KEY 21 SUGGESTION ON DRAFT GST RETURN

The GST Council in its 28th GST Council Meeting held on July 21, 2018 under the Chairmanship of Shri Piyush Goyal, Union Minister for Railways, Coal, Finance & Corporate Affairs had approved the new return formats. The Council had earlier approved the basic principles of GST return design and directed the law committee to finalize the return formats and changes in law. In pursuance thereof, the CBIC has placed Note on draft GST simplified returns and return formats in public domain on July 30, 2018 for perusal and feedback of stakeholders.


Following suggestions were compiled by Mr. Bimal Jain, Chairman, Indirect Tax Committee, PHD Chamber of Commerce towards making Return system and formats simplified for all taxpayers, which have been submitted to the Government for their kind consideration:

I   Date of implementation and mock drill

We understand that the government is expected to roll out the revised return frameworks from the beginning of the next calendar year i.e. January 2019. Implementing the new framework in the mid of the financial year is likely to create hassles for the taxpayers in terms of performing reconciliations.
Suggestion(s):
·         Implementation from next financial year - It is therefore humbly requested to kindly consider roll out of the new system from the beginning next financial year i.e. with effect from April 1, 2019. Further, new system of return may be introduced as trial option for 3 months if the Govt. is willing to introduce the new framework effective from January 2019.
·         API for system configuration - Please release the Return API by October 2018 so that sufficient time is available for system configuration and sync with ASP/GSP.
·         Selected companies for mock return filing - Further, it is requested to kindly consider for providing opportunities to certain selected companies to undertake a mock return filing under this new framework, sufficiently before being implemented.  This would give an opportunity for industries to practically experience the practical aspects in the framework and to understand the finer aspects in the whole process and also give an opportunity to the GSTN to have a check over various technical and validation issues and take necessary rectifying measures well before the new return filing framework is getting implemented.
·         Offline Utility of New Return format to be released by September for practical training of the tax payers on new return formats with SOP and guidance note of its usage.

II   Non-editable tax amount field

The new formats provide for system-based auto-computation of tax amount basis the taxable value and tax rate. It is also provided that that tax amount so computed will not be editable except in case of credit/debit notes issued.
Attention is drawn towards the fact that there can be genuine mistakes on the invoices where the multiple of taxable value and taxes have not been charged on the invoice and debit/credit notes have been issued for the differential. If the tax amount is auto-calculated by the portal, there would exist mis-matches in the invoices issued by the suppliers and the information uploaded on the portal.
Further, depending upon the rounding off logic of various IT Systems, the auto calculated figure may not be equal to the amount considered in books of accounts of dealers and therefore, can lead to infinite validation errors in data upload through ASP – GSP. In past, this issue has already been experienced which caused a huge unrest amongst the dealers and GSTN.

Suggestion(s):
·         Tax amount field to be made editable - It is humbly submitted that this field should be made editable so as to allow actual invoice reporting and no validation/tolerance limit be imposed on the assessees.

III   Quarterly return by small suppliers may result in block of working capital at recipient’s end
In the new return filing mechanism an exemption has been given to dealers having turnover upto Rs. 5 crores in last financial year to file quarterly returns with a facility to upload invoices in the normal course.
Apprehensions are being raised that if only an option is provided, hardly any such suppliers will rigorously upload the invoices on a continuous basis which will actually lead to a delay in credit realization in the hands of the recipients and blockage of working capital.

Suggestion(s):
·         Uniform monthly invoice uploading by all suppliers - It is requested that whilst these dealers can be allowed to file their returns quarterly, let there be one uniform statutory frequency of invoice uploading i.e. monthly for all dealers without any facility for cancellation / revoking at the supplier’s end.

IV   Missing invoice reporting in monthly return
 “Monthly return” allows the taxpayer to claim credits of any supplies which have not been uploaded by suppliers in Row 7, Part A of Table 4 wherein the user is required to furnish the amount of input tax credit and value. Further, “The Annexure of Supplies to main return” provides a table for reporting details of missing invoices on which credit had already been claimed, but the same have not been uploaded by the supplier in the next two tax periods.

Suggestion(s):
·         No table to furnish document level details of missing invoices of the relevant tax period - However, the return framework document does not clarify as to where the impact of such document level details of missing invoices of particular tax period would be taken in the monthly return.

V   Facility of missing and pending invoices should also be given to small taxpayers
Para 3 on Page No. 10 states that Quarterly return shall be akin to the monthly except that it has been simplified and shall, inter alia, not have the compliance requirement in relation to missing and pending invoices as small taxpayers do not use these procedures in their inventory management.

Suggestion(s):
Facility of adding missing invoices should be allowed to small taxpayers – The impact of input tax credit from missing invoice can be substantial even for small taxpayers even if they have fewer transactions. Thus, this facility must be allowed.

