November 29, 2017
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GST return filing reforms: restore ledger payment choice and procedural fixes to reduce compliance blockage and protect input credit.
The submission identifies systemic constraints in the GST return filing system that impede taxpayer compliance and preservation of entitlements, including prevention of cash ledger payments when Input Tax Credit exists, disallowance of cross-crediting, mandatory invoice-level B2B reporting, hard-blocks on filing subsequent returns, lack of interim acceptance or amendment of submitted data, burdensome HSN summary requirements, and exposure to late fees during system outages; it proposes technical and procedural fixes such as taxpayer choice of ledger usage within law, recipient accept/reject flows for B2B data, allowance for estimated tax payments, temporary deferral of HSN summary, automated rounding, acceptance of PAN where GSTIN is absent for reverse-charge reporting, and safeguards for Input Tax Credit verification.