of test conducted by the Central Institute of Plastics Engineering & Technology, Haldia, dated 15.03.2018, the Indian Institute of Packaging, Kolkata, dated 27.03.2018 and Indian Oil Corporation Ltd., Panipat, dated 12.03.2018 on his samples of PP Woven Leno Bags. These test reports arc based on samples provided by the Respondent. It is also seen that in the reports of Central Institute of Plastics Engineering & Technology and the Indian Institute of Packaging i.e. Test Rep

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[1993 (41) ECC 285; 1993; ECR 351 MP; [1990 (50) ELT 201 MP] = 1989 (9) TMI 120 – HIGH COURT OF MADHYA PRADESH AT INDORE, has rendered the following judgment: –
“……the process of the manufacture of the HDPE tapes, the earlier judgments of the CEGAT approved by the Supreme Court and accepted by the Department, all clearly go to show that the HDPE bags are the bags woven by the plastic strips and they, therefore, are goods of plastic and the material used for weaving those bags being the strips of plastic made from plastic granules, the strips of plastic used for weaving the aforesaid HDPE woven sacks has to be classified as an Item under entry 39.20 of Chapter 39 and not under entry 54.06 of Chapter 54. Accordingly the entries of the finished goods have also to be made under the proper Chapter of the Tariff Act treating them as the finished goods made of plastic strips.
In the result we hold that HDPE strips or tapes fall under the Heading 39.20, sub-heading 3920.32 of the Central

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M/s Steel & Metal Tubes (I) Ltd. Versus Commissioner Central GST, Noida
Central Excise
2018 (12) TMI 236 – CESTAT ALLAHABAD – TMI
CESTAT ALLAHABAD – AT
Dated:- 25-10-2018
APPEAL No. E/70555/2018-EX[SM] – FINAL ORDER NO 72578/2018
Central Excise
Mrs. Archana Wadhwa, Member (Judicial)
Shri Rajesh Chhibber (Advocate) for Appellant
Shri Pawan Kumar Singh (Supdt.) AR for Respondent
ORDER
Per: Archana Wadhwa
After hearing both the sides I find that the appellant is engaged in the manufacture of Steel Pipes and Tubes and was procuring HR Coils from various sources including SAIL, Rourkela. The said HR Coils was being received through Rail and Railways were charging service tax for transportation of the same, which were shown in the Railway Receipt (RR), on the basis of which the appellant was claiming the credit.
2. However, w.e.f. 27.08.2014, the Cenvat Credit Rules were amended and Clause (a) was introduced after Clause (f) of sub Rule (1) of Rule 9 of Cenvat

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dit and the credit availed by the consignee i.e., appellant is not proper. The appellant brought to the notice of the Adjudicating Authority a circular issued by the Board being Circular No. 1048/36/2016-CX dated 20.09.2016 wherein it was clarified that if the consignor is not availing the Cenvat Credit, the same can be availed by the consignee. The said circular was not followed by the Adjudicating Authority on the ground that the same stands issued in September, 2016 whereas the period involved in the appeal is from July, 2014 to March, 2015. It was also observed that since the STTG certificate was not issued by the Railways in the name of the appellant, the same would not form eligible document for the purpose of availment of credit. Hence demand to the tune of Rs. 10.58 lakhs approximately were confirmed along with confirmation of interest and imposition of penalty of identical amount.
The said order was upheld by Commissioner (Appeals). Hence the present appeal.
4. The facts are

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or ready reference:-
“(v) In case if the Service Tax has been paid by the consignor but CENVAT credit is to be availed by the consignee, who is eligible for such credit as per the rules, the consignor shall make a written request to Railways for issue of consignee-wise STTG certificate duly indicting the RR details pertaining to the consignee in the format prescribed above. The competent Railway Authority shall issue the STTG certificate accordingly, even though it will require issuance of more than one STTG certificates to the customer (consignor) for a particular month. The consignor shall transfer the consignee-wise 'STTG certificate' in original to the consignee concerned. The consignee may avail the CENVAT credit on the strength of this certificate.
(vi) Where a consolidated STTG Certificate has been issued in terms of clause (iii), no STTG Certificate consignee-wise in terms of clause (v) shall be issued and vice-versa.”
As is clear from reading of the above paragraphs the c

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Sanction of pending IGST refund claims where the records have not been transmitted from GSTN to DG Systems
PUBLIC NOTICE NO. 34/2018 Dated:- 25-10-2018 Trade Notice
Customs
OFFICE OF COMMISSIONER OF CUSTOMS
NEW CUSTOM HOUSE, KANDLA-370 210
Phone No. 02860-271468/469, FAX NO. 02836-271467
F. No. S/20-72/PN/IGST Ref/AG/2017-18
Dated: 25.10.2018
PUBLIC NOTICE NO. 34/2018
Subject:- Sanction of pending IGST refund claims where the records have not been transmitted from GSTN to DG Systems- M/ reg.
Attention of the Exporter, General Trade and all other stake holders is invited to the Public Notice No. 01/2018 dated 16.1.2018, Public Notice No. 9/2018 dated 27.2.2018, Public Notice No. 13/2018 dated 15.3.2018, Public Notice No. 16

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on said subject. The matter was examined in the Board and it has been observed that under CGST Act, 2017 Cost Accountants have also been recognized for various certification/ representations like in Section 35, Section 66, Section 116 and Section 48 read with Rule 24 of Return rules.
4. Accordingly, it has been decided that Cost Accountants are also authorized to provide the requisite certificates as envisaged under Circular 12/2018-Customs dated 29.05.2018.
5. Hence, It is requested that above changes in facility to obtain certificates from Cost Accountant also, may be utilized by one and all and co- operate with the Department in processing the refund claims immediately.
(Sanjay Kumar Agarwal)
Commissioner
Circular, Trade Notice,