VI   Missing clarity on period up to which supplier can upload missing invoices
As regards reporting of Missing Invoices, Sr. No. 10 at page 17 gives an example. In this example it has been clarified that if the credit has been availed by the recipient in April but the corresponding invoices have not been uploaded by the supplier till filing of return for the month of May (i.e. latest by 20th June), recipient will have to report all such invoices while filing the return for the month of June. While Table 3L at page 14 requires the recipient to report in current month’s return i.e. June all invoices on which credit was availed in T-2 tax period i.e. April but the same have not been reported by the supplier till filing of current tax period return (i.e. latest by 20th July).
Thus, there seems contradiction on same thing mentioned at two places.

Suggestion(s):
·         Guidance document on treatment of missing invoices - It is submitted that a separate guidance document should be created addressing to such concerns specifically with respect to the concept of missing invoices. It is also requested to clarify as to how the concept of missing invoices would work in subsequent phase including the impact of cutover transactions (i.e. input tax credit already claimed during this phase but invoices not uploaded by supplier in the current phase).

VII   Recovery from recipient for credit taken on missing invoices
Para 6 on Page No. 4 states that the Invoices or debit notes which have not been uploaded by the supplier and the recipient has availed input tax credit shall be considered as “missing invoices”. If such missing invoices are not uploaded by the supplier within prescribed time period, then ITC on such invoices or debit notes shall be recovered from the recipient.

Suggestion(s):
·         Adverse impact on recipient - If recipient has taken credit on the basis of invoice called as "missing invoice" and recipient has uploaded complete data of the invoice on the portal, then it should be good enough to avail input tax credit by recipient and action should be taken against supplier not uploading the invoice and recipient should not be asked to reverse input tax credit.
Moreover, if, above procedure is not possible and even after due follow up with the supplier, invoices are not being uploaded by the supplier, credit should not be get reversed at recipient end because it will block the working capital of the company and it will take huge time to search & account missing invoices & reporting them in the return which results wastage of manpower, time & money in following up with the suppliers.
It is suggested to allow input tax credit on self-declaration basis as is in transitional period of six months or if it is not possible, then, in case of missing invoice, only after uploading supplier's data on the portal, credit should be allowed to the recipient.

VIII  Supply side control
Para 30 on Page No. 8 states that for a newly registered taxpayer and a taxpayer who has defaulted in payment of tax beyond a time period and/or above a threshold, uploading of invoices shall be allowed only upto a threshold amount or only after the default in payment of tax is made good respectively.

Suggestion(s):
·         Fixing threshold limit for uploading invoices by newly registered taxpayer is unjust - Restricting a newly registered user to upload invoices up to a certain threshold is not proper without any grounds of default made by him. It is merely based on presumption that newly registered taxpayer may be incapable of discharging the tax liability. New registration does not necessarily mean a new assessee, it could also be a new registration of an existing large solvent taxpayer.
·         Adverse effect on recipients – Fixing threshold for defaulting supplier would mean that those buyers whose invoices were uploaded before reaching threshold will get credit and the rest will suffer. Further, there is no clarity as to how will a buyer get visibility of defaulter status of supplier and thus be cautious in making purchases from such suppliers.

IX   Reporting of shipping bill/ bill of entry details
It is submitted that no separate field has been provided for reporting bill of entry/ shipping bill number and date in the revised return formats. In this regard, there is lack of clarity as to whether these details would be required at a later date for performing invoice matching with the data available on ICEGATE. (Section 3J of Table 3 Annexure of Supplies to main return).

Suggestion:
·         It is thus humbly submitted to issue clarification with respect to reporting of bill of entry details while filing monthly returns.

X   Separate reporting of transactions covered under Schedule III
This is an additional reporting requirement of activities, which are neither a supply of goods nor supply of services, which has been incorporated in the new formats.

Suggestion(s):
·         Additional compliance burden - Reporting of such transactions would require taxpayers to make changes in their IT systems for identification of the same. Further, reporting of these transactions would create additional compliance burden on the tax payers. Therefore, it is requested to provide abundant clarity for reporting of transactions under the said Schedule

XI   ‘Non-GST supply’ Vs. ‘No supply’
Part D of Table No. 3 i.e. ‘Details of supplies having no liability’ in the monthly rerun, inter alia, requires separate disclosure as to the following:
1.    Exempt and Nil rated supplies;
2.    Non-GST supplies;
3.    No supply (Schedule III, Section 7)
Suggestion(s):
·         Exempt supplies already include Nil-rated supplies – Definition of ‘exempt supply’ under Section 2(47) of the CGST Act, 2017 is given as under:
“exempt supply” means supply of any goods or services or both which attracts nil rate of tax or which may be wholly exempt from tax under section 11, or under section 6 of the Integrated Goods and Services Tax Act, and includes non-taxable supply
Thus, when definition of exempt supply itself includes Nil rated supplies, separate mention of the same under Row 1 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.
·         Difference in ‘non-GST supply’ and ‘no supply’ – If schedule III items are to be treated as no supply for which separate reporting is required in Row 3 above, then items to be treated as ‘non-GST supply’ requires more clarity viz-a-viz non-taxable supplies and Schedule III items.

