Comments of the Department of Revenue (DoR) on the First Discussion Paper on GST

Dated:- 23-10-2015 – Sr. No. Para No. of the Discussion Paper Issues Comments of the DoR 1 3.1 It is important to take note of the significant administrative issues involved in designing an effective GST model in a federal system with the objective of having an overall harmonious structure of rates. Together with this, there is a need for upholding the powers of Central and State Governments in their taxation matters. Further, there is also the need to propose a model that would be easily implementable, while being generally acceptable to stakeholders. Agreed. 2 3.2 Keeping in view the report of the Joint Working Group on Goods and Services Tax, the views received from the States and Government of India, a dual GST with defined functions and responsibilities of the Centre and the States is recommended. An appropriate mechanism that will be binding on both the Centre and the States should be worked out whereby the harmonious rate structure along with the need for further modification c

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

ons should be levied by the Centre. SGST on imports should also be levied and collected by the Centre. Centre should pass on SGST collection on imports to concerned States on the destination principle. 4 3.2 (ii) The Central GST and the State GST should be applicable to all transactions of goods and services made for a consideration except the exempted goods and services, goods are outside the purview of GST and the transactions which are below the prescribed threshold limits. Agreed. There should be a common base for taxation between Centre and States. 5 3.2 (iii) The Central GST and State GST are to be paid to the accounts of the Centre and the States separately. It would have to be ensured that account-heads for all services and goods would have indication whether it relates to Central GST or State GST (with identification of the State to whom the tax is to be credited). Agreed. In addition, IGST should be paid to the accounts of the Centre. 6 3.2 (iv) Since the Central GST and Stat

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

djustment should be completed in a time bound manner. Agreed. 9 3.2 (vii) To the extent feasible, uniform procedure for collection of both Central GST and State GST may be prescribed in the respective legislation for Central GST and State GST. Agreed. 10 3.2 (viii) The administration of the Central GST to the Centre and for State GST to the States would be given. This would imply that the Centre and the States would have concurrent jurisdiction for the entire value chain and for all taxpayers on the basis of thresholds for goods and services prescribed for the States and the Centre. Agreed. The threshold for goods and services should be common between Centre and State on one hand and between goods and services on the other. 11 3.2 (ix) The present thresholds prescribed in different State VAT Acts below which VAT is not applicable varies from State to State. A uniform State GST threshold across States is desirable and, therefore, it is recommended that a threshold of gross annual turnov

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

al control is better addressed through a compounding scheme as well as administrative simplification for small dealers through measures such as: Registration by single agency for both SGST and CGST without manual interface No physical verification of premises and no pre-deposit of security Simplified return format Longer frequency for return filing Electronic Return filing through certified service centres / CAs etc. Audit in 1-2% cases based on risk parameters Lenient penal provisions There may not be any need to have direct link between compensation package, if decided for, and the threshold for registration for North-Eastern and special category States. 12 3.2 (x) The States are also of the view that Composition / Compounding Scheme for the purpose of GST should have an upper ceiling on gross annual turnover and a floor tax rate with respect to gross annual turnover. In particular there will be a compounding cut-off at ₹ 50 lakh of gross annual turnover and a floor rate of 0.5

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

e prevailing PAN-based system for Income tax facilitating data exchange and taxpayer compliance. There should be a uniform registration system through-out the country and this registration system should enable easy linkage with Income Tax database through use of PAN number. 15 3.2 (xiii) Keeping in mind the need of taxpayers convenience, functions such as assessment, enforcement, scrutiny and audit would be undertaken by the authority which is collecting the tax, with information sharing between the Centre and the States. Since the tax base is to be identical for the two components, viz., CGST and SGST, it is desirable that any dispute between a taxpayer and either of the tax administrations is settled in a uniform manner. The possibility of setting up a harmonised system for scrutiny, audit and dispute settlement may be developed. 16 3.4 On application of the principle, it is recommended that the following Central Taxes should be, to begin with, subsumed under the Goods and Services T

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

ions should be given. The difficulties of the food grain producing States and certain other states were appreciated as substantial revenue is being earned by them from Purchase Tax and it was, therefore, felt that in case Purchase Tax has to be subsumed then adequate and continuing compensation has to be provided to such States. This issue is being discussed in consultation with the Government of India. Purchase tax is nothing but sales tax where the responsibility for collection of tax is with the purchaser (and not with the seller as in the case of sales tax). Keeping purchase tax outside will give the loophole to the States to impose purchase tax on any commodity (food-grains, agricultural / forest produce, minerals, industrial inputs etc.) over and above GST. Hence, purchase tax must be subsumed. The compensation package, if agreed, need not have any link to any particular tax being subsumed. Tax on items containing Alcohol: Alcoholic beverages may be kept out of the purview of GST

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

e. crude, motor spirit (including ATF) and HSD should be kept outside GST as is the prevailing practice in India. Sales Tax could continue to be levied by the States on these products with prevailing floor rate. Similarly, Centre could also continue its levies. A final view whether Natural Gas should be kept outside the GST will be taken after further deliberations. Keeping crude petroleum and natural gas out of the GST net would imply that the credit on capital goods and input services going into exploration and extraction would not be available resulting in cascading. Diesel, ATF and motor spirit are derived from a common input, viz., crude petroleum along with other refined products such as naphtha, lubricating oil base stock, etc. Leaving diesel, ATF and motor spirit out of the purview of GST would make it extremely difficult for refineries to apportion the credit on capital goods, input services and inputs. These products are principal inputs for many services such as aviation, ro