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TRAN-1 Credit
Query (Issue) Started By: – DEEPAK SHARMA Dated:- 24-10-2018 Last Reply Date:- 25-10-2018 Goods and Services Tax – GST
Got 4 Replies
GST
A advertisement company audit of service tax is under process, the company were availing credit on input and were paying full rate of Service Tax. In audit officer raised question to payment of taxes under RCM on TPT and security service, the company agreed to its payment. However they wanted to claim it through TRAN-1. Is it possible today to take credit through TRAN-1, please suggest
Reply By Ganeshan Kalyani:
The Reply:
In my view, Tran1 due date is already passed. The Tran1 due date for special case where tran1 was submitted but not filed etc were given opportunity to file

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GST CREDIT
Query (Issue) Started By: – Mathew George Dated:- 24-10-2018 Last Reply Date:- 30-10-2018 Goods and Services Tax – GST
Got 4 Replies
GST
Hi,
My client is a Travel agent(in kerala) who books Hotel and accommodation for his clients, The hotel may be located in the state (kerala) or out side (Tamilnadu) the state and they will charge CGST and SGST. Now the question is whether the travel agent can claim both CGST and SGST…?
Reply By SHIVKUMAR SHARMA:
The Reply:
GST Regis

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old car dealer eligibilty for composition dealer
Query (Issue) Started By: – satbir singhwahi Dated:- 24-10-2018 Last Reply Date:- 25-10-2018 Goods and Services Tax – GST
Got 3 Replies
GST
Person dealing in old cars , can he opt for composition dealer and pay 1%, or normal dealer and with 18% on margin.Pls guide.
Reply By DR.MARIAPPAN GOVINDARAJAN:
The Reply:
In my view it can be do so if the turnover is within the threshold limit.
Reply By KASTURI SETHI:
The Reply:
I support th

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Refund of ITC in relation to Export of Goods without payment of tax
Query (Issue) Started By: – anuja bhandari Dated:- 24-10-2018 Last Reply Date:- 25-10-2018 Goods and Services Tax – GST
Got 2 Replies
GST
Dealer is in business of trading of Gaur Meal product, this item was taxable @ 5% GST before 15 Nov 2017 in GST. After 15 Nov 2017 vide notification Gaur Meal is at 0% GST. Dealer purchased gaur meal prior to 15 Nov 2017 and exported the same out of India in Dec 2017 without payme

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Casual taxable persons selling handicrafts are exempt from GST registration but must generate e-way bills for transport.
Notifications
GST
Exemption to a casual taxable person making taxable

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Job work/works contract
Query (Issue) Started By: – kishor kaushal Dated:- 24-10-2018 Last Reply Date:- 25-10-2018 Goods and Services Tax – GST
Got 1 Reply
GST
Dear Sir
I want to know that I take spares & repair & maintenance for Machinery some party.
Parties are an unregistered dealer. Can I take under job work & under RCM.
Kindly confirm me.
Thanks & regards
Kishor Kumar Kaushal
Reply By Ganeshan Kalyani:
The Reply:
Job worker are to pay tax on job worker charges.
Disc

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NO ANTI-PROFITEERING BY SUBWAY FRANCHISEE
By: – Dr. Sanjiv Agarwal
Goods and Services Tax – GST
Dated:- 24-10-2018

In one of the recent order dated 27.09.2018 issued by National Anti-profiteering Authority (NAA) in the case of Jijrusha N. Bhattacharya v. N.P. Foods (Franchisee Subway India) (2018) 9 TMI 1763 (NAA), it has been ordered that there was no anti-profiteering involved on sale of Hara Bhara Kabab (product) sold by the subway franchisee.
In the instant case, the respondent was a franchisee of 'subway' engaged in supply of breads / sandwiches. The applicant filed a complaint that the Respondent had not passed on the benefit of reduction in the rate of GST in restaurant service, when he had purchased i.e., '6 Hara B

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confirmed in his report that the rate of GST on the restaurant service had been reduced from 18% to 5% with the condition that ITC on the goods and services used in supplying the service will not be allowed vide Notification No. 46/2017-Central Tax (Rate) dated 14.11.2017 with effect from 15.11.2017. The DGAP had also stated that on scrutiny of the GSTR-1, GSTR-3B and the ITC Register submitted by the Respondent, it was observed that ITC amounting to ₹ 13,01,759/- was available to the Respondent during the period from July, 2017 to November, 2017 which came to approximately 11.80% of the taxable value of the service amounting to ₹ 1,10,29,612/- supplied during the same period but when the tax was reduced from 18% to 5%, the said

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Key 8 suggestions on Annual Return Format – Form GSTR-9
By: – Bimal jain
Goods and Services Tax – GST
Dated:- 24-10-2018

In terms of Section 44(1) of the CGST Act, 2017, every registered person, other than an Input Service Distributor, a person paying tax under Section 51 (TDS deductor) or Section 52 (TCS collector), a casual taxable person and a non-resident taxable person, shall furnish an Annual Return for every financial year on or before the 31st day of December following the end of such financial year. The Government vide Notification No. 39/2018 – Central Tax dated September 4, 2018 has notified the format of Annual Return Form GSTR-9 (for normal taxpayers) and Form GSTR-9A (for composition taxpayers).
Considering the complexity of Form GSTR-9 under the given time frame of 3 months for due date of 31st December, following suggestions are compiled by Mr. Bimal Jain, Chairman, Indirect Tax Committee, PHD Chamber of Commerce towards making Annual Return format si

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n-taxable supply”
Thus, when definition of exempt supply itself includes Nil rated supplies, separate mention of the same under Part E above will add to confusions.
* Clarity on meaning of non-GST supply – As seen supra that definition of exempt supply includes non-taxable supply i.e. a supply of goods or services or both which is not leviable to tax under this Act [Section 2(78) of the CGST Act, 2017], hence, scope of non-GST supplies is not understood. This confusion persists in current format of GSTR-3B as well which requires separate reporting of non-GST outward supplies apart from exempted outward supply, which includes non-taxable supplies, Nil rated supplies and exempted supply. Thus, clarity on items included in non-GST supplies is required.
II Table 6: No need for bifurcation of ITC into inputs, input services and capital goods
Table 6 of Form GSTR-9 while capturing details of ITC availed as declared in returns filed during the FY, also asks for details of such ITC on in