XII   Linking of Credit Notes with corresponding invoice
Para 16 at page no. 6 talks about a situation where a credit note has been issued on an invoice which has been kept pending by recipient. In such situation, it says that both the credit note and the original invoice shall be linked in the system so that excess credit is not taken by the recipient. However, there is lack of clarity as regards to below points:
Suggestion(s):
·         Clarity on establishing linkage between credit note and corresponding invoice no - Supplier is required to provide the details of credit notes in Table 3 of ‘Annexure of Supplies to Main Return’. But, the format of this table nowhere requires a supplier to give reference of original invoice no. on which credit note has been issued. In absence of this detail, it is not clear how the system will be able to establish linkage between credit note and corresponding invoice no.
·         Clarity on handling multiple invoices against single credit note - The proposed amendments in GST Law allow a supplier to issue single credit note against multiple invoices. Therefore, going forward there may certainly be a situation where a single credit note has been issued on multiple invoices out of which some invoices have been locked by recipient and some invoices have been kept pending. It is not clear, how the system will take care of such situation.
Therefore, it is requested to provide abundant clarity in this connection by setting out in details the process of linking credit notes with the original invoices.

XIII   HSN wise summary
The table for reporting supplies with the tax liability at various tax rates shall not capture HSN but would continue to capture supplies at different tax rates as is the present practice. The details of HSN shall be captured at four digit or more in a separate table in the regular monthly return as well as quarterly return.
Suggestion(s):
·         Generating HSN summary thus becomes an additional work.
·         For small taxpayer’s requirement to report HSN details can be done away with.
·         Preparing invoice data by grouping values tax rate-wise is not the general practice adopted. If invoice is grouped tax rate-wise it becomes difficult for buyer to reconcile with his physical invoice which has item-wise details. Thus, taxpayer should be allowed to upload invoice ‘as is’.

XIV   Switching from quarterly to monthly return in middle of quarter
As per Para 2 on Page No. 10, option for filing monthly or quarterly return shall be taken from these small taxpayers at the beginning of the year and generally thereafter they would continue to file the return during the year as per the option selected. During the course of the year, option to change from monthly to quarterly or vice-versa shall be allowed only once and at the beginning of any quarter.
Suggestion(s):
Switching in between may be permitted in exceptional cases – In exceptional scenarios like executing bulk order in middle of the quarter, small taxpayers would need the flexibility to change return type in between the the applicable quarter and comply with  return type as applicable to him for the relevant and subsequent quarter.

XIV      Complexity in reporting requirements for input tax credits (Table 4 of Monthly Return)
·         Inward supplies not received during previous tax periods on which ITC was kept pending: Manner of populating the information during the first month is not clear and clarity is also needed whether numbers will be auto-captured in the subsequent months from Annexure of Inward Supplies of previous month and will capture all pending invoices as on start of the month.
·         Inward supplies received (other than those attracting reverse charge): Whether the field will capture all documents issued during the tax period i.e. irrespective of action taken by taxpayer in the Annexure to inward supplies.
Example:
Total Invoices uploaded by various suppliers in May – 500
Accepted by Recipient – 300
Rejected – 150
Kept Pending – 50
Previous month’s pending Invoices shown in Last Month’s B5 – 200
Accepted during current month out of these 200 invoices – 100
Queries:
·         How many invoices will be captured in Table 4A – Sr. No. 1 [Inward supplies not received during previous tax periods on which ITC was kept pending] - will it be 200 reported in B5 during previous month?
·         Whether Sr. No. 2 of 4A [Inward supplies received (other than those attracting reverse charge)] will include all invoices issued during current month i.e. 500 or it will include only 300 accepted during current month?
·         Whether Sr. No. 2 of 4A will also include previous month’s pending invoice accepted during current month i.e. 100?
·         How many invoices will be shown in B5 of current month - will it be 150 invoices viz. 50 invoices pending out of current months’ and 100 invoices pending out of previous month’s pending invoices?
Suggestion - It is requested to clarify with examples how the data will flow into various rows of this table to avoid any ambiguity.
Further, the clarity also needed for capturing the details of ITC for import of goods, import of services and other reverse charge transactions – Please note that the Annexure of outward supplies, inward supplies attracting reverse charge and imports only requires us to furnish the details of taxes charged and not input tax credit eligible on the same.

XVI   Input tax credit claimed earlier (Row 7, Table 4 Part B)
The specific row captures auto-population of input tax credits claimed earlier. Please note that the framework document or the notes to the monthly return do not capture any information on the manner of capturing details in this particular row.
Suggestion(s):
·         Specific guidelines required for such reversal - It is requested to provide specific guidelines for various scenarios where any of such input tax credit which was claimed earlier would be subject to an auto-reversal as part of the monthly return.

