| Title | Description | Files |
| REPRESENTATION SEEKING RECONSIDERATION OF PROPOSED AUTOMATIC LATE FEE FOR DELAYED FILING OF TAX AUDIT REPORT UNDER THE INCOME-TAX ACT, 2025. |
Date – 17th March 2026
To,
The Hon’ble Finance Minister,
Ministry of Finance, Government of India,
North Block, New Delhi - 110001
(Copy to: The Chairman, Central Board of Direct Taxes)
SUBJECT: REPRESENTATION SEEKING RECONSIDERATION OF PROPOSED AUTOMATIC LATE FEE FOR DELAYED FILING OF TAX AUDIT REPORT UNDER THE INCOME-TAX ACT, 2025.
Respected Madam/Sir,
On behalf of the Tax Practitioners’ Association of Ratnagiri District, representing Chartered Accountants, tax professionals, and the MSME sector of our region, we extend our highest regards to the Government's continued efforts to rationalize compliance. We are submitting this representation seeking reconsideration of the proposed automatic late fee for delayed filing of the Tax Audit Report under the Income-tax Act, 2025 (applicable from Tax Year 2026-27).
While we appreciate the intent to reduce litigation, we wish to highlight the severe, unintended hardships this specific provision will inflict upon small taxpayers.
I. What Was the Earlier Situation or Existent Provisions?
Under the prior regulatory framework, Section 271B of the Income Tax Act, 1961 imposed a discretionary penalty of 0.5% of turnover/gross receipts (capped at 1.5 lakh) for failing to get accounts audited or furnish the tax audit report under Section 44AB.
The Assessing Officer had discretion ("may direct") to levy it, and Section 273B allowed waiver for "reasonable cause," such as genuine hardship, illness, or unavoidable circumstances. The law ensured equity, as courts consistently required a reasonable opportunity of being heard before imposing the penalty, emphasizing principles of natural justice and proportionality.
II. What is the Proposed Change?
The proposed fee under the Income-tax Act, 2025 (via Finance Bill 2026) for late filing of tax audit reports replaces the prior penalty regime with a mandatory, automatic structure lacking hearing opportunities. This shift applies from tax year 2026-27, imposing ₹75,000 for delays up to one month and ₹1,50,000 thereafter, even for a single day's delay.
Comparative Analysis of the Provisions:
Aspect Section 271B (1961 Act) Proposed Section 428(c) (2025 Act)
Nature Discretionary penalty Mandatory fee
Quantum 0.5% turnover (max 1.5L), proportional Fixed: 75K (≤1 month), 1.5L (>1 month)
Hearing/Waiver Yes, via Section 273B reasonable cause None; automatic charge of fees.
Application Only if AO directs after hearing Applies to any delay, even 1 day
III. Why This Change Will Cause Harm to MSMEs
The new fee eliminates judicial safeguards, treating minor delays identically to prolonged non-compliance, unlike the prior system's equity focus. This shift creates several critical hardships for taxpayers:
• Violation of Natural Justice: The proposed automatic fee raises serious concerns, including a violation of principles of natural justice, particularly audi alteram partem (right to be heard). There is an absolute absence of discretion, even in cases of bona fide and unavoidable delays.
• Real-World Mofussil Hardships: In real-world scenarios, delays in filing Tax Audit Reports are primarily attributable to genuine reasons. These include system and portal-related technical issues , health-related issues of auditors or key managerial personnel , last-minute statutory changes or clarifications in Audit Forms , and natural calamities or unfortunate events in the family.
• Disproportionate Impact: A fixed fee creates a disproportionate impact on small and medium taxpayers, professionals, and partnership firms. Furthermore, submission of the audit report is a technical compliance and the government is already recovering due tax along with interest and late fee and penalty if applicable. Due to the levy of automatic late fees, there will not be any chance to put the above genuine reasons before appropriate authorities, which will inevitably increase burdens on small taxpayers and professionals in India.
IV. Suggestions Fulfilling the Objective of the Law and Taxpayers' Interest
To ensure that the law acts as a deterrent for willful defaulters without financially crippling honest MSMEs facing genuine hardships, we humbly request your good offices to seek reconsideration or suitable modification of the proposed provision, so as to:
1. Implement a Graded Daily Fee: Introduce daily graded fees like GST, nominal per day of Rs 100 with maximum cap of 1.5 Lacs. This fulfills the government's objective of ensuring compliance while remaining equitable.