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available in initial period of GST introduction.
Further, in terms of Section 16(4) of the CGST Act, 2017, ITC in respect of invoices/ debit notes of a FY shall not be available after the due date of furnishing of return for September month following the end of financial year or furnishing of relevant annual return, whichever is earlier. In other words, taxpayers are required to complete the reconciliation process with their vendors latest by September 30, 2018 (Due date for filing GSTR 3B for the month of September 2018 is October 20, 2018), being the last day for claiming credit pertaining to the last FY.
* Technical glitches of GSTN portal – But it needs to be appreciated that owing to shortcomings of the GSTN portal, the envisaged system of ITC matching & mis-matching through Form GSTR-2 and GSTR-3 got indefinitely suspended and therefore, the matching mechanism could not be brought into action.
* Extension of due dates for filing GSTR-1 till October 31, 2018/ December 31, 20

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n 16(4) of the CGST Act, 2017 specifically refers to the return under Section 39 (GSTR-3) and the Annual Return but does not stipulate or refer to any return under Section 168 (GSTR-3B ). Thus, the last date for availing ITC of any invoice/debit note for a financial year, say 2017-18, would be the earlier of the due dates for filing the GSTR-3 for September 2018 and the Annual Return for the year 2017-18. Since, filing of GSTR-3 is suspended, the last date within which input tax credit for invoices/debit notes of 2017-18 can be taken is the date of filing of the Annual Return for 2017-18, i.e., 31st December 2018.
Suggestion(s):
* Extending date of ITC reconciliation from last date of September 30 – Considering the challenging task of completing reconciliation of ITC with vendors by September 30, 2018, the government may consider the case for extending this date of September 30. Else, suitable modification in Form GSTR-9 may be carried to allow ITC for invoices pertaining to FY 2017

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rsed during the FY and reclaimed in next FY
In terms of second proviso to Section 16(2) of the CGST Act, 2017, reversal of ITC is required to be made where the recipient fails to pay to the supplier the amount towards value of supply along with tax payable thereon. However, on the payment of consideration, ITC can be reclaimed. In case 180 days reversal happened in 2017-18 and reclaimed in 2018-19, how to disclose, disallow or reclaim such credit.
Suggestion(s):
* Clarity required for disclosure of ITC reversed but reclaimed in 2018-19 – It may happen that ITC reversal happened in 2017-18 and reclaimed in 2018-19. Clarity may be provided as how to disclose such credit.
VII Table 18: HSN wise summary of inward supplies should not be asked for
Table 18 of Form GSTR-9 requires the details of HSN wise summary of inward supplies received by the taxpayer. It may be noted that neither of the present return forms viz. Form GSTR-3B and GSTR-1 captures such details. Only Form GSTR-1 requir

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EOT Grab Cranes in Waste to Energy Plants Classified Under Sl. No 234, Schedule I with 5% IGST Rate.
Case-Laws
GST
Classification of goods – rate of GST – EOT Grab Cranes are integral part of the Waste to Energy Plants project for manufacturing and generation of end product of electricity and therefore the EOT Grab Cranes being used in waste to energy plant – covered under Sl. No 234 of Schedule I – liable to IGST @5%.
TMI Updates – Highlights, quick notes, marquee, annotation, news

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Inter-state transfers of rented, leased, or hired medium heavy-duty cranes are taxable under GST without usage rights transfer.
Case-Laws
GST
Supply or not – inter-state branch transfers – levy of GST – providing medium-sized heavy-duty cranes on rental/lease/ hire basis to its clients without transferring the right to use the cranes – the movement is a taxable supply – GST would be payable on the movement of both type of cranes i.e. tyre mounted cranes and crawler cranes.
TMI Updat

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Court to Reconsider Petitioners' Claim on Failed GST TRAN-1 Filing Due to Server Error, Input Tax Credit at Stake.
Case-Laws
GST
Rejection of petitioners’ request to receive their return in FORM GST TRAN-1 which would enable them to claim input tax credit for the tax paid prior to the introduction of GST – The impugned order does not deal with the petitioners’ claim of inability to file their return in FORM GST TRAN-1 on 27.12.2017 because of server error. – To be reconsidered afres

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Court Directs Petitioner to Submit Representation on GST Impact for Pre-July 1, 2017 Railways Contracts.
Case-Laws
GST
Implication of GST on the contracts between petitioners and Railways ent

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Seizure of Goods u/s 129(1) Deemed Illegal Due to Lack of Transaction Declaration Form, Penalty Inapplicable.
Case-Laws
GST
Seizure of goods u/s 129(1) – Transaction Declaration Form (T.D.F.) was not attached with the consignments – the seizure and penalty imposed upon the petitioners based on the notification dated 21.7.2017 issued under Rule 138 of the U.P.G.S.T. Act 2017, which was not applicable, is clearly illegal.
TMI Updates – Highlights, quick notes, marquee, annotation, new

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Seizure Order Invalidated: E-way Bill Not Mandatory Before March 31, 2018; Section 129(1) & 129(3) Set Aside.
Case-Laws
GST
Validity of Seizure Order u/s 129 (1) – goods not accompanied with E-way bill – Admittedly, till 31st March, 2018 it was not mandatory to download the E-way bill from the official portal – The order as passed on 25.3.2018 and the show cause notice issued u/s 129 (3) of the Act are hereby set aside
TMI Updates – Highlights, quick notes, marquee, annotation, news

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Goods and Vehicle Detained Over E-way Bill Issue; Discrepancy in Order Timing Raises Concerns of Malintent.
Case-Laws
GST
Detention of goods with vehicle – production of e-way bill – while passing the impugned order dated 27.03.2018 no time has been mentioned by the respondent no. 2 whereas while issuing notice/detention memo he has specifically mentioned the time. This clearly goes to show the ill intention on the part of the respondent no. 2.
TMI Updates – Highlights, quick notes,

