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PART-II Open Letter to the Honourable Prime Minster of India My Experience with GSTN-  Workable suggestion to Make GSTN a success

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. .....

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hether the system delivered what was originally perceived is a big question- as reported in media the system was required to handle 60000 transactions per second. Also, Question arises While designing the system why not existing online filing system and their acceptability at grassroot level was reviewed so as deliver best in class system. Before adopting any system for compliance of one of the biggest Tax system of the country, government should have assessed ground realities of the taxpayers i .....

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vercome 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 (S .....

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ted return (GSTR3) is not a workable preposition. The system will be a big failure as every return is dependent not only on of earlier return of same taxpayer but also reruns to be filed by corresponding sellers. Every Default & delay in filing return will have impact on other returns making the whole filing process a redundant system. The primary question arises why such real-time system is required, which is forcing sleepless nights for users of the system. Single Consolidated Quarterly Re .....

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rn 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 a .....

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g with Tax payment. Delay in filing 3B and payment thereon should be compensating by way of interest only for one more filing period after which a reasonable penalty can be levied. Ease of Payment and Adjustment -The payment of taxes should be allowed on consolidated basis under single head to be credit to taxpayer cash ledger, which can be utilized to set of liability under any heads of tax. The faster reflection of taxes paid into cash ledger should be ensured in all modes of payment. Ease of .....

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iew 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 .....

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net by providing basic exemption limit and providing compliance waiver to such business till they exceed the limit. Similarly, various intricacies of law should be removed resulting in difficulty in compliances. Reduce TAT for Registration- On registration front, the system akin to erstwhile ACES system should be adopted wherein PAN should be linked to the IT database so that PAN validation error due to name mismatch is done away. Presently the system tests you to provide your name as per PAN w .....

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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. E .....

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. Synchronization of Law & System - A lot of inconsistencies is prevailing in systems vis-à-vis the coded law. A proper check to be done to ensure whether the GSTN system and the law are in complete sync and to ensure that the system does not override the law or puts additional conditions or controls not visualized by the law to the detriment of the taxpayer. To sum up, to create a user friendly GSTN system following solutions need to be implemented: Discontinue monthly filing system .....

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