2. Restore Natural Justice: Restore an opportunity of being heard. Allow waiver of fee in cases of reasonable cause.
3. Alternative Safeguards: Retain a penalty-based system with safeguards similar to sections 271B and 273B of the Income-tax Act, 1961. This prevents a departure from judicial precedents which consistently hold that penal consequences cannot be imposed without considering reasonable cause.
We remain highly hopeful that your esteemed office will recognize the plight of taxpayers in non-metro jurisdictions and introduce the necessary amendments.
Thank you for your valuable time and consideration.
Yours faithfully,
For Tax Practitioners’ Association of Ratnagiri District
Ramakant Pathare
President
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| Representation regarding technical issues in MahaGST site |
Date – 12th March 2026
To,
Hon’ble Jt. Commissioner of State Tax,
Goods & Service Tax Department
Govt of Maharashtra
GST Bhavan,
Kolhapur
Sub: Representation about technical issues in MahaGST site and Request for Extension of Due Dates for VAT / Profession Tax Returns and Payments
Respected Sir,
1. At the outset, we would firstly like to thank you on behalf of our members and the tax payers in general for allowing us to represent them on various issues being faced by the tax payers under the indirect tax laws.
2. The Tax Practitioners’ Association of Ratnagiri District, established in 2017, is a district-level body representing tax practitioners and taxpayers before tax authorities. It has played an important role in the implementation of major tax laws such as MVAT, Income tax and GST and regularly conducts educational programs to support the effective implementation of tax laws in Maharashtra & India.
3. We respectfully submit this representation to bring to your kind attention the serious practical difficulties being faced by taxpayers in complying with the VAT due dates and recently preponed due date for payment and filing of returns under the
4. Profession Tax Act. The due date for filing of Professional Tax returns and payment of tax for both monthly and annual taxpayers has been preponed from 31st March to 15th March vide Notification 2026/C.R.4/Taxation-3 dated 28.02.2026. While taxpayers always endeavor to comply with statutory requirements within the prescribed timelines, the current technical issues on the department’s website have made such compliance extremely difficult. Sir, you have extended the time limit to file VAT and Prof Tax Returns for 2/3 times, but still the website is not working properly. If the dealers could not file the Prof Tax returns on or before 15th March 2026 [ as per the new notification dt. 28-02-206 ] he will have to pay late fees for which he is not responsible. So just extending the due date for filing return is not advisable, the system should work properly.
5. At present, the MahaGST portal is frequently non-functional and inaccessible, thereby preventing taxpayers from carrying out essential activities such as payment of Profession Tax and filing of the relevant returns. Further, several taxpayers who are not yet registered under Profession Tax are unable to obtain registration on the portal, as the registration functionality itself is not working properly.
6. It may also be noted that, pursuant to the migration from the earlier portal to the new MahaGST portal, taxpayers are required to reset their passwords as per the prescribed procedure before accessing their accounts. However, in many cases taxpayers are unable to generate the required One-Time Password (OTP) for resetting the password. As a result, they are unable to log in to the system and proceed with payment of tax or filing of returns. Despite repeated attempts, the OTP generation and password reset process continues to face technical glitches. Moreover, in many instances, even when the OTP is generated, it is received by the taxpayer after a considerable delay of several hours, by which time the OTP has already expired. As a result, the password reset process cannot be completed and taxpayers remain unable to access their accounts on the portal.
7. Consequently, even genuine taxpayers who are willing and ready to discharge their Profession Tax liability are unable to make payment or complete the filing process due to the non-availability of the system and the continuing OTP/password reset issues. Screenshot evidencing the website issues are enclosed herewith for your ready reference. The website issues continue to persist. In fact, at the time of writing this representation, the website itself is down. A screenshot showing the same is attached below:
8. With the implementation of GST in the year 2017, the department has suo moto cancelled VAT registrations of the dealers w.e.f 01.07.2017. In this process, some dealers who dealing in liquor or petroleum products also suffered. In few cases, such dealers are still not get registration under MVAT Act, 2002 and paying VAT on PAN basis. But what about late fee in respect of non filling / late filling of MVAT returns ?
9. New MahaGST website has been started since Nov 2025 but it is not working properly. Dealers can make payment of VAT/prof tax only, but not able to file vat returns, prof tax return, view chalans etc . Even new dealers cannot apply for new vat, PTEC, PTRC registration due to OTP and site issues. In some GST registration cases the State GST officer raises a show cause notice for PTEC and PTRC number. In such cases the dealer cannot apply for PTEC and PTRC. So, the new dealer does not get GST registration in time.