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IGST Export Refunds – extension in SB005 alternate mechanism and revised processing in certain cases including disbursal of compensation Cess – reg.
40/2018 Dated:- 24-10-2018 Circular
Customs
Circular No. 40/2018-Customs
F. No: 450/119/2017-Cus-IV
Government of India
Ministry of Finance
Dept. of Revenue
(Central Board of Indirect Taxes and Customs)
Room No. 227B, North Block, New Delhi
Dated, the 24th October, 2018
To,
All Principal Chief Commissioners/Chief Commissioners of Customs/Customs(Preventive)
All Principal Chief Commissioners/Chief Commissioners of Customs & Central Excise
All Principal Commissioners/Commissioners of Customs/Customs (Preventive)
All Principal Commissioners/Commissioners of Customs & Central Excise
Subject: IGST Export Refunds – extension in SB005 alternate mechanism and revised processing in certain cases including disbursal of compensation Cess – reg.
Madam/Sir,
Exporters are availing the refunds of IGST paid on exports regularly

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erved that exporters are committing same mistakes again and again in spite of several sensitisation/outreach programmes. However, giving high priority to the interests of exporters, it has been decided by the Board to extend the rectification facility to Shipping Bills filed up to 15.11.2018. However, it has been reiterated that the exporters shall have to take care to ensure the details of invoice, such as invoice number, IGST paid etc. under GSTR 1 and shipping bill match with each other since the same transaction is being reported under GST laws and Customs Act.
3. It may be noted that SBs which have not been scrolled due to the IGST paid amount erroneously declared as 'NA' are already being handled through officer interface as per Board's Circular 08/2018 – Customs dated 23.03.2018. However, no such provision was hitherto available in respect of those SBs which were successfully scrolled, albeit with a lesser than eligible amount.
4. CBIC has been receiving representations where

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acility would be available only for cases where Shipping Bills have been filed till 15.11.2018. However, exporters need to be cautious while filing details in Shipping Bill as a similar facility may not be available in future for the same mistake for referred shipping bill. Also, Customs Officers while processing claims using officer interface should exercise due diligence so that mistakes are not repeated again.
6. In order to claim the differential amount, the exporter is required to submit a duly filled and signed Revised Refund Request (RRR) annexed to this circular to the designated AC/DC A scanned copy of the RRR may also be mailed to dedicated email address of Customs locations from where exports took place. The designated/concerned AC/DC will then proceed to sanction the revised amount after due verification through the option provided in ICES, a detailed advisory on which will be communicated by DG Systems to all the System Managers shortly. Once the revised amount is approve

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ers within the stipulated time i.e.15.11.2018. Customs officers under your charge dealing with IGST refund may also be given suitable instructions to proactively and expeditiously process the revised refund requests.
9. Difficulties, if any, should be brought to the notice of the Board. Hindi version follows.
Yours faithfully,
Encl. Format of Revised Refund Request (RRR).
(Zubair Riaz)
Director (Customs)
Annexure: Revised Refund Request (RRR)
SB Number: SB Date: Port Code:
GSTIN: IEC: Exporter Name:
Sl No
GST Invoice Number/ Date
IGST Amount
Sl. No
Corresponding SB Invoice No. /Date
IGST Amount as declared per SB
Final (corrected) IGST Amount as per actual exports*
1
1
2
3
4
2
5
3
6
7
4
* after reducing amount pertaining to Short shipment etc.
IGST Refund already received (A): Total Revised IGST Claim (B):
Differential IGST Refund (B-A):
I declare that all the details declared given above are true to my knowledge and all the items contained in the above in

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IPCA LABORATORIES LTD. Versus UNION OF INDIA
GST
2018 (10) TMI 1389 – GUJARAT HIGH COURT – TMI
GUJARAT HIGH COURT – HC
Dated:- 24-10-2018
R/SPECIAL CIVIL APPLICATION NO. 16156 of 2018
GST
MR AKIL KURESHI AND MR UMESH TRIVEDI, JJ.
For The Petitioner : KUNTAL A PARIKH (7757)
ORAL ORDER
(PER : HONOURABLE MR.JUSTICE AKIL KURESHI)
1. The petitioners grievance is that the goods of the petitioners being transported by the transporter engaged by the petitioners did not reach the destination within the prescribed time as communicated in the documents maintained in terms of Rule 138 of the Central Goods and Services Tax Rules on account of transporters strike. The transporter did not extend the validity. As a result, the r

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Pawan Cargo Forwards Pvt. Ltd. Versus Principal Commissioner of Service Tax, Chennai- I (CGST & CE Chennai North)
Service Tax
2018 (10) TMI 1558 – CESTAT CHENNAI – 2020 (34) G. S. T. L. 559 (Tri. – Chennai)
CESTAT CHENNAI – AT
Dated:- 24-10-2018
Appeal Nos. ST/40931/2016 & ST/40932/2016 – FINAL ORDER No. 42656-42657/2018
Service Tax
Shri Madhu Mohan Damodhar, Member (Technical) And Shri P. Dinesha, Member (Judicial)
Shri G. Sivakumar, Consultant For the Appellant
Shri K. Veerabhadra Reddy, ADC (AR) For the Respondent
ORDER
Per Shri Madhu Mohan Damodhar
The appellants are a air cargo agent and are paying service tax on the commission amount paid from the airlines. Department took the view that appellants should have been paying service tax also on the freight charges reimbursed by them from their customers charged over and above the freight amount payable to the airline companies. Accordingly, SCN No.35/2014 dt. 29.10.2014 proposing service tax liability of

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amount collected from the Customer as the Value of Service and made it taxable in the hands of the Appellant, which is incorrect. In other words, the Department wants to tax the “Margin” but has calculated the Service Tax on the Gross amount collected from the Customer on behalf of the Airlines, which is contrary to the order itself.
(ii) Even assuming but without admitting that the intention of the Department is to tax the entire amount collected from the Customer in the hands of the Appellant – assessee still the demand would fail for the reasons below :
a. The Appellant is merely an agent collecting the freight on behalf of the Airlines and hence, the amount collected cannot be treated as Service Provided by the Appellant-assessee to the Customers.
b. In any case, on the freight amount, Service Tax has already been paid by the Airlines and hence, only again taxing the same in the hands of the Appellant, would amount to Double-taxation, which is incorrect. Reliance is placed on H