XVIII   Credit in respect of goods or services received in next month
Para 13.2 of Note on Returns (Page No. 6) explains that recipient will be eligible to avail input tax credit in respect of goods or services received after 1st of Next month but before 20th where the supplier has uploaded the invoices up to 10th of next month. This implies that even for the supplies received in the subsequent month, credit can be availed by buyer in the previous month itself depending on the data upload by the supplier.
Suggestion(s):
·         Mis-match with law provisions - In this regard, it is requested to please clarify if the same is in line with the provisions of the GST Law under Section 16(2) of the CGST Act, 2017, wherein receipt of goods & services is the primary condition for availing credit or necessary amendments in Law will be made to take care of this modality of availing input tax credit in such situation.

XVIII   Effect on input tax credit if invoices are uploaded but no Return filed by supplier
Table 3 Column 9 of ‘Annexure of Inward Supplies’ (Page 24) captures the date of data upload as well as date of return filing by the supplier. However, industry is not clear on consequences if the supplier has uploaded the invoice by due date i.e. 10th of next month but not filed the monthly return by 20th on next month.
Suggestion(s):
·         Clarity on flow of credit in Table 4 where return is not filed by supplier - It is requested to please clarify whether in such cases also, where return has not been filed by the supplier, input tax credit will automatically flow into Table 4 of Monthly Return and thus credit will be available to the recipient.

XIX   Amendment Return
Para 20 on Page No. 7 states that there would be facility to file two amendment returns.
Suggestion(s):
·         No restriction on number of amendments - It is requested to allow multiple amendments in the monthly return irrespective of the number of amendments keeping in mind that the initial challenges which would be faced during the implementation. Since taxpayer would be paying higher rate of interest (in case of liability) there should not be any restrictions on number of amendments possible. Filing of annual return will indicate closure of books for a given FY.
Also, a detailed guideline for use of the functionality should be provided.

XX     Transitional mechanism required to handle cut over transactions on transition to new framework
Please note that once the new framework is implemented, any changes/ amendments for the transactions reported during the ongoing return process may also be required. Further, any ITC claimed earlier for which invoices have not been uploaded by vendor or vice versa (i.e. invoices uploaded but credit claimed during the new framework) would also require to be reported.
Suggestion(s):
·         Detailed mechanism required - In this regard, it is requested to provide details of all such scenarios along with necessary reporting framework for cut over transactions or transactions pertaining to past period (i.e. pre-implementation of new return framework).
·         It is suggested to make arrangement on GST Portal to generate annual summary of GSTR 3B and GSTR 1. It will be helpful to the taxpayer to find out mistakes made during the filling of above said returns.

XXI   Others:
·         For supply of goods, taxable event does not arise at the time of advance payment and hence user need not be asked to provide advance received/adjusted information as part of the return.
·         System should assist user to calculate interest & payment amount on account of reversal of credit by taking all the relevant information.
·         E-Sign of return (Aadhaar OTP based) to be provided. It is simpler and more affordable than DSC based signing.
·         Format of GST Return should be based on Excel sheet like Income tax Return (Auto calculated).
·         Cash ledger on GST portal to be treated as wallet with freedom for cross utilization (across major and minor heads of tax/interest/penalty for IGST/CGST/SGST).


          