10. As far as old dealers are concerned, there is an option for reset password. But when we choose the option for reset password, either OTP does not receive or if it does, it takes more than half an hour. Till then the time period gets lapsed. So, it is a waste of time for all tax professionals and dealers. In a day only in one or two cases we got success.
11. In some cases mobile no of one of the partners is used for PTRC of partnership firm. Now when I tried to apply for PTEC of the company where the said partner is director, the portal showed a message that mobile no is already used for profile creation. Partners do not have another mobile no so we are not able to file an application for PTEC/PTRC of the company. So, it is advised that criteria for mobile no should be removed. One mobile no shall be used for more than one PTEC/PTRC.
12. All the professional tax registration certificate holders have received the mail from prof tax department for payment of tax for the current financial year i.e. 2025-26 and for earlier period also for non filing of PTR. In some cases, there is no name and RC no of the dealer in the mail sent. In most of the cases though the dealer has paid the tax and filed the returns also, the mail is received for non-filing of PTR. In the mail it is stated that if a reply is not given within 7 days of receipt of the letter, proceedings of prosecution will be initiated. Sir this is injustice to the honest tax payers. If the department is not having PTR data of the dealers then why should dealers be held responsible ?
13. Some dealers are filing monthly PTR and are making monthly tax payments, but most of the time the status of the challan is not shown as successful on the same day. It takes 4/5 days. After successful payment status we can't download PTR challan copy. Without successful payment status, the PTR can’t be uploaded. If it gets successful after the due date of filing the return, then the dealer has to pay a late fee for which he is not liable.
14. The system taking too much time to create new profile of the dealer and also the records prior to October 2025 are not showing by the portal. While paying vat tax through PAN, the system showing invalid PAN and so the dealer is not able to make payment of vat for old period. Please refer the below mentioned screen shot is this behalf-
15. It is also respectfully submitted that, despite the above technical difficulties, the department has been aggressively following up with taxpayers for compliance within the revised timeline. This has caused considerable anxiety among compliant taxpayers who are eager to fulfill their obligations but are prevented from doing so due to circumstances beyond their control.
16. The FORM-704 (ANNUAL VAT AUDIT FORM) is made available on the portal only after 22-02-2026, for uploading the form in new version whereas the due date for the submission of VAT audit report is 28/02/2026. Given this change, the deadline for submitting FORM-704 (VAT AUDIT FORM) needs to be extended and sufficient time should be given to taxpayers and VAT Auditors to familiar with new version of form and submit on line. Therefore, we kindly request an extension for the submission date until 31-05-2026.
17. In view of the above situation, we humbly request your good office to kindly take cognizance of the persistent technical issues on the portal and the genuine hardships faced by taxpayers. We therefore request that suitable relief may kindly be granted by either keeping the preponement in abeyance as well as by extending the due date for payment and filing of Professional Tax returns by at least 10 days from the date on which the website becomes fully functional, so that taxpayers are able to comply without being subjected to unintended penal consequences.
18. On the new portal, taxpayers are required to fill in data for various returns and forms directly by logging into the website and entering information online. This process is time-consuming, especially for practitioners handling multiple clients. Further, in areas with unstable internet connectivity, the system often logs out automatically or sessions expire before completion of data entry. As a result, users are required to repeatedly log in and re-enter data, causing considerable inconvenience and loss of productive time. In this regard, we humbly request the department to kindly provide an offline utility for preparation of returns and forms, similar to the earlier system. An offline tool would enable taxpayers and practitioners to prepare data without internet interruptions and upload the same on the portal quickly and efficiently.
19. It has been observed that pending returns for periods prior to October 2025 are not visible on the new portal. Due to this issue, taxpayers are unable to identify and comply with pending filing obligations relating to earlier periods. We request the department to kindly ensure migration and proper reflection of all pending returns pertaining to earlier periods on the new system
20. Additionally, challans paid and returns filed through the previous portal are not reflecting in the new portal in several cases. This creates confusion regarding compliance status and may result in unnecessary notices or demands. We therefore request that the department kindly synchronize and display all historical data including challans and returns filed through the earlier system to ensure continuity and transparency of records.