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49,34,46,556
(iv) Further, even assuming but without admitting tax is payable the difference amount, in the present case, there is no difference as the amount collected from the Customers and the amount paid to the Airlines is same. The same can be verified from Para 6(e) of the OIO.
(v) Finally, it is a settled law that no Service Tax can be demanded on difference between Amount Freight amount collected from the Customer and paid to the Airlines. Reliance is placed on :-
1.
M/s.Skylift Cargo (P) Ltd. Versus Commissioner of Service Tax, Chennai And (Vice-Versa)
2018 (2) TMI 320 – CESTAT CHENNAI
2.
M/s.La Freight Pvt. Ltd. Versus Commissioner of Service Tax, Chennai
2018 (3) TMI 113 – CESTAT CHENNAI
3. On the other hand, Ld. A.R Shri K. Veerabhadra Reddy, supports the impugned order. He submits that the assessee adopts two type of transaction, one in respect of which they act as intermediary which involves commission on agreed terms and the other booking cargo space from Airl

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se are that assessee M/s. Skylift Cargo (P) Ltd., [hereinafter referred to as assessees] are engaged in providing Cargo Handling Service, Clearing & Forwarding Service, Customs House Agent Service. They are also involved in the activities of booking domestic and international air cargo for various airlines for rendering the said bookings. Department took the view that the assessee were paying service tax under Business Auxiliary Service only on the commission amount without considering the incentive amount. Accordingly, proceedings were initiated against the assessee by way of issue of show-cause notices. These proceedings culminated in confirmation of demands of differential service tax liability of Rs. 19,98,332/- and Rs. 93,11,332/- respectively with interest liability thereon. Penalties, which were upheld by the impugned orders in respect of appeal nos.ST/00026/2008 and ST/20005/2009. Aggrieved, assessees are before this forum.”
We find that the facts of this case are pari materi

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Apar Industries Limited Versus Union of India & Others
GST
2018 (10) TMI 1619 – BOMBAY HIGH COURT – TMI
BOMBAY HIGH COURT – HC
Dated:- 24-10-2018
WRIT PETITION NO. 3985 OF 2018
GST
M.S. SANKLECHA, & RIYAZ I. CHAGLA, JJ.
Mr. Prakash D. Shah with Mr. Mihir Mehta and Ms. Shilpi Jain i/b. PDS Legal, for the Petitioner.
Mr. Pradeep S. Jetly with Mr. Ram Ochani, for the Respondents.
P.C:
This Petition under Article 226 of the Constitution of India, originally seeks a refund of Rs. 52.97 Crores along with interest thereon under Section 56 of the Central Goods & Service Tax Act (the Act). Besides, seeking an interest on delayed refund of Rs. 1.90 Crores which was already granted to the Petitioner. These refunds arose on account of tax paid in respect of exported goods under Section 16 of the Integrated Goods & Service Tax Act, 2017 (IGST Act). During the pendency of this Petition, an amount of Rs. 52.52 Crores has already been refunded under the Act read with IGST Act

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ioner, disputes the fact that there is any invoice mismatch. Our attention is invited to the Frequently Asked Questions (FAQ) issued by the Madras Commissionerate dated 23rd February, 2018 wherein an error in respect of Invoice mismatch I.e. SB005, was a subject matter of consideration. Our attention was also invited to the Circular issued by the Central Board of Indirect Taxes and Customs dated 23rd February, 2018 wherein again, non-grant of refund, because of mismatch of Invoices, was a subject matter of consideration. In both the cases, it was directed that refund be granted. Therefore, it submitted that in terms of the above the interest as sought should be granted.
5. We find that on oath, the Respondents state that there is an Invoices mismatch in respect of the refund sought. Thus, leading to delay in passing the refund. This is disputed by the Petitioner. Besides, the aforesaid Circulars and FAQ, inter alia, deal with grant of refund in spite of Invoices mismatch/ error, as in

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issioner of Customs, Nhava Sheva, Navi Mumbai. However, in the affidavit in reply, he has already taken a stand, that no interest can be granted in these facts to the Petitioner. Therefore, the apprehension of the Petitioner that it may not get justice at the hands of Mr. Balmukund Agarwal, seems justified. Justice must not only be done but also appear to be done. Therefore, in these circumstances, it would be appropriate that some other Assistant Commissioner of Customs be alloted to deal with the Petitioner's pending application for refund of tax as well as interest on the refunds already granted.
9. Mr. Jetly, learned Counsel appearing for the Revenue, on instructions, states that the representation could be filed with Mr. Jaiswal, Assistant Commissioner of Customs, Drawback, Navha sheva, Navi Mumbai. The above Officer who would adjudicate the Petitioner's claim for interest on the refund granted and the pending refund application, as expeditiously as possible and preferabl

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O/E/N India Ltd., & Another (OEN) Versus Union of India & Others
GST
2018 (10) TMI 1620 – BOMBAY HIGH COURT – 2019 (20) G. S. T. L. J45 (Bom.)
BOMBAY HIGH COURT – HC
Dated:- 24-10-2018
WRIT PETITION NO. 2086 OF 2018
GST
M.S. SANKLECHA, & RIYAZ I. CHAGLA,JJ.
Dr. Abhinav Chandrachud i/b. Mr. Shailendra Singh, for the Petitioners.
Mr. Pradeep S. Jetly with Mr. J.B. Mishra, for the Respondents.
P.C:
This Petition under Article 226 of the Constitution of India, seeks directions to Respondent Nos.1 and 3 to allow Petitioner, to resubmit/ rectify its form TRAN-1 filed under Section 140 of the Goods and Service Tax, 2017 (the Act).
2. This direction is being sought as the Petitioners had by mistake, keyed in incorrect fig