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indua,4,NRI.PIO,17,NSC ACCRUED INTEREST,15,NSC INTEREST CALCULATOR,8,nsc.,9,NSDL,4,NSE,2,NUMBER TO TEXT,1,numbers in to text,1,OCI,3,official notification,1,official website,2,oidar,1,oltas,4,one increment,2,ONE RANK ONE PENSION,1,one thousand rupee note,2,online,1,ONLINE BALANCE CHECK EPF,4,online bsnl bill verification,2,online deposit of tax,7,online earning,1,online emi calculator,1,online employee provident fund,3,online epf balcnce,8,online filing of service tax return,14,ONLINE FOREX TRADING,1,online life insurance,6,ONLINE PAN,2,online pan verification,3,online rectification itr,2,online refund,16,ONLINE REFUND STATUS,7,ONLINE REGISTRATION OF COMPANY,2,online return rectification,2,online service tax,2,online services by Govt,1,ONLINE ST-3,7,online tan regsitration,6,online tds payment,4,ONLINE VAT,2,opc,2,OPEN OFFER,1,option date,2,orop,1,other forms,1,other income to employer,3,out of debt,2,OUTPUT SERVICE TAX CREDIT,1,OUTSTATION CHARGES,2,own name,1,PACKAGE SOFTWARE,2,PAN,5,PAN ADDRESS,5,pan and income tax return,1,PAN AO CODE,6,pan application excel,4,pan correction,2,pan details,1,PAN LEDGER,8,pan login,7,pan mandatory for hra,2,pan mandatory in etds,2,pan name verificatio,3,PAN ON RENT RECIPT,1,pan regsitration,2,PAN STATUS NSDL,2,PAN STATUS UTI,1,PAN STRUCTURE,4,PAN SURRENDER,1,pan transfer,1,pan verification,8,pan vs return,1,parcel,1,PARNERSHIP,1,part time course tuition fees,3,part of the year employee form 16,2,part of the year employee form 24q,1,partial reverse charge in service tax,25,partial withdrawal,3,partner salary,5,PARTNERSHIP DEED,4,PARTNERSHIP RATES,1,passport,1,PASSWORD,4,PATENT,1,pay bands,3,Pay calculator,3,pay calculator revised,1,pay commission punjab,1,pay fixation examples,2,pay per post,1,PAY SERVICE TAX ON DUE BASIS,5,payable at par,1,paybands,1,payment bank,1,PAYMENT BY ACCOUNT PAYEE CHEQUE,4,payment by cheque income tax,2,payment due date reminder,1,payment exceeding 20000-35000,1,payment of gratuity act,5,paypal,1,paypal ceiling,1,PDF UTILITY,4,penalty for service tax,8,penalty if cheque cleared late,4,penalty on concealment of Income,7,penalty on late filing non filing of etds return,7,penalty on late filing of income tax return,20,pension,12,pension arrear,2,pension calculator,4,pension da,1,pension fitment,1,pension gazette notification,1,pension notification,1,pension on grade pay military pay,2,pension policy,2,pensioner benefit,3,Permanent account number,7,PERSONAL ACCIDENT INSURANCE,3,personal finance software,3,personal loan,3,PETROL DIESAL SAVE FISCAL DEFICIT,8,PETROL DIESEL PRICE HIKED,12,PETROL EXPENSES VALUATION,8,petrol prices reduced,5,PFC,1,PFC INFRA BONDS,2,PFC TAX FREE BONDS,2,pfrda,2,PHONE BANKING,2,phone password,1,pin,1,pivot tables,3,Place of Provision of Services Rules,4,PLAYER AUCTION,1,pmay,7,pmjdy,10,PMS,2,pmvvy,1,pnr,1,Point of sale,8,POINT OF TAXATION,45,political party deduction,2,Poppy Seeds,1,portfolio,1,POST GRADUATE TEACHER,1,post office fixed deposit,8,post office recurring deposit,9,post office saving deposit account,6,post office schemes,14,postal ballots,1,postal order,2,POWER FINANCE BONDS,2,POWER OF ATTORNEY,1,PPF,35,PPF CALCULATOR,16,ppf huf account,4,ppf interest rate,18,ppf limit,24,ppp,1,ppt,8,ppt fbt,3,ppt on budget 2011,1,PPT UP VAT,1,pranav mukharjee,1,pre construction interest,3,PRE EXISTING E-1 TRANSACTIONS,1,pre filled challan income tax,1,prepayment,1,prepayment penalty,4,press release,1,press release 14.08.2008,3,presumptive tax scheme,13,preventive health check up,4,PRIMARY TEACHER,1,PRINCIPAL,1,printing manual,1,private limited company,10,PROF. TAX,1,profession tax,2,PROFIT RATE UNDER 44AF,1,provident fund dues,1,PROVISION OF FBT ON ESOP,1,provisioning of npa,2,PSPCL,1,PSTCL,1,PSU PAY HIKE,2,public limited company,2,public provided fund,8,PUBLIC SHARE HOLDING IN LISTED COMPANY,2,punjab govt arrear calculator,1,PUNJAB VAT,20,punjab vat notification,16,purchase of residential house,1,pure agent,1,qfi,1,quarterly statement status,3,QUIZ,9,rail freight,6,railway budget,12,railway budget 2012,2,railway