-By All India Federation of Tax Practitioners
Macro Issues
Involving legal and
policy matters
Micro Issues
For efficient and
smooth collection of
Indirect Tax
MACRO SUGGESTIONS
- LEGAL AND POLICY MATTERS


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


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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
MICRO SUGGESTIONS
- FOR EFFICIENT AND SMOOTH COLLECTION
OF INDIRECT TAX


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
MUKUL GUPTA
CHAIRMAN
Mobile: 09811023739
E-mail: mukuladv@hotmail.com
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
THANK YOU!