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DAILY EXPRESS, ALEPPEY PARCEL SERVICE Versus THE ASSISTANT STATE TAX OFFICER, COMMISSIONER OF KERALA STATE GOODS AND SERVICE TAX DEPARTMENT, STATE OF KERALA
GST
2018 (11) TMI 141 – KERALA HIGH COURT – TMI
KERALA HIGH COURT – HC
Dated:- 24-10-2018
WP(C). No. 34250 of 2018, WP(C). No. 34217 of 2018, WP(C). No. 34206 of 2018 And WP(C). No. 34190 of 2018
GST
Mr. Justice Dama Seshadri Naidu
For the Petitioner : Adv. Smt. S. Sujini
JUDGMENT
[WP(C) 34250/2018, WP(C). 34217/2018 WP(C). 34206/2018, WP(C).34190/2018 ]
As the issue involved in all these writ petitions is similar, they are taken up for consideration together and disposed of by this common judgment.
2. The petitioners are the transporters. When they had been carrying goods, the respondent State Tax Officer intercepted them and detained the vehicle. It is because the e-way bills the petitioners carried with the consignment did not contain the vehicle details. Though the vehicle and the goods detained, the

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2018 in W.A. No.1640 of 2018) has dealt with an identical issue.
4. Applying the ratio of that judgment, I direct that respondent authorities to release the petitioner's goods and vehicles on their “furnishing Bank Guarantee for tax and penalty found due and a bond for the value of goods in the form as prescribed under Rule 140(1) of the CGST Rules”.
With the above direction I dispose of these writ petitions.
 
APPENDIX OF WP(C) 34250/2018
PETITIONER'S/S EXHIBITS:
EXHIBIT P1
TRUE COPY OF THE TAX INVOICE DATED 27.9.2018.
EXHIBIT P2
TRUE COPY OF THE E-WAY SLIP WITH RESPECT TO THE CONSIGNMENT IN PART A DATED 27.9.2018.
EXHIBIT P3
TRUE COPY OF THE FORM GST MOV-01 NO.SCN/S.S10/7/2018 DATED 29.9.2018 ISSUED BY THE IST RESPONDENT.
EXHIBIT P4
TRUE COPY OF THE FORM GST MOV-02, NO.SCN/S S10/7/2018 DATED 29.9.2018 ISSUED BY THE IST RESPONDENT.
EXHIBIT P5
TRUE COPY OF FORM GST MOV-04 NO.SCN/S/S S10/7/2018 DATED 29.9.2018 ISSUED BY THE IST RESPONDENT.
EXHIBIT P6

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THE 1ST RESPONDENT.
EXHIBIT P4
TRUE COPY OF THE FORM GST MOV-02, NO.SCN/MOB/II/3/18-19 DATED 29/08/2018 ISSUED BY THE 1ST RESPONDENT.
EXHIBIT P5
TRUE COPY OF FORM GST MOV-0, NO.SCN/MOB/II/3/18-19 DATED 29/08/2018 ISSUED BY THE 1ST RESPONDENT.
EXHIBIT P6
TRUE COPY OF THE NOTICE UNDER SECTION 129(1) OF THE CENTRAL GOODS AND SERVICE TAX ACT, 2017 AND THE STATE/UNION TERRITORY GOODS AND SERVICES TAX ACT, 2017 IN FORM GST MOV-06 SCN/MOB/II/3/18-19 DATED 29/08/2018 ISSUED BY THE 1ST RESPONDENT.
EXHIBIT P7
TRUE COPY OF THE NOTICE U/S 129(3) OF THE CENTRAL GOODS AND SERVICES TAX ACT, 2017 AND THE STATE/UNION TERRITORY GOODS AND SERVICES TAX ACT, 2017 IN FORM GST MOV-07 SCN/MOB/II/3/18-19 DATED 29/08/2018.
EXHIBIT P8
TRUE COPY OF THE WRITTEN COMMUNICATION DATED 06/10/2018, SENT BY THE PETITIONER ADDRESSED TO THE 1ST RESPONDENT.
EXHIBIT P9
TRUE COPY OF THE PROOF OF REGISTERED POST SENT TO THE 1ST RESPONDENT.
 
APPENDIX OF WP(C) 34206/2018
PETITIONER'S/S EXHIBITS:
E

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RUE COPY OF THE WRITTEN COMMUNICATION DATED 06/10/2018, SENT BY THE PETITIONER ADDRESSED TO THE 1ST RESPONDENT.
EXHIBIT P9
TRUE COPY OF THE PROOF OF REGISTERED POST SENT TO THE 1ST RESPONDENT.
 
APPENDIX OF WP(C) 34190/2018
PETITIONER'S/S EXHIBITS:
EXHIBIT P1
TRUE COPY OF THE TAX INVOICE -AA1432. DATED 18/09/2018.
EXHIBIT P2
TRUE COPY OF THE E-WAY SLIP GENERATED WITH RESPECT TO THE CONSIGNMENT DATED 18/09/2018.
EXHIBIT P3
TRUE COPY OF THE FORM GST MOV-01 NO.SCN/MOB/II/18/18-19 DATED 19/09/2018 ISSUED BY THE 1ST RESPONDENT.
EXHIBIT P4
TRUE COPY OF THE FORM GST MOV-02, NO.SCN/MOB/II/18/18-19 DATED 19/09/2018 ISSUED BY THE 1ST RESPONDENT.
EXHIBIT P5
TRUE COPY OF FORM GST MOV-04, SCN/MOB/II/18/18-19 DATED 19/09/2018 ISSUED BY THE 1ST RESPONDENT.
EXHIBIT P6
TRUE COPY OF THE NOTICE UNDER SECTION 129(1) OF THE CENTRAL GOODS AND SERVICES TAX ACT, 2017 AND THE STATE/UNION TERRITORY GOODS AND SERVICE TAX ACT, 2017 IN FORM GST MOV-06 SCN/MOB/II/18/18-19 DATED 19/0

