Representation for extension of due date for Annual GST return

REPRESENTATION FOR EXTENSION OF DUE DATE FOR FILING OF ANNUAL

RETURN IN FORM GSTR-9, 9A, 9B AND AUDIT REPORT IN FORM GSTR-9C.

“REPRESENTATION

There is sufficient cause and need for the extension of filing of Annual Forms GSTR-9, 9A, 9B and 9C for a reasonable period of time to give justice to the correctness of returns, considering the need for reconciliations state-wise. The reasons for the request are as outlined below:

We have written to your good selves many times populating issues and possible solutions. Herein, we are representing before your good selves the difficulties and hardships faced by the trade, industries and consultants at large due to delay in enabling GST Annual & Audit related returns, requirement to file state wise Audit and GST reconciliations for all taxpayers. GST has been a bold and epic reform of the Government, implementation of which had taken a decade to reach a logical implication, and naturally this introduction had its fair share of issues on trade and companies due to capacity constraints of GSTN IT infrastructure and various other issues, which required incessant changes of forms, procedures, compliances etc. Since, it was unable to introduce in lucid manner, it has a tumultuous impact on reconciliation of accounts for corporate and other bodies. This has continuously percolated and intruded into time required for GST as well as other compliances and has continued a chain reaction of effect.

Also, unless proper reconciliation is affected, it could be a matter for extended litigation later-on to the un-reconciled returns and/or qualified Audit Reports by auditors if proceeded as it were. It may also give rise to corruption. The reconciliation element possibly arises partly due to the niggling issues in GST and loose ends therein pursuant to delayed corrections / submissions from suppliers of goods and services for genuine reasons, onslaught of financial difficulties having cumulative bearing on compliances.

Without proper reconciliation and audit reports, even Revenue would face its fair share of difficulties to rely up on the inputs thrown from audit and it may lead to prolonged litigation, which could be mitigated by an appropriate changes, simplification and extension. We are listing following points to justify the need of extension.

• The formats prescribed for GST Annual Returns and GST Audits are not only voluminous but confusing as well.The confusion all the more rises when GST Portal itself malfunction giving two information from the same source of data. 
• Auto populated data of 3B in GSTR 9 differs from the actual data uploaded in monthly GSTR 3B. This type of technical errors happens on both side i.e. outward supply as well as inward supply.
• GST website is passing through numerous technical glitches nowadays. The issue is persisting since more than 10 days.
• The error “Received But Pending” appears as and when we try to upload GSTR 9C.
• We are unable to upload JSON file in One attempt. It requires multiple attempts to upload the same. It kills time.
• GSTR 9C latest utility 1.6 is made available on 08/01/2020 only. The time left after this is very short.
• GST Portal is having multiple issues with OTP sending. We are not getting OTPs on Domains. Even on Regular E-Mails, OTP is coming after 2-3 hours which is of no use. It gives frustration and anxiety to filers.

The ground realities mentioned above emerge from the communications received by the professionals from the entities, companies, management and other stakeholders and the same being sought herein for redressal through your august office. Your goodself is requested to makethe GST Portal error free and Extend the due date of Annual returns and Audit of 2017-18 upto 31/03/2020.

Thanking You.

Yours Faithfully,

The Southern Gujarat Commercial Tax Bar Association

President / Vice President / Secretary / Jt. Secretary

AL TAX BAR QO

Place : Surat

Date : 24/01/2020