ticket,9,RAILWAYS BUDGET 09-10,2,RAILWAYS BUDGET 11-12,1,rajiv gandhi equity saving scheme,13,RAJKUMAR S ADUKIA,4,ramalingam,15,Rate of return,1,RATES AFTER BUDGET,1,rates of service tax,3,rbi,79,RBI ACT,22,RBI Circular on e-payment of taxes,2,RBI FALSE CALLS,9,RBI FALSE MAIL,5,RBI INSTRUCTIONS GAR-7,1,RBI MONETARY POLICY,13,rbi monetary policy 2012,2,RBI NOTIFICATIONS,7,rbi report on customer services,2,ready reckoner income tax,4,REAL ESTATE,7,Real Estate Investments,4,REAL TIME GROSS SETTELEMENT,1,reason for mis matching,6,REBATE ON INPUT GOODS AND SERVICE,3,REC Bonds,3,rec infra bonds,1,rec tax free bonds,2,recent,210,rectification of return online,4,reducction in crr,1,refinance calculator,3,refund,8,refund due to diff in valuation of perquisites,3,refund of service tax on cancellation of tickets,4,refund pilot scheme,4,refund without matching,6,registration charges tax saving,1,RELIANCE COMMERCIAL FINANCE,1,RELIANCE GOLD LOAN,3,RELIANCE LIFE INSURANCE,3,RELIANCE MUTUAL FUNDS,1,relief calculator 2010-11,1,relief calculator fy 2011-12,1,REMUNERATION TO PARTNERS,6,RENT,1,rent a cab,2,RENT RECIPT,1,RENTING OF IMMOVABLE PROPERTY AFTER 01.07.2012,8,RENTING OF IMMOVABLE PROPERTY AFTER BUDGET 2010,5,repayment of housing loan,1,REPLY TO CPC FOR NOTICE,11,REPO RATE,12,Reserve Bank of India,2,reset password,1,RESIDENTIAL STATUS,4,RESOLUTIONS,1,response to outstanding demands,3,RESTAURANT,10,restricted leave,1,retail investor,4,retirement planning,8,retirement steps,2,Retiring early,1,retrospective amendment,1,RETURN EXEMPTION SALARIED CLASS UP TO 5 LAKH,6,RETURN FILING DATES,1,return filing in odd conditions,1,return for contractors tax deducted,1,return not required with pan,1,return of income,1,RETURN PROCESSING,4,RETURN UP TO 5 LAKH,5,RETURN UPTO 5 LAKH,1,REVENUE STAMP ON CHEQUE PAYMENT,4,REVENUE STAP ON RECEIPT,1,reverse charge on works contract,17,REVERSE CHARGE GST,57,reverse charge of service tax,43,reverse mortgage,2,reverse of 80C benefits,3,REVERSE REPO RATE,12,REVISE RETURN,3,revised option date,1,revised pay calculator,3,revised return,3,REVISED SCALE,1,rgess,9,rich,1,right to reject,2,RPF,5,rpu,8,rpu 1.7,1,rpu 2.2,2,rpu 2.5,1,rpu 2.7,1,RPU 3.00,1,rpu 3.1,1,RPU ITR 2011-12,1,rpu2.8,1,RTGS,12,rti,2,rti fees,2,rule 12 of income tax return.,10,RULE 2A,1,rule 4A,2,rule 6(4A),1,rule 6(b),2,rule 6DD,5,rule3,2,rule40BA,1,RUPEE SYMBOL,4,s,1,safety tips for atm,4,SAHRE SHORT TERM CATIAL GAIN,5,salary calculator,7,SALARY ETDS Q4,5,salary in new direct tax code,1,salary structure,2,salary tds,7,sale in transit,4,sale of agriculture land,8,SALE OF DEBENTURE,1,sale of residential house,2,SALES MEANING 44AB,5,Sales tax,1,samsung case,3,saral 2,3,saral II,1,SARAL II IN EXCEL,1,Satyam,1,Satyamevjayate,1,SAVE TAX,2,SAVING ACCOUNT,6,saving bank interest,18,saving bank interest rate,2,saving linit u/s 80c,8,saving more than income,2,SAVING PASSBOOK,1,sbi 9.75 % bonds,1,SBI bonds,1,sbi home loan,4,SBI interest rates,10,sbi net banking,4,sbi rates,6,SBIOAHC,1,SBS WIKI,1,SCAM,2,schedule VI companies act,2,SCOPE OF ETDS STATEMENT,1,SCOPE OF SERVICE ENLARGED,1,SCOPE OF SERVICES WIDENED,1,scrutiny fy 11-12,3,scrutiny selection,17,search income tax,5,seat wise/constituencies wise and party and party candidate wise latest position,1,sebi,24,SEC 194 C,5,SEC 194 I,10,sec 194 J,4,secion 80c,4,SECRETARIAL STANDARD,3,secrutiny of itr,1,section 10(10AA),1,SECTION 10(13A),4,section 10(38),1,SECTION 10(5),1,section 139(1),1,section 139(4),1,section 139(5),1,Section 14,1,SECTION 145,3,section 154 return online income tax,4,section 16(iii),1,section 189,1,section 192,7,section 194-J,6,SECTION 194A,4,section 195,10,SECTION 195A,1,section 197,4,SECTION 2(37A),1,section 201(1A),2,section 203(3) section 206(C)(5),5,section 205,1,SECTION 24(b),8,section 269SS 269T,6,section 270A,5,section 271(1)(c),1,section 282B,1,Section 36(1)(vii),1,section 40(a)(ia),13,SECTION 40A(3),12,section 43(5),1,SECTION 44AB 2007-08 LAST DATE,4,section 44AB limit,13,SECTION 44AE,4,SECTION 44AF,2,Section 50,1,Section 50C,2,section 54,28,section 54f,8,SECTION 60,1,section 616(c),1,SECTION 