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Providing various e-Filing facility to Taxpayers for smooth GST Compliance
29T of 2018 Dated:- 24-10-2018 Maharashtra SGST
GST – States
Office of the
Commissioner of State Tax
(GST), 8th Floor, GST Bhavan,
Mazgaon, Mumbai-400010.
Trade Circular
To,
No. JC (Nodal-I)/E-Helpdesk/Trade Circular/B3044 Mumbai. Dated24/10/18.
Trade Circular No. 29T of 2018.
Sub. Providing various e-filing facility to tax payers for smooth GST Compliance.
Gentlemen/ Sir/Madam,
In pursuance of ease of doing business and helping the tax payers to discharge various obligations in context to GST, Maharashtra State GST Department has established dedicated helpdesks in all State GST offices in the state for assisting taxpayers in e-filing of various applications/forms, namely-
1) Registration- Application for New Registration, Amendment and Cancellation.
2) Return – GST 3B, GSTR 1, GSTR 4, GSTR 5, GSTR 6, GSTR 7.
3) Payment- GST 3B related payments.
4) Refund- All types of refund applicatio

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Malegaon
GST Bhavan, Yash Kripa Building, Soygaon Market Road, Near M G Petrol Pump Malegaon 423203
13
Ahmednagar
Room No-8, Ground Floor, GST Bhavan, Near SBI & GPO Chowk, Ahmednagar-414001
Amravati
14
Akola
GST Bhavan, Neemwadi Bypass Road, Akola444001
15
Amravati
GST Bhavan, Revenue Commr.Off.Compound, Old By Pass Road, Amravati-444601
16
Khamgaon
GST Bhavan, Nandura Road, Khamgaon-444303
17
Washim
GST Bhavan, Pusad Naka, Turke Complex, Washim -444505
18
Yavatmal
GST Bhavan, Administrative Building, Collector Office Campux, Civil Lines, Yavatmal- 445001
Kolhapur
19
Kolhapur
GST Bhavan, Near SP Office, Kasaba Bawda Road, Kolhapur-416003
20
Oras
Main Administrative Building, A Block, First Floor, Oras-416812
21
Ratnagiri
GST Bhavan, Boarding Road, Ratnagiri.
22
Sangli
GST Bhavan, Chintamani Nagar, In Front Of Mahda Colony, Off Madhav Nagar Road, Sangli-416416
23
Satara
GST Bhavan, 178A, Raviwar Peth, Satara-415001
Nanded
24
Nanded
Goods And Serv

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37
Jalgaon
GST Bhavan, Rasik Marg, Opp. Hotel Royal Palace, Ganpati Nagar, Jalgaon – 425001
38
Dhule
GST Bhavan, Gopal Nagar, Jamnagiri Road, Dhu1e-424001
39
Nandurbar
GST Karyalaya, Indira Gandhi Shopping Complex, Girivihar Gate, Nandurbar.
Who can avail this facility
1. The facility can be availed by taxpayers and new applicants.
2. Only 2 applications will be entertained per person (Copy of PAN card will be taken and also noted in electronic format).
3. Dealer themselves can attend and take benefit of this facility upon production of valid ID proof of ownership (as a proprietor, partner or director etc.)
4. Every form requires different type of information. Detail description of form type wise required information (of all the columns) is given in attached Annexure. Dealer/ authorized person are requested to bring proper information in given format in a pen drive for smooth and quick uploading of relevant forms.
5. Any person of behalf of dealer can avail this facility

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s clarificatory in nature. If any member of the trade has any doubt, he may refer the matter to this office for further clarification.
Yours faithfully,
(Rajiv Jalota)
Commissioner of State Tax,
Maharashtra State, Mumbai
No. JC (Nodal- 1)/E-Helpdesk/Trade Circular/B-3044
Mumbai. Dated: 24/10/2018
Trade Circular No 29T of 2018
Annexure
Requirement For Filing Of GST Returns
GSTR 3B:
1. Turnover & Tax on outward and reverse charge inward supplies
2. Inter-state supplies.
3. Eligible ITC.
4. Exempt, nil and Non GST inward supplies.
GSTR 1:
Data should be in format as per given in latest Offline Tool Version at https://www.gst.gov.in/dounload/returns
GSTR 4 : Composition Dealers)
Data should be in format as per given in latest Offline Tool Version at https://www.gst.gov.in/quicklinks/downloads-utilities
GSTR 5 (Non- Resident Taxpayer)
Original Details
* 3 – Import of Goods – To add details of inputs/ capital goods received from overseas
* 5 – Outward Supplies Made

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ended B2C (Small) – To add details of amendments to outward supplies to unregistered persons
GSTR 6 (INPUT SERVICE DISTRUBUTOR):
Data should be in format as per given in latest Offline Tool Version at https://tutorialgst.gov.in/offiineutilities/returns/GSTR 6 Offline Utility.zip
Requirement for filing GST refund
1] Refund of Excess Balance in Electronic Cash Ledger –
Details of cash ledger.
2] Refund of ITC on Account of Exports without Payment of Tax:
1. Turnover of zero rated supply of goods and services.
2. Adjusted total turnover.
3. Net input tax credit.
3] Refund on Account of Supplies made to SEZ Unit/ SEZ Developer (Without Payment of Tax)
1. Turnover of zero rated supply of goods and services.
2. Adjusted total turnover.
3. Net input tax credit.
4] Refund of ITC accumulated due to Inverted Tax Structure (RFD-01A)
1. Turnover of inverted supply of goods.
2. Tax payable on such inverted rated supply of goods.
3. Adjusted total turnover.
4. Net input tax credit.

