| S. No. |
Proposed change |
Impact |
Suggestion |
| 1. |
Reduction of provisional credit limit under Rule 36(4) from 10% to 5% |
Negative |
The limit should not be reduced till the system settles the matching mechanism – Rules should be clear in terms of the application of Rules 36(4) in the context of GSTR 2A/2B. |
| 2. |
Introduction of Quarterly Return Monthly Payment scheme |
Positive |
No immediate coercive step by officers on MSME in case of low tax payment during the quarter when compared to last quarter as sale vary in many cases |
| 3. |
Suspension and cancellation of registration by an officer in case of difference between GSTR 3B and GSTR 1 (without any limit of such difference) |
Negative |
The term significant difference in rules is subjective and shall lead to varied results. The limits in terms of %age deviation should be set. |
| 4. |
No GSTR 1 incase two last period’s GSTR 3B has not been filed |
Positive |
|
| 5. |
Suspension of registration – an opportunity of being heard deleted |
Negative |
This goes against the very principles of natural justice – Audi alteram partem cannot be deleted from any administrative action |
| 6. |
Rule 86B – Restriction of ITC to 99% |
Negative |
Eligible ITC once availed is a vested right of a taxpayer and such a right is useful when its seamless use for payment of output tax is made. The relaxations shall not be of help to newly established new startups / large infra projects which incur losses in their initial years. |
| 7. |
Introduction of stricter control in case of new registrations – Biometric-based Aadhaar authentication and Photograph |
Positive |
Would make it tough for establishing fake firms. However, the genuine business should not be troubled with lengthy procedural formalities (when the physical visit is already done). |
| 8. |
Increase in time for grant of new Registration (3 days to 7 days) |
Neutral |
The increased time limit should at least be honored in giving registrations |
| 9. |
The validity of the E-way bill increased to 200 Kms per day (from 100 Kms per day) |
Negative |
Considering the road infrastructure, it is not right to push the travel speed of carriers. |