64,1,section 66B service tax,4,section 68,1,Section 73,1,section 80 M,2,section 80c,3,section 80CCF,7,section 80D,18,section 80E,8,secured code master card,5,Securities and Exchange Board of India,1,security features,1,sehaj,1,self assessment tax,4,Seminar on service tax changes,1,Senior citizen,14,Senior Citizens Savings Scheme 2004,17,service charge,2,service ta,1,SERVICE TAX,44,service tax code,1,Service Tax (Removal of Difficulty) Order,1,SERVICE TAX 2010,1,service tax ac class,1,service tax accounting code,5,service tax adjustment,1,service tax audit,9,SERVICE TAX CHANGES FROM 01.07.2012,46,service tax changes in budget,58,Service TAX CLARIFICATION,17,SERVICE TAX COMPLIANCE,1,SERVICE TAX DEPOSIT DUE DATE,9,SERVICE TAX DUE DATE,6,Service Tax excel pdf word,1,SERVICE TAX EXEMPTION LIMIT,9,Service Tax Form excel pdf word,3,SERVICE TAX FORMS,1,service tax internet banking,1,service tax notifications,5,SERVICE TAX ON LAW FIRM ADVOCATES,3,service tax on transportation of passengers by air,2,service tax on advocates,5,SERVICE TAX ON BROKERAGE,2,service tax on ca,2,service tax on coaching,4,service tax on construction services,22,service tax on director services,5,SERVICE TAX ON DISTRIBUTION OF ELECTRICITY,1,SERVICE TAX ON EDUCATIONAL SERVICES,4,service tax on gta,7,service tax on health services,4,service tax on hotel clarification,12,SERVICE TAX ON HOTEL ROOM RENT,10,service tax on invoice basis,5,service tax on lawyers,1,SERVICE TAX ON LEASING,1,SERVICE TAX ON PACKAGE SOFTWARE,1,service tax on railway freight,8,SERVICE TAX ON RENT,6,service tax on road,4,service tax on transmission distribution of electricity,3,service tax on work contract tax,9,service tax on wrong head,1,service tax onr eimbursements,1,SERVICE TAX PAYMENT,6,SERVICE TAX PROCEDURES,3,SERVICE TAX RATE CHART,12,service tax rate effective date,12,service tax rate reduced,5,service tax rates increased,21,SERVICE TAX REGISTRATION,12,SERVICE TAX REGISTRATION LIMIT,4,SERVICE TAX RETURN,34,SERVICE TAX RULES,11,service tax section 65(105)m,1,SERVICE TAX VOLUNTARY COMPLIANCE ENCOURAGEMENT SCHEME,17,SERVICES CHARGES OF BANKS,2,SERVICES TAXABLE,5,servicetax,1,set off in same head or other head.,9,sevice tax on associate enterprises,2,sez,6,share,2,share market,3,SHARE SHORT TERM Capital GAIN,7,share transfer,1,share your thoughts,1,SHOME COMMITTEE REPORT,3,Short term capital gain depreciable Assets,1,SHORT 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pan,1,surcharge cess on tds,3,Surrender-Cancellation of Service Tax Registration,1,survey income tax,5,SWACHH BHARAT CESS,12,swiss bank,1,Systematic Investment Plan,6,tally 7.2,3,tally 9,4,tally easy,3,tally erp9,5,tally recycle bin,3,tally shortcut,10,tally simple,8,tally tips,5,TAN,3,TAN STRUCTURE,1,Tariff Value,1,Tax saving,4,tax accounting standards,4,TAX AMNESTY SCHEME,4,tax benefit from budget,2,TAX CALCULATION,4,TAX CALCULATION 2008-09,1,TAX CALCULATION FORMULA ADDIN EXCEL,2,TAX CALCULATOR,1,tax calculator 10-11,2,TAX CALCULATOR 2008-09,1,tax calculator 2010-11,2,tax calculator after budget 2011,1,tax calculator financial year 10-11,1,tax calculator fy 11-12,1,tax calculator income tax,1,tax collection,3,Tax credit,5,TAX DEDUCTED AT SOURCE CALCULATOR (TDS)2007-08,2,tax deducted at source return etds,3,Tax deduction,4,tax deduction at source chart,1,TAX EVASION,1,Tax free bonds,4,TAX ON ARRERS,1,tax on due date by cheque,2,tax on perquisite,4,TAX ON PROVIDENT FUND,2,tax payment by internet,1,tax payment from other's account,1,tax payment online,1,tax planning for salary,4,TAX RATES,2,tax rates changes in budget 2011,2,tax rates in new tax code,1,tax return preparer,1,tax saving capital gain,3,tax saving mutual funds,17,tax saving tips,1,TAX SLABS,6,tax through atm,2,tax yogi,3,taxable allowances,5,Taxation,1,Taxation in India,1,TAXES BY INTERNET,1,TAXMANN,4,TAXPRO CHALLAN,2,tcs on gold,11,tcs on jewellery,8,TCS ON MINERALS,2,tcs rate chart,5,TCS RATES,14,tds certificate,2,tds 194I Limit for deduction,7,tds at less rate,5,tds calculations,2,tds calculator,11,tds calculator after 1.10.2009,1,TDS CERTIFICATE,6,tds challan 281,5,tds