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

e adopted. Such a decision may be taken and communicated to DoR. 17 3.5 Inter-State Transactions of goods & services: The Empowered Committee has accepted the recommendations of the Working Group of concerned officials of Central and State Governments for adoption of IGST model for taxation of inter-State transaction of Goods and Services The scope of IGST Model is that Centre would levy IGST which would be CGST plus SGST on all inter-State transactions of taxable goods and services with appropriate provision for consignment or stock transfer of goods and services. The inter-State seller will pay IGST on value addition after adjusting available credit of IGST, CGST, and SGST on his purchases. The Exporting State will transfer to the Centre the credit of SGST used in payment of IGST. The Importing dealer will claim credit of IGST while discharging his output tax liability in his own State. The Centre will transfer to the importing State the credit of IGST used in payment of SGST. Th

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

and services and for Centre and States. Having more than one rate either for CGST or SGST will complicate the working of IGST model. 18 3.6 GST Rate Structure: The Empowered Committee has decided to adopt a two-rate structure – a lower rate for necessary items and goods of basic importance and a standard rate for goods in general. There will also be a special rate for precious metals and a list of exempted items. For upholding of special needs of each State as well as a balanced approach to federal flexibility, and also for facilitating the introduction of GST, it is being discussed whether the exempted list under VAT regime including Goods of Local Importance may be retained in the exempted list under State GST in the initial years. It is also being discussed whether the Government of India may adopt, to begin with, a similar approach towards exempted list under the CGST. There should be a single rate of SGST both for goods and services. A two rate structure for goods would pose the f

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

regime. At the end, there must be a common list of exemptions for CGST and SGST. The States are of the view that for CGST relating to goods, the Government of India may also have a two-rate structure, with conformity in the levels of rate under the SGST. For taxation of services, there may be a single rate for both CGST and SGST. There should be one CGST rate both for goods as well as services. The exact value of the SGST and CGST rates, including the rate for services, will be made known duly in course of appropriate legislative actions. SGST and CGST rates are required to be put in public domain much before initiation of legislative action. 19 3.7 Zero Rating of Exports: Exports should be zero-rated. Similar benefits may be given to Special Economic Zones (SEZs). However, such benefits should only be allowed to the processing zones of the SEZs. No benefit to the sales from an SEZ to Domestic Tariff Area (DTA) will be allowed. Agreed. 20 3.8 GST on Imports: The GST is proposed to be l

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

fter collection of tax, so that the GST scheme on the basis of a continuous chain of set-offs is not disturbed. Regarding Special Industrial Area Schemes, it is clarified that the benefits of such exemptions, remissions etc. would continue up to legitimate expiry time both for the Centre and the States. Any new exemption, remission etc. or continuation of earlier exemption, remission etc. would not be allowed. In such cases, the Central and the State Governments could provide reimbursement after collecting GST. Agreed. 22 3.10 IT Infrastructure: After acceptance of IGST Model for Inter-State transactions, the major responsibilities of IT infrastructural requirement will be shared by the Central Government through the use of its own IT infrastructure facility. The issues of tying up the State Infrastructure facilities with the Central facilities as well as further improvement of the States own IT infrastructure, including TINXSYS, is now to be addressed expeditiously and in a time bound

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

ow. Department of Revenue is closely working with Ministry of Law, Government of India, for finalisation of draft Constitutional amendment. The issue of empowering States to levy GST on imports has been deliberated by the JWG and the view which has emerged out of discussion is that the Centre shall collect GST on imports and pass on the SGST component of it to concerned State on destination principle. 24 3.12 Harmonious structure of GST and the States autonomy in federal framework: As a part of the exercise on Constitutional Amendment, there would be, as mentioned earlier, in para 3.2, a special attention to the formulation of a mechanism for upholding the need for a harmonious structure for GST along with the concern for the States autonomy in a federal structure. Agreed in principle. 25 3.13 Dispute Resolution & Advance Rulings: As a part of the exercise on drafting of legislation, rules and procedures for the administration of CGST and SGST, specific provisions will also be made

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =

s duly in every month on the basis of neutrally monitored mechanism. Empowered Committee has already referred the issue to the Thirteenth Finance Commission (TFC). TFC is likely to submit its report shortly. A view on the subject will be taken after more clarity on the subject is available. 27 3.15 With this First Discussion Paper and the Annexure on frequently asked Questions and Answers on GST, interaction with the representatives of industry, trade and agriculture would begin immediately at the national level, and then also simultaneously at the State levels. Similarly awareness campaign for common consumers would also be initiated at the same time. As a part of the discussion and campaign the views of the industry, trade and agriculture as well as consumer may be sought to be obtained in a structured and time bound manner. Empowered Committee may prepare a plan with clear timelines for orientation of stakeholders so that required steps may be taken by all the States in time. – News

= = = = = = = =

Plain text (Extract) only
For full text:-Visit the Source

= = = = = = = =