There are few validation issues in ANX-1

There are few validation issues in ANX-1 

1. State once selected in 3A of ANX-1 reappears in next selection also

2. Rate once selected also reappears in next selection too

3. Non marking of supply u/s 7 of IGST doesn’t stop the pop up for other states

4. Missing Invoices information should be allowed for RET-2/3 also

5. Auto calculation of interest should not be allowed

6. Relaxation of HSN up to 5 Crore and not seeking information on stock also may result in tax evasion

7. In 3C/3D of ANX-1 For port code information, pop up should be given , otherwise wrong port code shall result hampering of refunds.

8. Sale to composition persons is always available for amendment by supplier . However while switching to normal scheme and taking credit through ITC 01 acceptance of invoices should be allowed.

9. Allowing some amendments in ANX-1 and some in ANX-1A May lead to confusions

10. When only 7% are more than 5 crore filers then having 25th as return filing date for balance 93% shall not reduce load on the portal

11. How 5 crore shall be calculated ? PAN wise, GSTIN wise not clear.

12. Missing Invoices information in 3L no where travels to RET-1 and is for record of department (to the extent of my understanding). This information should be made to travel to respective suppliers for Accepting/ Rejecting

13. There is no point in waiting for T+2 for missing invoices. This information should be given at once to substantiate 4A.10 of RET-1

14. Though 3H of ANX-1 for RCM supplies has been purported to be enabled for PAN but it is not accepting PAN in Trial Run

15.In 3H of ANX-1 for RCM supplies we may go for Aadhar instead of PaN having regard to Aadhar substitution in Income tax also.

16. On the lines of 3H of ANX-1, Aadhar information may be called for inward supplies exceeding certain threshold even if not subject to RCM so that purpose of 9(4) that lost its way may be met.

17. If supplier fails to report / rebut missing invoices, recipient may be given option to pay tax and claim ITC

18. There should not any fetters on making number of times amendments in ANX-1.

19. As per instructions under ANX-2 status of return filing of supplier doesn’t affect the eligibility of ITC by recipient. Doesn’t go well with 16(2).

20. Instructions to ANX-2 say that interest liability shall be invited for rejecting already accepted invoice. Without prescribing the manner of calculation in S. 50 this legal statement may be under challenge.

21. In PMT-08 Table 4 from where tax already paid shall carry information is not clear. It indicates PMT-08 can be used as many times as one wishes and not only monthly. Further whether PMT 08 information shall auto travel to Table 7 of RET-1 is not clear from instructions.

22. Where tax paid is more than tax payable for a return period excess tax paid should also be allowed to be travelled to next return period, without compelling for seeking refund for the same.

23. Rule 37, 39, 42,43 have been placed in ITC reversal category in 4B.4 of RET-1 but 37 is output tax, 39 is reduction, 42 is reversal and 43 is again output tax liability. Hence form and law are not in sync.

24. As per 4B.5 of RET-1, transition from composition to normal is downward adjustment of ITC but it is other way round I.e. transition from normal to composition is downward adjustment of ITC. Further no such adjustment should be allowed thorough user input because it should auto travel through ITC-01 and ITC 03.

25. User input requires bifurcation of itc for capital goods and services and does not require the information on inputs. Preparing for this information shall be a cumbersome exercise. In case of composite supplies it may be sometimes difficult to decide whether it is input or input service. Suppliers classification for limited purpose of determining tax liability may not be good guideline when it is going to impact my refunds also.

26. In 3A of Anx -1, PAN information of consumer may be allowed to be given so that if later point of time one want to avail itc on stock and capital goods , verification of ITC-01 is possible.

27. For casual traders and non resident taxable persons willing to avail itc an abridged version on the lines of Sahai/Sugam May be launched.

28. There may be difference in shipping bill value and taxable value in 3C of ANX-1 due to certain value inclusions not taken in shipping bill which needs to be taken cognisance of.

29. How declaration for claiming refund by supplier shall be made has not been clarified in context of deemed exports and SEZ supplies.

30. 4A.11 of RET-1 should clarify that reclamations of excess reversal under Rule 42/43 and 3rd proviso to S. 16(2) may be taken

31. Regarding exempt supplies nature of supply and relevant entry number in exemption notification 2/2017 or 12/2017 should be called for

32. Pending invoices which so remain till Sep of next financial year shouldn’t be allowed to be restored back.

33. There is no point in calling detailed information including HSN for import of goods when it has no connection with liability of the taxpayer and is only a stop gap arrangement till ICEGATE is integrated with ANX-1

34. On the lines of import, export information in ICEGate should also be integrated with ANX-1. This shall result in lesser hassles for refunds

35. Information in 3B.1 of RET-1 and 4A.5 of RET-1 regarding RCM is auto populating from 3H of ANX-1 , whole one may not be entitled to entire itc on RCM, hence 4A. 5 should be based on user input and shouldn’t be auto populated.

36. Where supplier doesn’t file return for two months and recipient neither rejects nor takes action of keeping them pending then return forms do not provide for auto reversal of those invoices