-By All India Federation of Tax Practitioners

Macro Issues Micro Issues

- LEGAL AND POLICY MATTERS MACRO SUGGESTIONS

 Creation of ‘National Taxation Council’ to provide a distinct divide between the formation of tax policy and administration/collection of tax  Financial Discipline & ‘Documented Consent’ For Uniformity By Respective States

 Uniform Local GST Law & Rate Structure with Common Return Format & same Form Identification Numbers  HSN Classification of all Goods  Cross Utilization of ITC between CGST and SGST

 Draft Bill and Rules must be placed well in Advance in Public domain and on the Web Site for Fruitful Discussion and Well Considered Views  ‘Definitions’ must be Un-Ambiguously Framed in accordance to the Present Business Scenario

 Mutually Exclusive Domain of The Central GST Law and the State GST Law  Protection of Concepts such as “ In-Transit Sales” under Section 6 (2) of the CST Act and “High Sea Sale” under Section 5 of the CST Act

 Elimination of Ambiguity between the Centre and the State to Levy Indirect Tax on “Deemed Sale of Goods” and should be implemented without any Discrimination  Definition Of ‘Taxable Supplies’ Require A Close Scrutiny  Seamless Movement Of Goods Without Any Hindrance And Delay

 Guidelines for the Transition Period well in Advance  Amendment in GST Act & Rules only Once in a Year  Immunity of ‘Tax Collectors’ for all the Actions within the Provisions of the Act should Not be Provided

 Application of GST to Real Estate  Inclusion of Electricity Duty under State GST  Inclusion of Octroi, Market Fee or Market Cess and Entry Tax within State GST

- FOR EFFICIENT AND SMOOTH COLLECTION OF INDIRECT TAX MICRO SUGGESTIONS

 The ITC should be Uniformly Allowed on Inputs and Capital Goods from the Output tax on Goods as well as Services under the CGST as well as under SGST  Uniform Principles governing Eligibility and Utilization of Credit across the Country for Goods as well as Services must be placed in Central as well as Local GST Laws

 Reasonable Period for Changeover after Comprehending the New Law  Taxes should not be allowed to be Exported  Refund  Minimum Exemptions in CGST and SGST

 Clear Policy for Consignment Sales and Branch Transfers  Benefits to Special Economic Zone  Supplies to Public Utilities and treatment thereof  Redressal Mechanism for Conflicting Views on Same Set of Return and Claim of Assessee by the Administrators of CGST and SGST

 Disbanding the condition of Pre-Deposit of hearing of Appeal on Merits  Carry Forward of Input Tax Credit on purchase of Capital Goods and the balance ITC of VAT  Single Audit for both Central GST and State GST by the Advocates and Chartered Accountants providing Professional Services in Indirect Tax field

THANK YOU! MUKUL GUPTA CHAIRMAN MUKUL GUPTA CHAIRMAN Mobile: MEMBERS: C.A. Madhukar N. Hiregange, Bangalore C.A. Neena Maheshwari, Kolkota Adv. P. Puroshottam, Chennai Adv. Sameer Jain, Jaipur Adv. Sujit Ghosh, New Delhi Adv. Vikram Nankani, Mumbai