Goods and Services Tax – GST – By: – Mohammed Lakkadsha – Dated:- 9-9-2017 Last Replied Date:- 11-9-2017 – PART-II Open Letter to the Honourable Prime Minster of India My Experience with GSTN- Workable suggestion to Make GSTN a success As an addendum to my earlier open letter to Honorable Prime Minister of India, I thought to pen down suggestion based on my experiences; input from various professional colleagues and taxpayers -how the GSTN network should work to really term it as user friendly. The successful implementation of GST Law heavily depends on technology, as government plans to make it front end and done way with all kinds of manual intervention. Backdrop: It is worthwhile to note that GSTN system has been designed by one of the most valued software company of India Infosys Limited (Company is also managing MCA and other Government portal) which is going to be cost 1380 Crores to the Government. The development cost incurred by the government on GSTN is not a big issue, but
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overcome such bottleneck over the period and matured enough to be replicated for new tax system like GST. Real bottleneck is Numbers & time line of Filing: In view of large numbers of user which is estimated at 70-80 lacs which will be soon exceed the 8-digit figure, the present online system will not work as return filing process is time bound and it is most likely that 80% of user will log in last 2-3 days to file their return, ultimately queuing theory will fail as µ > λ (Service Time is Greater than Arrival Rate). WHAT IS THE SOLUTIONS TO LARGER PROBLEM: A Robust Offline Utility – The Solution to present day situation can be only providing fast & robust offline utility with all validation checks; sensitive help and troubleshooting for generating Offline Return file to be uploaded on GSTN portal. Replacement of existing un-workable Three Tier system -The system of filing Outward return(GSTR1), followed by matching (GSTR2/2A/1A) and finally generating consolid
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urn before finalizing the liability of taxpayer and converting it to demand or refund to be carried forward in next quarter returns. Reduce return Frequency – The most important and burning issue amongst all the taxpayer is monthly frequency of compliance. Every taxpayer must go through same process every month which requires lot of resources in terms of Time & money, which every taxpayer cannot afford. One Time longer frequency to adjust to new system – Beside Initially when every taxpayer and consultant are struggling to understand new Law, concepts and reporting standards, the frequency should be of six months to nine months for the current financial year 2017-18 and which can be subsequently settled down to ideal period of quarter. Monthly Summary return to assure Tax collection – The government concern for revenue collection can be taken care by imposing a single page summary monthly return as presently termed as GSTR-3B to be filed within 15-21 days of completion of month alo
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view of vide acceptance of smart phones, preferably mobile applications should be provided for locating correct HSN code and corresponding tax rate applicable. Submission of other Forms – Other necessary Submission need to be made available online immediately and alternatively through manual system initially which can be done away once online system gets smooth and workable. The issue under Composition scheme (Opt-In/ Opt-Out); registration cancellations; need to be sorted out immediately. Ensure speedy resolution at Local Department Level – The local department offices should be armed with interface for speedy disposal of issue arising, which cannot be resolved under available system. Making law Simpler to reduce the system complexity- The taxability under reverse charge being a totally new to business specially in SME sectors is making un-workable at grass root level. Instead of that all business and service provider should be Invariably asked to register and should be kept out of ta
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d provide updated details of Dealers so that proper status (Regular/Composition) can be known before entering into transaction. Verification (EVC /DSC) – Presently the system requires OTP for various services, there is no provision to change the contact details (email ID and or Mobile number) given at the time of registration, which need to be implemented with proper security check before change the contact details. The verification with DSC option should be made workable in line with ITD site. Effective Redressal System – A Well-equipped redressal system should be established in form of online portal manned with resourceful and skilled staff to resolve all sorts of issue of taxpayers. The queries raised to GSTN should be replied in specified time as per Service Level Agreements (SLAs). Where such queries are not replied, the action of the taxpayer should be considered bonafide and no interest on penalty should be charged for any action or inaction resulting from system errors or issue
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esirable as they are user friendly and already adapted by the professional. Provide redressal portal for authoritative and timely solution Providing Taxpayer, a reasonable time preferably by the end of this fiscal year to adapt to new law and system and make them ready for proper compliances. The government should also think on lines of consolidating compliances under various fiscal law for providing a common portal for submission of business information be it be Financial statement, Audit report or trade specific compliances. This will greatly help in reducing compliance time, duplication of data and interoperability of data. Government need to be responsive and consultative to taxpayer demands, then only user friendly robust GSTN System can be implemented in real terms or it will remain like another government command to be followed under fear of enforcement system. Taxpayer are keeping their fingers crossed and hopeful of getting needed relief. User friendliness should be given more
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