21. We further wish to bring to your kind attention a practical difficulty being faced by several Government and Government-aided departments while filing returns under the Profession Tax Act. In many Government departments, the payment of Profession Tax is made through the Treasury Office by way of book entries instead of the regular challan payment mechanism available on the portal. However, it has been observed that such payments made through treasury book adjustments are not reflected either on the earlier portal or on the newly launched MahaGST portal. Due to the non-reflection of such payments on the system, the concerned departments face serious difficulty while filing PTRC (Profession Tax Return for Employers). At the time of filing the return, the system does not show the payment made through treasury book entry, resulting in mismatch between the tax liability and payment details. Because of this technical limitation, several departments are unable to correctly file their PTRC returns on the portal. In order to avoid late filing fees and penal consequences, many Government departments are constrained to file PTRC returns showing “Nil liability”, even though the Profession Tax has already been deducted from employees’ salaries and remitted to the treasury through book entries. The departments are fully aware that such reporting does not reflect the correct position; however, they are left with no practical alternative due to the system limitations. This situation creates unnecessary compliance difficulties and may also lead to discrepancies in departmental records as well as in the records maintained by the Profession Tax Department
In view of the above circumstances, we humbly request your good office to kindly consider the genuine difficulties faced by taxpayers and professionals and provide suitable relief by:
• Keeping the preponement of the due date for Profession Tax returns in abeyance, or
• Extending the due date for payment and filing of Profession Tax returns by at least 15 days from the date on which the portal becomes fully functional, and
• Extending the due date for submission of FORM-704 (VAT Audit Report) up to 31 May 2026, and
• Taking necessary technical measures to ensure smooth functioning of the portal including availability of offline utilities and proper migration of historical data.
• Appropriate mechanism may be introduced for mapping treasury payments with the PTRC return filing system, so that Government departments can correctly report their tax liability and payment details.
We sincerely hope that the difficulties faced by the taxpayer community will receive your sympathetic consideration and that appropriate directions will be issued to alleviate the present compliance challenges.
Sir, we trust you will consider this representation favorably and provide timely relief to taxpayers at large.
We shall be happy to meet you personally and explain the situation. The issue requires your immediate attention and intervention.
Thanking you.
Yours faithfully,
For Tax Practitioners’ Association of Ratnagiri District
Ramakant Pathare Adv Abhijit Berde
President Representation Committee Head
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| Suggestions to Charity Commissioner for their new web portal |
Date – 11-08-2025
To
The Hon’ble Astt Charity Commissioner
Maharashtra State Charity Department
Ratnagiri Division, Ratnagiri
Subject - Suggestions for New Web Portal of Maharashtra State Charity Department
Ref : - Your Letter No. Astha/1608/2025 dt 4-8-2025
- Meeting held at your office on 6-8-2025 with our committee members
Respected Sir,
With reference to the proposed development/hosting of the new web portal for the Maharashtra State Charity Department, we wish to submit the following suggestions for your kind consideration. The aim of these suggestions is to improve efficiency, transparency, security, and ease of use for both the department and stakeholders.
Suggestions:
1. Unique Login Credentials – Department to generate a unique ID for each registered Trust and each Auditor.
2. Auditor Registration – Mandatory registration of all auditors (both panel auditors and chartered accountants) on the portal.
3. Audit Report Upload – Auditor to upload the audit report and related details only through their registered login.
4. Trust Approval of Audit Reports – Authorised person(s) of the Trust (as per registered profile) to approve audit reports uploaded by the auditor through the Trust login.
5. Annual Auditor Appointment – Appointment of auditor for each financial year to be done online by the Trust through its login, with the auditor giving consent via their own login.
6. Offline Filing Option – Facility to generate and upload JSON or XML files (similar to the Income Tax portal) for audit reports and financial statements.
7. Access Control – At present, anyone can upload an audit report for any trust without login; this should be restricted to authorised logins only.
8. Paperless Compliance – No physical submission or appearance to be required if audit reports are uploaded within due dates.
9. Public Access Restrictions – Restrict viewing of audit reports and statements to the general public, or provide them only after login as “General Public.”
10. Limited Public View – Keep a separate, restricted view option for the public (similar to GST portal – “Search Taxpayer” feature).
11. Trust Login Features – All trust documents (registration certificate, Memorandum of Association, change reports, audit reports, etc.) to be available for download in the Trust login.
12. Online Change Report Filing – Change reports to be submitted online.
13. Edit Before Submission – Allow users to edit entries before final submission.
14. Detailed Balance Sheet Format – Expand the balance sheet format to report fixed assets rate‐wise depreciation (as per Income Tax portal format).
15. Authentication – All submissions/approvals to be authenticated via Aadhaar authentication or OTP verification on registered mobile/email of the Trust or Auditor.