chart,1,TDS CORRECTION,3,TDS CREDIT MORE TAN ONE YEAR,4,tds cut off limit changed,1,tds deducted in march,8,TDS DEFAULT BY EMPLOYER,2,tds deposited on time,2,tds due date,5,tds man,4,tds matching,5,tds noitce,1,tds not deducted penalty,5,tds not paid,1,TDS ON BANK INTEREST,1,tds on car charges,1,TDS ON COLD STORAGE RENT,4,tds on 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10-11,11,tds rates 2012,4,tds rates after budget 2010,2,TDS RATES ASSESSMENT YEAR 2011-12,4,tds rates chart 10-11,2,TDS RATES DIRECT TAX CODE,2,TDS RATES FOR AY 2010-11,2,tds rates fy 2016-17,3,TDS RATES FY 2017-18,3,TDS RATES FY 2018-19,1,TDS REFUND,11,tds return online free,3,tds rules amendment,4,tds salary rate,3,tds section 194C,9,tds software,1,tds statement,2,tds taxi charges,1,tds u/s 194C,6,TDS U/S 195,8,tds verification,2,TDSCPC,28,tdsman,12,tdsman software,12,TEACHER PAY SCALE,1,TERM DEPOSIT,3,TERM INSURANCE,5,term plan,2,The companies act 2013,131,The companies rules,114,THIN CAPITALISATION,1,third party insurance,2,ticket booking tds,2,time deposit,1,TIMING CHANGE,1,tin structure,2,tin-nsdl,13,tin-nsdl free etds statement software,3,TIN-NSDL.TIN NSDL FORM 16,4,TOLL FEES,1,tool bar for Chartered Accountants,5,TOP BANK OFFICIAL CBI ARREST,1,TR-6,1,traces,15,TRADEMARK,2,trading in shares,5,transaction not transfer,1,transfer fee,1,transfer includes,2,transfer loan from one bank to other,1,transport allownace,6,transport of goods by rail,5,travel agent tds,1,tribunal,1,trp,1,tuition fees,6,tuition fees children,2,TURNOVER MEANING 44AB,8,two challan in same month,1,uan,12,ubislate,1,UGC PAY SCALES,1,uid,10,uidai,5,ulip,25,ULIP AFTER BUDGET,1,ulp,2,unclaimed deposits,5,undeliverd refund status,1,undelivered refund status,4,uniform allowance,2,union budget 2010,1,union budget 2011,2,union budget 2012,5,union budget 2012-13,29,unique identity number,5,unique tds certificate number,2,Unique trasaction number,3,unit linked insurance plan,4,UNIVERSAL ACCOUNT NUMBER,3,universal life plans,1,unsecured non convertible debentures,1,up election,3,UP VAT,2,UPI,1,USA,1,use of tally,1,uti pan card,3,UTN,5,V S Vadivel FCA ACS,1,valuation of motor car,5,valuation of perquisites,16,valuation of perquisities,11,valuation of rent free house accommodation,4,valuation of works contract 01.07.2012,11,VALUE ADDED TAX,5,VAT,8,vat 11 digit detail,2,VAT ACT,3,VAT AND SERVICE TAX ON SOFTWARE,2,VAT DEFULTERS,1,VAT FORMS,2,VAT LATEST RULES,3,VAT MEANING,1,VAT NUMBER PUNJAB,1,vat on petrol,3,vat rate 4 to 5 %,1,vat rate changes punjab,3,VAT RATES,2,VAT RULES,1,VAT SCHEDULE,1,VAT TDS ON WORK CONTRACT,4,VAT UP AT A GLANCE,1,VCES,7,verified by Visa,3,VERIFY EXCISE CODE,1,verify pan,2,VERIFY SERVICE TAX CODE,7,VERIFY YOUR SERVICE TAX DEPOSIT,1,video,10,VIEW 26AS,6,VIEW YOUR TAX CREDIT,6,view your taxes online,5,Visa,2,VISHAL-REHEJA,1,vodafone,2,WAGES,3,ward circle,2,wealth tax,8,WEBCAST OF BUDGET 2011 ON COMPUTER,2,weighted scientific research deduction,2,what do u mean by micr,2,what does 10 digits of pan card indicates,1,what does each letter in pan number indicate,1,WHAT IS CHEAPER,1,what is company code 0020,1,WHAT IS DEARER,1,what is micr code,2,what is neft,4,what is PAN,1,WHAT IS STC,3,what is the meaning of rtgs,2,whatsapp,1,WHEAT AND PADDY,1,white paper,1,who can file sahaj.,10,who can sign income tax return,2,who can use itr-2,2,WIFE'S POLICY PREMIUM,2,wifes name,2,WILL,4,window dressing,1,without consideration,1,work contract service tax,16,working capital,1,Workmens Compensation Act,3,WORKS CONTRACT,3,wrong accounting code in service tax,1,wrong assessment year in challan,4,wrong head on challan,2,wrong name error in e filing registration,7,WRONG NAME IN ETDS RETURN,2,wrong pan on challan,2,wrong pan while deposit,1,wrong section on challan,3,www.satyamevjayate.in,1,xbrl,5,XLSX,2,ynitya income tax calculator,22,
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SIMPLE TAX INDIA: KEY 21 SUGGESTION ON DRAFT GST RETURN
KEY 21 SUGGESTION ON DRAFT GST RETURN
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SIMPLE TAX INDIA
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