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F
Private Limited Company
Certificate of Incorporation
1 MB
JPEG, PDF
Public Limited Company,
Certificate of Incorporation
1 MB
JPEG, PDF
Society/Club/Trust/AOP;
Trust Deed; Registration Certificate; Any Proof substantiating Constitution
1 MB
JPEG, PDF
Government Department;
Any Proof substantiating Constitution
1 MB
JPEG, PDF
Public Sector Undertaking
Certificate of Incorporation
1 MB
JPEG, PDF
Unlimited Company
Certificate of Incorporation
1 MB
JPEG, PDF
Limited Liability Partnership
Certificate of Incorporation
1 MB
JPEG, PDF
Local Authority;
Any Proof substantiating Constitution
1 MB
JPEG, PDF
Statutory Body;
Any Proof substantiating Constitution
1 MB
JPEG, PDF
Foreign Company
Certificate for Establishment
1 MB
JPEG, PDF
Foreign Limited Liability Partnership
Certificate for Establishment
1 MB
JPEG, PDF
2. While filling the details of , you are required to attach Photograph for each records entered. Maximum file Size

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C (In case of no/ expired agreement)
AND any 1 attachment
Rent/ Lease agreement OR Rent receipt with NOC (In case of no/ expired agreement AND
Property Tax Receipt OR Municipal Khata copy OR Electricity bill copy OR Legal ownership document
4
Consent
Consent letter AND any 1 attachment
Consent letter AND
Property Tax Receipt OR Municipal Khata copy OR Electricity bill copy OR Legal ownership document
5
Shared
Consent letter AND any 1 attachment
Consent letter AND
Property Tax Receipt OR Municipal Khata copy OR Electricity bill copy OR Legal ownership document
6
Others
Legal ownership document
Legal ownership document
5. Documents Required for Bank Accounts
Documents Required
File Type
File Size
First page of Pass Book
JPEG, PDF
100 KB
Bank Statement
JPEG, PDF
100 KB
Cancelled Cheque
JPEG PDF
100 KB
Any document issued by Bank on this behalf.
JPEG, PDF
100 KB
[II] Documents Required for Application for Registration as Tax Deductor
Please keep the scann

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Board of
Directors/ Managing Committee and Acceptance letter
JPEG, PDF
100 KB
Letter of Authorization
JPEG, PDF
100 KB
4. Documents Required for Principal Place of Business:
Sr.
Nature of possession of remises
Minimum No. of attachments
Proof of Principal Place of Business
1
Own
Any 1 attachment
Property Tax Receipt OR Municipal Khata copy OR Electricity bill copy OR Legal ownership document
2
Leased
Rent/ Lease agreement OR Rent receipt with NOC (In case of no/ expired agreement)
AND any 1 attachment
Rent/ Lease agreement OR Rent receipt with NOC (In case of no/ expired agreement AND
Property Tax Receipt OR Municipal Khata copy OR
Electricity bill copy OR Legal ownership document
3
Rented
Rent/ Lease agreement OR Rent receipt with NOC (In case of no/ expired agreement)
AND any 1 attachment
Rent/ Lease agreement OR Rent receipt with NOC (In case of no/ expired agreement AND
Property Tax Receipt OR Municipal Khata copy OR Electricity bill copy OR Legal owners

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(No Attachment required)
1MB
JPEG, PDF
Partnership;
Partnership Deed; Any Proof substantiating Constitution
1MB
JPEG, PDP
Hindu Undivided Family
Nil (No Attachment required)
1MB
JPEG, PDF
Private Limited Company
Certificate of Incorporation
1MB
JPEG, PDF
Public Limited Company
Certificate of Incorporation
1MB
JPEG, PDF
Society/Club/Trust/ AOP;
Trust Deed; Registration Certificate; Any Proof substantiating Constitution
1MB
JPEG, PDF
Government Department;
Any Proof substantiating Constitution
1MB
JPEG, PDF
Public Sector Undertaking
Certificate of Incorporation
1MB
JPEG, PDF
Unlimited Company;
Certificate of Incorporation
1MB
JPEG, PDF
Limited Liability Partnership
Certificate of Incorporation
1MB
JPEG, PDF
Local Authority;
Any Proof substantiating Constitution
1MB
JPEG, PDF
Statutory Body;
Any Proof Substantiating Constitution
1MB
JPEG2 PDF
Foreign Company
Certificate for Establishment
1MB
JPEG, PDF
Foreign Limited Liability Partnership

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nt
Rent/ Lease agreement OR Rent receipt with NOC (In case of no/ expired agreement AND
Property Tax Receipt OR Municipal Khata copy OR Electricity bill Copy QR Legal ownership document
3
Rented
Rent/ Lease agreement OR Rent receipt with NOC (In case of no/ expired agreement)
AND any 1 attachment
Rent/ Lease agreement OR Rent receipt with NOC (In case of no/ expired agreement AND
Property Receipt OR Municipal Khata copy OR Electricity bill copy OR. Legal ownership document
4
Consent
Consent letter AND any I attachment
Consent letter AND
Property Tax Receipt OR Municipal Khata copy OR Electricity bill copy OR Legal ownership document
5.
Shared
Consent letter AND any 1 attachment
Consent letter AND
Property Tax Receipt OR Municipal Khata copy OR Electricity bill copy OR Legal ownership document
6
Others
Legal ownership document
Legal ownership document
[IV] Documents Required to Complete the Application for Enrolment of GSTP
1. Applicant who is filing the applicat

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opy OR Electricity bill copy OR Legal ownership document
4
Consent
Consent letter AND any 1 attachment
Consent letter AND
Property Tax Receipt OR Municipal Khata copy OR Electricity bill copy OR Legal ownership document
5
Shared
Consent fetter AND any 1 attachment
Consent letter AND
Property Tax Receipt, OR Municipal Khata copy OR Electricity bill copy OR Legal ownership document
6
Others
Legal ownership document
Legal ownership document
3. Qualifying Degree: All the applicants except Retired Government Officials are required to attach the scanned copy of the Qualifying degree. Maximum file Size for attachment allowed is 1MB and File Type must be PDF / JPEG only. Multiple Documents uploads arc allowed.
4. In case of Government Officials, they are required to attach, "Pension certificate issued by AG officer Or LPC". Maximum file Size for attachment allowed is IMB and File Type must be PDF / JPEG only.
OTHER REQUIREMENTS
1. DSC is mandatory to all taxpayers e

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