16. Excel Utility – Provide Excel‐based utilities for preparation of audit reports, financial statements, and change reports.
17. New Trust Registration – Specify time limits for approval, objections, and physical verification, following processes similar to the GST portal.
18. Single Window for Uploads – Provide a single upload window for all document attachments across forms/modules.
19. Temporary Profile for Registration – Validate trust name with Income Tax/Aadhaar database during provisional profile creation.
20. Help Pop‐ups – Display context‐based information pop‐ups in each form to assist while entering data.
We believe that implementing the above suggestions will streamline compliance, enhance user experience, and strengthen the integrity of data on the portal.
We request your kind consideration and necessary action.
Thanking you,
Yours faithfully,
For Tax Practitioners’ Association of Ratnagiri District
Ramakant C Pathare
Head-Website Committee
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| Sub: URGENT Representation – Request for extension of Due dates for GSTR3B for the month of July 2025 |
Date – 19-08-2025
To,
The Commissioner of State Tax
Maharashtra
Sub: URGENT Representation – Request for extension of Due dates for GSTR3B for the month of July 2025
Respected Sir,
1. At the outset, we would firstly like to thank you on behalf of our members and the tax payers in general for allowing us to represent them on various issues being faced by the tax payers under the indirect tax laws.
2. Sir, as you are aware, on account of the incessant rain since the last 4 days Mumbai, Ratnagiri, Kolhapur, Thane, Bhiwandi, Palghar, Raigad, adjoining areas and other districts across Maharashtra are severally flooded. Today as well (19th Aug 2025), the BMC / local collector has ordered closure of all schools, colleges as well as Government Departments on account of relentless rains and severe waterlogging. As you are aware, 20th Aug 2025, is the due date for filing of GSTR3B, however, on account of the above hardship faced by taxpayers in the state, it may be difficult for them to comply with the deadline in hand. Also in many places, there are totally electricity shut down due to heavy rainfall. Non-compliance with the deadline subjects the taxpayers to interest and penalty.
3. On account of the above, we request to please consider our request to extend the deadline by 2-3 days for making payment and filing of GSTR3B for the month of July 2025 in the state of Maharashtra and grant relief to the taxpayers in the state.
Thanking You
For Tax Practitioners’ Association of Ratnagiri District
(Representation Committee)
Ramakant C Pathare
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| Formal Grievance Regarding Unlawful Request for GST and Income Tax Portal Credentials | बँकांकडून अनेकदा आपल्या सभासदांना आपल्या पक्षकारांचे इनकम टॅक्स, जीएसटी इत्यादीचे पासवर्ड फोनच्या माध्यमातून मागितले जातात. यासंदर्भात आज आपल्या असोसिएशनने लीड डिस्ट्रिक्ट बँक मॅनेजर, बँक ऑफ इंडिया यांच्याकडे निवेदन सादर केले. निवेदनाची कॉपी सोबत देत आहोत.
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| GST AMNESTY 2024 | जीएसटी एमनेस्टी संदर्भातील तांत्रिक अडचणींसंदर्भात आज आपल्या असोसिएशन तर्फे आज स्टेट जीएसटी आणि सेंट्रल जीएसटी ऑफिसला निवेदन देण्यात आले. PLEASE SEE ATTACHED FILE
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| Representation regarding keeping recovery in abeyance in respect of cases involving ITC disallowance U/s 16(4) |
Ref: 2024-25/567 Date: 5th August, 2024
To,
The Commissioner of State Tax
Maharashtra State
Mazgaon, Mumbai – 400010
Subject: - Representation regarding keeping recovery in abeyance in respect of cases involving ITC disallowance U/s 16(4)
Reference: - Circular No.224/18/2024 Dt.11.07.2024 regarding Guidelines for recovery of dues.
Respected Sir,
1. At the outset, we would firstly like to thank both the Governments on behalf of our members and the tax payers in general for introducing various beneficial amendments in the Financial Bill (No. 2), 2024. The CBIC has also issued various circulars pursuant ot the Recommendations of the GST Council in its 53rd Meeting.
2. We would like to draw your attention towards the Circular No. 224/18/2024 Dt.11.07.2024 regarding Guidelines for recovery of dues, in cases wherein first appeal has been disposed off and the assesses want to file second appeal U/s 112 before Hon’ble GSTAT. As per the provisions of Sub-section 8 of Section 112 of the CGST Act, the recovery proceedings for the outstanding dues is deemed to be stayed till disposal of the appeal by the Hon’ble GSTAT on payment of prescribed pre-deposit for appeal. But due to non- constitution of Hon’ble GSTAT, the tax payers were not able to file the appeal or make payment of pre-deposit for second appeal. In such cases, the Para 4 & 5 of the aforesaid Circular had given option as under –
a. In cases where the taxpayer decides to file an appeal against the order of the first appellate authority and wants to make the payment of the amount of pre-deposit as per sub-section (8) of section 112 of CGST Act, he can make the payment of an amount equal to the amount of pre-deposit by navigating to Services >> Ledgers>> Payment towards demand, from his dashboard. The taxpayer would be navigated to Electronic Liability Register (ELL) Part-II in which he can select the order, out of the outstanding demand orders, against which payment is intended to be made. The amount so paid would be mapped against the selected order and demand amount would be reduced in the balance liability in the aforesaid register. The said amount deposited by the taxpayer will be adjusted against the amount of pre-deposit required to be deposited at the time of filing appeal before the Appellate Tribunal.
b. The taxpayer also needs to file an undertaking/ declaration with the jurisdictional proper officer that he will file appeal against the said order of the appellate authority before the Appellate Tribunal, as and when it comes into operation, within the timelines mentioned in section 112 of the CGST Act read with Central Goods and Services Tax (Ninth Removal of Difficulties) Order, 2019 dated 03.12.2019. On providing the said undertaking and on payment of an amount equal to the amount of pre-deposit as per the procedure mentioned in para 4 above, the recovery of the remaining amount of confirmed demand as per the order of the appellate authority will stand stayed as per provisions of sub-section (9) of section 112 of CGST Act.
3. We take this opportunity to represent certain issues with respect to implementation of the above provisions for the recovery actions started against the dealers by the department.
4. Sir in initial years, such as F.Y. 2017-2018, F.Y. 2018-2019, many adjudication orders have been passed raising demand merely on the ground of dis-allowance of ITC u/s. 16(4). In many orders on the grounds for demand if dis-allowance of ITC u/s. 16(4). Now the Government has introduced Section 16(5) in the GST Law retrospectively w.e.f. 01.07.2017. In view of the Section 16(5) all ITC availed by the tax payer upto the Novemeber 2021 will not be hit by the restriction of Section 16(4) and the same even if claimed beyond the time limits prescribed in Section 16(4) is regularised. Thus, no tax liability will arise on account of Section 16(4) for the periods F.Y. 2017-2018, F.Y. 2018-2019, F.Y. 2019-2020 where in ITC for invoices pertaining to said years are availed before November 2021.
5. In view of the above beneficial amendment in Section 16(5), it would be unjust to recover dues from the tax payers where the demand is raised merely on account of ITC dis-allowance under Section 16(4) or one of the grounds for demand in the order is ITC disallowance u/s 16(4). Further, it would also be injustice to if the tax payers are required to pay additional pre-deposit for filing second appeal in Hon’ble GSTAT for the issue of ITC dis-allowance u/s. 16(4). as per the Para 4 & 5 of the abovementioned Circular.
6. In view of the above issues, it is humbly represented that, a clarification may issued to keep recovery of for orders where the liability raised in the appeal order is due to disallowance of ITC U/s 16(4) in abeyance. The proper officers should not insist upon making the payment of further pre-deposit for Tribunal appeal, otherwise it will defeat the intention of the Law. It is also a settled law by the Supreme Court that first making payment and then giving refund is no solace.
7. We also humbly suggest to make appropriate provision U/s 161 of the CGST Act, 2017 for making application for Rectification of mistake before the Proper Officer / first appellate authority in the cases in which the liability is going to be reduced due to implementation of Section 16(5) in the CGST Act, 2017. This will not only lead reduction in litigation burden before the Hon’ble GSTAT but also benefit the Department in general to close the recovery proceedings.
8. The above issues require your immediate attention and intervention and we request to please consider the issues and if necessary forward the same to concerned authorities for taking appropriate action. We thankfully request your honour to consider the above issues.
9. We shall be happy to meet you in person to explain the issues and representation as per the convenient time and date.
Thanking you,
Yours faithfully,
CC: Finance Minister, Maharashtra
CC: Finance Minister, Union of India
CC: The Chief / Principal Commissioner of CGST, Mumbai
CC: The Chief / Principal Commissioner of CGST, Pune
CC: The Chief / Principal Commissioner of CGST, Nagpur
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